TCR_Public/110213.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, February 13, 2011, Vol. 15, No. 43

                            Headlines

1888 FUND: S&P Raises Ratings on Various Classes of Notes
AIRCRAFT CERTIFICATE: S&P Cuts Ratings on Two 2003-A Notes to 'BB'
ALFA DIVERSIFIED: S&P Affirms 'BB+' Ratings on Five Series
AMERICREDIT AUTOMOBILE: Moody's Assigns Final Ratings to Notes
AMERICREDIT AUTOMOBILE: S&P Assigns Ratings to $780.056 Mil. Notes

ANTHRACITE CDO: Fitch Downgrades Ratings on Seven Classes of Notes
ARGENT MORTGAGE: Moody's Cuts Ratings on Two 2005-W1 Tranches
ASSET SECURITIZATION: S&P Cuts Rating on 1997-D5 Certs. to 'D'
ATRIUM CDO: S&P Raises Ratings on Various Classes of Notes
ATRIUM III: S&P Raises Ratings on Various Classes of Notes

AURORA BANK: Moody's Reviews Ratings on 48 Tranches
AURUM CLO: S&P Raises Ratings on Various Classes of Notes
AUSTIN HOUSING: S&P Gives Stable Outlook on 'CC' Bond Rating
AVALON CAPITAL: S&P Raises Ratings on Various Classes of Notes
AVENUE CLO: S&P Raises Ratings on Various Classes of Notes

AVERY POINT: S&P Raises Ratings on Various Classes of Notes
BABSON CLO: S&P Raises Ratings on Various Classes of Notes
BAKER STREET: S&P Raises Ratings on Four Classes of Notes
BANC OF AMERICA: Moody's Affirms Ratings on 20 2005-2 Certs.
BEAR STEARNS: Moody's Upgrades Ratings on Series 1998-C1 Certs.

BELHURST CLO: S&P Raises Ratings on Various Classes of Notes
CARLYLE ARNAGE: S&P Takes Rating Actions on Various Classes
CARLYLE AZURE: S&P Raises Ratings on Three Classes of Notes
CD 2007-CD4: Moody's Reviews Ratings on 10 Classes of Certs.
CENTURION CDO: S&P Raises Ratings on Various Classes of Notes

CHASE MANHATTAN: S&P Raises Ratings on Three Classes of Certs.
CITIMORTGAGE ALTERNATIVE: Moody's Cuts Ratings on 2005-A1 Tranches
CLARET TRUST: Moody's Takes Rating Actions on Various 2006-1 Notes
COLORADO HOUSING: S&P Junks Rating on Series 2007 Bonds From 'BB'
COMM 2004-LNB4: Moody's Affirms Ratings on 18 Classes of Certs.

COMM 2005-FL11: Moody's Affirms Ratings on Nine Pooled Classes
COMM 2006-C7: Fitch Downgrades Ratings on 14 Classes of Certs.
COMMONWEALTH PORTS: Fitch Affirms 'CCC' Rating on $14.6 Mil. Bonds
COMMONWEALTH PORTS: Fitch Affirms 'BB-' Rating on Revenue Bonds
CONSUMER PORTFOLIO: Moody's Reviews Ratings on 15 Tranches

CORIOLANUS LTD: S&P Downgrades Rating on Series 39 to 'D'
CORPORATE BACKED: Moody's Upgrades Ratings on Certs. to 'Ba2'
CREDIT PROTECTION: Moody's Upgrades Ratings on Bonds From 'Ba1'
CREDIT SUISSE: Moody's Affirms Ratings on Six 2002-CKP1 Certs.
CREDIT SUISSE: Moody's Downgrades Ratings on Six 2001-CK6 Certs.

CREDIT SUISSE: Moody's Reviews Ratings on 2004-C4 Certificates
CREDIT SUISSE: S&P Downgrades Ratings on Seven 2005-C4 Notes
CSAB MORTGAGE-BACKED: Moody's Downgrades Ratings on Three Tranches
CSAM FUNDING: Moody's Upgrades Ratings on Various Classes of Notes
CSAM FUNDING: S&P Raises Ratings on Various Classes of Notes

CT CDO: Fitch Downgrades Ratings on Two Classes of Notes
DBUBS 2011-LC1: Moody's Assigns Ratings on 11 CMBS Securities
DELTA AIR: Moody's Assigns 'Ba3' Ratings on Class B Certificates
DELTA AIR: S&P Assigns 'BB' Rating to 2010-2B Certificates
DRYDEN VII-LEVERAGED: Moody's Upgrades Ratings on Four Notes

FAIRWAY LOAN: S&P Raises Ratings on Various Classes of Notes
FIRST UNION-LEHMAN: S&P Raises Ratings on 1997-C2 Securities
FM LEVERAGED: S&P Raises Ratings on Various Classes of Notes
FORD CREDIT: Fitch Takes Rating Actions on Various Classes
FORD MOTOR: S&P Raises Ratings on Eight Transactions to 'B+'

FOREST CREEK: S&P Raises Ratings on Various Classes of Notes
FOUR CORNERS: S&P Raises Ratings on Various Classes of Notes
G-FORCE 2005-RR2: Fitch Downgrades Ratings on 14 Classes of Notes
GMAC 2004-C2: Moody's Reviews Ratings on Nine 2004-C2 Certs.
GRANITE VENTURES: S&P Raises Ratings on Various Classes of Notes

GREENWICH CAPITAL: Moody's Downgrades Ratings on 2003-C2 Certs.
GREENPOINT MORTGAGE: Moody's Cuts Ratings on 16 2005-AR5 Tranches
GSAA HOME: Moody's Downgrades Ratings on Eight Tranches
ING INVESTMENT: S&P Raises Rating on Class D Notes to BB (sf)
ING INVESTMENT: S&P Raises Ratings on Various Classes of Notes

JP MORGAN: Moody's Affirms Ratings on 22 Series 2004-C3 Certs.
JP MORGAN: Moody's Reviews 'B2' Ratings on Class A-2 Tranche
JP MORGAN: Moody's Takes Rating Actions on Series 2003-ML1 Notes
KATONAH III: Moody's Upgrades Ratings on Seven Classes of Notes
KATONAH IX: Moody's Upgrades Ratings on Two Classes of Notes

KATONAH V: S&P Raises Ratings on Various Classes of Notes
KINGSLAND IV: Moody's Upgrades Ratings on Various Classes of Notes
LEAF RECEIVABLES: DBRS Puts 'B (Low) ' Rating on Class E-2 Notes
LEHMAN MORTGAGE: Moody's Downgrades Ratings on 50 Tranches
LONGHORN CDO: S&P Raises Ratings on Various Classes of Notes

MADISON SQUARE: Fitch Downgrades Ratings on Three Classes of Notes
MERRILL LYNCH: Moody's Affirms Ratings on 16 Classes of Certs.
MERRILL LYNCH: Moody's Downgrades Ratings on Three Certificates
MERRILL LYNCH: Moody's Takes Rating Actions on Various Classes
ML-CFC COMMERCIAL: Fitch Downgrades Ratings on 15 Certificates

MONROE COUNTY: S&P Raises Ratings on Revenue Bonds From 'BB+'
MORGAN STANLEY: Fitch Issues Presale Report on 2011-C1 Certs.
MORGAN STANLEY: Fitch Downgrades Ratings on 13 2006-HQ9 Certs.
MORGAN STANLEY: Moody's Takes Rating Actions on 1998-CF1 Notes
MORGAN STANLEY: Moody's Downgrades Ratings on 2003-IQ6 Certs.

MORGAN STANLEY: S&P Assigns Ratings to $1.55 Bil. 2011-C1 Certs.
MORGAN STANLEY: S&P Downgrades Ratings on Three Classes of Notes
NATIONAL CITY: Fitch Withdraws Ratings on Six Classes of Notes
NEWCASTLE CDO: Moody's Downgrades Ratings on Class I-MM to 'B1'
NORTHWOODS CAPITAL: S&P Raises Ratings on Various Classes of Notes

OAK HILL: S&P Raises Ratings on Various Classes of Notes
OHA INTREPID: S&P Assigns Ratings on $364 Mil. Floating Notes
OSPREY CDO: Moody's Upgrades Ratings on Various Classes of Notes
PACIFICA CDO: S&P Affirms Junk Ratings on 3 Classes of Notes
PACIFICA CDO: S&P Raises Ratings on C-1 & C-2 Notes to B+

PEGASUS 2007-1: Moody's Cuts Rating on Class A1 Notes to 'Ba1'
PHOENIX CDO: Moody's Upgrades Ratings on Two Classes of Notes
PHOENIX CLO: Moody's Upgrades Ratings on Four Classes of Notes
PONTIAC BUILDING: Moody's Downgrades GO Limited Tax Rating to 'B2'
RESIX FINANCE: Fitch Withdraws Ratings on All Classes of Notes

SARATOGA CLO: S&P Raises Ratings on Various Classes of Notes
SATURN CLO: S&P Raises Ratings on Various Classes of Notes
SCHOONER TRUST: Moody's Affirms Ratings on 17 Certificates
SIERRA CLO: S&P Raises Ratings on Various Classes of Notes
SOLAR TRUST: Moody's Upgrades Ratings on Six 2003-CC1 Certs.

ST JOSEPH: S&P Withdraws 'CCC' Rating on Revenue Bonds
SUFFIELD CLO: Fitch Upgrades Ratings on Three Classes of Notes
SWISS CHEETAH: Moody's Upgrades Ratings on 8B Bonds to 'B1'
TRIAD FINANCIAL: Moody's Takes Rating Actions on Two Classes
VELOCITY CLO: S&P Raises Ratings on Four Classes of Notes

VERICREST FINANCIAL: Moody's Downgrades Ratings on Four Tranches
VERITAS CLO: Moody's Upgrades Ratings on Various Classes of Notes
VERITAS CLO: Moody's Downgrades Ratings on Five Classes of Notes
VERITAS CLO: S&P Raises Ratings on All Classes of Notes
WEST PENN: Moody's Downgrades Rating on $748 Mil. Bonds to 'B2'

WF-RBS COMMERCIAL: Fitch Issues Presale Report on 2011-C2 Certs.
WHITEHORSE I: S&P Raises Ratings on Various Classes of Notes

* Fitch Takes Rating Actions on New Orleans' Special Tax Bonds
* S&P Downgrades Ratings on 43 Classes From Five CMBS Transactions
* S&P Downgrades Ratings on 53 Certs. From Seven CMBS Transactions
* S&P Downgrades Ratings on 182 Classes From 67 RMBS Transactions

                            *********

1888 FUND: S&P Raises Ratings on Various Classes of Notes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, and C notes from 1888 Fund Ltd., a collateralized
loan obligation transaction with APEX credit swap feature, managed
by Guggenheim Investment Management LLC.  At the same time, S&P
removed the ratings on class A-1, A-2, and B from CreditWatch with
positive implications.

The upgrades reflect the effect of a reduction in the outstanding
balance of the class A-1 and A-2 notes since S&P's last rating
action in March 2010.  The class A overcollateralization test
improved to 144.9% in January 2011 from 131.6% as of February
2010, largely as a result of $77 million and $20 million in pay
downs to the class A-1 and A-2 notes, respectively, since S&P's
last rating action.

According to the Jan. 6, 2011 trustee report, the transaction held
$14 million in defaulted assets, down from $24 million noted in
the Feb. 6, 2010, trustee report.  In addition, assets from
obligors rated in the 'CCC' category were 19% of the collateral
pool in January 2011, compared with 14% in February 2010.

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

                          1888 Fund Ltd.

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


AIRCRAFT CERTIFICATE: S&P Cuts Ratings on Two 2003-A Notes to 'BB'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'BB
(sf)' from 'BB+ (sf)' on the class D and E notes from Aircraft
Certificate Owner Trust's series 2003-A.

The rating actions follow lowering of the ratings on one of the
transaction's underlying securities.  The rating on the 2003-A
transaction reflects the lowest of the ratings on the underlying
securities, three US Airways class G pass-through certificates.

The cash flow from the underlying aircraft securities is used to
make interest and principal payments on the rated notes.  Interest
for the underlying aircraft certificates and the notes accrue on a
fixed-rate basis and is payable semiannually.  Principal
collections are allocated to the rated notes and unrated
certificates pro rata from series 2003-A, according to the
transaction's documents.  However, principal is allocated on a
sequential basis between classes D and E--the only remaining two
outstanding classes of notes from the 2003-A transaction.

Even though the principal payment priority is sequential for the
rated classes from series 2003-A (i.e., class E starts receiving
principal payments and begins to amortize only after class D is
retired) if there is no event of default, interest is distributed
on a pro rata basis for these notes.  Therefore, the ratings on
classes D and E are linked to the lowest of the ratings on the
three underlying US Airways class G securities.

S&P will continue to monitor the transaction and take rating
actions as appropriate.

                 Underlying Aircraft Certificates

           US Airways class G pass-through certificates

      Series        -   2000-2G        2000-3G     2001-1G

      CUSIP         -   90332UAK9      90332UAL7   90332UAN3

      Original bal.
      (mil. $)      -   362.414        491.135     458.047

      Original
      issue date    -   July 2000      Oct. 2000   Jan. 2001

      Current
      rating        -   BBB-           BBB         BB/Negative

                         Ratings Lowered

             Aircraft Certificate Owner Trust 2003-A
  Aircraft certificate-backed notes and owner trust certificates

                                  Rating
                                  ------
               Class       To              From
               -----       --              ----
               D           BB (sf)         BB+ (sf)
               E           BB (sf)         BB+ (sf)


ALFA DIVERSIFIED: S&P Affirms 'BB+' Ratings on Five Series
----------------------------------------------------------
Standard & Poor's Ratings Services affirmed its 'BB+ (sf)' ratings
on five series of notes issued by Alfa Diversified Payment Rights
Finance Co. S.A.  The note issuances are Russian financial future
flow securitizations backed by all current and future diversified
payment rights in the form of U.S. dollar- and euro-denominated
SWIFT MT100 and 200 category payment order messages that OJSC Alfa
Bank (B+/Positive) receives.  Payment orders are created as a
result of Alfa Bank's role as a financial intermediary between
foreign payors that send funds to Russia and resident Russian
entities that receive these funds.

The rating actions follow S&P's completed review of Alfa Bank's
ability to generate the necessary assets to service the
transactions for timely principal and interest payments even under
a state of selective default or other financial impairment.  S&P's
'BB+ (sf)' ratings on the outstanding series are based on no
adverse impact from the pending merger with Severnaya Kazna Bank
OJSC and, among other things, the structural enhancements that are
intended to mitigate sovereign risk and the overcollateralization
levels that reflect the transactions' ability to withstand a
decline in DPR receivables generation.

Factors that support the transactions' credit quality include:
Alfa Bank's size and systemic importance in Russia's banking
system, which S&P believes would likely earn it the Russian
government's support, if needed, when under financial stress.
This support reduces the risk that Alfa Bank might have to cease
operating if it were to default on one or more of its other
financial obligations.

The strategic importance of the payment order business to Alfa
Bank.  Alfa Bank is Russia's largest private bank, and its ability
to provide corporate loan finance and payment order processing
services is a major part of both its corporate and retail banking
business lines.  Standard & Poor's believes it is unlikely,
therefore, that the bank will allow itself to become uncompetitive
in or to abandon this business.  The strong debt service coverage.
Based only on non-Russian-generated receivables, S&P's cash flow
analysis indicates the transactions' minimum DSC will be 33.8x the
quarterly debt service at the point at which maximum debt service
is due.  Based on S&P's final stress scenarios its stress
scenarios, which include interest rate and foreign exchange stress
assumptions, this coverage declines to a minimum of 16.8x the
quarterly debt service amount due.

The structural features that mitigate sovereign and other
potential credit risks.  These features include, among others, DSC
triggers, an offshore collection and debt service payment
mechanism, and provisions for an early amortization of debt
service if certain adverse events occur.  In addition, Alfa Bank
has obtained signed acknowledgements from several of its key
correspondent banks (the designated depository banks) obligating
these institutions to deposit relevant collections directly into
the transactions' concentration accounts without setoff.

Key risk factors that could affect the transactions' performance
include:

A potential decline in payment order generation.  The dollar and
euro value of generated payment orders depends on many factors,
including the Russian economy's health, Alfa Bank's competitive
position in the corporate loan market, the level of foreign direct
and portfolio investment into Russia, the level of worker
remittances sent to Russia by non-resident Russians, and the state
of the world economy in general.

The presence of Russian DPR flows in the transactions.  Standard &
Poor's believes the Russian payment orders securitized in these
transactions that originate in Russia--largely as a result of the
domestic currency regime and historical payment methods--are at
particular risk of a sharp decline, or even a total cessation, if
the Russian government were to impose currency transfer and
convertibility controls as a result of severe financial stress.
Even with these flows completely excluded, however, S&P believes
the aforementioned stressed coverage ratios are sufficient to
support the current ratings.

Sovereign interference risk.  Although S&P regard this risk as
modest for properly structured financial future flow transactions
issued by systemically important banks, the possibility remains
that the government may be able to interfere in the transactions'
payment mechanics, should it choose to do so.

S&P will continue to surveil the ratings on these asset-backed
transactions and revise the ratings as necessary to reflect any
changes in the transactions' underlying credit quality.

                         Ratings Affirmed

         Alfa Diversified Payment Rights Finance Co. S.A.

                   Series              Rating
                   ------              ------
                   2006-A              BB+ (sf)
                   2006-B              BB+ (sf)
                   2006-C              BB+ (sf)
                   2007-A              BB+ (sf)
                   2007-B              BB+ (sf)


AMERICREDIT AUTOMOBILE: Moody's Assigns Final Ratings to Notes
--------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to the
notes to be issued by AmeriCredit Automobile Receivables Trust
2011-1.  This is the first senior/subordinated transaction of the
year for AmeriCredit Financial Services, Inc.

The complete rating actions are:

Issuer: AmeriCredit Automobile Receivables Trust 2011-1

  -- Class A-1 Notes, rated Prime-1 (sf);
  -- Class A-2 Notes, rated Aaa (sf);
  -- Class A-3 Notes, rated Aaa (sf);
  -- Class B Notes, rated Aa1 (sf);
  -- Class C Notes, rated Aa3 (sf);
  -- Class D Notes, rated Baa1 (sf);
  -- Class E Notes, rated Ba1 (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 2011-
1 pool is 11.0% 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 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%,
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 B3, respectively; Class C notes
might change from Aa3 to Ba1, B3, and below B3, respectively;
Class D notes might change from Baa1 to below B3 in all three
scenarios; and Class D notes might change from Ba1 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 to $780.056 Mil. Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
AmeriCredit Automobile Receivables Trust 2011-1's $780.056 million
auto receivables-backed notes.

AmeriCredit Automobile Receivables Trust 2011-1's note issuance is
a securitization of subprime auto loan receivables.  The ratings
reflect S&P's assessment of:

* The availability of approximately 44.8%, 39.8%, 33.1%, 26.4%,
  and 23.0% 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 12.25%-12.75% 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 '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', stress
  scenario, its 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 (sf)' and 'AA (sf)' rated securities,
  this is consistent with S&P's rating stability criteria.  In the
  case of the 'A+ (sf)' rated notes, this is slightly better than
  S&P's 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 ratings;

* The collateral characteristics of the securitized pool of
  subprime automobile loans;

* General Motors Financial Co. Inc.'s (GM Financial; formerly
  known as AmeriCredit Financial Services Inc.; B/Watch Pos/--)
  extensive securitization performance history going back to 1994;
  and

* The transaction's payment and legal structures.

                         Ratings Assigned

         AmeriCredit Automobile Receivables Trust 2011-1

         Class             Rating        Amount (mil. $)*
         -----             ------        ----------------
         A-1               A-1+ (sf)             138.000
         A-2               AAA (sf)              255.000
         A-3               AAA (sf)              174.000
         B                 AA (sf)                61.544
         C                 A+ (sf)                76.393
         D                 BBB (sf)               75.119
         E*                BB (sf)                19.944

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


ANTHRACITE CDO: Fitch Downgrades Ratings on Seven Classes of Notes
------------------------------------------------------------------
Fitch Ratings has downgraded seven and affirmed three classes
issued by Anthracite CDO I Ltd./Corp. as a result of significant
negative credit migration and increased interest shortfalls on the
underlying collateral.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  The default levels were then
compared to the breakeven levels generated by Fitch's cash flow
model of the CDO under the various default timing and interest
rate stress scenarios, as described in the report 'Global Criteria
for Cash Flow Analysis in Corporate CDOs'.  Based on this
analysis, the class A through F notes' breakeven rates are
generally consistent with the ratings assigned below.

Since Fitch's last rating action in March 2010, approximately
43.2% of the portfolio has been downgraded and 3.4% is currently
on Rating Watch Negative.  Approximately 36.9% has a Fitch derived
rating below investment grade and 15.8% has a rating in the 'CCC'
category or lower, compared to 26.4% and 1.8%, respectively, at
last review.  As of the Jan. 20, 2011 trustee report, 24.4% of the
portfolio is experiencing interest shortfalls compared to 3.4% at
last review.  The class A notes have paid down by $1.4 million
since the last review.

The Negative Outlook on the class A through F notes reflects
Fitch's expectation that underlying commercial mortgage backed
security loans will continue to face refinance risk.  The Loss
Severity rating indicates a tranche's potential loss severity
given default, as evidenced by the ratio of tranche size to the
base-case loss expectation for the collateral, as explained in
'Criteria for Structured Finance Loss Severity Ratings'.  The LS
rating should always be considered in conjunction with the
probability of default for tranches.  Fitch does not assign LS
ratings or Outlooks to classes rated 'CCC' and below.

Anthracite CDO I is a static cash flow commercial real estate
collateralized debt obligation that closed on May 29, 2002.  The
collateral is composed of 94.8% of CMBS from the 1998 through 2003
vintages and 5.2% of real estate investment trusts.

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

  -- $112,582,938 Class A-FL affirmed at 'AAAsf'; Outlook
     Negative; to 'LS3' from 'LS2';

  -- $22,000,000 Class B affirmed at 'AAAsf'; Outlook Negative; to
     'LS5' from 'LS3';

  -- $24,433,000 Class B-FL affirmed at 'AAAsf'; Outlook Negative;
     to 'LS5' from 'LS3';

  -- $29,331,000 Class C downgraded to 'Asf/LS4' from 'AA+sf/LS3';
     Outlook Negative;

  -- $30,000,000 Class C-FL downgraded to 'Asf/LS4' from
     'AA+sf/LS3'; Outlook Negative;

  -- $16,000,000 Class D downgraded to 'BBBsf/LS5' from 'AA-
     sf/LS3'; Outlook Negative;

  -- $14,955,000 Class D-FL downgraded to 'BBBsf/LS5' from 'AA-sf/
     LS3'; Outlook Negative;

  -- $20,506,000 Class E downgraded to 'BBsf/LS5' from 'A+sf/LS4';
     Outlook Negative;

  -- $4,000,000 Class E-FL downgraded to 'BBsf/LS5' from
     'A+sf/LS4'; Outlook Negative;

  -- $43,853,000 Class F downgraded to 'Bsf/LS5' from 'BBB/LS3';
     Outlook Negative.


ARGENT MORTGAGE: Moody's Cuts Ratings on Two 2005-W1 Tranches
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of two
tranches issued by Argent Mortgage Loan Trust 2005-W1.  The
tranches were downgraded to B3 from Ba2, and remain on review for
further downgrade given uncertainty regarding future benefit from
a mortgage pool insurance policy issued by Radian Guaranty Inc
(Insurer Financial Strength rated Ba3).  The collateral backing
these deals primarily consists of first-lien adjustable-rate
subprime residential mortgages.

                        Ratings Rationale

The primary source of assumption uncertainty is the future benefit
of a mortgage pool insurance policy issued by Radian Guaranty.
The policy has a detachment point of 7.65% of original balance,
and if all potential claims were accepted could provide a lifetime
benefit of up to $191,250,016 (including all claims paid to date).
Additionally, overcollateralization and excess spread serves as a
deductible that must be exhausted in each period before claims can
be considered.  If the pool policy provider rejects claims, and
overcollateralization and excess spread are depleted, the tranches
will experience losses.

Pool insurance policies are intended to offer protection to
investors by reducing the amount of losses borne by a
securitization trust.  Typically these policies work by
reimbursing losses from approved claims otherwise borne by the
securitization between fixed attachment and detachment points.
The attachment point (or deductible), is the amount of losses the
securitization trust bears before the insurance policy kicks in.
The insurer is expected to cover losses from approved claims up to
the detachment point (a pre-specified cap) at which time the
securitization, again, bears all losses.  Claims may be
contractually rejected by pool insurance providers in several
ways.  The most prevalent is rescission, typically occurring when
the insurer deems that a loan does not comply with the
originator's established underwriting guidelines.  Denials (or
"claims without payment"), represent a relatively small portion of
overall rejected claims, and, according to insurers, typically
result from incomplete/inadequate documentation provided by the
servicer to the insurer.

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 tranches are wrapped by
Financial Guaranty Insurance Company (Rating Withdrawn).  RMBS
securities wrapped by Financial Guaranty Insurance Company are
rated at their underlying rating without consideration of the
respective guaranties.

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

Complete rating actions are:

Issuer: Argent Mortgage Loan Trust 2005-W1

  -- Cl. A-1, Downgraded to B3 (sf) and Remains On Review for
     Possible Downgrade; previously on Jan. 13, 2010 Ba2 (sf)
     Placed Under Review for Possible Downgrade

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

   -- Cl. A-2, Downgraded to B3 (sf) and Remains On Review for
     Possible Downgrade; previously on Jan. 13, 2010 Ba2 (sf)
     Placed Under Review for Possible Downgrade

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


ASSET SECURITIZATION: S&P Cuts Rating on 1997-D5 Certs. to 'D'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
on the class B-1 commercial mortgage pass-through certificate from
Asset Securitization Corp.'s series 1997-D5, a U.S. commercial
mortgage-backed securities transaction.  Concurrently, S&P
affirmed its ratings on seven other classes from the same
transaction.

S&P's rating actions follow its review of the transaction's
remaining collateral, the transaction structure, and the liquidity
available to the trust.  Although the trust balance has
deleveraged significantly, the uncertainty of timely interest
payments that could impact the trust waterfall due to ongoing
litigation tempered S&P's rating actions.  The special servicer,
ORIX Capital Markets LLC, in the name of the trustee, Bank of
America Merrill Lynch, has filed various claims against the
depositor and loan seller.  The claims include, among other items,
the breach of representation and warranties of several loans that
were in the trust.  Litigation expenses relating to this matter
are being passed through to the trust, and it is S&P's
understanding that the legal expenses are likely to increase
significantly once a trial date is scheduled and takes place.

S&P lowered its rating on the class B-1 certificate to 'D (sf)'
due to accumulated interest shortfalls that have been outstanding
for four months, and S&P expects these shortfalls to remain
outstanding for the foreseeable future.

The affirmed ratings on the seven principal and interest
certificates reflect subordination and liquidity support levels
that are consistent with the outstanding ratings.

S&P's analysis included a review of the credit characteristics of
all of the remaining loans in the pool.  Using servicer-provided
financial information, S&P calculated an adjusted debt service
coverage of 1.42x and a loan-to-value ratio of 55.7%.  S&P further
stressed the loans' cash flows under its 'AAA' scenario to yield a
weighted average DSC of 1.09x and an LTV ratio of 78.2%.  The
implied defaults and loss severity under the 'AAA' scenario were
16.6% and 24.5%, respectively.  The DSC and LTV calculations noted
above exclude 13 fully defeased and one partially defeased loans
($125.4 million, 33.2%) and one specially serviced asset
($3.2 million, 0.8%).  S&P separately estimated losses for the
specially serviced asset and included it in S&P's 'AAA' scenario
implied default and loss figures.

                        Transaction Summary

As of the Jan. 14, 2011 trustee remittance report, the collateral
pool balance was $377.3 million, which is 21.5% of the balance at
issuance.  The pool includes 42 loans and one real estate asset,
down from 155 loans at issuance.  The master servicer, KeyBank
Real Estate Capital, provided financial information for 98.8% of
the nondefeased loans in the pool, 91.1% of which was full-year
2009 data.

S&P calculated a weighted average DSC of 1.47x for the loans in
the pool based on the servicer-reported figures.  S&P's adjusted
DSC and LTV ratio were 1.42x and 55.7%, respectively.  S&P's
adjusted DSC and LTV figures excluded 13 fully defeased and one
partially defeased loans ($125.4 million, 33.2%) and one specially
serviced asset ($3.2 million, 0.8%).  The transaction has
experienced $101.1 million in principal losses to date.  Six loans
($61.4 million, 16.3%) in the pool are on the master servicer's
watchlist. Eleven loans ($82.9 million, 22.0%) have reported DSCs
below 1.10x, six of which ($72.5 million, 19.2%) have a reported
DSC of less than 1.00x.

                      Credit Considerations

As of the Jan. 14, 2011 trustee remittance report, one asset
($3.2 million, 0.8%) in the pool was with the special servicer,
ORIX. The Value City - Carol Stream asset, a 106,500-sq.-ft.
retail strip center in Carol Stream, Ill., was transferred to ORIX
on April 24, 2008, and became REO on March 12, 2009.  ORIX stated
that the property is currently under contract for sale. A December
2010 appraisal valued the retail property significantly below the
total exposure of $4.9 million. S&P expects a significant loss
upon the eventual resolution of this asset.

                Summary of Top 10 Real Estate Loans

The top 10 loans secured by real estate have an aggregate
outstanding balance of $223.2 million (59.1%).  Using servicer-
reported numbers, S&P calculated a weighted average DSC of 1.46x
for the top 10 real estate loans.  S&P's adjusted DSC and LTV
ratio for the top 10 real estate loans are 1.40x and 56.7%,
respectively. The second-largest nondefeased loan ($55.2 million,
14.6%) is on the master servicer's watchlist.  Details on the
three largest top 10 real estate loans are:

The Saul Centers Retail Pool loan is the largest nondefeased loan
in the pool.  Excluding two retail properties totaling 427,300 sq.
ft. that defeased in 2010 with an allocated trust balance of
$19.2 million, the remaining collateral consists of seven retail
centers totaling 1.9 million sq. ft. in various cities in Maryland
and Virginia.  The nondefeased whole-loan balance of $84.4 million
is divided into an $83.9 million senior component that makes up
22.2% of the pooled trust balance and a $0.5 million junior
component that provides 100% of the cash flow for the class B-3SC
raked certificate (not rated by Standard & Poor's).  KeyBank
reported a combined DSC of 1.76x for year-end 2009, and the
overall occupancy was 94.1% according to the June 30, 2010 rent
rolls.

The Westin Peachtree Hotel loan ($55.2 million, 14.6%), the
second-largest nondefeased loan in the pool, is secured by a
1,068-room, full-service convention hotel in Atlanta.  The loan is
on the master servicer's watchlist due to a low DSC. KeyBank
reported a 0.82x DSC and 53.1% occupancy for year-end 2009.

The Dayton Mall loan ($51.7 million, 13.7%), the third-largest
nondefeased loan in the pool, is secured by 663,400 sq. ft. of a
1.3 million-sq.-ft. enclosed mall in Dayton, Ohio.  KeyBank
reported a 1.87x DSC for year-end 2009, and occupancy was 91.9%
according to the Sept. 30, 2010 rent roll.

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

                          Rating Lowered

                    Asset Securitization Corp.
   Commercial mortgage pass-through certificates series 1997-D5

                    Rating
                    ------
    Class      To           From        Credit enhancement (%)
    -----      --           ----        ----------------------
    B-1        D (sf)       B (sf)                        2.51

                         Ratings Affirmed

                     Asset Securitization Corp.
   Commercial mortgage pass-through certificates series 1997-D5

        Class    Rating             Credit enhancement (%)
        -----    ------             ----------------------
        A-1D     AAA (sf)                            98.97
        A-1E     AAA (sf)                            85.02
        A-2      AAA (sf)                            61.78
        A-3      AA+ (sf)                            47.83
        A-4      A+ (sf)                             40.86
        A-5      A- (sf)                             30.40
        A-6      BBB- (sf)                           18.78


ATRIUM CDO: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A, B-1, B-2, C-1, C-2, D-1, and D-2 notes from Atrium CDO,
a collateralized loan obligation transaction managed by Credit
Suisse Alternative Capital Inc.  S&P removed its ratings on the
class A, B-1, B-2, C-1, and C-2 notes from CreditWatch with
positive implications.

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

According to the Jan. 19, 2011 trustee report, the transaction
currently holds $10.7 million in 'CCC' rated assets, down from
$29.9 million noted in the Sept. 15, 2009, trustee report.  In
addition, the transaction holds $12.2 million in defaulted
securities, down from $40.1 million in September 2009.  The deal
has paid down $26.1 million to the class A notes since the last
review.  Accordingly, the transaction's overcollateralization
ratios have improved slightly.  The class A O/C ratio is 129.53%,
versus 127.75% in September 2009, and the class B O/C ratio is
115.49% versus 115.23%.

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

                            Atrium CDO

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


ATRIUM III: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2a, A-2b, B, C, D-1, and D-2 notes from Atrium III, a
collateralized loan obligation transaction managed by Credit
Suisse Alternative Capital Inc.  S&P removed four of those ratings
from CreditWatch with positive implications.

The upgrades reflect the improved performance S&P has observed in
the transaction's underlying asset portfolio since November 2009.
At that time, S&P lowered the ratings on all notes following a
review of the transaction under S&P's updated criteria for rating
corporate collateralized debt obligations.

At the time of S&P's last rating action, the transaction held
approximately $40.1 million in defaulted obligations and
$76.1 million in underlying obligors with a rating in the 'CCC'
range, according to the Sept. 25, 2009, trustee report.  As of the
Dec. 24, 2010 trustee report Atrium III held $17.1 million in
defaulted obligations and $40.4 million in assets from underlying
obligors with ratings in the 'CCC' range.

Since the time of S&P's last rating action, a number of defaulted
obligors held in the deal emerged from bankruptcy, with some
receiving proceeds that were higher than their carrying value in
the overcollateralization (O/C) ratio test calculation.  This, in
combination with a reduction in assets with ratings in the 'CCC'
range and in discount assets, benefited the transaction's O/C
ratios.  The class A O/C ratio increased to 123.8% as of the
Dec. 24, 2010 report from 119.3% as of Sept. 25, 2009 report.
The transaction is passing its O/C and interest coverage tests.

S&P will continue to review its ratings on the notes and assess
whether, in its view, the ratings remain consistent with the
credit enhancement available to support them and take rating
actions as S&P deems necessary.

                  Rating And Creditwatch Actions

                            Atrium III

                                  Rating
                                  ------
     Class                   To           From
     -----                   --           ----
     A-1                     AA+ (sf)     AA (sf)/Watch Pos
     A-2a                    AA (sf)      A (sf)/Watch Pos
     A-2b                    AA (sf)      A (sf)/Watch Pos
     B                       BBB+ (sf)    BBB- (sf)/Watch Pos
     C                       BB+ (sf)     BB- (sf)
     D-1                     B+ (sf)      B- (sf)
     D-2                     B+ (sf)      B- (sf)



AURORA BANK: Moody's Reviews Ratings on 48 Tranches
---------------------------------------------------
Moody's Investors Service has placed on review for possible
downgrade 48 tranches issued in six securitizations of small
business loans and four tranches issued in three net interest
margin securities transactions.  The deals are serviced by Aurora
Bank FSB, formerly known as Lehman Brothers Bank, FSB.  The loans
are secured primarily by commercial real estate.

                        Ratings Rationale

The rating actions are due to a significant rise in 60 days or
more delinquencies, including amounts in foreclosure and REO, from
a range of 10%-13% of the current pool balance in February 2009 to
20%-25% as of the January 2011 distribution date.  The 2005-1 deal
experienced an increase in 60 days or more delinquencies from 4%
to 8% of the current pool balance.

The methodology used in these rating actions included an analysis
of the loan collateral to arrive at a range of estimated lifetime
losses.  This range of net losses was then evaluated against the
available credit enhancement provided by the reserve account,
overcollateralization, and excess spread.  Sufficiency of coverage
was considered in light of the credit quality of the collateral
pool, industry, geographical and loan concentrations, historical
variability of losses experienced by the issuer, and servicer
quality.

The methodology used for the net interest margin securities
included evaluating the likelihood of paying interest and
principal from excess cash and prepayment fees from the respective
underlying small business loan transaction.  The potential cash
inflow was considered in relation to accumulated interest
shortfalls and reserve account deficits.

During the review period, Moody's will project expected defaults
on the underlying pools of loans using delinquency roll rates and
an estimate of market recoveries.  The Aaa volatility proxies will
also be determined.  Driving factors of the Aaa volatility proxy
for each deal are the credit quality of the collateral pool, the
historical variability in losses experienced by the issuer, the
servicer quality as well as the industrial, geographical and
obligor concentrations.

Based on Moody's revised expected losses and Aaa volatility
proxies, Moody's will evaluate whether the available credit
enhancement adequately protects investors against future
collateral losses for given rating assignments.

Primary sources of assumption uncertainty are the general economic
environment, commercial property values, and the ability of small
businesses to recover from the recession.

The complete rating actions are:

Issuer: Lehman Brothers Small Balance Commercial Mortgage Pass-
Through Certificates, Series 2005-1

  -- Cl. A, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. A-IO, Aa1 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. M1, Baa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Baa2 (sf)

  -- Cl. M2, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to B1 (sf)

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

Issuer: Lehman Brothers Small Balance Commercial Mortgage Pass-
Through Certificates, Series 2006-2

  -- Cl. 1A, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A2, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A3, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. M1, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Baa1 (sf)

  -- Cl. M2, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Baa3 (sf)

  -- Cl. M3, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Ba3 (sf)

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

Issuer: Lehman Brothers Small Balance Commercial Mortgage Pass-
Through Certficates, Series 2006-3

  -- Cl. 1A, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A2, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A3, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. M1, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Baa1 (sf)

  -- Cl. M2, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Ba1 (sf)

  -- Cl. M3, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to B1 (sf)

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

Issuer: Lehman Brothers Small Balance Commercial Mortgage Pass-
Through Certificates, Series 2007-1

  -- Cl. 1A, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A1, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A2, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A3, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. M1, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Baa1 (sf)

  -- Cl. M2, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Baa3 (sf)

  -- Cl. M3, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Ba3 (sf)

  -- Cl. M4, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to B1 (sf)

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

Issuer: Lehman Brothers Small Balance Commercial Mortgage Pass-
Through Certificates, Series 2007-2

  -- Cl. 1A2, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 1A3, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 1A4, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A1, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A2, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. 2A3, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. M1, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to A3 (sf)

  -- Cl. M2, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Baa3 (sf)

  -- Cl. M3, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Ba1 (sf)

  -- Cl. M4, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Ba3 (sf)

  -- Cl. M5, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to B1 (sf)

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

Issuer: Lehman Brothers Small Balance Commercial Mortgage Pass-
Through Certificates, Series 2007-3

  -- Cl. AM, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. AJ, Aa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Aa1 (sf)

  -- Cl. M1, A3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to A3 (sf)

  -- Cl. M2, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Baa3 (sf)

  -- Cl. M3, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Ba2 (sf)

  -- Cl. M4, Ba3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to Ba3 (sf)

  -- Cl. M5, B1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 4, 2009 Downgraded to B1 (sf)

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

Issuer: LBSBC Net Interest Margin Securities, Series 2005-2

  -- Cl. N2, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2009 Downgraded to Caa3 (sf)

Issuer: LBSBC Net Interest Margin Notes, Series 2006-1

  -- Cl. N1, Ba1 (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2009 Downgraded to Ba1 (sf)

  -- Cl. N2, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2009 Downgraded to Ca (sf)

Issuer: LBSBC Net Interest Margin Securities, Series 2006-2

  -- Cl. N1, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on March 18, 2009 Downgraded to Ca (sf)


AURUM CLO: S&P Raises Ratings on Various Classes of Notes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-2, B, C, D-1, and D-2 notes from Aurum CLO 2002-1 Ltd.,
a collateralized loan obligation transaction managed by Deutsche
Asset Management Inc. S&P removed its ratings on the class A-2, B,
and C notes from CreditWatch with positive implications.  At the
same time, S&P affirmed its rating on the class A-1 notes.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio and the significant paydowns to
the class A-1 notes since S&P's last rating action in November
2009.  The affirmation reflects the availability of credit support
at the current rating level.

According to the Jan. 6, 2011 trustee report, the transaction
currently holds $16.0 million in 'CCC' rated assets, down from
$39.1 million noted in the Sept. 1, 2009, trustee report.  In
addition, the transaction holds $1.7 million in defaulted
securities, down from $16.4 million in September 2009.  The deal
has paid down $108.3 million to the class A-1 notes since the last
review.  Accordingly, the transaction's overcollateralization
ratios have improved since September 2009:

* The class A O/C ratio is 164.23%, compared with 133.74%;
* The class B O/C ratio is 126.86%, compared with 115.4%;
* The class C O/C ratio is 114.68%, compared with 108.46%; and
* The class D O/C ratio is 105.29%, compared with 102.72%.

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 may take
rating actions as it deems necessary.

                  Rating And Creditwatch Actions

                       Aurum CLO 2002-1 Ltd.

                           Rating
                           ------
           Class       To          From
           -----       --          ----
           A-2         AAA (sf)    AA+ (sf)/Watch Pos
           B           AA+ (sf)    A+ (sf)/Watch Pos
           C           A (sf)      BB+ (sf)/Watch Pos
           D-1         B (sf)      CCC- (sf)
           D-2         B (sf)      CCC- (sf)

                         Rating Affirmed

                       Aurum CLO 2002-1 Ltd.

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


AUSTIN HOUSING: S&P Gives Stable Outlook on 'CC' Bond Rating
------------------------------------------------------------
Standard & Poor's Ratings Services revised the outlook on its 'CC'
long-term rating on Austin Housing Finance Corp., Texas' single-
family mortgage revenue refunding bonds series 1997A-1 to stable
from negative.  The bonds are secured by Ginnie Mae mortgage pass-
through certificates.

The rating reflects S&P's view of the insufficiency of revenues
from mortgage debt service payments and investment earnings to pay
full and timely debt service on the bonds until maturity,
investments held in JPMorgan 100% U.S. Treasury Money Market Fund
(AAAm), and an asset-to-liability ratio of 97.18% as of Jan. 5,
2011.

"S&P expects that the parity position will continue to decline,"
said Standard & Poor's credit analyst Renee J. Berson.  "The
outlook is also reflective of the current rating on the bonds."


AVALON CAPITAL: S&P Raises Ratings on Various Classes of Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, C Def, and D Def notes from Avalon Capital Ltd. 3, a
collateralized loan obligation transaction managed by INVESCO
Senior Secured Management Inc. At the same time, S&P removed its
ratings on the class A-1, A-2, and B notes from CreditWatch, where
S&P placed them with positive implications on Nov. 8, 2010.

The upgrades primarily reflect an improvement in the performance
of the transaction's underlying portfolio since S&P's Nov. 17,
2009 rating action, when S&P downgraded the notes following the
application of its September 2009 corporate CDO criteria.  As of
the Jan. 10, 2011 trustee report, the transaction had
$2.71 million of defaulted assets.  This was down from
$45.33 million noted in the Oct. 7, 2009, trustee report,
which S&P referenced for its November 2009 rating actions.

The upgrade on the class D notes additionally reflects turbo
payments to the tranche balance.  Since the last action, the class
D notes have been paid down by a total of $5.7 million, leaving
them at 77% of their original note balance.

Subsequently, the transaction has benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratios in the Jan. 10, 2011 monthly
report:

* The class A/B O/C ratio was 121.86%, compared with a reported
  ratio of 116.52% in October 2009;

* The class C O/C ratio was 112.37%, compared with a reported
  ratio of 107.44% in October 2009; and

* The class D O/C ratio was 105.69%, compared with a reported
  ratio of 99.98% in October 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

                      Avalon Capital Ltd. 3

                           Rating
                           ------
            Class       To         From
            -----       --         ----
            A-1         AA+ (sf)   AA (sf)/Watch Pos
            A-2 Var Fu  AA+ (sf)   AA (sf)/Watch Pos
            B           AA (sf)    A+ (sf)/Watch Pos
            C Def       BBB+ (sf)  BBB (sf)
            D Def       BB+ (sf)   CCC- (sf)

  Transaction Information
  -----------------------
Issuer:              Avalon Capital Ltd. 3
Coissuer:            Avalon Capital LLC 3
Collateral manager:  INVESCO Senior Secured Management Inc.
Underwriter:         Lehman Bros. Inc.
Trustee:             Bank of New York Mellon (The)
Transaction type:    Cash flow CLO


AVENUE CLO: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1L, A-2L, A-3L, B-1L, and B-2L notes from Avenue CLO II Ltd., a
collateralized loan obligation transaction managed by Avenue
Capital Management II L.P.  At the same time, S&P removed its
ratings on the class A-1L, A-2L, A-3L, and B-1L notes from
CreditWatch, where S&P had placed them with positive implications
on Nov. 8, 2010.

The upgrades reflect an improvement in the credit quality
available to support the notes since S&P's Dec. 18, 2009, rating
action, when S&P downgraded the rated notes, following the
application of S&P's September 2009 corporate collateralized debt
obligation criteria.  As of the Dec. 21, 2010 trustee report, the
transaction had $18.37 million in defaulted assets.  This was down
from $44.13 million noted in the Nov. 18, 2009 trustee report,
which S&P referenced for its December 2009 rating actions.

The transaction has also benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratios in the Dec. 21, 2010 monthly
report:

* The senior class A O/C ratio (which includes the class A-1L and
  A-2L notes) was 121.71%, compared with a reported ratio of
  117.58% in November 2009;

* The class A O/C ratio was 114.03%, compared with a reported
  ratio of 110.30% in November 2009;

* The class B-1L O/C ratio was 108.18%, compared with a reported
  ratio of 104.68% in November 2009; and

* The class B-2L O/C ratio was 103.23%, compared with a reported
  ratio of 98.90% 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

                         Avenue CLO II Ltd.

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

Transaction Information
-----------------------
Issuer:              Avenue CLO II Ltd.
Co-issuer:           Avenue CLO II (Delaware) Corp.
Collateral manager:  Avenue Capital Management II L.P.
Underwriter:         Bear Stearns Cos.  LLC (The)
Trustee:             Bank of New York Mellon (The)
Transaction type:    Cash flow CLO


AVERY POINT: S&P Raises Ratings on Various Classes of Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-3, B, C-1, C-2, D-1, D-2, and E notes from Avery Point CLO
Ltd., a collateralized loan obligation transaction managed by
Sankaty Advisors LLC.  S&P removed its ratings on the class A-3,
B, C-1, and C-2 notes from CreditWatch with positive implications.
At the same time, S&P affirmed its rating on the class A-2 notes.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio and significant paydowns to the
class A-1 and A-2 notes since S&P's last rating action in December
2009.  The affirmation reflects the availability of credit support
at the current rating level.

According to the Jan. 5, 2011, trustee report, the transaction
currently holds $16.8 million in 'CCC' rated assets, down from
$43.3 million noted in the Oct. 5, 2009, trustee report.  In
addition, the transaction holds $3.4 million in defaulted
securities, down from $32.9 million in October 2009.  The deal has
paid down $49.7 million and $97.8 million to the class A-1 and A-2
notes, respectively, since S&P's December 2009 rating action.
Accordingly, the transaction's overcollateralization ratios have
improved.  The class A/B O/C ratio is 144.0% versus 124.76% in
October 2009, the class C O/C ratio is 127.4% versus 115.37%, the
class D O/C ratio is 117.7% versus 109.45%, and the class E O/C
ratio is 114.3% versus 107.3%.

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

                        Avery Point CLO Ltd.

                           Rating
                           ------
           Class       To          From
           -----       --          ----
           A-1         AAA (sf)    AA+ (sf)
           A-3         AAA (sf)    AA+ (sf)/Watch Pos
           B           AAA (sf)    AA- (sf)/Watch Pos
           C-1         AA- (sf)    BBB+ (sf)/Watch Pos
           C-2         AA- (sf)    BBB+ (sf)/Watch Pos
           D-1         BBB+ (sf)   BB+ (sf)
           D-2         BBB+ (sf)   BB+ (sf)
           E           BB+ (sf)    B+ (sf)

                         Rating Affirmed

                        Avery Point CLO Ltd.

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


BABSON CLO: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1, A-2B, B, C, and D notes from Babson CLO Ltd. 2003-I,
a collateralized loan obligation transaction managed by Babson
Capital Management LLC.  At the same time, S&P removed those
ratings from CreditWatch, where S&P placed them with positive
implications on Nov. 8, 2010.  S&P also affirmed its 'AAA (sf)'
rating on the class A-2A notes and its 'CCC- (sf)' rating on the
class E notes and senior preferred shares.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio and paydowns on the class A-1
and class A-2A notes since S&P's Dec. 11, 2009 rating action, when
S&P downgraded most of the rated notes following the application
of its September 2009 corporate CDO criteria.  As of the Dec. 31,
2010 trustee report, the transaction had $1.46 million of
defaulted assets.  This was down from $15.13 million noted in the
Sept. 30, 2009 trustee report, which S&P referenced for its
December 2009 rating actions.  The affirmations of the class A-2A
and E notes and the senior preferred shares reflect the
availability of credit support at the current rating levels.

The transaction has also benefited from an increase in
overcollateralization (O/C) available to support the rated notes.
The trustee reported these O/C ratios in the Dec. 31, 2010 monthly
report:

* The class A/B O/C ratio was 138.80%, compared with a reported
  ratio of 120.48% in September 2009;

* The class C/D O/C ratio was 109.31%, compared with a reported
  ratio of 104.67% in September 2009; and

* The class E/senior preferred shares O/C ratio was 104.50%,
  compared with a reported ratio of 100.46% in September 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

                      Babson CLO Ltd 2003-I

                           Rating
                           ------
             Class     To           From
             -----     --           ----
             A-1       AAA (sf)     AA+ (sf)/Watch Pos
             A-2B      AAA (sf)     AA+ (sf)/Watch Pos
             B         AAA (sf)     A+ (sf)/Watch Pos
             C         A+ (sf)      BBB+ (sf)/Watch Pos
             D         BB+ (sf)     B+ (sf)/Watch Pos

                         Ratings Affirmed

                      Babson CLO Ltd. 2003-I

                 Class                    Rating
                 -----                    ------
                 A-2A                     AAA (sf)
                 E                        CCC- (sf)
                 Senior preferred shares  CCC- (sf)

Transaction Information
-----------------------
Issuer:             Babson CLO Ltd. 2003-I
Coissuer:           Babson (Delaware) CLO Corp. 2003-I
Collateral manager: Babson Capital Management LLC
Underwriter:        Wachovia Securities Inc.
Trustee:            U.S. Bank National Association
Transaction type:   Cash flow CLO


BAKER STREET: S&P Raises Ratings on Four Classes of Notes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, D, and E notes from Baker Street Funding CLO 2005-1 Ltd., a
collateralized loan obligation transaction managed by Seix
Advisors.  S&P also affirmed its 'AA+' (sf) ratings on the class
A-1 and A-2 notes.  At the same time, S&P removed its ratings on
the class A-1, A-2, B, and C notes from CreditWatch, where S&P
placed them with positive implications on Nov. 8, 2010.

The upgrades reflect an improvement in the credit quality
available to support the notes since S&P's Feb. 8, 2010 rating
actions, when S&P downgraded most of the rated notes, following
the application of S&P's September 2009 corporate CDO criteria.
As of the Dec. 8, 2010 trustee report, the transaction had
$10.34 million in defaulted assets. This was down from
$32.97 million noted in the Jan. 4, 2010, trustee report, which
S&P referenced for its February 2010 rating actions.

The transaction has also benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported the following O/C ratios in the Dec. 8, 2010
monthly report:

* The class A/B O/C ratio was 119.31%, compared with a reported
  ratio of 115.73% in January 2010;

* The class C O/C ratio was 112.13%, compared with a reported
  ratio of 108.76% in January 2010;

* The class D O/C ratio was 106.86%, compared with a reported
  ratio of 103.66% in January 2010; and

* The class E O/C ratio was 103.75%, compared with a reported
  ratio of 100.46% in January 2010.

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

                Baker Street Funding CLO 2005-1 Ltd.

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

Transaction Information
-----------------------
Issuer:              Baker Street Funding CLO 2005-1 Ltd.
Coissuer:            Baker Street Funding CLO 2005-1 Corp.
Collateral manager:  Seix Advisors
Underwriter:         SunTrust Capital Markets
Trustee:             The Bank of New York Mellon
Transaction type:    Cash flow CLO


BANC OF AMERICA: Moody's Affirms Ratings on 20 2005-2 Certs.
------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 20 classes of
Banc of America, Commercial Mortgage Pass-Through Certificates,
Series 2005-2:

  -- Cl. A-4, Affirmed at Aaa (sf); previously on July 5, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-AB, Affirmed at Aaa (sf); previously on July 5, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-5, Affirmed at Aaa (sf); previously on July 5, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-C, Affirmed at Aaa (sf); previously on July 5, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-P, Affirmed at Aaa (sf); previously on July 5, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-M, Affirmed at Aaa (sf); previously on July 5, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-J, Affirmed at Aaa (sf); previously on Aug. 27, 2009
     Confirmed at Aaa (sf)

  -- Cl. B, Affirmed at Aa2 (sf); previously on Aug. 27, 2009
     Confirmed at Aa2 (sf)

  -- Cl. C, Affirmed at Aa3 (sf); previously on Aug. 27, 2009
     Confirmed at Aa3 (sf)

  -- Cl. D, Affirmed at A3 (sf); previously on Aug. 27, 2009
     Downgraded to A3 (sf)

  -- Cl. E, Affirmed at Baa1 (sf); previously on Aug. 27, 2009
     Downgraded to Baa1 (sf)

  -- Cl. F, Affirmed at Baa2 (sf); previously on Aug. 27, 2009
     Downgraded to Baa2 (sf)

  -- Cl. G, Affirmed at Baa3 (sf); previously on Aug. 27, 2009
     Downgraded to Baa3 (sf)

  -- Cl. H, Affirmed at Ba2 (sf); previously on Aug. 27, 2009
     Downgraded to Ba2 (sf)

  -- Cl. J, Affirmed at Ba3 (sf); previously on Aug. 27, 2009
     Downgraded to Ba3 (sf)

  -- Cl. K, Affirmed at B1 (sf); previously on Aug. 27, 2009
     Downgraded to B1 (sf)

  -- Cl. L, Affirmed at B2 (sf); previously on Aug. 27, 2009
     Downgraded to B2 (sf)

  -- Cl. M, Affirmed at Caa2 (sf); previously on Aug. 27, 2009
     Downgraded to Caa2 (sf)

  -- Cl. N, Affirmed at Caa2 (sf); previously on Aug. 27, 2009
     Downgraded to Caa2 (sf)

  -- Cl. O, Affirmed at Caa3 (sf); previously on Aug. 27, 2009
     Downgraded to Caa3 (sf)

                        Ratings Rationale

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 3.3%.  Moody's stressed scenario loss is
13.5% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

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

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors.  Therefore,
the rating outcome may differ from the model output.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated August 27, 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 January 10, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 26% to $1.2 billion
from $1.6 billion at securitization.  The Certificates are
collateralized by 77 mortgage loans ranging in size from less than
1% to 9% of the pool, with the top ten loans representing 51% of
the pool.  Two loans, representing 3% of the pool, have defeased
and are collateralized with U.S. Government securities.

Twenty-two loans, representing 26% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the 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 trust has experienced an aggregate $12,573 loss since
securitization.  Currently four loans, representing 2% of the
pool, are in special servicing.  The largest specially serviced
loan is the Great Wall Mall Loan ($14.6 million -- 1.2% of the
pool), which is secured by 73,866 square foot (SF) anchored retail
center located in Kent, Washington.  The loan was transferred to
special servicing on December 31, 2010 and is currently in its
grace period.  The master servicer has recognized an aggregate
$772,808 appraisal reduction on two of the specially serviced
loans.  Moody's has estimated an aggregate $9.1 million loss (37%
expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for seven poorly
performing loans representing 13% of the pool.  Moody's has
estimated a $8.9 million loss (18% expected loss based on a 50%
probability default) from the troubled loans.

Moody's was provided with full year 2009 operating results for 99%
of the pool.  Excluding troubled loans, Moody's weighted average
LTV 95% compared to 101% 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 9.3%.

Excluding troubled loans, Moody's actual and stressed DSCRs are
1.60X and 1.11X, respectively, compared to 1.61X and 1.01X 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 24 compared to 30 at Moody's prior review.

The top three performing conduit loans represent 24% of the pool.
The largest loan is the New York University Housing Loan
($110.0 million -- 9.1% of the pool), which is secured by a 264-
unit, 17-story student housing property located in the Tribeca
sub-market of New York City.  The property is 100% master leased
to New York University.  Performance has increased since
securitization due to a higher base rent.  Moody's LTV and
stressed DSCR are 96% and 0.90X, respectively, compared to 114%
and 0.76X, at last review.

The second largest loan is the Canyon Ranch Loan ($95.0 million --
7.8% of the pool), which is secured by two resort hotels
containing a total of 315 rooms.  The resorts are located in
Arizona and Massachusetts.  Performance has improved over the
trailing 12 months due to increases in occupancy and revenues.
Moody's LTV and stressed DSCR 80% and 1.42X, respectively,
compared to 87% and 1.30X at last review.

The third largest loan is the Regents Square I & II Loan
($88.6 million -- 7.3% of the pool), which is secured by a 307,450
SF office portfolio located in the La Jolla sub-market of San
Diego, California.  The property was 73% leased as of July 2010
compared to 75% at last review.  Performance has declined due to
an increase in vacancy and increases in operating expenses.  The
loan is currently on the master servicer's watchlist for low
occupancy.  Moody's has assumed a high default probability for
this loan.  Moody's LTV and stressed DSCR 171% and 0.59X,
respectively, compared to 140% and 0.70X at last review.


BEAR STEARNS: Moody's Upgrades Ratings on Series 1998-C1 Certs.
---------------------------------------------------------------
Moody's Investors Service upgraded the rating of one class and
placed the class on watch for possible downgrade and affirmed
three classes of Bear Stearns Commercial Mortgage Securities Inc.,
Commercial Mortgage Pass-Through Certificates, Series 1998-C1:

  -- Cl. E, Upgraded to Aaa (sf) and Placed Under Review for
     Possible Downgrade; previously on April 1, 2009 Upgraded to
     Aa2 (sf)

  -- Cl. G, Affirmed at Ba2 (sf); previously on June 29, 1998
     Assigned Ba2 (sf)

  -- Cl. H, Affirmed at B1 (sf); previously on May 25, 2006
     Downgraded to B1 (sf)

  -- Cl. I, Affirmed at C (sf); previously on May 25, 2006
     Downgraded to C (sf)

                        Ratings Rationale

Moody's rating action did not address the ratings of Classes B, C,
D and X, which are all currently rated Aaa, on review for possible
downgrade.  These classes were placed on review on January 19,
2011.  KeyCorp Real Estate Capital Markets, Inc. is the master
servicer on this transaction and deposits collection, escrow and
other accounts in KeyBank, National Association.  Keybank no
longer meets Moody's rating criteria for an eligible depository
account institution for Aaa and Aa1 rated securities.  Moody's is
reviewing arrangements that KeyBank has proposed, and that it may
propose, to mitigate the incremental risk indicated by the lower
rating of the depository account institution, so as possibly to
allow the classes on review to maintain their current ratings.

The upgrade of Class E is due to overall improved pool performance
and a significant increase in subordination levels due to loan
paydowns and amortization.  However, given that KeyBank does not
meet Moody's rating criteria as an eligible despository account
institution, this place is placed on review for possible downgrade
along with the transaction's other Aaa rated classes.

The affirmations of Classes G, H and I 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
2.0% of the current balance.  At last review, Moody's cumulative
base loss was 5.1%.  Moody's stressed scenario loss is 4.3% of the
current balance.

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

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

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a pay down analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade 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 10 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 April 1, 2009.

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.

                         Deal Performance

As of the January 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 80% to $146.5
million from $714.7 million at securitization.  The Certificates
are collateralized by 28 mortgage loans ranging in size from less
than 1% to 14% of the pool, with the top ten loans representing
63% of the pool.  Nine loans, representing 29% of the pool, have
defeased and are collateralized by U.S. Government securities.
There are no loans in the pool with investment grade credit
estimates.

Two loans, representing 3% 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 since
securitization, resulting in a $21.2 million loss (50% loss
severity).  The pool had experienced an aggregate $20.2 million
loss at last review.  There are no loans currently in special
servicing.

Moody's has assumed a high default probability for the two poorly
performing loans representing 3% of the pool and has estimated a
$993,000 loss (27% expected loss based on a 61% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 86% and 85%, respectively, of the pool's
non-defeased loans.  Excluding specially serviced and troubled
loans, Moody's weighted average LTV is 50% compared to 57% at
Moody's prior review.  Moody's net cash flow reflects a weighted
average haircut of 11.2% to the most recently available net
operating income.  Moody's value reflects a weighted average
capitalization rate of 9.6%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 2.57X and 2.27X, respectively, compared to
1.83X and 1.96X 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 34% of the pool
balance.  The largest loan is the Mission Marketplace Loan
($19.8 million -- 13.5% of the pool), which is secured by a
344,100 square foot retail center located in Oceanside,
California.  Major tenants include Kmart, Mission Market Cinema
and Henry Markets.  Financial performance has been stable since
last review.  The property was 87% leased as of September 2010
versus 90% at last review.  The loan has amortized 4% since last
review.  Moody's LTV and stressed DSCR are 71% and 1.37X,
respectively, compared to 74% and 1.31X at last review.

The second largest loan is the Lomas Santa Fe Plaza Loan
($17.5 million -- 12.0% of the pool), which is secured by a
214,000 SF retail center located north of San Diego in Solana
Beach, California.  Although financial performance at this
property has declined since last review due to lower occupancy,
the property is performing better than Moody's expectations.  At
last review Moody's analysis reflected a stressed cash flow due to
concerns about potential income volatility caused by upcoming
lease expirations.  The center was 94% leased as September of 2010
versus 98% at last review.  The loan has amortized 4% since last
review.  Moody's LTV and stressed DSCR are 37% and 2.66X,
respectively, compared to 44% and 2.24X at last review.

The third largest loan is the Torrey Reserve South Court Loan
($12.9 million -- 8.8% of the pool), which is secured by a 130,641
SF office building located in San Diego, California.  Although
financial performance at this property has declined since last
review due to lower occupancy, the property is performing better
than Moody's expectations.  At last review Moody's analysis
reflected a stressed cash flow due to concerns about potential
income volatility caused by upcoming lease expirations.  The
property was 86% leased as of September 2010 versus 90% at last
review.  This loan has amortized 4% since last review.  The loan
is on the Master Servicer's watchlist due to lower occupancy.
Moody's LTV and stressed DSCR are 48% and 2.33X, respectively,
compared to 54% and 2.11X at last review.


BELHURST CLO: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, A-3, B, C, D, and E notes from Belhurst CLO Ltd., a
collateralized loan obligation managed by INVESCO Senior Secured
Management Inc.  S&P removed the ratings on the class A-1, A-2, A-
3, B, C, and D notes from CreditWatch with positive implications.
At the same time, S&P withdrew its rating on the transaction's
principal protected notes.

The upgrades reflect the improved performance S&P has observed in
the transaction's underlying asset portfolio since its last rating
action in October 2009.  S&P withdrew its rating on the principal
protected notes, which is dependent on the rating on the
segregated collateral securities pledged for that class, in
accordance with the rating of the segregated collateral
securities.

According to the Dec. 7, 2010 trustee report, the transaction held
$4.21 million in defaulted assets, down from $32.2 million in
defaulted assets as of the Sept. 8, 2009 trustee report.

The transaction has also benefited from an increase in
overcollateralization (O/C) available to support the rated notes.
The trustee reported these O/C ratios in the Dec. 7, 2010 trustee
report:

* The class A/B O/C ratio was 120.5%, compared with a reported
  ratio of 115.5% in September 2009;

* The class C O/C ratio was 110.7%, compared with a reported ratio
  of 106.0% in September 2009; and

* The class D O/C ratio was 107.51%, compared with a reported
  ratio of 102.99% in September 2009.

The transaction has paid down the deferred interest on the class D
and E notes that had previously accumulated when it was failing
the class C and class D principal coverage tests.

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

                         Belhurst CLO Ltd.

                                      Rating
                                      ------
Class                            To           From
-----                            --           ----
A-1                              AA+ (sf)     AA- (sf)/Watch Pos
A-2                              AA+ (sf)     AA- (sf)/Watch Pos
A-3                              AA+ (sf)     AA- (sf)/Watch Pos
B                                AA (sf)      A+ (sf)/Watch Pos
C (deferrable)                   BBB+ (sf)    BBB- (sf)/Watch Pos
D (deferrable)                   BBB (sf)     B+ (sf)/Watch Pos
E (deferrable)                   B+ (sf)      CCC- (sf)
Principal protected              NR           AAA (sf)

                         NR -- not rated.


CARLYLE ARNAGE: S&P Takes Rating Actions on Various Classes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
B-2L notes and affirmed its ratings on the class A-1L, A-1LA, A-
1LB, A-2L, A-3L, and B-1L notes from Carlyle Arnage CLO Ltd.
(formerly known as Stanfield Arnage CLO Ltd.), a collateralized
loan obligation managed by Carlyle Investment Management LLC.  At
the same time, S&P removed its ratings on classes A-1L, A-1LA, and
A-1LB from CreditWatch with positive implications.

The upgrade reflects the improved performance S&P has observed
in the transaction since its last rating action in November
2009.  According to the Jan. 27, 2011 trustee report, the
transaction held $1 million in defaulted assets, down from
$5 million noted in the Sept. 15, 2009 trustee report.  The
class A overcollateralization test improved to 112.93% in January
2011 from 111.69% as of September 2009.  In addition, class B-2L's
credit enhancement has improved.  The rating was capped by the
application of the largest obligor default supplemental test at
the time of S&P's last rating action; however, as of January 2011,
class B-2L had sufficient credit enhancement to withstand the
combinations of underlying asset defaults specified by the largest
obligor default supplemental test at the 'B+ (sf)' rating level.

The affirmations and CreditWatch removals reflect S&P's view that
sufficient credit support is available to the classes at their
current rating levels.

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 will take
rating actions as it deems necessary.

                  Rating And Creditwatch Actions

                      Carlyle Arnage CLO Ltd.

                            Rating
                            ------
            Class       To          From
            -----       --          ----
            B-2L        B+ (sf)     CCC+ (sf)
            A-1L        AA+ (sf)    AA+ (sf)/Watch Pos
            A-1LA       AA+ (sf)    AA+ (sf)/Watch Pos
            A-1LB       AA+ (sf)    AA+ (sf)/Watch Pos

                         Ratings Affirmed

                      Carlyle Arnage CLO Ltd.

                 Class                   Rating
                 -----                   ------
                 A-2L                    A+ (sf)
                 A-3L                    BB+ (sf)
                 B-1L                    BB+ (sf)


CARLYLE AZURE: S&P Raises Ratings on Three Classes of Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on three
classes of notes from Carlyle Azure CLO Ltd., a collateralized
loan obligation transaction managed by The Carlyle Group.  S&P
also affirmed its ratings on an additional class of notes from the
same transaction.  At the same time, S&P affirmed its ratings on
the class A-1L and A-1LV notes and removed them from CreditWatch
with positive implications.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio since its last rating action in
October 2009.

According to the December 2010 trustee report, which S&P used in
its current analysis, the balance of defaulted obligations in the
transaction's asset portfolio was $5 million, compared with $10
million as of the September 2009 trustee report (which S&P used as
a reference for its October 2009 analysis). Similarly, there were
$14 million of 'CCC' rated obligations in the transaction's asset
portfolio according to the December 2010 trustee report, down from
$36 million as of the September 2009 trustee report.

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

                          Ratings Raised

                       Carlyle Azure CLO Ltd.

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

                         Rating Affirmed

                      Carlyle Azure CLO Ltd.

                      Class         Rating
                      -----         ------
                      X             AAA (sf)

          Ratings Affirmed And Removed From Creditwatch

                       Carlyle Azure CLO Ltd.

                Class         Rating
                -----         ------
                A-1L          AA+ (sf)/Watch Pos
                A-1LV         AA+ (sf)/Watch Pos


CD 2007-CD4: Moody's Reviews Ratings on 10 Classes of Certs.
------------------------------------------------------------
Moody's Investors Service placed 10 classes of CD 2007-CD4
Commercial Mortgage Trust Commercial Mortgage Pass-Through
Certificates, Series 2007-CD4 on review for possible downgrade:

  -- Cl. A-1A, Aaa (sf) Placed Under Review for Possible
     Downgrade; previously on April 10, 2007 Affirmed at Aaa (sf)

  -- Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
     previously on April 10, 2007 Affirmed at Aaa (sf)

  -- Cl. A-MFX, Aa1 (sf) Placed Under Review for Possible
     Downgrade; previously on March 4, 2010 Downgraded to Aa1 (sf)

  -- Cl. A-MFL, Aa1 (sf) Placed Under Review for Possible
     Downgrade; previously on March 4, 2010 Downgraded to Aa1 (sf)

  -- Cl. A-J, Baa3 (sf) Placed Under Review for Possible
     Downgrade; previously on March 4, 2010 Downgraded to Baa3
     (sf)

  -- Cl. B, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on March 4, 2010 Downgraded to Ba2 (sf)

  -- Cl. C, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on March 4, 2010 Downgraded to B2 (sf)

  -- Cl. D, Caa1 (sf) Placed Under Review for Possible Downgrade;
     previously on March 4, 2010 Downgraded to Caa1 (sf)

  -- Cl. E, Caa3 (sf) Placed Under Review for Possible Downgrade;
     previously on March 4, 2010 Downgraded to Caa3 (sf)

  -- Cl. F, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on March 4, 2010 Downgraded to Ca (sf)

The classes were placed on review 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 March 24th, 2010.

                   Deal And Performance Summary

As of the January 5th, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 3% to $6.4 billion
from $6.6 billion at securitization.  The Certificates are
collateralized by 375 mortgage loans ranging in size from less
than 1% to 6% of the pool, with the top ten loans representing 34%
of the pool.

One hundred and two loans, representing 26% of the pool, are on
the master servicer's watchlist.  The watchlist includes loans
which meet certain portfolio review guidelines established as part
of the 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 an
aggregate realized loss of $3.3 million (45% loss severity).
Forty loans, representing 19% of the pool, are currently in
special servicing.  The specially serviced loans are secured by a
mix of multifamily, retail, hotel and industrial property types.
The master servicer has recognized appraisal reductions totaling
$509.3 million for 24 of the specially serviced loans.  At last
review, there were 30 loans, representing 13% of the pool, in
special servicing.

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


CENTURION CDO: S&P Raises Ratings on Various Classes of Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A, B-1, B-2, C, D-1, D-2, and D-3 notes from Centurion CDO
VI Ltd. a collateralized loan obligation transaction managed by
RiverSource Investments LLC.  At the same time, S&P removed the
ratings on the class A, B-1, B-2, and C notes from CreditWatch,
where S&P placed them with positive implications on Nov. 8, 2010.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio since its Nov. 17, 2009 rating
action, when S&P downgraded all of the rated notes following the
application of its September 2009 corporate CDO criteria.  As of
the Jan. 5, 2011 trustee report, the transaction had $4.7 million
of defaulted assets.  This was down from $21.42 million noted in
the Oct. 5, 2009 trustee report, which S&P referenced for its
November 2009 rating actions.

The transaction has also benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratios in the Jan. 5, 2011 monthly
report:

* The class A O/C ratio was 136.24%, compared with a reported
  ratio of 130.89% in October 2009;

* The class B O/C ratio was 119.6%, compared with a reported ratio
  of 116.61% in October 2009;

* The class C O/C ratio was 115.05%, compared with a reported
  ratio of 112.63% in October 2009; and

* The class D O/C ratio was 110.49%, compared with a reported
  ratio of 108.61% in October 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

                      Centurion CDO VI Ltd.

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

Transaction Information
-----------------------
Issuer:             Centurion CDO VI Ltd.
Coissuer:           Centurion CDO VI Corp.
Collateral manager: RiverSource Investments LLC
Underwriter:        Credit Suisse AG
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CLO


CHASE MANHATTAN: S&P Raises Ratings on Three Classes of Certs.
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on three
classes of commercial mortgage pass-through certificates from
Chase Manhattan Bank-First Union National Bank Commercial Mortgage
Trust's series 1999-1, a U.S. commercial mortgage-backed
securities transaction.  In addition, S&P affirmed its ratings on
seven other classes from the same transaction.

The rating actions reflect S&P's analysis of the remaining
collateral in the pool, the deal structure, and liquidity
available to the trust. The raised ratings reflect increased
credit enhancement levels resulting from principal paydowns to the
trust.

S&P's analysis included a review of the credit characteristics of
all the assets in the pool. Using servicer-provided financial
information, S&P calculated an adjusted debt service coverage of
1.27x and a loan-to-value ratio of 68.2%. S&P further stressed the
loans' cash flows under S&P's 'AAA' scenario to yield a weighted
average DSC of 0.99x and an LTV ratio of 77.4%.  The implied
default and loss severity rates under S&P's 'AAA' scenario were
25.8% and 12.3%, respectively.  All of the DSC and LTV
calculations S&P noted above exclude the transaction's three
($12.5 million, 6.5%) specially serviced assets, three
($3.4 million, 1.7%) loans that S&P determined to be credit-
impaired, and 20 ($55.2 million, 28.7%) defeased loans.  S&P
separately estimated losses for the six specially serviced and
credit-impaired assets and included them in the 'AAA' scenario
implied default and loss figures.

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

                        Transaction Summary

As of the Jan. 18, 2011 trustee remittance report, the collateral
pool balance was $192.8 million, which is 13.8% of the balance at
issuance.  The pool includes 56 loans and one real estate owned
asset, down from 205 loans at issuance.  Twenty ($55.2 million,
28.7%) loans are defeased and 18 ($35.1 million, 18.2%) loans are
classified as credit-tenant-lease loans.  The master servicer,
Berkadia Commercial Mortgage LLC, provided financial information
for 88.4% of the nondefeased and non-CTL loans in the pool. Of
that information, 95.2% was full-year 2009, with the balance
reflecting interim 2010 reporting. S&P calculated a weighted
average DSC of 1.50x for the pool based on the servicer-reported
figures.  S&P's adjusted DSC and LTV ratio were 1.27x and 68.2%,
respectively. S&P's adjusted figures exclude the transaction's
three ($12.5 million, 6.5%) specially serviced assets, three
($3.4 million, 1.7%) loans that S&P determined to be credit-
impaired, and the defeased loans.  Four ($7.0 million, 3.7%) loans
in the pool are on the master servicer's watchlist, including one
of the top 10 real estate exposures, which S&P discuss below.  Two
($2.8 million, 1.5%) loans have a reported DSC below 1.10x, one
($1.5 million, 0.8%) of which has a reported DSC of less than
1.00x.  The transaction has experienced $18.9 million in principal
losses to date.

                      Credit Considerations

As of the Jan. 18, 2011 trustee remittance report, three
($12.5 million, 6.5%) assets in the pool were with the special
servicer, C-III Asset Management LLC. Two of these assets are top
10 real estate exposures.  The reported payment status of the
specially serviced assets is as follows: one ($5.9 million, 3.0%)
is REO and two ($6.7 million, 3.5%) are 90-plus-days delinquent.
The largest specially serviced asset has a $3.2 million appraisal
reduction amount in effect.  S&P estimated losses on all three of
the specially serviced assets, arriving at a weighted-average loss
severity of 27.5%. Details on the two specially serviced top 10
real estate exposures are:

The Villa Park III asset ($5.9 million, 3.0%) is the seventh-
largest exposure in the pool, and the largest asset with the
special servicer.  The REO asset is an 88,960-sq.-ft. industrial
property in Richmond, Va. The loan was originally transferred to
the special servicer on June 5, 2009.  Recent DSC data was not
available for this asset, and the property was 91.0% occupied as
of April 2009.  Standard & Poor's anticipates a moderate loss upon
the eventual resolution of this asset.

The Sierra Pacific Spectrum loan ($5.1 million, 2.7%) is the
ninth-largest loan in the pool, and the second-largest asset with
the special servicer.  The loan is secured by a 70,511-sq.-ft.
office property in Phoenix, Ariz.  The loan was transferred to the
special servicer on Aug. 12, 2010, and is classified as 90-plus-
days delinquent. Reported DSC was 1.17x as of December 2009 and
reported property occupancy was 94.1% as of June 2010.  Standard &
Poor's anticipates a moderate loss upon the eventual resolution of
this asset.

In addition to the specially serviced assets, S&P determined three
($3.4 million, 1.7%) loans to be credit-impaired.  Each individual
loan has a balance that represents less than 0.7% of the pool.
The collateral properties are located in Rome, Ga.; San Benito,
Texas; and Harlingen, Texas.  The loans appear on the master
servicer's watchlist, one for a low DSC and two for other factors
cited as increasing the loans' default risk.  Based on the
reported loan statuses, financial information, and watchlist
comments, S&P determined the loans to be at an increased risk of
default and loss.

                Summary of Top 10 Real Estate Loans

The top 10 real estate loans, excluding CTL loans, have an
aggregate outstanding balance of $87.9 million (45.6%). Using
servicer-reported numbers, S&P calculated a weighted average DSC
of 1.51x for the top 10 real estate loans.  S&P's adjusted DSC and
LTV ratio were 1.32x and 68.0%, respectively. S&P's adjusted
figures exclude two specially serviced, top 10 loans.  The Norwest
Bank Office Building loan ($3.7 million, 1.9%), which is the 10th-
largest loan in the pool, is the only top 10 loan that appears on
the master servicer's watchlist.  The loan is secured by a 68,536-
sq.-ft. office property in Denver, Colo.  Reported DSC was 1.67x
as of December 2009, and the property was 88.9% occupied as of
March 2010.  The loan appears on the master servicer's watchlist
for an impending maturity date, which, according to the master
servicer, is now March 1, 2011.

Standard & Poor's stressed the assets in the pool according to its
criteria and the analysis is consistent with its raised and
affirmed ratings.

                          Ratings Raised

     Chase Manhattan Bank-First Union National Bank Commercial
    Mortgage Trust Commercial mortgage pass-through certificates
                           series 1999-1

                   Rating
                   ------
       Class    To         From      Credit enhancement (%)
       -----    --         ----      ----------------------
       F        AAA (sf)   AA+ (sf)                 64.50
       G        A+ (sf)    BBB+ (sf)                33.69
       H        A- (sf)    BBB (sf)                 28.26

                         Ratings Affirmed

     Chase Manhattan Bank-First Union National Bank Commercial
    Mortgage TrustCommercial mortgage pass-through certificates
                           series 1999-1

        Class       Rating          Credit enhancement (%)
        -----       ------          ----------------------
        D           AAA (sf)                         98.93
        E           AAA (sf)                         73.56
        I           BBB- (sf)                        22.82
        J           BB- (sf)                         11.95
        K           B+ (sf)                           8.32
        L           B- (sf)                           3.79
        X           AAA (sf)                           N/A

                       N/A - Not applicable.


CITIMORTGAGE ALTERNATIVE: Moody's Cuts Ratings on 2005-A1 Tranches
------------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 11
tranches from Citimortgage Alternative Loan Trust Series 2005-A1.

                        Ratings Rationale

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

Moody's final rating actions are based on current ratings, level
of credit enhancement, collateral performance and updated pool-
level loss expectations relative to current level of credit
enhancement.  Moody's took into account credit enhancement
provided by seniority, cross-collateralization, excess spread,
time tranching, and other structural features within the senior
note waterfalls.

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: Citimortgage Alternative Loan Trust Series 2005-A1

  -- Cl. IA-1, Downgraded to B3 (sf); previously on Jan. 14, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IA-2, Downgraded to B3 (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

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

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

  -- Cl. IA-5, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IA-6, Downgraded to C (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. IIA-1, Downgraded to B3 (sf); previously on Jan. 14, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

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

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

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


CLARET TRUST: Moody's Takes Rating Actions on Various 2006-1 Notes
------------------------------------------------------------------
Moody's Investors Service upgraded the ratings of four classes and
affirmed eight classes of Claret Trust Commercial Mortgage Pass-
Through Certificates, Series 2006-1:

  -- Cl. A Certificate, Affirmed at Aaa (sf); previously on
     June 26, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. X Certificate, Affirmed at Aaa (sf); previously on
     June 26, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. B Certificate, Affirmed at Aaa (sf); previously on
     Feb. 25, 2010 Upgraded to Aaa (sf)

  -- Cl. C Certificate, Affirmed at Aaa (sf); previously on
     Feb. 25, 2010 Upgraded to Aaa (sf)

  -- Cl. D Certificate, Upgraded to Aa1 (sf); previously on
     Feb. 25, 2010 Upgraded to Aa2 (sf)

  -- Cl. E Certificate, Upgraded to A1 (sf); previously on
     Feb. 25, 2010 Upgraded to A2 (sf)

  -- Cl. F Certificate, Upgraded to A3 (sf); previously on
     Feb. 25, 2010 Upgraded to Baa1 (sf)

  -- Cl. G Certificate, Upgraded to Baa2 (sf); previously on
     Feb. 25, 2010 Upgraded to Baa3 (sf)

  -- Cl. H Certificate, Affirmed at Ba2 (sf); previously on
     Feb. 25, 2010 Upgraded to Ba2 (sf)

  -- Cl. J Certificate, Affirmed at B1 (sf); previously on
     June 26, 2006 Definitive Rating Assigned B1 (sf)

  -- Cl. K Certificate, Affirmed at B2 (sf); previously on
     June 26, 2006 Definitive Rating Assigned B2 (sf)

  -- Cl. L Certificate, Affirmed at B3 (sf); previously on
     June 26, 2006 Definitive Rating Assigned B3 (sf)

                        Ratings Rationale

The upgrades are due to the significant increase in subordination
due to loan payoffs and amortization.  The pool has paid down by
39% 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
2.4% of the current balance.  At last review, Moody's cumulative
base expected loss was 0.9%.  Moody's stressed scenario loss is
7.0% of the current balance.

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

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

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 15 compared to 26 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 February, 25 2010.

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

                         Deal Performance

As of the January 17, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 76% to
$92.3 million from $379.6 million at securitization.  The
Certificates are collateralized by 23 mortgage loans ranging in
size from 1% to 13% of the pool, with the top ten loans
representing 66% of the pool.  No loans have defeased and there
are no loans with credit estimates.

Four 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.

The pool has not realized any losses since securitization and
currently there are no loans currently in special servicing.

Moody's was provided with full year 2009 operating results for
100% of the pool.  Moody's weighted average LTV is 61% compared to
54% 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 9.1%.

Moody's actual and stressed DSCRs are 1.44X and 1.74X,
respectively, compared to 1.69X and 2.04X 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 30% of the
pool balance.  The largest loan is the Control Number 2 Loan
($11.4 million -- 12.3%), which is secured by a 305,267 square
foot industrial building located in Calgary, Alberta.  The
property was 90% leased as of January 2010 compared to 100% at
last review.  Property performance has declined since last review.
Moody's LTV and stressed DSCR are 74% and 1.27X, respectively,
compared to 63% and 1.51X at last review.

The second largest loan is the Control Number 17 and 40 Loan
($8.6 million -- 9.3%), which is secured by two adjacent retail
properties totaling 108,091 square feet located in Orillia,
Ontario.  The properties were 100% leased as of January 2010,
similar at last review.  Moody's LTV and stressed DSCR are 56%
and 1.70X, respectively, essentially the same as at last review.

The third largest loan is the Control Number 5 Loan ($7.9 million
-- 8.6%), which is secured by a 68,751 square foot office and
retail building located in Calgary, Alberta.  The property was
100% leased as of March 2010, similar at last review.  Moody's is
concerned about potential income volatility due to leases
representing 31% of the portfolio expiring within the next 18
months.  Moody's LTV and stressed DSCR are 64% and 1.65X,
respectively, compared to 60% and 1.76X at last review.


COLORADO HOUSING: S&P Junks Rating on Series 2007 Bonds From 'BB'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its long-term rating to
'CCC' from 'BB' on Colorado Housing & Financing Authority's series
2007 bonds revenue bonds issued for Evergreen Country Day School.

The rating reflects Standard & Poor's understanding that debt
service on the school's series 2007 bonds is vulnerable to
nonpayment and is dependent on favorable business, financial, and
economic conditions.  The school remains in default of its debt
service coverage covenant and the bond trustee and issuing
authority have the right to declare a default, which could include
acceleration of the bonds, resulting in a working capital deficit.

The rating reflects Standard & Poor's understanding that
management continues to make debt service payments in a timely
manner, have not accessed debt service reserves, and have
unrestricted endowment funds that support debt payments through
2013.

The rating also reflects Standard & Poor's assessment of a debt
service covenant that is in default as of fiscal 2010 with a debt
service ratio that is negative; limited financial resources to
support debt service, which currently is interest-only until 2013;
continued negotiations with bondholders, which management
indicates may result in an agreement at below par workout of debt
obligations; very weak operations on a full accrual basis;
continued softening of financial resources levels; and an
extremely high debt burden.

Credit factors that Standard & Poor's believes support the rating
include preliminary indications from management that it has made
progress on reaching a resolution favorable to ECDS and that fall
2011 enrollment continues to grow and operations for fiscal 2011
should be self-sustaining on a cash basis not including debt
service.  Also supporting the rating is Standard & Poor's
understanding that there has been growth in donor support in 2011
with fundraising surpassing goals and the previous year's funds.

"The negative outlook reflects S&P's assessment of the school's
ability to continue meeting its debt service payments and avoid an
event of default over the next year," said Standard & Poor's
credit analyst Blake Cullimore.

A negative rating action would reflect the increased vulnerability
of nonpayment or nonpayment resulting in a pending or actual
default on a payment on the bonds.  A positive rating action over
the next year, while unlikely in Standard & Poor's opinion, would
reflect the school's ability to continue to meet current
obligations, have no covenant violations, and have the long-term
financial strength to meet its debt service obligations.

The school used the $12.95 million debt to build a new building
for the school in 2008 and help the school expand enrollment.
However, the slowing economy and the projections on which the
school built the initial financial model have not materialized as
planned.  While management has reorganized and developed more
reasonable enrollment, cost, and fundraising goals and achieved
them, financially the school remains stressed due to their debt
service obligations, on which they currently only pay interest.
In addition, sinking fund payments will begin in June of 2013.


COMM 2004-LNB4: Moody's Affirms Ratings on 18 Classes of Certs.
---------------------------------------------------------------
Moody's Investors Service upgraded the rating of 1 and affirmed
the ratings of 18 classes of COMM 2004-LNB4 Commercial Mortgage
Pass-Through Certificates, Series 2004-LNB4:

  -- Cl. A-3, Affirmed at Aaa (sf); previously on March 25, 2010
     Confirmed at Aaa (sf)

  -- Cl. A-4, Upgraded to Aaa (sf); previously on March 25, 2010
     Downgraded to Aa3 (sf)

  -- Cl. A-5, Affirmed at Aa3 (sf); previously on March 25, 2010
     Downgraded to Aa3 (sf)

  -- Cl. A-1A, Affirmed at Aa3 (sf); previously on March 25, 2010
     Downgraded to Aa3 (sf)

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

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

  -- Cl. B, Affirmed at A2 (sf); previously on March 25, 2010
     Downgraded to A2 (sf)

  -- Cl. C, Affirmed at Baa2 (sf); previously on March 25, 2010
     Downgraded to Baa2 (sf)

  -- Cl. D, Affirmed at Ba2 (sf); previously on March 25, 2010
     Downgraded to Ba2 (sf)

  -- Cl. E, Affirmed at B2 (sf); previously on March 25, 2010
     Downgraded to B2 (sf)

  -- Cl. F, Affirmed at Caa2 (sf); previously on March 25, 2010
     Downgraded to Caa2 (sf)

  -- Cl. G, Affirmed at Ca (sf); previously on March 25, 2010
     Downgraded to Ca (sf)

  -- Cl. H, Affirmed at C (sf); previously on March 25, 2010
     Downgraded to C (sf)

  -- Cl. J, Affirmed at C (sf); previously on March 25, 2010
     Downgraded to C (sf)

  -- Cl. K, Affirmed at C (sf); previously on March 25, 2010
     Downgraded to C (sf)

  -- Cl. L, Affirmed at C (sf); previously on March 25, 2010
     Downgraded to C (sf)

  -- Cl. M, Affirmed at C (sf); previously on March 25, 2010
     Downgraded to C (sf)

  -- Cl. N, Affirmed at C (sf); previously on March 25, 2010
     Downgraded to C (sf)

  -- Cl. O, Affirmed at C (sf); previously on March 25, 2010
     Downgraded to C (sf)

                        Ratings Rationale

The upgrade of Class A-4 is due to increased subordination due to
paydowns and amortization and overall stable pool performance.  In
addition, anticipated recoveries from specially serviced and
troubled loans along with near term maturities of defeased loans
are expected to further deleverage Class A-4.

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
7.2% of the current balance.  At last full review, Moody's
cumulative base expected loss was 8.5%.  Moody's stressed scenario
loss is 19.6% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 32 compared to 33 at Moody's prior full 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 March 25, 2010.

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

                         Deal Performance

As of the January 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 25% to
$917.26 million from $1.22 billion at securitization.  The
Certificates are collateralized by 100 mortgage loans ranging
in size from less than 1% to 8% of the pool, with the top ten
loans representing 41% of the pool.  Seven loans, representing
13% of the pool, have defeased and are collateralized with U.S.
Government securities, compared to 12% at last review.  Two loans,
representing 3% of the pool, have investment grade credit
estimates.

Twenty-one loans, representing 24% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Six loans have been liquidated from the pool since securitization,
resulting in an aggregate $20.2 million loss (42% loss severity
on average).  The pool had experienced an aggregate loss of
$10.8 million at last review.  Currently seven loans, representing
9% of the pool, are in special servicing.  The master servicer has
recognized an aggregate $37.2 million appraisal reduction for six
of the specially serviced loans.  Moody's has estimated an
aggregate loss of $48.4 million (56% expected loss on average) for
all of the specially serviced loans.

Moody's has assumed a high default probability for three poorly
performing loans representing 4% of the pool and has estimated a
$4.9 million loss (15% 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 85% and 68% of the performing pool,
respectively.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 93% compared to 92% at last full
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
9.5%.

Excluding specially serviced and troubled loans, Moody's actual
DSCR is 1.55X compared to 1.43X 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.

The loan with a credit estimate is the 731 Lexington Avenue Loan
($62.4 million -- 6.8% of the pool), which is a 23.6%
participation interest in a $314 million loan.  The property is
also encumbered by a $86 million junior loan which is held outside
the trust.  The loan is secured by a 694,634 square foot (SF)
office building located in New York City.  The property is 100%
leased to Bloomberg, LP until 2028.  The loan had a 24-month
interest-only period and is now amortizing on a 237-month schedule
maturing in March 2014.  Moody's current credit estimate and
stressed DSCR are A3 and 2.01X, respectively, compared to A3 and
1.99X at last full review.

The top three performing conduit loans represent 16% of the pool
balance.  The largest loan is the Crossings at Corona-Phase I & II
Loan ($76 million -- 8.3% of the pool), which is secured by a
503,037 SF retail power center located in Corona, California.  The
loan had a 35-month interest-only period and is now amortizing on
a 395-month schedule maturing in October 2014.  The loan has
amortized 4% since last full review.  Property performance has
been stable.  Moody's LTV and stressed DSCR are 101% and 0.91X,
respectively, compared to 102% and 0.9X at last full review.

The second largest loan is the Woodyard Crossing Shopping Center
Loan ($38.7 million -- 4.2% of the pool), which is secured by a
483,724 SF retail power center located in Washington, DC.  The
loan had a 42-month interest-only period and is now amortizing on
a 360-month schedule maturing in April 2016.  The loan has
amortized 3% since last full review.  Moody's LTV and stressed
DSCR are 78% and 1.25X, respectively, compared to 79% and 1.2X at
last full review.

The third largest loan is the 280 Trumbull Street Loan
($31.9 million -- 3.5% of the pool), which is secured by a 664,479
SF Class A office property located in Hartford, Connecticut.  The
loan had a 24-month interest-only period and is now amortizing on
a 384-month schedule maturing in August 2014.  Moody's LTV and
stressed DSCR are 85% and 1.2X, respectively, compared to 95% and
1.02X at last review.


COMM 2005-FL11: Moody's Affirms Ratings on Nine Pooled Classes
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of nine pooled
classes of COMM 2005-FL11 Commercial Mortgage Securities Corp.
Series 2005-FL11.  Moody's rating action is:

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

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

  -- Cl. D, Affirmed at Aaa (sf); previously on Feb. 25, 2010
     Upgraded to Aaa (sf)

  -- Cl. E, Affirmed at Aa1 (sf); previously on Feb. 25, 2010
     Upgraded to Aa1 (sf)

  -- Cl. F, Affirmed at Aa3 (sf); previously on Feb. 25, 2010
     Upgraded to Aa3 (sf)

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

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

  -- Cl. X-2-DB, Affirmed at Aaa (sf); previously on Dec. 6, 2005
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-3-DB, Affirmed at Aaa (sf); previously on Dec. 16, 2005
     Assigned Aaa (sf)

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

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
previous 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based Large Loan
Model v 8.0.  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 February 25, 2010.

                         Deal Performance

As of the January 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 92%
to $130.8 million from $1.69 billion at securitization.  The
Certificates are secured by three loans ranging in size from 9% to
72% of the pool balance.

The pool has experienced losses of $22,905 since securitization.
As of the January18, 2011 remittance statement, there are interest
shortfalls totaling $5,101 to Class L.  Generally, interest
shortfalls are caused by special servicing fees, including workout
and liquidation fees, appraisal subordinate entitlement reductions
and extraordinary trust expenses.

Currently one loan, the DDR/Macquarie Mervyn's Portfolio Loan
($11.4 million -- 9% of the pool balance), is in special
servicing.  This loan represents a pari-passu interest in a
$153.4 million first mortgage loan.  The loan has paid down 41%
since securitization.  The loan was originally secured by 35
single tenant buildings leased to Mervyn's.  Mervyn's filed for
Chapter 11 bankruptcy protection in July 2008, closed all its
stores, and rejected the leases on all the properties in this
portfolio.  The loan was transferred to special servicing in
October 2008 due to imminent default.  The borrower is focused on
selling or releasing the properties.  Eleven properties have been
sold and one sale is pending.  Ten properties have been fully or
partially leased.  Thirteen properties are vacant.  The loan
matured in October of 2010 and is delinquent in paying debt
service.  Moody's loan to value ratio is over 100%, the same as
last review.  Moody's current credit estimate is C, the same as
last review.

The largest loan in the pool is the Whitehall/Starwood Golf
Portfolio Loan ($93.8million - 72% of the pool balance) which was
initially supported by fee and leasehold interests in a portfolio
of 173 public and private golf courses containing 3,374 holes.
Seventy three properties have been released since securitization
and the loan is now secured by 100 courses containing 1,968 holes
across the United States.  The properties are managed by AGC Corp.
The servicer recently executed a forebearance through July 2012
which requires two principal payments of $25 million due in August
2011 and June 2012.  Moody's current pooled LTV is 64% and
stressed DSCR is 1.77X.  Moody's current credit estimate is Ba1
the same as last review.

The second largest loan is the Crossgate Commons Loan
($25.5 million -- 19% of the pool balance), which is secured by a
690,000 square foot power center located in Albany, New York.  The
center is anchored by Wal-Mart and Sam's Club, although neither
tenant is part of the collateral.  Other anchor tenants include
Home Depot, Sport's Authority and Jeepers.  As of October 2010,
the center was 77% leased.  Both the cash flow and occupancy have
deteriorated since securitization.  This loan has been extended
through September 2012.  In addition, the borrower is providing an
additional guarantee of up to $8 million and the cash flow is
being swept into a reserve account and will be held as additional
collateral.  Moody's current pooled LTV is over 100% and stressed
DSCR is 0.85X.  Moody's current credit estimate is Caa2 the same
as last review.


COMM 2006-C7: Fitch Downgrades Ratings on 14 Classes of Certs.
--------------------------------------------------------------
Fitch Ratings has downgraded and removed from Rating Watch
Negative 14 classes of COMM 2006-C7's commercial mortgage pass-
through certificates.  The downgrades are due to further
deterioration of performance, most of which involves increased
losses on the specially serviced loans.

The downgrades reflect an increase in Fitch expected losses across
the pool.  Fitch modeled losses of 8.3% of the remaining pool;
expected losses of the original pool are at 8.7%.  Fitch has
designated 49 loans (30.9%) as Fitch 'Loans of Concern', which
includes nine specially serviced loans (10.2%).  Fitch expects
losses associated with the specially serviced loans to deplete
classes J thru P and a portion of class H.

The largest contributors to modeled losses are three (8.2%) of the
top 15 loans in the transaction, two (6.7%) of which are currently
specially serviced.

Granite Run Mall is secured by a 1,046,667 square foot (sf)
super regional mall located in Media, PA approximately 12
miles from the central business district of Philadelphia and is
sponsored by Simon Property Group, L.P. and The Macerich
Partnership, L.P.  The mall is anchored by Sears, Boscov's, JC
Penney, and Kohl's.  Sears and JC Penney own their stores but are
subject to ground leases with the sponsor.  The loan was
transferred to special servicing in October 2010 due to imminent
default.  The special servicer is in the process of determining
the appropriate workout strategy.  The most recent servicer
reported debt-service coverage ratio as of Dec. 31, 2010 was
0.97X.  The inline mall space is currently 68% occupied.  The
total mall including the non-owned anchors is currently 89%
occupied.

Lakeview Square Mall is secured by a 254,880 sf retail property
located in Battle Creek, MI and is sponsored by General Growth
Properties.  The mall is anchored by Macy's, Sears and J.C.
Penney's.  The loan was transferred back to special servicing in
August 2010 due to imminent default.  GGP has submitted a workout
proposal and have also proposed an issuance of a deed-in-lieu of
foreclosure notice if the debt restructuring proposal is not
achieved.  The most recent reported DSCR as of September 2010 is
0.99X.  The inline mall space is 72% occupied.  The entire mall is
91.7% occupied.

The Meadowood Resort is collateralized by a 98 room, full-service
luxury resort located in St. Helena, CA in the heart of Napa
Valley.  Property continues to show declining performance since
issuance due to increasing operating expenses, stagnant revenue,
and current economic conditions.  The net operating income of the
property is no longer sufficient to meet debt service.  The loan
remains current due to the sponsor's funding the debt service
shortfalls.  The sponsor continues to make monthly required
deposits of 4% of Effective Gross Income into a Furniture,
Fixtures, and Equipment reserve.  Per the latest remittance
report, there is approximately $1.8 million on deposit in the
reserve.  The most recent servicer reported occupancy year-to-date
as of June 30, 2010 was 45% with ADR of $545.50, and RevPAR of
$243.13.  The sponsor is Pacific Union Meadowood Partners, L.P.

Fitch has downgraded, removed from Rating Watch Negative and
assigned Recovery Ratings where noted to these classes:

  -- $189.7 million class A-J to 'A'/LS4' from 'AAA/LS3'; Outlook
     Stable;

  -- $52 million class B to 'BB/LS5' from 'AA/LS4'; Outlook
     Stable;

  -- $24.5 million class C to 'BB/LS5' from 'A/LS5'; Outlook
     Stable;

  -- $36.7 million class D to 'B-/LS5' from 'A/LS5'; Outlook
     Stable;

  -- $21.4 million class E to 'B-/LS5' from 'BBB/LS5'; Outlook
     Stable;

  -- $30.6 million class F to 'B-/LS5' from 'BBB-/LS5'; Outlook
     Negative;

  -- $24.5 million class G to 'CCC/RR1' from 'BB/LS5';

  -- $30.6 million class H to 'CC/RR4' from 'B/LS5';

  -- $12.2 million class J to 'C/RR6' from 'B-/LS5';

  -- $6.1 million class K to 'C/RR6' from 'B-/LS5';

  -- $9.2 million class L to 'C/RR6' from 'B-/LS5';

  -- $3.1 million class M to 'C/RR6' from 'B-/LS5';

  -- $6.1 million class N to 'C/RR6' from 'B-/LS5';

  -- $9.2 million class O to C/RR6' from 'B-/LS5'.

Additionally, Fitch has affirmed and revised Loss Severity ratings
on these classes:

  -- $99.7 million class A-2 at 'AAA/LS2; Outlook Stable;
  -- $40.1 million class A-3 at 'AAA/LS2'; Outlook Stable;
  -- $98.8 million class A-AB at 'AAA/LS2'; Outlook Stable;
  -- $1.0527 billion class A-4 at 'AAA/LS2'; Outlook Stable;
  -- $316.4 million class A-1A at 'AAA/LS2'; Outlook Stable;
  -- $244.7 million class A-M at 'AAA/LS3'; Outlook Stable.

Fitch has also withdrawn the rating on the interest-only class X.

Fitch does not rate the $22.2 million class P.  Class A-1 has paid
in full.


COMMONWEALTH PORTS: Fitch Affirms 'CCC' Rating on $14.6 Mil. Bonds
------------------------------------------------------------------
Fitch Ratings affirms the 'CCC' rating on approximately
$14.6 million of outstanding Commonwealth Ports Authority,
Commonwealth of the Northern Mariana Islands, senior series 1998A
airport revenue bonds.  The Rating Outlook for all airport bonds
is Negative.

Rating Rationale:

The Negative Outlook reflects the potential for weakness in
passenger traffic despite the up tick of 1.8% in fiscal 2010.
Passenger traffic to the CNMI is tourist driven and heavily
dependent on Asian markets, particularly Japan which has been
quite dormant for the past few years.  Year-to-date fiscal 2011
(as of November) enplanements are up 4.9% compared to a 22%
decline in fiscal 2010 due to an increase in tourist inflow from
the Japanese market.  Chinese, Russian and South Korean markets
remain quite consistent going into 2011.  Weak traffic continues
to pressure airport finances.  Preliminary operating revenue and
expense figures point to expectations of violating the rate
covenant with 0.83 times coverage in fiscal 2010.  The draws on
cash balances will continue and the depletion of funds is a real
possibility over the next several years absent a sustained traffic
recovery or a revision of airline rates and charges.  Fitch
recognizes management's successful cost tightening strategies over
the last several years and continued efforts in exploring
additional non-airline revenue generating projects.  However,
should the overarching themes of a sluggish CNMI economy, weak
passenger inflow, and lack of financial flexibility deteriorate
further, the airports' current rating level could be pressured.
The U.S planned relocation of approximately 8,000 military
personnel and their dependents from Okinawa, Japan to neighboring
Guam by 2014 could lead to inter-Island migration further
dampening local demand.  As part of the relocation, the U.S
Department of Defense leased the northern two-thirds of Tinian
Island from the CNMI for training groups of 200 Marines or larger
due to land availability.

Credit strengths include:

  -- Essentiality of the airports serving as the gateway to and
     within the Mariana Islands and CNMI's ability to continue to
     draw visitors from new markets;

  -- Management's focus on and effective containment of operating
     expenses for the past four fiscal years through various
     adjustments to personnel and operations;

Credit concerns include:

  -- Potential for prolonged economic weakness of the air trade
     area due to CNMI's weak underlying economy with an elevated
     dependence on a diminished tourist base.  The fragile tourism
     sector has led to a reduction in productivity on the islands.
     The CNMI also faces competition as a leisure destination from
     other islands in the Pacific;

  -- Sustained reduction in the airports' traffic base impacting
     airport revenues and debt service coverage levels.  The CPA
     expects non-compliance with the rate covenant in fiscal 2010;

  -- Limited financial flexibility will continue to pressure
     liquidity due to management's reluctance to pass through
     charges to carriers during weak performing periods.

Key Rating Drivers:

  -- Continued changes in the underlying service area economy and
     the airports' ability to maintain a stable traffic base;

  -- Substantial shift in the airports' short term liquidity and
     financial flexibility;

Security:

The series 1998A bonds are secured by a pledge of gross airport
revenues generated by the operations of the airport, including
Passenger Facility Charges eligible for payment of debt service.

Credit Summary:

Fiscal 2010 was the first year since 2004 that saw growth in
passenger traffic adding 8,375 enplanements or 1.8% to its 475,769
enplanement base.  Management is fairly optimistic about traffic
performance in fiscal 2011 and believes that another year of
positive growth is probable should the slight increase in
travelers seen in the first quarter continue throughout the year.
Overall airport traffic has been declining in recent years due to
the loss of signatory carriers (Continental Airlines and Japan
Airlines) being replaced with airlines operating charter flights
on an as need basis.  The slower demand from the Korean and
Japanese markets prompted airlines to reduce seat capacity and
suspend flights during slow periods.  The airport system lost
about one third of its traffic base since 2004.  The airports'
prolonged period of traffic recovery is consistent with weak
traffic attributes and a lack of resiliency to downturns.

Service at the airports is dominated by Delta Airlines and Asiana
Airlines, combined, accounting for approximately 60% of total
traffic served at Saipan airport -- CNMI's main gateway airport.
Delta Airlines reduced passenger traffic by 17.5% in fiscal 2010;
however volume was picked up by several other carriers.  This
reduction was expected at the time Fitch last reviewed the credit.
The CPA expects a new carrier, Sichuan Airlines, to start service
from various Asian cities to Saipan in 2011.  The airline has
received approval from the Department of Transportation and is now
awaiting FAA approval.  A full or partial loss of service from one
of the airports' main signatory carriers would likely have credit
implications.

Fiscal 2010 operating revenue is expected to come in 3.4% lower
than the previous year at $10.6 million.  The CPA continues to
expand non-aviation revenue sources and recently completed
appraisals of airport properties which are expected to enhance
future leases.  Operating revenue in fiscal 2009 jumped 29% over
2008 due to a revision of airline rates and charges.  Management
has not passed any additional increases since, feeling that it
could deter carriers from serving at the airport especially when
the global economy has not fully recovered.  Erosion of the
airports' revenue generating base constrains revenue generating
sources and limits the flexibility of producing sufficient
revenues to meet debt service.  Coverage for fiscal 2009 was 1.44x
while 0.83x coverage is expected for fiscal 2010.  A $1 million
unbudgeted but necessary contractual expenditure to meet certain
federal requirements is responsible for the deficiency in
coverage.  Operating costs are projected at $10.5 million, 1.7%
higher than the previous year.  CPA continues to make efforts to
reduce operating expenses through the use of scheduled work
reductions and the elimination of non-essential expenses.
Operating costs are 7.9% lower than in fiscal 2006.

Preliminary cash balances show a $1.4 million increase over fiscal
2009 attributed to better control of costs and aggressive
collections of past due accounts, yet liquidity levels remain weak
with 136 days cash on hand.  Cost per enplanement (CPE) is
expected to slightly decrease to the $15 range in fiscal 2010 as
traffic improves.  In fiscal 2009, CPE doubled to $16 over the
previous year due to the substantial increase in airlines charges.
Fitch forecast scenarios for small leisure airports contemplate a
10% loss in traffic and a seven-year recovery.  While Fitch
acknowledges the airport's austerity measures, under a stress
scenario and absent revenue generating alternatives and a
sustainable traffic recovery, the airports' unrestricted liquidity
is expected to be depleted by 2019 at the expense of subsidizing
debt service and maintaining a low cost structure to carriers.
The airports exhibit a heighten vulnerability to macroeconomic
stresses due to the Islands' natural dependence on external
economic factors.

The CPA owns and operates three airports in the CNMI, the largest
of which is Saipan International Airport.  The commonwealth
consists of a chain of 14 islands of which four are inhabited.
The islands are located in the North Pacific Ocean, approximately
1,458 miles southeast of Tokyo, Japan and 5,969 miles west of Los
Angeles.  As CNMI is a commonwealth of the United States, U.S.
federal law and regulation, such as minimum wage law requirements,
immigration restrictions, and environmental regulation all have an
impact on the island's economy.  The islands are also subject to
weather related events such as typhoons due to their geographical
location in the Pacific.


COMMONWEALTH PORTS: Fitch Affirms 'BB-' Rating on Revenue Bonds
---------------------------------------------------------------
Fitch Ratings affirms the 'BB-' rating on approximately
$33.5 million of outstanding Commonwealth Ports Authority,
Commonwealth of the Northern Mariana Islands, senior series 1998A
and 2005A seaport revenue bonds.  The Rating Outlook for all
seaport bonds is Negative.

Rating Rationale:

The Negative Outlook reflects the possibility of a restrained
capacity to meet financial commitments if CPA's business profile
and CNMI's economic environment continue to be unfavorable.  The
overall economy of the CNMI is in decline and will likely take
several years for seaport operations to be adequately sized for a
more stabilized economy.  While CPA has historically exhibited
strong cash flows and a healthy balance sheet, the ports' ability
to return to historical financial strength will require a
sustained increase in wharfage rates which will undoubtedly have a
dampening effect on demand and will increase the cost of goods
across the islands.  The U.S planned relocation of approximately
8,000 military personnel and their dependents from Okinawa, Japan
to neighboring Guam by 2014 could lead to inter-island migration
further dampening local demand.  As part of the relocation, the
U.S Department of Defense leased the northern two-thirds of Tinian
Island from the CNMI for training groups of 200 Marines or larger
due to land availability.  Future inbound cargo operations will
rely on CNMI's internal demand for raw material and goods.

Credit strengths include:

  -- Essentiality of the seaports for the import of goods to an
     island economy;

  -- Management's focus on and effective containment of operating
     expenses through various adjustments to personnel and
     operations as well as the ability to adjust rates to mitigate
     lower revenue tonnage passing through the ports;

  -- Leverage of 6 times net debt to cash flow available for debt
     service and 48% cash to debt provides the CPA with some
     degree of flexibility to meet financial commitments in weak
     performing periods.  However, should the drop in revenue
     tonnage continue or seaport tariffs and wharfage rates not
     continue to grow, liquidity draws would accelerate.

Credit concerns include:

  -- Potential for prolonged economic weakness of the service area
     due to CNMI's weak underlying economy with an elevated
     dependence on a diminished tourist base.  The fragile tourism
     sector has led to a reduced productivity on the islands.  The
     CNMI also faces competition as a leisure destination from
     other islands in the Pacific;

  -- Sustained reduction in the ports' inbound revenue tonnage
     impacting seaport revenues and debt service coverage levels.

Key Rating Drivers:

  -- Continued changes in the underlying service area economy and
     the seaport's ability to maintain base cargo levels;

  -- Shift in the seaport's short-term liquidity and financial
     flexibility resulting from changes in operating expense
     management or pricing power.

Security:

The seaport bonds are secured solely by gross seaport revenues and
certain accounts established pursuant to the bond indenture.

Credit Summary:

Fiscal 2010 total revenue tonnage increased 2.7% to 375,442 metric
tons over 2009, reversing five years of consecutive decreases in
cargo activity.  Inbound cargo is up 4.5% and outbound is down
20%.  Management is fairly optimistic on cargo performance in
fiscal 2011, however no projections were provided.  Fiscal 2008
and 2009 cargo declined by 5% and 22% respectively due to the loss
of what remained of the garment manufacturing business, global
recessionary conditions, and fragile tourism sector.  Having lost
the garment industry, imports of raw materials dropped
significantly and associated exports of the finished products fell
accordingly.  Since 2004, inbound cargo and outbound cargo lost
47.3% and 86.8% of its revenue base respectively.  Fitch believes
that the current level of cargo is now tied more closely to
economic activity of the CNMI.

Fiscal 2010 (preliminary) and 2009 seaport operating revenue
increased by 4.6% and 21.2% to $6.5 and $6.2 million respectively
due to an increase in seaport tariffs and concession franchise
fees.  The upward revision in tariffs in March of fiscal 2009
offset the loss from the 22.9% drop in cargo operations that year.
The CPA has been under sustained austerity measures in order to
meet the rate covenant.  They have managed to reduce personnel and
benefit expenses by imposing reduced working hours and by avoiding
unnecessary expenses.  Fiscal 2010 unaudited financials point to
$2.1 million in operating expenses, a slight increase of 2.4% over
2009.  Operating expenses decreased significantly in 2008 and 2009
by 4.7% and 19.2% respectively.  CPA's revenue enhancing and cost
cutting measures resulted in a 1.5x coverage in fiscal 2009 and
projects a 1.41x coverage for fiscal 2010.  Cash balances remain
adequate in 2010 with days-cash-on-hand increasing to 305 days
from 154 days in 2009.  Fitch forecast scenarios contemplate a no
growth stress case for the CPA which could lead to the depletion
of cash balances in 2020 absent a recovery in CNMI's economy and
sustainable growth in cargo operations.

The CPA owns and operates three seaports in the CNMI, the largest
of which is the Port of Saipan.  The commonwealth consists of a
chain of 14 islands of which four are inhabited.  The islands are
located in the North Pacific Ocean, approximately 1,458 miles
southeast of Tokyo, Japan and 5,969 miles west of Los Angeles.  As
CNMI is a commonwealth of the United States, U.S. federal law and
regulation, such as minimum wage law requirements, immigration
restrictions, and environmental regulation all have an impact on
the islands' economy.  The Islands are also subject to weather
related events such as typhoons due to their geographical location
in the Pacific.


CONSUMER PORTFOLIO: Moody's Reviews Ratings on 15 Tranches
----------------------------------------------------------
Moody's has placed on review for possible upgrade fifteen tranches
from eleven transactions sponsored by Consumer Portfolio Services,
Inc., from 2005 to 2008.

Issuer: CPS Auto Receivables Trust 2005-C

  -- Cl. A-2, Aa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Nov. 12, 2009 Confirmed at Aa3 (sf)

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously Confirmed on 11/12/2009)

  -- Underlying Rating: A3 (sf) Placed Under Review for Possible
     Upgrade; previously on Aug. 5, 2008 Upgraded to A3 (sf)

Issuer: CPS Auto Receivables Trust 2005-D

  -- Cl. A-2, Aa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Nov. 12, 2009 Confirmed at Aa3 (sf)

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously Confirmed on 11/12/2009)

  -- Underlying Rating: A3 (sf) Placed Under Review for Possible
     Upgrade; previously on Aug. 5, 2008 Upgraded to A3 (sf)

Issuer: CPS Auto Receivables Trust 2006-A

  -- Cl. A-4, Aa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Nov. 12, 2009 Confirmed at Aa3 (sf)

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously Confirmed on 11/12/2009)

  -- Underlying Rating: Baa3 (sf) Placed Under Review for Possible
     Upgrade; previously on March 31, 2006 Assigned Baa3 (sf)

Issuer: CPS Auto Receivables Trust 2006-B

  -- Cl. A-4, Baa2 (sf) Placed Under Review for Possible Upgrade;
     previously on Feb. 18, 2009 Downgraded to Baa2 (sf)

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

  -- Underlying Rating: Baa2 (sf) Placed Under Review for Possible
     Upgrade; previously on July 3, 2006 Assigned Baa2 (sf)

Issuer: CPS Auto Receivables Trust 2006-C/CPS Cayman Residual
Trust 2006-C

  -- Cl. A-4, Baa2 (sf) Placed Under Review for Possible Upgrade;
     previously on Aug. 5, 2008 Downgraded to Baa2 (sf)

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

  -- Underlying Rating: Baa2 (sf) Placed Under Review for Possible
     Upgrade; previously on Oct. 3, 2006 Assigned Baa2 (sf)

  -- Cl. B, Ba3 (sf) Placed Under Review for Possible Upgrade;
     previously on Oct. 3, 2006 Assigned Ba3 (sf)

Issuer: CPS Auto Receivables Trust 2006-D/CPS Cayman Residual
Trust 2006-D

  -- Cl. A-4, Aa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Nov. 12, 2009 Confirmed at Aa3 (sf)

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously Confirmed on 11/12/2009)

  -- Underlying Rating: Baa3 (sf) Placed Under Review for Possible
     Upgrade; previously on April 7, 2009 Downgraded to Baa3 (sf)

  -- Cl. B, B1 (sf) Placed Under Review for Possible Upgrade;
     previously on April 7, 2009 Downgraded to B1 (sf)

Issuer: CPS Auto Receivables Trust 2007-A/CPS Cayman Residual
Trust 2007-A

  -- Cl. A-4, Baa3 (sf) Placed Under Review for Possible Upgrade;
     previously on April 7, 2009 Downgraded to Baa3 (sf)

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

  -- Underlying Rating: Baa3 (sf) Placed Under Review for Possible
     Upgrade; previously on April 7, 2009 Downgraded to Baa3 (sf)

  -- Cl. B, B1 (sf) Placed Under Review for Possible Upgrade;
     previously on April 7, 2009 Downgraded to B1 (sf)

Issuer: CPS Auto Receivables Trust 2007-B

  -- Cl. A-4, Aa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Nov. 12, 2009 Confirmed at Aa3 (sf)

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously Confirmed on 11/12/2009)

  -- Underlying Rating: Baa3 (sf) Placed Under Review for Possible
     Upgrade; previously on April 7, 2009 Downgraded to Baa3 (sf)

Issuer: CPS Auto Receivables Trust 2007-C

  -- Cl. A-4, Aa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Nov. 12, 2009 Confirmed at Aa3 (sf)

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously Confirmed on 11/12/2009)

  -- Underlying Rating: Baa3 (sf) Placed Under Review for Possible
     Upgrade; previously on Dec. 31, 2008 Downgraded to Baa3 (sf)

Issuer: CPS Auto Receivables Trust 2007-TFC

  -- Cl. A-2, Baa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Aug. 5, 2008 Downgraded to Baa3 (sf)

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

  -- Underlying Rating: Baa3 (sf) Placed Under Review for Possible
     Upgrade; previously on May 14, 2007 Assigned Baa3 (sf)

Issuer: CPS Auto Receivables Trust 2008-A

  -- Cl. A-3, Aa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Nov. 12, 2009 Confirmed at Aa3 (sf)

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously Confirmed on 11/12/2009)

  -- Underlying Rating: Baa1 (sf) Placed Under Review for Possible
     Upgrade; previously on April 7, 2009 Downgraded to Baa1 (sf)

  -- Cl. A-4, Aa3 (sf) Placed Under Review for Possible Upgrade;
     previously on Nov. 12, 2009 Confirmed at Aa3 (sf)

  -- Financial Guarantor: Assured Guaranty Municipal Corp. (Aa3;
     previously Confirmed on 11/12/2009)

  -- Underlying Rating: Baa1 (sf) Placed Under Review for Possible
     Upgrade; previously on April 7, 2009 Downgraded to Baa1 (sf)

                        Ratings Rationale

The review was prompted by updated lower loss expectations
relative to current levels of credit enhancement.

Moody's expects CPS Auto Receivables Trust 2005-C to incur
lifetime cumulative net losses in the range of 14.50% to 14.75% of
the original pool balance, compared to previous expectation of
17%.  Total hard credit enhancement (excluding excess spread of
approximately 8.0% per annum) for class A-2 notes is approximately
100.00% of the outstanding collateral pool balance.  This
transaction has paid down significantly with a pool factor of 3.1
% of original pool balance.

Moody's expects CPS Auto Receivables Trust 2005-D to incur
lifetime CNL in the range of 15.50% to 16.00% of the original pool
balance, compared to previous expectation of 17%.  Total hard
credit enhancement (excluding excess spread of approximately 8.1%
per annum) for class A-2 notes is approximately 80% of the
outstanding collateral pool balance.  This transaction has paid
down significantly with a pool factor of 4.8% of original pool
balance.

Moody's expects CPS Auto Receivables Trust 2006-A to incur
lifetime CNL in the range of 16.50% to 17.00% of the original pool
balance, compared to previous expectation of 17%.  Total hard
credit enhancement (excluding excess spread of approximately 7.7%
per annum) for class A-4 notes is approximately 45% of the
outstanding collateral pool balance.  This transaction has paid
down significantly with a pool factor of 7.2% of original pool
balance.

Moody's expects CPS Auto Receivables Trust 2006-B to incur
lifetime CNL in the range of 18.00% to 19.00% of the original pool
balance, compared to previous expectation of 19%.  Total hard
credit enhancement (excluding excess spread of approximately 7.6%
per annum) for class A-4 notes is approximately 55% of the
outstanding collateral pool balance.  This transaction has paid
down significantly with a pool factor of 10.0% of original pool
balance.

Moody's expects CPS Auto Receivables Trust 2006-C, 2006-D, 2007-A,
2007-B, 2007-C and 2008-A to incur lifetime CNL in the range of
19.50% to 21.00% of the original pool balance, compared to
previous expectations of 21%, 22%, 21%, 22%, 22%, 23%
respectively.  For 2006-C transaction, total hard credit
enhancement (excluding excess spread of approximately 8.0% per
annum) for class A-4 and class B notes is approximately 41% and
31% of the outstanding collateral pool balance.  For 2006-D
transaction, total hard credit enhancement (excluding excess
spread of approximately 8.5% per annum) for class A-4 and class B
is approximately 31% and 25% respectively of the outstanding
collateral pool balance.  For 2007-A transaction, total hard
credit enhancement (excluding excess spread of approximately 8.4%
per annum) for class A-4 and class B is approximately 33% and 26%
respectively of the outstanding collateral pool balance.  For
2007-B transaction, total hard credit enhancement (excluding
excess spread of approximately 8% per annum) for class A-4 is
approximately 30% of the outstanding collateral pool balance.  For
2007-C transaction, total hard credit enhancement (excluding
excess spread of approximately 7.7% per annum) for class A-3 and
A-4 is approximately 26% of outstanding collateral pool balance.
For 2008-A transaction, total hard credit enhancement (excluding
excess spread of approximately 5.9% per annum) for class A-3 and
A-4 is approximately 38% of outstanding collateral pool balance.
Pool factors for 2006-C, 2006-D, 2007-A, 2007-B, 2007-C and 2008-A
are 12.6%, 17.0%, 21.0%, 25.4%, 29.3% and 36.3% respectively of
original pool balance.

Moody's expects CPS Auto Receivables Trust 2007-TFC to incur
lifetime CNL in the range of 16% to 17% of the original pool
balance.  Total hard credit enhancement for class A-2 is 45% of
outstanding collateral pool balance.  Pool factor for the
transaction is 12.9% of original pool balance.

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


CORIOLANUS LTD: S&P Downgrades Rating on Series 39 to 'D'
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the
tranche from Coriolanus Ltd.'s series 39 to 'D (sf)'.

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

                          Rating Lowered

                          Coriolanus Ltd.
                             Series 39

                                 Rating
                                 ------
                Class           To        From
                -----           --        ----
                Tranche         D (sf)    CC (sf)


CORPORATE BACKED: Moody's Upgrades Ratings on Certs. to 'Ba2'
-------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
rating of these certificates issued by Corporate Backed Trust
Certificates, Series 2001-27 (Royal Caribbean):

* 1,521,126 Corporate Backed Trust Certificates, Series 2001-27,
  Class A-1; Upgraded to Ba2; previously on July 2, 2009
  Downgraded to Ba3

                        Ratings Rationale

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction.  The rating action is the result of the change of the
rating of the underlying securities which are the 7.50% Senior
Debentures issued by Royal Caribbean Cruises, Ltd., which were
upgraded to Ba2 by Moody's on January 28, 2011.


CREDIT PROTECTION: Moody's Upgrades Ratings on Bonds From 'Ba1'
---------------------------------------------------------------
Moody's Investors Service announced this rating action on Credit
Protection Trust 259, a collateralized debt obligation
transaction.

The CSO, issued in 2007, references a portfolio of corporate
synthetic senior unsecured bonds.

Issuer: Credit Protection Trust 259

  -- US$1,000,000,000 Super Senior, Upgraded to A2 (sf);
     previously on Sept. 4, 2009 Downgraded to Ba1 (sf)

                         Rating Rationale

Moody's rating action is the result of the credit improvement
of the underlying portfolio, the level of credit enhancement
remaining in the transaction and the shortened time to maturity
of the CSO.

Since the last rating action in September 2009, the 10-year
weighted average rating factor of the portfolio improved from 4412
to 3790, equivalent to Caa1, including settled credit events.  The
portfolio continues to improve with 29 percent of the portfolio
rated Caa1 or below, compared to 43 percent since the last rating
action took place.  There are six reference entities with a
negative outlook and one entity on watch for downgrade compared to
25 entities on negative outlook and two on watch for downgrade as
of the previous rating action date.  As of February 4, eleven
reference entities are on positive outlook and two are on review
for possible upgrade versus four on positive outlook and zero on
review for possible upgrade as of the previous rating action date.

There is approximately 36% subordination remaining in the deal.
There have been no credit events since the last rating action.
The portfolio has experienced eight credit events since inception,
equivalent to a ten percent loss of the portfolio based on the
portfolio notional value at closing.  Although Clear Channel
Communications, Dynegy Inc., Harrah's Operating Company and
Residential Capital, LLC, have not experienced a credit event so
far, Moody's assumptions for modeling purposes treat them as
defaulted given their low rating combined with a negative outlook
or a review for possible downgrade, if any.

The CSO has a remaining life of 3.38 years.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios, discussed below.  Results are given in terms
of the number of notches' difference versus the base case, where
higher notches correspond to lower expected losses, and vice-
versa:

* Moody's reviews a scenario consisting of reducing the maturity
  of the CSO by 6 months, keeping all other parameters constant.
  The result of this run is comparable to the base case.

* Market Implied Ratings are modeled in place of the corporate
  fundamental ratings to derive the default probability of the
  reference entities in the portfolio.  The gap between an MIR and
  a Moody's corporate fundamental rating is an indicator of the
  extent of the divergence in credit view between Moody's and the
  market.  The result of this run is two notches higher than that
  of the base case.

* Moody's performs a stress analysis consisting of defaulting all
  entities rated Caa1 and below.  The result of this run is three
  notches lower than in the base case.

* Moody's conducts a sensitivity analysis consisting of notching
  down by one the ratings of the most referenced industry ( High
  Tech Industries, 13.75% of the portfolio).  The result of this
  run is comparable to the base case.

* Removing the notch-down adjustment on ratings of all reference
  entities on negative outlook and/or on watch for downgrade
  generates a result that is comparable to the base case.

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

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

Moody's does not run a separate loss and cash flow analysis other
than the one already done by the CDOROM model.  For a description
of the analysis, refer to the methodology and the CDOROM user's
guide on Moody's website.

Moody's analysis of CSOs is subject to uncertainties, the primary
sources of which include 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
CSO liabilities, rating transitions in the reference pool may have
leveraged rating implications for the ratings of the 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 in
the corporate universe.  Should macroeconomics conditions evolve
towards a more severe scenario, such as a double dip recession,
the CSO rating will likely be downgraded to an extent that depends
on the expected severity of the worsening conditions.


CREDIT SUISSE: Moody's Affirms Ratings on Six 2002-CKP1 Certs.
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of six classes and
downgraded two classes of Credit Suisse First Boston Commercial
Mortgage Corp., Commercial Mortgage Pass-Through Certificates,
Series 2002-CKP1:

  -- Cl. E Certificate, Affirmed at Aa3 (sf); previously on
     March 18, 2010 Downgraded to Aa3 (sf).

  -- Cl. F Certificate, Affirmed at A3 (sf); previously on
     March 18, 2010 Downgraded to A3 (sf)

  -- Cl. G Certificate, Affirmed at Baa2 (sf); previously on
     March 18, 2010 Downgraded to Baa2 (sf)

  -- Cl. H Certificate, Affirmed at Ba2 (sf); previously on
     March 18, 2010 Downgraded to Ba2 (sf)

  -- Cl. K-Z Certificate, Downgraded to Caa2 (sf); previously on
     March 18, 2010 Downgraded to B3 (sf)

  -- Cl. L Certificate, Downgraded to Ca (sf); previously on
     March 18, 2010 Downgraded to Caa3 (sf)

  -- Cl. M Certificate, Affirmed at C (sf); previously on
     March 18, 2010 Downgraded to C (sf)

  -- Cl. N Certificate, Affirmed at C (sf); previously on
     March 18, 2010 Downgraded to C (sf)

                        Ratings Rationale

Moody's rating action did not address the ratings of Classes A3,
B, C, D, and AX, which are all currently rated Aaa or Aa1, on
review for possible downgrade.  These classes were placed on
review on January 19, 2011.  KeyCorp Real Estate Capital Markets,
Inc. is a primary servicer on this transaction and deposits
collection, escrow and other accounts in KeyBank, National
Association.  Keybank no longer meets Moody's rating criteria for
an eligible depository account institution for Aaa and Aa1 rated
securities.  Moody's is reviewing arrangements that KeyBank has
proposed, and that it may propose, to mitigate the incremental
risk indicated by the lower rating of the depository account
institution, so as possibly to allow the classes on review to
maintain their current ratings.

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
4.5% of the current balance.  At last review, Moody's cumulative
base expected loss was 5.5%.  Moody's stressed scenario loss is
7.7% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 27 compared to 29 at Moody's prior review.

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 22, 2010.

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

                         Deal Performance

As of the December 17, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by 23% to $768 million
from $992.9 million at securitization.  The Certificates are
collateralized by 134 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten non-defeased loans
representing 40% of the pool.  Twenty-six loans, representing 23%
of the pool, have defeased and are secured by U.S. Government
securities.  Defeasance at last review represented 22% of the
pool.

Thirty-six loans, representing 30% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Twenty-one loans have been liquidated from the pool, resulting in
an aggregate realized loss of $38.7 million (49% loss severity on
average).  The pool had experienced an aggregate loss of $23.5
million at last review.  Four loans, representing 4% of the pool,
are currently in special servicing.  The largest specially
serviced loan is the Chaparral Apartments Loan ($15.5 million --
2.0% of the pool), which is secured by a 444-unit apartment
complex located in Largo, Florida.  The loan was transferred to
special servicing in October 2010 for payment default and is now
90+ days delinquent.  The remaining three specially serviced loans
are secured by a mix of multifamily and retail properties.
Moody's has estimated a $16.1 million aggregate loss for the four
specially serviced loans (47% loss severity on average).

Moody's has assumed a high default probability on nine troubled
loans, representing 3% of the pool.  These loans mature within the
next 36 months and have a Moody's stressed DSCR less than 1.0X.
Moody's has estimated a $3.8 million aggregate loss on these loans
(15% loss severity on average).

Moody's was provided with year-end 2009 for 97% of the pool.
Moody's weighted average LTV for the conduit pool, excluding
specially serviced and troubled loans, is 73% compared to 79% at
the prior full 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 9.6%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.45X and 1.51X, respectively, compared to
1.30X and 1.33X at last review.  Moody's actual DSCR is based on
Moody's net cash flow and the loan's actual debt service.  Moody's
stressed DSCR is based on Moody's NCF and a 9.25% stressed rate
applied to the loan balance.

The top three loans represent 20% of the pool.  The largest loan
is the Metroplex West Loan ($58.5 million -- 7.6% of the pool),
which is secured by the borrower's interest in a 477,000 square
foot retail center located in Plymouth Meeting, Pennsylvania.  The
center is anchored by Target and Lowe's, both of which own their
respective buildings and are not part of the collateral.  As of
October 2010, the property was 100% leased, the same last review
and securitization.  Property performance has increased since the
last review due to rent steps on existing long term tenants.
Moody's LTV and stressed DSCR are 69% and 1.48X, respectively,
compared to 77% and 1.33X at last review.

The second largest loan is the 300 M Street Office Building Loan
($47.3 million -- 6.2% of the pool), which is secured by a 280,000
square foot Class A office building located in Washington, D.C.
As of June 2010 the property was 100% leased, the same as last
review.  The largest tenants are Northrop Grumman, URS Federal
Technical Services, and Allon Science and Technology (total of 68%
of the NRA).  All of these tenants leases are scheduled to expire
in 2011 but early indications are that the tenants will renew.
Moody's analysis reflects a stressed cash flow due to Moody's
concerns about the property's significant lease rollover in 2011.
Moody's LTV and stressed DSCR are 75% and 1.40X, respectively,
compared to 77% and 1.37X at last review.

The third largest loan is The Shops at Deerfield Square Loan
($44.8 million -- 5.8% of the pool), which is secured by a mixed-
use property that includes 170,000 square feet of retail and
67,000 square feet of office space located in Deerfield, Illinois.
The property was 100% leased as of October 2010, the same as last
review.  Moody's LTV and stressed DSCR are 85% and 1.15X,
respectively, compared to 90% and 1.08X at last review.


CREDIT SUISSE: Moody's Downgrades Ratings on Six 2001-CK6 Certs.
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of six classes
and affirmed five classes of Credit Suisse First Boston Mortgage
Securities Corp. Commercial Mortgage Pass-Through Certificates,
Series 2001-CK6:

  -- Cl. E, Affirmed at Aa3 (sf); previously on Sept. 12, 2007
     Upgraded to Aa3 (sf)

  -- Cl. F, Affirmed at A1 (sf); previously on Sept. 12, 2007
     Upgraded to A1 (sf)

  -- Cl. G, Affirmed at A3 (sf); previously on Sept. 12, 2007
     Upgraded to A3 (sf)

  -- Cl. H, Affirmed at Baa2 (sf); previously on Sept. 12, 2007
     Upgraded to Baa2 (sf)

  -- Cl. J, Affirmed at Baa3 (sf); previously on Sept. 12, 2007
     Upgraded to Baa3 (sf)

  -- Cl. K, Downgraded to Ba3 (sf); previously on Dec. 21, 2001
     Definitive Rating Assigned Ba2 (sf)

  -- Cl. L, Downgraded to Caa1 (sf); previously on Dec. 21, 2001
     Definitive Rating Assigned Ba3 (sf)

  -- Cl. M, Downgraded to Ca (sf); previously on March 11, 2009
     Downgraded to B2 (sf)

  -- Cl. N, Downgraded to C (sf); previously on March 11, 2009
     Downgraded to B3 (sf)

  -- Cl. O, Downgraded to C (sf); previously on March 11, 2009
     Downgraded to Caa1 (sf)

  -- Cl. P, Downgraded to C (sf); previously on March 11, 2009
     Downgraded to Ca (sf)

                        Ratings Rationale

Moody's rating action did not address the ratings of Classes A3,
B, C, D, and A-X, which are all currently rated Aaa, on review for
possible downgrade.  These classes were placed on review on
January 19, 2011.  KeyCorp Real Estate Capital Markets, Inc.
(KRECM) is a primary servicer on this transaction and deposits
collection, escrow and other accounts in KeyBank, National
Association (Keybank).  Keybank no longer meets Moody's rating
criteria for an eligible depository account institution for Aaa
and Aa1 rated securities.  Moody's is reviewing arrangements that
KeyBank has proposed, and that it may propose, to mitigate the
incremental risk indicated by the lower rating of the depository
account institution, so as possibly to allow the classes on review
to maintain their current ratings.

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 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
5.5% of the current balance.  At last full review, Moody's
cumulative base expected loss was 2.8%.  Moody's stressed scenario
loss is 9.5% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 26 compared to 50 at Moody's prior full 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 September 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 January 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 32% to $670 million
from $986 million at securitization.  The Certificates are
collateralized by 106 mortgage loans ranging in size from less
than 1% to 9.6% of the pool, with the top ten loans representing
38% of the pool.  Twenty-two loans, representing 24% of the pool,
have defeased and are collateralized with U.S. Government
securities, compared to 26% at last review.

Twenty-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.

Twenty loans have been liquidated from the pool since
securitization, resulting in an aggregate $9 million loss (41%
loss severity on average).  At last review the pool had realized
an aggregate $7.7 million loss.  Currently eight loans,
representing 6% of the pool, are in special servicing.  The master
servicer has recognized an aggregate $20 million appraisal
reduction for the specially serviced loans.  Moody's has estimated
an aggregate loss of $22.4 million (59% expected loss on average)
for all of the specially serviced loans.

Moody's has assumed a high default probability for nine poorly
performing loans representing 5% of the pool and has estimated a
$6.9 million loss (21% expected loss based on a 61% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 99% and 37% of the performing pool,
respectively.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 83% compared to 89% at last full
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
9.8%.

Excluding specially serviced and troubled loans, Moody's actual
DSCRs is 1.31X compared to 1.20X 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.

The top three performing conduit loans represent 19.7% of the
pool balance.  The largest loan is the Avalon Pavilions Loan
($64.1 million -- 9.6% of the pool), which is secured by a 932-
unit multifamily property located in Manchester, Connecticut.  The
loan is amortizing on a 360-month schedule maturing in August
2011.  The loan has amortized 3% since last full review.  Property
performance has been stable but the loan is currently on the
master servicer's watchlist due to low DSCR.  Moody's LTV and
stressed DSCR are 96% and 1.04X, respectively, compared to 96% and
1.05X at last full review.

The second largest loan is the Washington Design Center Loan
($43.4 million -- 6.5% of the pool), which is secured by a 357,518
SF mixed use building located in Washington, DC.  The loan is
amortizing on a 360-month schedule maturing in November 2011.  The
loan has amortized 3% since last full review.  The property was
87% leased as of October 2010 compared to 96% at last review.
Moody's LTV and stressed DSCR are 75% and 1.52X, respectively,
compared to 77% and 1.44X at last full review.

The third largest loan is the Rockland Center Loan ($24.6 million
-- 3.7% of the pool), which is secured by a 259,244 SF retail
community center located in Nanuet, New York.  Although property
performance has been relatively stable, the loan is on the master
servicer's watchlist due to the uncertainty around the status of
Pathmark, the property's largest tenant.  Pathmark is a subsidiary
of A&P which filed for bankruptcy on December 13, 2010.  A&P has
announced plans to close 25 stores.  The loan is amortizing on a
360-month schedule maturing in November 2011.  The loan has
amortized 3% since last full review.  Moody's LTV and stressed
DSCR are 100% and 1.03X, respectively, compared to 103% and 1X at
last review.


CREDIT SUISSE: Moody's Reviews Ratings on 2004-C4 Certificates
--------------------------------------------------------------
Moody's Investors Service placed these seven additional classes of
Credit Suisse First Boston Mortgage Securities Corp., Commercial
Mortgage Pass-Through Certificates, Series 2004-C4 on review for
possible downgrade, adding it to the ten classes previously placed
on review for possible downgrade on January 19, 2011:

  -- Cl. B, A1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2010 Downgraded to A1 (sf)

  -- Cl. C, Baa1 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2010 Downgraded to Baa1 (sf)

  -- Cl. D, Baa3 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2010 Downgraded to Baa3 (sf)

  -- Cl. E, Ba2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2010 Downgraded to Ba2 (sf)

  -- Cl. F, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2010 Downgraded to B2 (sf)

  -- Cl. G, Caa2 (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2010 Downgraded to Caa2 (sf)

  -- Cl. H, Ca (sf) Placed Under Review for Possible Downgrade;
     previously on Feb. 3, 2010 Downgraded to Ca (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from anticipated
losses from specially serviced and troubled loans as well as
interest shortfalls.  On January 19, 2011, Moody's placed ten
classes on review for possible downgrade because KeyBank National
Association, the bank in which the related transactions'
collection, escrow and other accounts are held, no longer meets
Moody's rating criteria for an eligible depository account
institution for Aaa- and Aa1-rated securities.

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 3, 2010.

                   Deal And Performance Summary

As of the January 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 27% to
$832.9 million from $1.14 billion at securitization.  The
Certificates are collateralized by 158 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 32% of the pool.  Thirteen loans, representing 8% of
the pool, have defeased and are collateralized with U.S.
Government securities.  Defeasance at last review represented 23%
of the pool.

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

Twelve loans have been liquidated from the pool since
securitization, resulting in an aggregate $6.5 million loss (12%
loss severity on average).  The pool had experienced a $660,340
loss at Moody's prior review.  Currently 4 loans, representing 11%
of the pool, are in special servicing.  The largest specially
serviced loan is the Village on the Parkway Loan ($45.0 million --
5.0%) which is secured by a 381,000 square feet retail center
located in Addison, Texas.  The loan was transferred to special
servicing in October 2009.  The property was foreclosed in
September 2010 and is REO.  The remaining three specially serviced
loans are secured by a mix of property types.  The master servicer
has recognized an aggregate $21.6 million appraisal reduction for
the specially serviced loans.

Based on the most recent remittance statement, Classes J through
O have experienced cumulative interest shortfalls totaling
$1.3 million.  Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced loans.  Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions and extraordinary
trust expenses.

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


CREDIT SUISSE: S&P Downgrades Ratings on Seven 2005-C4 Notes
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on seven
classes of commercial mortgage-backed securities from Credit
Suisse First Boston Mortgage Securities Corp.'s series 2005-C4.

The downgrades of the class L and M certificates to 'D (sf)'
follow a principal loss to the class, which was detailed in
the Jan. 18, 2011 remittance report.  The class L certificate
experienced a loss totaling 51.42% of its $6.64 million beginning
certificate balance, and the class M certificate experienced a
loss totaling 100% of its $1.66 million beginning balance.  The
class N certificates, which Standard & Poor's previously lowered
to 'D (sf)', lost 100% of its $3.28 million opening balance.

According to the January 2011 remittance report, the
$10.67 million total principal loss to the trust resulted from
the liquidation of The Pavilion Center loan, which was with the
special servicer, C-III Asset Management LLC.  The Pavilion
Center asset is a 136,774-sq.-ft. retail property in Vista,
Calif., which was transferred to the special servicer on Feb. 19,
2009, due to payment default.  The asset had an outstanding
balance of $20.6 million at the time of liquidation.  Based on the
January 2011 remittance report data, the loss severity was 51.8%.

The downgrades of classes F through K reflect recurring interest
shortfalls and reduced liquidity available to absorb future
interest shortfalls.  S&P expects the class J and K certificates
to experience ongoing interest shortfalls for the foreseeable
future resulting from ASERs related to two of the seven loans that
are currently with the special servicer, as well as interest not
advanced and special servicing fees.  Consequently, S&P lowered
these classes to 'D (sf)'.

According to the January 2011 remittance report, the trust
experienced a net repayment of accumulated interest shortfalls
totaling $509,163.  The net recovery is primarily due to a one-
time ASER recovery associated with the liquidation of the Pavilion
Center loan.  Prior to the liquidation, as of the Dec. 17, 2010,
trustee remittance report, accumulated interest shortfalls were
$620,318, and had affected all classes subordinate to and
including class J.  Classes J and K had accumulated interest
shortfalls outstanding for five months or more.

The total reported ASER amount for loans currently in special
servicing was $23,249, and the reported cumulative ASER amount was
$170,607.  ARAs totaling $5.9 million were in effect for three
loans.  Standard & Poor's considered the two ASER amounts, both of
which were based on MAI appraisals, as well as interest not
advanced ($7,315) on the remaining loan, and current special
servicing fees in determining its rating actions.

       Credit Suisse First Boston Mortgage Securities Corp.
   Commercial mortgage pass-through certificates series 2005-C4

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To       From        Credit enhancement     Current   Accumulated
-----  --       ----        ------------------     -------   -----------
F      B+ (sf)   BB (sf)       4.11                 0            0
G      CCC+ (sf) BB- (sf)      2.87                 0            0
H      CCC- (sf) B (sf)        1.32                 0            0
J      D (sf)    B- (sf)       0.86          (36,306)            0
K      D (sf)    CCC+ (sf)     0.09         (168,502)            0
L      D (sf)    CCC- (sf)     0.00         (151,811)            0
M      D (sf)    CCC- (sf)     0.00          (40,445)            0


CSAB MORTGAGE-BACKED: Moody's Downgrades Ratings on Three Tranches
------------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches and confirmed the rating on one tranche from CSAB
Mortgage-Backed Trust 2006-2.

                        Ratings Rationale

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

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: CSAB Mortgage-Backed Trust 2006-2

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

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

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

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

  -- Cl. A-3-A, Current Rating at Aa3 (sf); previously on Nov. 12,
     2009 Confirmed at Aa3 (sf)

  -- Underlying Rating: Confirmed at Caa3 (sf); previously on
     Jan. 21, 2010 Caa3 (sf) Placed Under Review for Possible
     Downgrade

  -- Financial Guarantor: Assured Guaranty Municipal Corp
     (Confirmed at Aa3, Outlook Negative on Nov. 12, 2009)

  -- Cl. A-4, Current Rating at Aa3 (sf); previously on Nov. 12,
     2009 Confirmed at Aa3 (sf)

  -- Underlying Rating: Confirmed at Caa3 (sf); previously on
     Jan. 21, 2010 Caa3 (sf) Placed Under Review for Possible
     Downgrade

  -- Financial Guarantor: Assured Guaranty Municipal Corp
     (Confirmed at Aa3, Outlook Negative on Nov. 12, 2009)


CSAM FUNDING: Moody's Upgrades Ratings on Various Classes of Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by CSAM Funding I:

  -- US$10,500,000 Class A-1 Notes (current outstanding balance of
     $7,320,514), Upgraded to Aa1 (sf); previously on November 23,
     2010 Aa3 (sf) Placed Under Review for Possible Upgrade;

  -- US$563,500,000 Class A-2 Notes (current outstanding balance
     of $392,867,614), Upgraded to Aa1 (sf); previously on
     November 23, 2010 Aa3 (sf) Placed Under Review for Possible
     Upgrade;

  -- US$22,500,000 Class B-1 Notes, Upgraded to Baa1 (sf);
     previously on November 23, 2010 Ba1 (sf) Placed Under Review
     for Possible Upgrade;

  -- US$40,000,000 Class B-2 Notes, Upgraded to Baa1 (sf);
     previously on November 23, 2010 Ba1 (sf) Placed Under Review
     for Possible Upgrade;

  -- US$18,000,000 Class C-1 Notes, Upgraded to Ba2 (sf);
     previously on November 23, 2010 B3 (sf) Placed Under Review
     for Possible Upgrade;

  -- US$11,700,000 Class C-2 Notes, Upgraded to Ba2 (sf);
     previously on November 23, 2010 B3 (sf) Placed Under Review
     for Possible Upgrade;

  -- US$11,800,000 Class D-1 Notes, Upgraded to Caa3 (sf);
     previously on November 23, 2010 Ca (sf) Placed Under Review
     for Possible Upgrade;

  -- US$12,000,000 Class D-2 Notes, Upgraded to Caa3 (sf);
     previously on November 23, 2010 Ca (sf) Placed Under Review
     for Possible Upgrade.

                        Ratings Rationale

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

The overcollateralization ratios of the rated notes have
improved due to the delevering of the Class A-1 and Class A-2
Notes, which have been paid down by approximately 19.7% or $98
million since the rating action in July 2009.  Based on the
January 2011 trustee report, the Class A, Class B, Class C, and
Class D overcollateralization ratios are reported at 136.42%,
118.49%, 111.53% and 106.51%, respectively, versus June 2009
levels of 127.3%, 113.10%, 107.40% and 103.30%, respectively, and
all related overcollateralization tests are currently in
compliance.

Moody's also notes that the deal has benefited from improvement in
the credit quality of the underlying portfolio since the last
rating action.  The weighted average rating factor in the January
2011 report was 2716 compared to 2944 in June 2009, and securities
rated Caa1 and below make up approximately 9.6% of the underlying
portfolio versus 17.7% in June 2009.  The deal also experienced a
decrease in defaulted securities.  In particular, the dollar
amount of defaulted securities has decreased to about $25 million
from approximately $75 million in June 2009.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" and "Annual Sector Review (2009): Global CLOs," key
model inputs used by Moody's in its analysis, such as par,
weighted average rating factor, diversity score, and weighted
average recovery rate, may be different from the trustee's
reported numbers.  In its base case, Moody's analyzed the
underlying collateral pool to have a performing par and principal
proceeds balance of $563 million, defaulted par of $31 million, a
weighted average default probability of 23.65% (implying a WARF of
3796), a weighted average recovery rate upon default of 38.89%,
and a diversity score of 65.  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.

CSAM Funding I, issued on March 29, 2001, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

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

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on all
rated notes of various default probabilities.

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 loss), assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (3037)

  -- Class A-1: +1
  -- Class A-2: +1
  -- Class B-1: +2
  -- Class B-2: +2
  -- Class C-1: +2
  -- Class C-2: +2
  -- Class D-1: +3
  -- Class D-2: +3

Moody's Adjusted WARF + 20% (4555)

  -- Class A-1: -1
  -- Class A-2: -1
  -- Class B-1: -2
  -- Class B-2: -2
  -- Class C-1: -2
  -- Class C-2: -2
  -- Class D-1: -1
  -- Class D-2: -1

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the manager's
investment strategy 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:

1) Delevering: The main source of uncertainty in this transaction
   is at what pace delevering will continue.  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 deal's
   overcollateralization levels.  Further, the timing of
   recoveries and the manager's decision to work out versus sell
   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.

4) 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.

5) Other collateral quality metrics: The deal is allowed to
   reinvest from unscheduled proceeds and the manager has the
   ability to deteriorate the collateral quality metrics' existing
   cushions against the covenant levels.  Moody's analyzed the
   impact of assuming lower of reported and covenanted values for
   weighted average rating factor, weighted average spread,
   weighted average coupon, and diversity score.


CSAM FUNDING: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A, B-1, B-2, C-1, C-2, and D notes from CSAM Funding II,
a collateralized loan obligation transaction managed by CSFB
Alternative Capital Inc. At the same time, S&P removed the ratings
on the class A, B-1, B-2, C-1, C-2, and D notes from CreditWatch
with positive implications.

The upgrades reflect the improved performance S&P has observed in
the transaction's underlying asset portfolio since S&P's last
rating action in November 2009.

According to the Jan. 10, 2011 trustee report the transaction
held $19 million in defaulted assets, down from $45 million noted
in the Oct. 7, 2009 trustee report.  In addition, assets from
obligors rated in the 'CCC' category were approximately 6% of the
collateral pool in January 2011 as compared with approximately 9%
in October 2009.  The class A par value test improved to 135.53%
in January 2011 from 129.54% as of October 2009.  The class A
notes were paid down by $53 million since S&P's last rating
action.

Standard & Poor's will continue to review the ratings assigned to
the notes to asses whether they remain consistent with the credit
enhancement available to support them and take rating actions as
S&P deems necessary.

                  Rating And Creditwatch Actions

                          CSAM Funding II

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


CT CDO: Fitch Downgrades Ratings on Two Classes of Notes
--------------------------------------------------------
Fitch Ratings has downgraded two and affirmed 12 classes issued by
CT CDO III Ltd./Corp.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs'.  The
ratings are not based on the Portfolio Credit Model given the high
obligor concentration and seasoning of the portfolio.  Instead,
the projected recovery estimate on the distressed collateral was
applied in accordance with the principal waterfall.  Additionally,
an asset by asset analysis was performed for the remaining assets
to determine the collateral coverage for the remaining
liabilities.

Since Fitch's last rating action in February 2010, the weighted
average rating of the portfolio has remained the same at 'BB/BB-'.
Currently, 29.1% has a Fitch derived rating below investment grade
and 15.8% has a rating in the 'CCC' rating category or lower,
compared to 28.7% and 15.9%, respectively, at last review.  The
class A-1 notes have paid down by $14.5 million since the last
review.  The portfolio has become increasingly concentrated with
13 obligors remaining.

The class A-1 notes have been affirmed and are assigned a Stable
Outlook, since they are adequately supported by 'AAA' rated
collateral.  Classes A-2 through H have been affirmed at their
current ratings given that their balances are covered by
collateral with equal or better rated collateral.  These classes
have been assigned a Negative Outlook reflecting Fitch's
expectation that underlying commercial mortgage backed security
loans will continue to face refinance risk.  The Loss Severity
rating indicates a tranche's potential loss severity given
default, as evidenced by the ratio of tranche size to the base-
case loss expectation for the collateral, as explained in
'Criteria for Structured Finance Loss Severity Ratings'.  The LS
rating should always be considered in conjunction with the
probability of default for tranches.  Fitch does not assign LS
ratings or Outlooks to classes rated 'CCC' and below.

Fitch affirmed classes J through L at their current ratings given
the limited amount of credit enhancement that would remain after
liquidation of the distressed collateral.  The total loss estimate
for the distressed assets is expected to erode the class O notes
and part of class N, and significantly reduce the credit
enhancement for class M.  As a result, the class M and N notes
have been downgraded to 'Csf, indicating default is inevitable.

CT CDO III is a commercial real estate collateralized debt
obligation that closed Aug. 4, 2005.  The transaction is
collateralized by 21 CMBS assets from 13 obligors from the 1996-
1999 vintages.

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

  -- $44,387,524 Class A-1 Notes affirmed at 'AAAsf/LS4'; Outlook
     to Stable from Negative;

  -- $147,169,000 Class A-2 Notes affirmed at 'Asf/LS3'; Outlook
     Negative;

  -- $29,007,000 Class B Notes affirmed at 'BBB+sf/LS4'; Outlook
     Negative;

  -- $13,650,000 Class C Notes affirmed at 'BBBsf'; Outlook
     Negative; to 'LS5' from 'LS4';

  -- $5,118,000 Class D Notes affirmed at 'BBB-sf/LS5'; Outlook
     Negative;

  -- $6,825,000 Class E Notes affirmed at 'BB+sf/LS5'; Outlook
     Negative;

  -- $6,825,000 Class F Notes affirmed at 'BB+sf/LS5'; Outlook
     Negative;

  -- $9,811,000 Class G Notes affirmed at 'BBsf/LS5'; Outlook
     Negative;

  -- $11,517,000 Class H Notes affirmed at 'Bsf/LS5' Outlook
     Negative;

  -- $6,825,000 Class J Notes affirmed at 'CCCsf';

  -- $3,839,000 Class K Notes affirmed at 'CCCsf';

  -- $5,118,000 Class L Notes affirmed at 'CCsf';

  -- $5,545,000 Class M Notes downgraded to 'Csf' from 'CCsf';

  -- $4,265,000 Class N Notes downgraded to 'Csf' from 'CCsf'.


DBUBS 2011-LC1: Moody's Assigns Ratings on 11 CMBS Securities
-------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to 11
classes of CMBS securities, issued by DBUBS 2011-LC1, Commercial
Mortgage Pass-Through Certificates Series 2011-LC1.

  -- Cl. A-1 Certificate, Assigned (P)Aaa (sf)
  -- Cl. A-2 Certificate, Assigned (P)Aaa (sf)
  -- Cl. A-3 Certificate, Assigned (P)Aaa (sf)
  -- Cl. X-A Certificate, Assigned (P)Aaa (sf)
  -- Cl. X-B Certificate, Assigned (P)Aaa (sf)
  -- Cl. B Certificate, Assigned (P)Aa2 (sf)
  -- Cl. C Certificate, Assigned (P)A2 (sf)
  -- Cl. D Certificate, Assigned (P)Baa1 (sf)
  -- Cl. E Certificate, Assigned (P)Baa3 (sf)
  -- Cl. F Certificate, Assigned (P)Ba2 (sf)
  -- Cl. G Certificate, Assigned (P)B2 (sf)

                        Ratings Rationale

The Certificates are collateralized by 47 fixed rate loans secured
by 83 properties.  The ratings are based on the collateral and the
structure of the transaction.

Moody's CMBS ratings methodology combines both commercial real
estate and structured finance analysis.  Based on commercial real
estate analysis, Moody's determines the credit quality of each
mortgage loan and calculates an expected loss on a loan specific
basis.  Under structured finance, the credit enhancement for each
certificate typically depends on the expected frequency, severity,
and timing of future losses.  Moody's also considers a range of
qualitative issues as well as the transaction's structural and
legal aspects.

The credit risk of loans is determined primarily by two factors:
1) Moody's assessment of the probability of default, which is
largely driven by each loan's DSCR, and 2) Moody's assessment of
the severity of loss upon a default, which is largely driven by
each loan's LTV ratio.  The Moody's Actual DSCR of 1.43X is higher
than the 2007 conduit/fusion transaction average of 1.31X.  The
Moody's Stressed DSCR of 1.07X is higher than the 2007
conduit/fusion transaction average of 0.92X.  Moody's Trust LTV
ratio of 94.0% is lower than the 2007 conduit/fusion transaction
average of 110.6%.  Moody's Total LTV ratio (inclusive of
subordinated debt) of 97.7% is also considered when analyzing
various stress scenarios for the rated debt.

Moody's also considers both loan level diversity and property
level diversity when selecting a ratings approach.  With respect
to loan level diversity, the pool's loan level Herfindahl score is
18.  With respect to property level diversity, the pool's property
level Herfindahl score is 19.  The transaction is concentrated
relative to previously rated conduit and fusion transactions but
more diverse than previously rated large loan transactions.  As a
result, Moody's approach to rating the deal incorporated a blend
of both Moody's conduit and large loan rating methodologies.

Properties located in major markets represent approximately 91.2%
of the pool balance.  Additionally, Moody's Red-Yellow-GreenTM
analysis covers properties representing 83.3% of the pool balance.
The tertiary market share of 8.8% is amongst the lowest exposures
Moody's has observed in its rated conduit and fusion universe.
Properties situated in major markets tend to exhibit more cash
flow and cap rate stability over time compared to assets located
in tertiary markets.

Moody's also grades properties on a scale of 1 to 5 (best to
worst) and considers those grades when assessing the likelihood of
debt payment.  The factors considered include property age,
quality of construction, location, market, and tenancy.  The
pool's weighted average property quality grade is 1.8, which is
lower than the average of recently rated conduit deals.  The low
weighted average grade is indicative of the strong market
composition of the pool and the stability of the cash flows
underlying the assets.

The transaction benefits from two loans, representing
approximately 11.3% of the pool balance in aggregate, assigned an
investment grade credit estimate.  Loans assigned investment grade
credit estimates are not expected to contribute any loss to a
transaction in low stress scenarios, but are expected to
contribute minimal amounts of loss in high stress scenarios.

Moody's analysis employs the excel-based CMBS Conduit Model v2.50
which derives credit enhancement levels based on an aggregation of
adjusted loan level proceeds derived from Moody's loan level DSCR
and LTV ratios.  Major adjustments to determining proceeds include
loan structure, property type, sponsorship and diversity.

The V Score for this transaction is assessed as Low/Medium, the
same as the V Score assigned to the U.S. Conduit and CMBS sector.
This reflects typical volatility with respect to the critical
assumptions used in the rating process as well as an average
disclosure of securitization collateral and ongoing performance.

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 Moody's value of the
collateral used in determining the initial rating were decreased
by 5%, 15%, or 23%, the model-indicated rating for the currently
rated Aaa classes would be Aa1, Aa3, A1, respectively.  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 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.


DELTA AIR: Moody's Assigns 'Ba3' Ratings on Class B Certificates
----------------------------------------------------------------
Moody's Investors Service assigned Ba3 ratings to the respective
Class B Pass Through Certificates, Series 2010-1B of the 2010-1B
Pass Through Trust and the Series 2010-2B of the 2010-2B Pass
Through Trust to be issued by Delta Air Lines, Inc.  At the same
time, the Baa2 ratings previously assigned by Moody's to the
respective Class A Pass Through Certificates , Series 2010-1A
which Delta issued on July 2, 2010, and Series 2010-2A, which
Delta issued on November 22, 2010, and all of Delta's other EETC
and debt ratings, are affirmed by Moody's and remain in force.

                        Ratings Rationale

A portion of the 2010-2B Certificates' proceeds will immediately
fund the purchase of 12 Class B equipment notes that Delta will
issue.  The remaining proceeds will be held in escrow, and will
fund the purchase of the remaining 16 Class B equipment notes of
that Series to be issued by Delta for refinancings concluding with
Delta's 2001-1 EETC that has a scheduled maturity in September
2011.  The proceeds of the 2010-1B Series will fund the immediate
purchase of the Class B equipment notes of that Series to be
issued by Delta.  The company will use the Notes proceeds for
general corporate purposes.  Please refer to Moody's press
releases dated June 28, 2010 and November 15, 2010 on
www.moodys.com for descriptions of the aircraft that comprise the
respective collateral for each of these EETCs.  The Class B
Certificates of each Series will generally be subordinated to the
Class A Certificates of that Series for the distribution of
scheduled principal and interest payments on the Notes, as well as
for non-scheduled distributions, if any.  Scheduled interest
payments on the Class B Certificates are supported by separate
Class B Liquidity Facilities, each sized to pay up to three
respective consecutive semi-annual interest payments in the event
Delta defaults on its obligations under the Notes.

Assignments:

Issuer: Delta Air Lines, Inc.

  -- Series 2010-1B Senior Secured Enhanced Equipment Trust, Class
     B, Assigned Ba3

  -- Series 2010-2B Senior Secured Enhanced Equipment Trust, Class
     B, Assigned Ba3

The ratings of the Certificates consider the credit quality of
Delta (Corporate Family Rating of B2, stable outlook) as obligor
under the Notes, Moody's opinion of the collateral protection of
the Notes, the credit support provided by the liquidity
facilities, the cross-subordination provisions of the inter-
creditor agreement and certain structural characteristics of the
Notes such as the cross-collateralization and cross-default
provisions and the applicability of Section 1110 of Title 11 of
the United States Code.  The assigned ratings reflect Moody's
opinion of the ability of the Pass-Through Trustees to make timely
payment of interest and the ultimate payment of principal at a
date no later than the final legal distribution dates of July 2,
2017 for 2010-1B and May 23, 2017 for 2010-2B.
Series 2010-1B

Moody's believes that affirmation of the 2010-1 Series under a
bankruptcy scenario would be likely because the aircraft
collateral represent some of the youngest vintages for the
respective models in Delta's fleet.  Additionally, the B777-
200LR's are among the newest aircraft in the fleet and fill a key
role in Delta's strategy to increase capacity on its longest-haul
routes between the U.S. and Asia.  The structure's cross-default
feature further supports the anticipation of affirmation given the
relatively younger age and relevance of the collateral to Delta's
route network, even under a reorganization scenario.

Moody's estimates the peak loan-to-value inclusive of benefit for
the cross-collateralization feature at above 70%.  The resultant
over-collateralization through the Class B Certificates obligation
provides an adequate cushion to support recovery on the B tranche
in the event of a bankruptcy filing by Delta during the upcoming
five years, the tenor of the Class B obligations.  The cross-
collateralization of the aircraft securing each equipment note
underlying the transaction could enhance the recovery for
investors in the event Delta was to dis-affirm its obligations
under the equipment notes under a bankruptcy filing by it and
pursuant to the provisions of the Code.

                         Series 2010-2B

Moody's believes that affirmation of the 2010-2 Series under a
bankruptcy scenario is also likely but possibly somewhat less so
than that of the other three of Delta's EETC's including 2010-1
that provide cross-default and cross-collateralization of the
respective underlying equipment notes.  This is because of the few
number of many models of aircraft in this financing transaction.

Moody's estimates the peak loan-to-value inclusive of the benefit
for the cross-collateralization feature at above 75% initially.
The resultant over-collateralization through the Class B
Certificates obligation should provide an adequate cushion to
support a good recovery on the B tranche in the event of a
bankruptcy filing by Delta during the upcoming five years, the
tenor of the Class B obligations.  The cross-collateralization of
the aircraft securing each equipment note underlying this Series
could enhance the recovery for investors in the event Delta was to
disaffirm its obligations under the equipment notes under a
bankruptcy filing by it and pursuant to the provisions of the
Code.

Any combination of future changes in the underlying credit quality
or ratings of Delta, unexpected material changes in the value of
the aircraft pledged as collateral, and/or changes in the status
or terms of the liquidity facilities could cause Moody's' to
change its ratings of the Certificates.

The last rating action was on November 15, 2010 when Moody's
assigned a Baa2 rating to the $474 million of Class A Pass Through
Certificates, Series 2010-2A of the 2010-2 Pass Through Trust
issued by Delta.

Delta Air Lines, Inc., headquartered in Atlanta, Georgia, is the
world's largest airline, providing scheduled air transportation
for passengers and cargo throughout the U.S. and around the world.


DELTA AIR: S&P Assigns 'BB' Rating to 2010-2B Certificates
----------------------------------------------------------
Standard & Poor's Ratings Services said that it has assigned its
preliminary 'BB' (sf) rating to Delta Air Lines Inc.'s pass-
through certificates series 2010-2B, a rule 415 shelf registration
drawdown, with an expected maturity of Nov. 23, 2015.  The final
legal maturity will be 18 months after the expected maturity.  The
issue is a junior tranche secured by the same collateral as the
$474.1 million series 2010-1A certificates issued Nov. 15, 2010.
The issuance of this series has no effect on S&P's 'A-' (sf)
rating on the 2010-A series.

The preliminary 'BB' (sf) rating on the 2010-1 class B
certificates reflects Delta's credit quality, substantial
collateral coverage by a combination of very desirable and
somewhat-less-liquid aircraft, and legal and structural
protections available to the certificates.  The 2010-2A and 2010-
2B certificates are secured by aircraft notes which, in turn, are
secured -- one per aircraft -- by aircraft Delta already owns:
six B737-800, one B757-200ER, and three B767-300ER aircraft
(previously collateral for earlier pass-through certificates);
two B737-700, six B757-200ER, one B777-200LR, and one A330-200
aircraft (previously collateral for third-party financings); and
three B757-300, one A320-200, one A330-300, and three MD90-30
aircraft (previously unencumbered).  Each aircraft's secured notes
are cross-collateralized and cross-defaulted, a provision that S&P
believes increases the likelihood that Delta would affirm the
notes (and, therefore, continue to pay on the certificates) in
bankruptcy.

The pass-through certificates are a form of enhanced equipment
trust certificates and benefit from legal protections afforded
under Section 1110 of the federal bankruptcy code and by a
liquidity facility provided by Natixis S.A.  This facility is
intended to cover up to three semiannual interest payments -- a
period during which collateral could be repossessed and remarketed
by certificateholders following any default by the airline -- or
to maintain continuity of interest payments as certificateholders
negotiate with Delta in a bankruptcy with regard to certificates.

The preliminary rating applies to a unit consisting of
certificates representing the trust property and escrow receipts,
initially representing interests in deposits (the proceeds of the
offerings).  The escrow deposits are held by a depositary bank,
the Bank of New York Mellon, pending delivery of the aircraft that
Delta will refinance with proceeds from the certificates (10 of
which currently secure Delta's 2001-1 EETCs).  Amounts deposited
under the escrow agreements are not the property of Delta and
are not entitled to the benefits of Section 1110 of the U.S.
Bankruptcy Code, and any default arising under an indenture solely
by reason of the cross-default in such indenture may not be of a
type required to be cured under Section 1110.  Any cash collateral
held as a result of the cross-collateralization of the equipment
notes also would not be entitled to the benefits of Section 1110.
Neither the certificates nor the escrow receipts may be separately
assigned or transferred.

S&P believes that Delta views these planes as important and would,
given the cross-collateralization and cross-default provisions,
likely affirm the aircraft notes in a bankruptcy scenario.  In
contrast to most EETCs issued before 2009, the cross-default would
take effect immediately in a bankruptcy if Delta rejected any of
the aircraft notes.  This should prevent Delta from selectively
affirming some aircraft notes and rejecting others ("cherry-
picking"), which often harms the interests of certificateholders n
a bankruptcy.

S&P considers the collateral pool overall to be of mixed quality,
with some aircraft models more attractive than others.  The
largest proportion of value, about 60%, is comprised of good
collateral: B737-800s and B737-700s (26%), A330-200s and A330-300s
(16%), B777-200LRs (15%), and one A320 (3%).  The B737-800 and
closely related B737-700 are Boeing's most popular aircraft, a
midsize narrowbody plane that more than 100 airlines worldwide
operate.  Given the modern technology incorporated in the plane,
its wide user base, and expected demand in excess of supply over
the intermediate term, S&P considers it to be the best aircraft
collateral available.  Boeing currently says that it could
possibly introduce a successor to the various current B737 models
toward the end of this decade.  The A330-200 and A330-300 are
popular Airbus widebodies operated globally.  However, they will
compete in the global aircraft market with the B787, which
incorporates newer technology, with the first aircraft expected to
be delivered in 2011.  The Airbus A350, scheduled to enter service
in 2013, is a somewhat larger and longer-range plane than the A330
models, but will also represent a successor.  The B777-200LR is a
long-range version introduced in 2005 of Boeing's successful B777
model.  It's more specialized than the predecessor B777-200ER from
which it was derived and has attracted fewer airline operators so
far; S&P accordingly judges its liquidity to be somewhat less than
the B777-200ER's.  The A320-200 is the core of Airbus' very
successful narrowbody product line and widely used by airlines
worldwide.  Although this plane was introduced in 1995, S&P does
not expect Airbus to introduce a successor model until at least
late this decade, now that Airbus has announced a re-engined
version available mid-decade.

The balance of value, about 40%, is comprised of B757-200ERs
(14%), B767-300ERs (13%), B757-300s (10%), and MD9-30s (3%).  The
B757-200ER is a large narrowbody aircraft introduced in the 1980s
and widely used, especially by U.S. airlines.  Boeing's current
generation of narrowbodies includes a successor aircraft, the
B737-900 and B737-900ER, although even the long-range "-ER"
version does not have trans-Atlantic capability.  S&P considers
these planes of average desirability as collateral.  The B757-300,
introduced in 1999 as a derivative of the B757-200, does not
incorporate the most current technology and has a much narrower
user base than the A330s.  The B757-300 had the misfortune of
being introduced two years before the global aviation downturn
that started in 2001, and production was ended in 2004.
Accordingly, S&P considers resale prospects for this plane to
be more limited than for the A330.  The B767-300ER is a small
widebody introduced in the 1980s.  This plane has a fairly wide
user base and is well suited to flying routes that cannot support
larger models.  It will eventually be superseded by the new B787.
The MD90-30 is the least attractive of the aircraft types due to
its age (1990s production), small user base, and fuel efficiency
that is somewhat less than that in the current generation of B737s
and A320 family.  Since all of the models of aircraft represented
in the collateral form significant parts of Delta's current fleet,
S&P believes that most are likely to remain part of Delta's fleet
if the airline enters bankruptcy a second time and reorganizes.
Since Delta has no new aircraft on order, S&P would expect most of
the other model types to remain in the fleet.  Indeed, Delta is
actively looking for more MD90s to replace its aging DC9s.

S&P's analysis of the aircraft collateral, which focuses mainly on
resale liquidity and technological risk, also considers the age of
the aircraft, as well as the characteristics of the models.  S&P
judged that the 10-year-old B737-800 aircraft would exhibit
somewhat greater potential volatility of values than the new
delivery B737-800s in an airline industry downturn, and factored
that into S&P's conclusions.

The initial loan-to-value of the class B certificates is 70.3%%
using the appraised base values and depreciation assumptions in
the offering memorandum.  However, S&P focused on more-
conservative maintenance-adjusted current market values (not
disclosed in the offering memorandum) for the B767-300ER, B757-
200ER, B757-300, and MD90-30 aircraft, and more-conservative
maintenance-adjusted base values for the B737-800 and B737-700,
B777-200LR, A330-200 and A330-300, and A320-200 aircraft.  S&P
also use more-conservative depreciation assumptions for all of the
planes than those in the prospectus.  S&P assumed that, absent
cyclical fluctuations, the values of the B737-800s and B737-700s
would decline by 5% of the preceding year's value per year; the
A320s, 6%; the A330-200s and A330-300s, 6.5%; the B757-200ERs,
B767-300ERs, and B777-200LRs, 7%; the B757-300s, 8%; and the MD90-
30s, 10%.  Using these values and assumptions, the class B initial
LTV is higher, 70.3%--its peak, before declining gradually.  S&P's
analysis also considered that a full draw of the liquidity
facility, plus interest on those draws, represents a claim senior
to the certificates.  However this amount is, because of current
low interest rates, somewhat below levels (as a percent of asset
value) of EETCs of the past several years.  Initially, a full
draw, with interest, is equivalent to about 6.6% of asset value
using S&P's assumptions.

S&P's ratings on Atlanta, Ga.-based Delta Air Lines Inc. reflect a
highly leveraged financial profile, with significant intermediate-
term debt maturities, and risks associated with participation in
the price-competitive, cyclical, and capital-intensive airline
industry.  Ratings also incorporate the reduced debt load and
operating costs Delta achieved while in Chapter 11 in 2005-2007,
and an enhanced competitive position and synergy opportunities
associated with its 2008 merger with Northwest Airlines Corp.
(parent of Northwest Airlines Inc.), with the two airlines fully
integrated in December 2009.  S&P characterizes Delta's business
risk profile as weak and its financial risk profile as highly
leveraged.

S&P's outlook on Delta is stable.  S&P doesn't expect to make any
rating revisions over the next year.  However, if continued strong
earnings, coupled with debt reduction, generate adjusted funds
flow to debt in the high-teen percent area, S&P could raise its
ratings.  On the other hand, if adverse industry conditions (for
example, a serious fuel price spike) cause financial results to
deteriorate so that funds flow to debt falls into the mid-single-
digit percent area, or unrestricted liquidity falls below
$3.5 billion on a sustained basis, S&P could lower ratings.

                           Ratings List

                        Delta Air Lines Inc.

        Corporate credit rating                B/Stable/--

                            New Rating

                        Delta Air Lines Inc.

           Pass-thru cert series 2010-2B         BB (sf)


DRYDEN VII-LEVERAGED: Moody's Upgrades Ratings on Four Notes
------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Dryden VII-Leveraged Loan CDO
2004:

  -- US$26,000,000 Class A-2L Floating Rate Notes, Upgraded to Aa1
     (sf); previously on August 26, 2010 Upgraded to Aa3 (sf)

  -- US$22,000,000 Class A-3F Fixed Rate Notes, Upgraded to A3
     (sf); previously on August 26, 2010 Upgraded to Baa3 (sf)

  -- US$22,000,000 Class B-1L Floating Rate Notes, Upgraded to Ba2
     (sf); previously on August 26, 2010 Upgraded to B3 (sf)

  -- US$7,500,000 Class B-2L Floating Rate Notes, Upgraded to B3
     (sf); previously on August 26, 2010 Upgraded to Caa3 (sf)

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from the delevering of the Senior Class A notes (Class
A1L, Class A1LA, and Class A1LB notes), which have been paid down
by approximately 24% or $49.7 million since the last rating action
in August 2010.  As a result of the delevering, the
overcollateralization ratios have increased since August 2010.  As
of the latest trustee report dated January 7, 2011, the Senior
Class A, Class A, Class B-1L, and Class B-2L overcollateralization
ratios are reported at 143.6%, 128.4%, 116.1%, and 112.4%,
respectively, versus August 2010 levels of 134.1%, 122.6%, 113.0%,
and 110.0%, respectively.  Moody's notes that the credit profile
of the underlying portfolio has been relatively stable since the
last rating action.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" and "Annual Sector Review (2009): Global CLOs," key
model inputs used by Moody's in its analysis, such as par,
weighted average rating factor, diversity score, and weighted
average recovery rate, may be different from the trustee's
reported numbers.  In its base case, Moody's analyzed the
underlying collateral pool to have a performing par and principal
proceeds balance of $266.6 million, defaulted par of $4.3 million,
a weighted average default probability of 23.95% (implying a WARF
of 3779), a weighted average recovery rate upon default of 41.0%,
and a diversity score of 49.  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.

Dryden VII-Leveraged Loan CDO 2004, issued in July 2004, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

In addition to the base case analysis, Moody's also performed
sensitivity analyses to test the impact on all rated notes of
various default probabilities.  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 loss), assuming
that all other factors are held equal:

Moody's Adjusted WARF -20% (3023)

  -- Class A1L: 0
  -- Class A1LA: 0
  -- Class A1LB: 0
  -- Class A2L: +1
  -- Class A3F: +2
  -- Class B1L: +2
  -- Class B2L: +3

Moody's Adjusted WARF +20% (4535)

  -- Class A1L: 0
  -- Class A1LA: 0
  -- Class A1LB: 0
  -- Class A2L: -2
  -- Class A3F: -2
  -- Class B1L: -1
  -- Class B2L: -3

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 manager's
investment strategy 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:

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 deal's
   overcollateralization levels.  Further, the timing of
   recoveries and the manager's decision to work out versus sell
   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.


FAIRWAY LOAN: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1L, A-1LV, A-2L, and B-1L notes from Fairway Loan Funding Co.,
a collateralized loan obligation transaction managed by Pacific
Investment Management Co. LLC.  At the same time, S&P removed its
ratings on the class A-2L and A-3L notes from CreditWatch, where
S&P placed them with positive implications on Nov. 8, 2010.  S&P
also affirmed its ratings on the class X, A-3L, B-2L, and C-6
notes, and withdrew its ratings on the class C-2 and C-5 notes.

The upgrades of the class A-1L, A-1LV, A-2L, and B-1L notes
reflect improved performance S&P has observed in the deal's
underlying asset portfolio since S&P's Dec. 8, 2009, rating
action, when S&P downgraded the A-1L, A-1LV, A-2L, A-3L, B-1L, and
B-2L notes following the application of its September 2009
corporate CDO criteria.  As of the January 2011 trustee report,
the transaction had $3.7 million of defaulted assets.  This was
down from $53.8 million as reflected in the October 2009 trustee
report, which S&P referenced for its December 2009 rating actions.
The affirmations of the class X, A-3L, and B-2L notes reflects the
availability of credit support at the current rating level.  The
affirmation of its 'AAA (sf)' rating on the class C-6 notes
reflects the principal protection on the notes by U.S. Treasury
collateral.  Additionally, S&P withdrew its ratings on the class
C-2 and C-5 note balances as they had paid down to zero.

The transaction has also benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratio in the January 2011 monthly
report

* The senior class A O/C ratio was 122.42%, compared with a
  reported ratio of 120.31% in October 2009;

* The class A O/C ratio was 113.50%, compared with a reported
  ratio of 111.60% in October 2009;

* The class B-1L O/C ratio was 108.35%, compared with a reported
  ratio of 106.57% in October 2009; and

* The class B-2L O/C ratio was 103.61%, compared with a reported
  ratio of 100.28% in October 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

                     Fairway Loan Funding Co.

                         Rating
                         ------
              Class  To          From
              -----  --          ----
              X      AAA (sf)    AAA (sf)
              A-1L   AAA (sf)    AA+ (sf)
              A-1LV  AAA (sf)    AA+ (sf)
              A-2L   AA+ (sf)    A+ (sf)/Watch Pos
              A-3L   BBB+ (sf)   BBB+ (sf)/Watch Pos
              B-1L   B+ (sf)     CCC+  (sf)
              B-2L   CCC-  (sf)  CCC- (sf)
              C-2    NR          AAA (sf)
              C-5    NR          AAA (sf)
              C-6    AAA  (sf)   AAA (sf)

                         NR - Not rated.

  Transaction Information
  -----------------------
Issuer:              Fairway Loan Funding Co.
Coissuer:            Fairway Loan Funding (Delaware) Corp.
Collateral manager:  Pacific Investment Management Co. LLC
Underwriter:         Bear Stearns Cos.  LLC (The)
Trustee:             Bank of New York Mellon (The)
Transaction type:    Cash flow CLO


FIRST UNION-LEHMAN: S&P Raises Ratings on 1997-C2 Securities
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
F and G certificates of commercial mortgage-backed securities from
First Union-Lehman Bros. Trust's series 1997-C2.  Concurrently,
S&P lowered its rating to 'CCC+ (sf)' on the class J certificates
and affirmed its ratings on three other classes from the same
transaction.

The upgrades reflect increased credit enhancement levels resulting
from principal paydowns to the trust, as well as S&P's analysis of
the remaining collateral in the pool and the transaction
structure.  The downgrade to 'CCC+ (sf)' on the class J reflects
the reduced liquidity support available to this class, and the
potential for future shortfalls.  Finally, the affirmations follow
S&P's analysis of the remaining collateral in the pool and the
transaction structure.

S&P's analysis included a review of the credit characteristics of
all of the loans in the transaction.  Using servicer-provided
financial information, Standard & Poor's calculated an adjusted
debt service coverage of 1.16x and an adjusted loan-to-value ratio
of 70.2%.  S&P further stressed the loans' cash flows under S&P's
'AAA' scenario to yield a weighted average DSC of 0.85x and an LTV
ratio of 77.8%.  The implied defaults and loss severity under the
'AAA' scenario were 42.4% and 18.6%, respectively.  The DSC and
LTV calculations S&P noted above exclude four defeased loans
($52.9 million, 17.5%), and one ($3.0 million, 1.0%) specially
serviced loan.  S&P separately estimated a loss for the specially
serviced loan and including it in its 'AAA' scenario implied
default and loss figures.  S&P's analysis also considered the
volume of near-term maturing loans with final maturities in 2012
($141.6 million, 46.9%).

                        Transaction Summary

As of the January 2011 remittance report, the aggregate pooled
trust balance was $302.2 million, which represents 13.7% of the
aggregate pooled trust balance at issuance.  There are 80 loans
remaining in the pool, down from 422 at issuance.  Four
($52.9 million, 17.5%) loans are defeased and 42 ($63.5 million,
21.0%) loans are classified as credit tenant lease loans.  The
master servicer, Wells Fargo Commercial Mortgage Servicing,
provided financial information for 87.1% of the nondefeased and
nonCTL loans in the pool, 53.2% of which was full-year 2009, with
the balance reflecting interim 2010 reporting.  S&P calculated a
weighted average DSC of 1.23x for the pool based on the reported
figures.  S&P's adjusted DSC and LTV ratio were 1.16x and 70.2%,
respectively.  S&P's adjusted figures exclude the four defeased
loans, as well as the one ($3.0 million, 1.0%) specially serviced
loan.

Eighteen loans ($68.9 million, 22.8%) are on the master servicer's
watchlist.  Ten loans ($41.0 million, 13.6%) have a reported DSC
of less than 1.10x, and eight of these loans ($38.4 million,
12.7%) have a reported DSC of less than 1.00x.  To date, the
transaction has realized 28 principal losses totaling
$62.4 million.

The transaction benefits from seasoning and also has a significant
amount of fully amortizing loans (27.0% by balance).

                     Specially Serviced Loan

As of the January 2011 remittance report, the Texas Melody loan
($3.0 million, 1.0%) was the sole loan with the special servicer,
CWCapital Asset Management LLC.  The loan is secured by a 262-unit
multifamily property in Dallas, Texas.  The loan was reported as
90-plus-days delinquent.  The reported DSC was 0.78x as of
December 2009.  The loan was originally transferred to the special
servicer on Oct. 21, 2010, due to imminent payment default.
Standard & Poor's anticipates a moderate loss upon the eventual
resolution of this asset.

             Summary of Top 10 Real Estate Exposures

The top 10 exposures secured by real estate have an aggregate
outstanding pooled balance of $152.2 million (50.4%).  Using
servicer-reported numbers, S&P calculated a weighted average DSC
of 1.23x for the top 10 exposures.  S&P's adjusted DSC and LTV
ratio for the top 10 exposures were 1.16x and 75.1%, respectively.
Three of the top 10 exposures appear on the master servicer's
watchlist.  Details regarding these loans are:

The Drury Portfolio #1 loan ($21.2 million, 7.0%) is the third-
largest real estate exposure in the pool and the largest loan on
the master servicer's watchlist.  The loan is secured by five
lodging properties totaling 676 rooms in Missouri and
Indianapolis.  The loan appears on the master servicer's watchlist
due to low DSC.  As of June 2010, the consolidated reported DSC
and occupancy were 0.77X and 67.2%, respectively.  Two of the five
properties are performing poorly.  The poor performance at one of
these two properties is due to a reduction of flights at the St.
Louis airport, while the other property is performing poorly
because of renovations that took several rooms offline.

The Yaohan Plaza Costa Mesa loan ($7.1 million, 2.4%) is the
eighth-largest real estate exposure in the pool and the second-
largest loan on the master servicer's watchlist.  The loan is
secured by a 44,419-sq.-ft. retail property in Costa Mesa, Calif.
The loan appears on the master servicer's watchlist due to past
delinquency issues, however, it is now reported as current.  The
property is 100% occupied by Yaohan USA, with a lease through Aug.
22, 2017.

The Nob Hill Apartments - Madison loan ($5.3 million, 1.7%) is the
10th-largest real estate exposure in the pool and the third-
largest loan on the master servicer's watchlist.  The loan is
secured by a 272-unit multifamily property in Madison, Wis.  The
loan appears on the master servicer's watchlist due deferred
maintenance.  As of September 2010, reported DSC and property
occupancy were 1.58x and 83.5%, respectively.

Standard & Poor's stressed the assets in the pool according to its
criteria and the analysis is consistent with its rating actions

                          Ratings Raised

                 First Union-Lehman Brothers Trust
   Commercial mortgage pass-through certificates series 1997-C2

                Rating
                ------
        Class  To      From         Credit enhancement (%)
        -----  --      ----         ----------------------
        F      AA(sf)  A  (sf)                       37.69
        G      A (sf)  BBB+ (sf)                     21.28

                          Rating Lowered

                 First Union-Lehman Brothers Trust
   Commercial mortgage pass-through certificates series 1997-C2

                Rating
                ------
        Class  To      From         Credit enhancement (%)
        -----  --      ----         ----------------------
        J      CCC+ (sf) B- (sf)                      1.23

                         Ratings Affirmed

                 First Union-Lehman Brothers Trust
   Commercial mortgage pass-through certificates series 1997-C2

           Class  Rating        Credit enhancement (%)
           -----  ------        ----------------------
           D      AAA (sf)                       70.50
           E      AAA (sf)                       59.56
           H      BB+ (sf)                       15.81


FM LEVERAGED: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, C, D, and E notes from FM Leveraged Capital Fund II, a
collateralized loan obligation transaction managed by GSO Capital
Partners L.P.  At the same time, S&P removed its ratings on the
class B, C, and D notes from CreditWatch, where S&P placed them
with positive implications on Nov. 8, 2010.  S&P also affirmed its
'AAA' (sf) rating on the class A-1 notes.

The upgrades mainly reflect an improvement in the credit quality
available to support the notes since S&P downgraded most of the
rated notes on Dec. 29, 2009, following the initial application
of its updated corporate collateralized debt obligation criteria,
as well as deterioration in the credit quality of certain CLO
tranches due to increased exposure to obligors that have either
defaulted or experienced downgrades into the 'CCC' range.  As
of the Dec. 20, 2010 trustee report, the transaction had
$19.96 million in defaulted assets.  This was down from
$47.75 million noted in the Nov. 6, 2009 trustee report, which
S&P referenced for S&P's December 2009 rating actions.

The transaction has also benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratios in the Dec. 20, 2010 monthly
report:

* The class A/B O/C ratio was 146.19%, compared with a reported
  ratio of 130.47% in November 2009;

* The class C O/C ratio was 124.81%, compared with a reported
  ratio of 115.73% in November 2009;

* The class D O/C ratio was 114.02%, compared with a reported
  ratio of 107.84% in November 2009; and

* The class E O/C ratio was 105.71%, compared with a reported
  ratio of 1.55% 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

                   FM Leveraged Capital Fund II

                         Rating
                         ------
            Class     To          From
            -----     --          ----
            A-2       AAA (sf)    AA+ (sf)
            B         AA+ (sf)    AA (sf)/Watch Pos
            C         A+ (sf)     BBB+ (sf)/Watch Pos
            D         BBB (sf)    BB+ (sf) /Watch Pos
            E         B+ (sf)     CCC+ (sf)

                          Rating Affirmed

                   FM Leveraged Capital Fund II

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

Transaction Information
-----------------------
Issuer:              FM Leveraged Capital Fund II
Coissuer:            FM Leveraged Capital Fund II LLC
Collateral manager:  GSO Capital Partners L.P.
Underwriter:         Wachovia Capital Markets LLC
Trustee:             U.S. Bank N.A.
Transaction type:    Cash flow CLO


FORD CREDIT: Fitch Takes Rating Actions on Various Classes
----------------------------------------------------------
Fitch Ratings affirms 17 and upgrades 10 classes of five Ford
Credit Auto Owner Trust transactions, as part of its on going
surveillance process.

The affirmations and upgrades are a result of continued available
credit enhancement in excess of stressed remaining losses.
Further, the upgraded subordinate notes reflect Fitch's view on
the transaction's improving loss performance.  The collateral in
each transaction continues to perform within Fitch's base case
expectations.  Currently, the securities can withstand stress
scenarios consistent with the current rating categories and still
make full payments of interest and principal in accordance with
the terms of the documents.

As before, the ratings reflect the quality of Ford Motor Credit
Co.'s retail auto loan originations, the sound financial and legal
structure of the transactions, and servicing provided by FMCC.

The rating actions are:

2007-A

  -- Class A-4a notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-4b notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class B notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class C notes upgraded to 'AAAsf' from 'AAsf'; Outlook Stable
     from Positive;

  -- Class D notes upgraded to 'Asf' from 'BBBsf'; Outlook Stable
     from Positive.

2007-B

  -- Class A-3a notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-3b notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-4a notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-4b notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class B notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class C notes upgraded to 'AAA' from 'AA'; Outlook Stable
     from Positive;

  -- Class D notes upgraded to 'AAsf' from 'Asf'; Outlook Stable
     from Positive.

2008-B

  -- Class A-3a notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-3b notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-4a notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-4b notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class B notes upgraded to 'AAAsf' from 'AAsf'; Outlook Stable
     from Positive;

  -- Class C notes upgraded to 'AAsf' from 'Asf'; Outlook
     Positive;

  -- Class D notes upgraded to 'Asf' from 'BBsf'; Outlook Stable
     from Positive.

2008-C

  -- Class A-3 notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-4a notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class A-4b notes affirmed at 'AAAsf'; Outlook Stable;

  -- Class B notes upgraded to 'AAAsf' from 'AAsf'; Outlook
     revised to Stable from Positive;

  -- Class C notes upgraded to 'AAsf' from 'Asf'; Outlook
     Positive;

  -- Class D notes upgraded to 'Asf' from 'BBsf'; Outlook Stable
     from Positive.

2009-B

  -- Class A-3 notes affirmed at 'AAAsf'; Outlook Stable;
  -- Class A-4 notes affirmed at 'AAAsf'; Outlook Stable.


FORD MOTOR: S&P Raises Ratings on Eight Transactions to 'B+'
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on eight
Ford Motor Co.-related transactions to 'B+' from 'B'.

All of the transactions are pass-through structures.  The ratings
on each of them are dependent on the ratings on one of these
underlying securities (see the ratings list for more detailed
information): Ford Motor Co.'s 7.45% debentures due July 16, 2031
('B+'); Ford Motor Co.'s 7.7% debentures due May 15, 2097 ('B+');
and Ford Motor Co.'s 7.4% debentures due Nov. 1, 2046 ('B+').

The upgrades follow S&P's Feb. 1, 2011, raising of its ratings on
the three underlying securities to 'B+' from 'B'.  S&P may take
subsequent rating actions on these transactions due to changes in
its ratings assigned to the underlying securities.

                          Ratings Raised

        Corporate Backed Trust Certificates Ford Motor Co
              Debenture-Backed  Series 2001-36 Trust
  US$58.501 million pass-through series 2001-36 due May 15, 2097
      (underlying security: Ford Motor Co.'s 7.7% debentures
                         due May 15, 2097)

                                     Rating
                                     ------
           Class              To                  From
           -----              --                  ----
           A1                 B+                  B

                  CorTS Trust For Ford Debentures
         US$300 million 7.4% pass-through due Nov. 1, 2046
      (underlying security: Ford Motor Co.'s 7.4% debentures
                         due Nov. 1, 2046)

                                     Rating
                                     ------
           Class              To                  From
           -----              --                  ----
           Certs              B+                  B

                   CorTS Trust II For Ford Notes
US$219.584 million 8% pass-through series 2003-3 due July 16, 2031
     (underlying security: Ford Motor Co.'s 7.45% debentures
                         due July 16, 2031)

                                     Rating
                                     ------
           Class              To                  From
           -----              --                  ----
           Certs              B+                  B

                     PPLUS Trust Series FMC-1
  US$40 million 8.25% pass-through series FMC-1 due July 16, 2031
      (underlying security: Ford Motor Co.'s 7.45% debentures
                        due July 16, 2031)

                                     Rating
                                     ------
           Class              To                  From
           -----              --                  ----
           Certs              B+                  B

                 PreferredPlus Trust Series FRD-1
          US$50 million trust certificates series FRD-1
      (underlying security: Ford Motor Co.'s 7.4% debentures
                         due Nov. 1, 2046)

                                     Rating
                                     ------
           Class              To                  From
           -----              --                  ----
           Certs              B+                  B

               Public STEERS Series 1998 F-Z4 Trust
US$231.903 million pass-through series 1998 F-Z4 due Nov. 15, 2018
      (underlying security: Ford Motor Co.'s 7.7% debentures
                         due May 15, 2097)

                                     Rating
                                     ------
           Class              To                  From
           -----              --                  ----
           A                  B+ (sf)             B (sf)
           B                  B+ (sf)             B (sf)

                     SATURNS Trust No. 2003-5
       US$75.027 million 8.125% pass-through series 2003-5
                        due July 16, 2031
     (underlying security: Ford Motor Co.'s 7.45% debentures
                        due July 16, 2031)

                                     Rating
                                     ------
           Class              To                  From
           -----              --                  ----
           Units              B+                  B

          Trust Certificates (TRUCs) Series 2002-1 Trust
  US$32 million 7.7% pass-through series 2002-1 due May 15, 2097
      (underlying security: Ford Motor Co.'s 7.7% debentures
                         due May 15, 2097)

                                     Rating
                                     ------
           Class              To                  From
           -----              --                  ----
           A-1                B+                  B


FOREST CREEK: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1LB, A-2L, A-3L, A-4L, and B-1L notes from Forest Creek CLO Ltd,
a collateralized loan obligation transaction managed by Deerfield
Capital Management LLC.  At the same time, S&P removed its ratings
on the class A-1LB, A-2L, A-3L, and A-4L notes from CreditWatch,
where S&P placed them with positive implications on Nov. 8, 2010.
S&P also affirmed its ratings on the class A-1LA and B-2L notes.

The upgrades reflect improved performance S&P has observed in
the deal's underlying asset portfolio since its March 4, 2010
rating action, when S&P downgraded most of the rated notes
following the application of its September 2009 corporate CDO
criteria.  As of the Jan. 3, 2011 trustee report, the transaction
had $9.44 million of defaulted assets, and $15.00 million in
assets from obligors with ratings in the 'CCC' range.  This was
down from $18.58 million in defaults and $21.83 million in assets
from obligors with ratings in the 'CCC' range noted in the
Nov. 30, 2009 trustee report, which S&P referenced for its March
2010 rating actions.  In addition, the principal was paid down on
the class A-1LA notes from $110.48 million in November 2009 to
$43.07 million in January 2011, while the class A-1LB notes
principal was paid down from $69.79 million to $32.65 million
during the same period.  The affirmations of the class A-1LA and
B-2L notes reflect its opinion of the availability of sufficient
credit support at the current rating levels.

The transaction has benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratios in the Jan. 3, 2011 monthly
report:

* The senior class A O/C ratio was 135.82%, compared with a
  reported ratio of 114.98% in November 2009;

* The class A O/C ratio was 116.87%, compared with a reported
  ratio of 104.83% in November 2009;

* The class B-1L O/C ratio was 103.27%, compared with a reported
  ratio of 96.76% in November 2009; and

* The class B-2L O/C ratio was 98.18%, compared with a reported
  ratio of 93.81% 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

                      Forest Creek CLO Ltd.

                          Rating
                          ------
            Class     To           From
            -----     --           ----
            A-1LB     AAA (sf)     AA+ (sf)/Watch Pos
            A-2L      AAA (sf)     AA+ (sf)/Watch Pos
            A-3L      AAA (sf)     AA (sf)/Watch Pos
            A-4L      AA- (sf)     BBB+ (sf)/Watch Pos
            B-1L      CCC+ (sf)    CCC- (sf)

                        Ratings Affirmed

                      Forest Creek CLO Ltd.

                Class                    Rating
                -----                    ------
                A-1LA                    AAA (sf)
                B-2L                     CCC- (sf)


FOUR CORNERS: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B, C, and D from Four Corners CLO III Ltd., a cash flow
collateralized loan obligation transaction managed by Four Corners
Capital Management LLC, and removed its rating on the class B note
from CreditWatch with positive implications.  S&P also affirmed
its ratings on the class A and E notes.

In its most recent monthly report as of January 2011, the trustee
calculated the class A/B, C, D, and E overcollateralization ratios
to be 121.92%, 111.71%, 107.24%, and 102.83%, respectively.  The
corresponding O/C ratios were 116.09%, 107.67%, 103.9%, and
100.16%, respectively, as per the November 2009 trustee report,
which S&P used for its analysis when S&P downgraded the classes in
December 2009.

The improved O/C ratios reflect a decline in both the class A note
balance and the level of defaults in the transaction's underlying
asset portfolio.  As of January 2011, the class A note balance
was $188.198 million (81.68% of its original balance), down
from $221.137 million in November 2009 (95.98% of its original
balance).  In addition, the trustee reports in the January 2011
report $1 million in par defaults, which is down from
$13.8 million reported in November 2009.

The transaction has also benefited from an improvement in the
credit quality of the underlying collateral.  The trustee
calculated $7.05 million of assets in the pool to be rated
'CCC+' or below (excluding defaulted obligations), down from
$21.71 million in November 2009.

The transaction is currently passing its class E O/C ratio and
interest diversion test, which were both failing in November 2009.
The interest diversion test is measured in the interest proceeds
section of the payment priorities waterfall; if the test is
breached during the reinvestment period (ending October 2012),
the cure amount (restricted to 50% of available interest proceeds)
is diverted toward reinvestment.  If the test fails after the
reinvestment period, the cure amount is diverted to pay down the
class E notes.

As a result of the factors listed above, S&P raised its ratings on
the class B, C, and D notes.  S&P affirmed its ratings on the
class A and E notes to reflect the classes' adequate credit
support at their current rating 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

                     Four Corners CLO III Ltd.

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

                         Ratings Affirmed

                     Four Corners CLO III Ltd.

                    Class                Rating
                    -----                ------
                    A                    AA+
                    E                    CCC-


G-FORCE 2005-RR2: Fitch Downgrades Ratings on 14 Classes of Notes
-----------------------------------------------------------------
Fitch Ratings has downgraded 14 and affirmed two classes issued by
G-Force 2005-RR2, LLC as a result of negative credit migration of
the commercial mortgage back securities collateral.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model for projecting future default levels
for the underlying portfolio.  The Rating Loss Rates were then
compared to the credit enhancement of the classes.  Based on this
analysis, the credit enhancement for classes A-2 and A-3FL are
inconsistent with the current ratings and are downgraded as
indicated below.  In addition to the stated criteria, Fitch
analyzed the structure's sensitivity to refinance risk on the
underlying CMBS loans.

Since Fitch's last rating action in February 2010, approximately
59.9% of the portfolio has been downgraded.  Currently, 87.7% has
a Fitch derived rating below investment grade and 51.7% has a
rating in the 'CCC' rating category or lower, compared to 81.4%
and 25.1%, respectively, at last review.  The class A-2 notes have
paid down by $21.7 million since the last review.

The Negative Outlook on the class A-2 and A-3FL notes reflects
Fitch's expectation that underlying CMBS loans will continue to
face refinance risk.  The Loss Severity rating indicates a
tranche's potential loss severity given default, as evidenced by
the ratio of tranche size to the base-case loss expectation for
the collateral, as explained in 'Criteria for Structured Finance
Loss Severity Ratings'.  The LS rating should always be considered
in conjunction with the probability of default for tranches.
Fitch does not assign LS ratings or Outlooks to classes rated
'CCC' and below.

Fitch has downgraded classes A-4 through D and affirmed classes E
and F, given that these classes are reliant on distressed assets
('CC' and below) for repayment.  Since the last review, classes H
through N have realized a complete loss and class G has
experienced a partial loss, due to principal losses on the
underlying collateral.  As a result, Fitch has downgraded these
classes to 'Dsf'.

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

G-Force 2005-RR2 is a CMBS Resecuritization issued in August 2005.
The transaction is currently collateralized by 105 CMBS assets
from 23 obligors from the 1998-2002 vintages.  The collateral is
primarily composed of CMBS B-Piece resecuritizations which are CRE
CDOs and ReRemic transactions that include the most junior bonds
of CMBS transactions.

Fitch has taken these actions as indicated:

  -- $100,035,535 class A-2 downgraded to 'AAsf/LS5' from
     'AAAsf/LS5'; Outlook Negative

  -- $250,000,000 class A-3FL downgraded to 'Bsf/LS4' from 'BBB-sf
     /LS4'; Outlook Negative;

  -- $50,000,000 class A-4A downgraded to 'CCsf' from 'B/LS5';

  -- $58,446,000 class A-4B downgraded to 'CCsf' from 'B/LS5';

  -- $64,860,000 class B downgraded to 'Csf' from 'B/LS5';

  -- $47,397,000 class C downgraded to 'Csf' from 'CCCsf';

  -- $17,462,000 class D downgraded to 'Csf' from 'CCsf';

  -- $21,204,000 class E affirmed at 'Csf';

  -- $23,698,000 class F affirmed at 'Csf';

  -- $31,182,000 class G downgraded to 'Dsf' from 'Csf';

  -- $19,957,000 class H downgraded to 'Dsf' from 'Csf';

  -- $12,473,000 class J downgraded to 'Dsf' from 'Csf';

  -- $11,226,000 class K downgraded to 'Dsf' from 'Csf';

  -- $12,472,000 class L downgraded to 'Dsf' from 'Csf';

  -- $11,226,000 class M downgraded to 'Dsf' from 'Csf';

  -- $9,978,000 class N downgraded to 'Dsf' from 'Csf';

  -- Interest-only, class X withdrawn.


GMAC 2004-C2: Moody's Reviews Ratings on Nine 2004-C2 Certs.
------------------------------------------------------------
Moody's Investors Service placed nine classes of GMAC 2004-C2,
Commercial Mortgage Securities, Inc., Commercial Mortgage Pass-
Through Certificates, Series 2004-C2 on review for possible
downgrade:

  -- Cl. B Certificate, Aa1 (sf) Placed Under Review for Possible
     Downgrade; previously on March 27, 2007 Upgraded to Aa1 (sf)

  -- Cl C Certificate, Aa3 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 11, 2010 Downgraded to Aa3 (sf)

  -- Cl. D Certificate, A3 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 11, 2010 Downgraded to A3 (sf)

  -- Cl. E Certificate, Baa2 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 11, 2010 Downgraded to Baa2
     (sf)

  -- Cl. F Certificate, Ba1 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 11, 2010 Downgraded to Ba1 (sf)

  -- Cl. G Certificate, B2 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 11, 2010 Downgraded to B2 (sf)

  -- Cl. H Certificate, Caa2 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 11, 2010 Downgraded to Caa2
     (sf)

  -- Cl. J Certificate, Caa3 (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 11, 2010 Downgraded to Caa3
     (sf)

  -- Cl. K Certificate, Ca (sf) Placed Under Review for Possible
     Downgrade; previously on Feb. 11, 2010 Downgraded to Ca (sf)

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated February 11, 2010.

                   Deal And Performance Summary

As of the January 10, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 17% to
$773.4 million from $933.7 million at securitization.  The
Certificates are collateralized by 64 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 52% of the pool.  Six loans, representing 26% of the
pool, have defeased and are collateralized by U.S. Government
securities.  Defeasance at last review represented 16% of the
pool.  The pool also contains three loans, representing 25% of the
pool, with investment grade credit estimates.

Ten loans, representing 9% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Four loans have been liquidated from the pool since
securitization, resulting in an aggregate $4.6 million loss (19%
loss severity on average).  Currently seven loans, representing
18% of the pool, are in special servicing.  The seven specially
serviced loans are secured by a mix of property types.  The master
servicer has recognized an aggregate $33 million appraisal
reduction for the specially serviced loans.  At last review the
pool contained 5 specially serviced loans, representing 8% of the
pool.

Based on the most recent remittance statement, Classes L through P
have experienced interest shortfalls totaling $1.6 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.


GRANITE VENTURES: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, and C notes from Granite Ventures II Ltd., a
collateralized loan obligation transaction managed by Stone Tower
Debt Advisors LLC.  At the same time, S&P removed the ratings from
CreditWatch, where S&P placed them with positive implications on
Nov. 8, 2010.  S&P also affirmed its 'CCC+ (sf)' rating on the
class D notes.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio and a paydown to the balance of
the class A-1 notes.  As of the Dec. 6, 2010, trustee report, the
transaction had $2.62 million in defaulted assets.  This was down
from $3.55 million noted in the Oct. 5, 2009, trustee report,
which S&P referenced for its November 2009 rating actions.
Additionally, the class A-1 note balance has been paid down to
$203.175 million from $273.00 million over the same period of
time.

The transaction has also benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratios in the Dec. 6, 2010, monthly
report:

* The class A O/C ratio was 122.12%, compared with a reported
  ratio of 116.28% in October 2009;

* The class B O/C ratio was 112.89%, compared with a reported
  ratio of 109.49% in October 2009;

* The class C O/C ratio was 106.20%, compared with a reported
  ratio of 104.40% in October 2009; and

* The class D O/C ratio was 103.74%, compared with a reported
  ratio of 102.50% in October 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

                     Granite Ventures II Ltd.

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

                          Rating Affirmed

                     Granite Ventures II Ltd.

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

Transaction Information
-----------------------
Issuer:              Granite Ventures II Ltd.
Collateral manager:  Stone Tower Debt Advisors LLC
Underwriter:         Citigroup Global Markets Inc.
Trustee:             U.S. Bank N.A.
Transaction type:    Cash flow CLO


GREENWICH CAPITAL: Moody's Downgrades Ratings on 2003-C2 Certs.
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes
and affirmed 11 classes of Greenwich Capital Commercial Funding
Corp., Commercial Mortgage Pass-Through Certificates, Series 2003-
C2:

  -- Cl. A-3 Certificate, Affirmed at Aaa (sf); previously on
     Jan. 14, 2004 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4 Certificate, Affirmed at Aaa (sf); previously on
     Jan. 14, 2004 Definitive Rating Assigned Aaa (sf)

  -- Cl. XC Certificate, Affirmed at Aaa (sf); previously on
     Jan. 14, 2004 Definitive Rating Assigned Aaa (sf)

  -- Cl. B Certificate, Affirmed at Aaa (sf); previously on
     Aug. 17, 2006 Upgraded to Aaa (sf)

  -- Cl. C Certificate, Affirmed at Aaa (sf); previously on
     July 23, 2007 Upgraded to Aaa (sf)

  -- Cl. D Certificate, Affirmed at Aa1 (sf); previously on
     Sept. 25, 2008 Upgraded to Aa1 (sf)

  -- Cl. E Certificate, Affirmed at Aa3 (sf); previously on
     July 23, 2007 Upgraded to Aa3 (sf)

  -- Cl. F Certificate, Affirmed at A2 (sf); previously on
     July 23, 2007 Upgraded to A2 (sf)

  -- Cl. G Certificate, Affirmed at Baa1 (sf); previously on
     July 23, 2007 Upgraded to Baa1 (sf)

  -- Cl. H Certificate, Affirmed at Baa3 (sf); previously on
     Dec. 3, 2009 Confirmed at Baa3 (sf)

  -- Cl. J Certificate, Affirmed at Ba1 (sf); previously on
     Dec. 3, 2009 Confirmed at Ba1 (sf)

  -- Cl. K Certificate, Downgraded to B1 (sf); previously on
     Dec. 3, 2009 Downgraded to Ba3 (sf)

  -- Cl. L Certificate, Downgraded to B3 (sf); previously on
     Dec. 3, 2009 Downgraded to B2 (sf)

  -- Cl. M Certificate, Downgraded to Caa2 (sf); previously on
     Dec. 3, 2009 Downgraded to Caa1 (sf)

  -- Cl. N Certificate, Downgraded to Ca (sf); previously on
     Dec. 3, 2009 Downgraded to Caa3 (sf)

  -- Cl. O Certificate, Downgraded to C (sf); previously on
     Dec. 3, 2009 Downgraded to Ca (sf)

                        Ratings Rationale

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

Moody's rating action reflects a cumulative base expected loss of
4.2% of the current balance.  At last review, Moody's cumulative
base expected loss was 3.5%.  Moody's stressed scenario loss is
7.0% of the current balance.

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

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

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

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 17, compared to 19 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 December 3, 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 January 7, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 38% to
$1.072 billion from $1.735 billion at securitization.  The
Certificates are collateralized by 63 mortgage loans ranging in
size from less than 1% to 11% of the pool, with the top ten loans
representing 50% of the pool.  There are no loans with investment
grade credit estimates.  Twenty loans representing 23% of the pool
have defeased and are collateralized with U.S. Government
securities.  Defeasance at last review represented 36% of the
pool.

Thirteen loans, representing 24% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Four loans have been liquidated from the pool since
securitization, resulting in an aggregate $18.8 million loss (48%
loss severity on average).  The pool had experienced an aggregate
$4.0 million loss at last review.  Three loans, representing 7% of
the pool, are currently in special servicing.  The largest
specially serviced loan is The Windsor Capital Portfolio Loan
($47.6 million -- 4.4% of the pool), which represents a pari passu
interest in a $95.2 million first mortgage loan.  The loan is
secured by six full service hotel properties located in California
(5) and Michigan (1).  The hotels operate under the Embassy
Suites, Marriot and Radisson.  The loan was transferred to special
servicing in May 2010 due to imminent maturity default.  The
borrower has been granted a loan modification and extension and
the loan is current.  Moody's is not currently estimating a loss
on this loan at this time.

The remaining two specially serviced loans are secured by office
properties.  Moody's has estimated an aggregate $16.5 million loss
(51% expected loss on average) for these two specially serviced
loans.

Moody's was provided with full year 2009 operating results for 99%
of the pool and partial year 2010 for 87% of the pool.  Excluding
specially serviced and troubled loans, Moody's weighted average
LTV is 99% compared to 87% at last review.  Moody's net cash flow
reflects a weighted average haircut of 18.8% to the most recently
available net operating income.  Moody's value reflects a weighted
average capitalization rate of 9.7%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.44X and 1.11X, respectively, compared to
1.64X and 1.26X at last review.  Moody's actual DSCR is based on
Moody's net cash flow and the loan's actual debt service.  Moody's
stressed DSCR is based on Moody's NCF and a 9.25% stressed rate
applied to the loan balance.

The top three performing conduit loans represent 27% of the
pool balance.  The largest loan is the U.S. Bank Tower Loan
($120.2 million -- 11.1% of the pool), which represents a pari
passu interest in a $250 million first mortgage loan.  The loan is
secured by a 1.4 million square foot office tower and accompanying
parking garage in downtown Los Angeles, California.  The loan
sponsor is Maguire Properties (Maguire).  The property was 57%
leased as of September 2010 compared to 88% at last review.  The
largest tenant at securitization, Latham & Watkins (20% of the net
rentable area) vacated the premises at its December 2009 lease
expiration.  Furthermore, the lease for the second largest tenant,
Sempra Energy (16% of the NRA) expired in June 2010.  Even with
the substantial decline in cash flow from the dramatic rise in
vacancy, Moody's projects that the property will still generate
cash flow in excess of debt service.  However, given the softness
in the Los Angeles office market, it is anticipated that new
tenants will be paying lower rents than those currently in place.
In addition, due to Maguire's current financial issues, Moody's is
concerned about the availability of funds for leasing costs.  The
loan is interest-only for the entire term.  The loan is currently
on the master servicer's watch list for high vacancy.  Moody's LTV
and stressed DSCR are 130% and 0.77X, respectively, compared to
103% and 1.01X, at last review.

The second largest loan is the Broadway Mall Loan ($88.0 million -
- 8.1% of the pool), which is secured by the borrower's interest
in a 1.1 million SF regional mall located 27 miles east of New
York City in Hicksville (Nassau County), New York.  The property
was 79% leased as of October 2010, the same as last review.  The
center is anchored by Macy's, IKEA and Target.  Performance has
been stable.  Moody's LTV and stressed DSCR are 91% and 1.10X,
respectively, compared 103% and 0.97X at last review.

The third largest loan is the Pinnacle Building Loan
($86.1 million -- 8.0% of the pool), which is secured by a 393,000
SF Class A office building located in Burbank, California.  The
property was 98% leased as of September 2010, the same as last
review.  The largest tenant is Warner Music Group, which leases
50% of the premises through December 2019.  The loan is interest-
only for the entire term.  Moody's LTV and stressed DSCR are 80%
and 1.25X respectively, compared to 75% and 1.33X at last review.


GREENPOINT MORTGAGE: Moody's Cuts Ratings on 16 2005-AR5 Tranches
-----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 16
tranches from Greenpoint Mortgage Funding Trust 2005-AR5.

                        Ratings Rationale

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

To assess the rating implications of the updated loss levels on
option arm 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.

Complete rating actions are:

Issuer: Greenpoint Mortgage Funding Trust 2005-AR5

  -- Cl. I-A-1, Downgraded to Ca (sf); previously on Jan. 27, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. I-A-2, Downgraded to C (sf); previously on Jan. 27, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. I-X-1, Downgraded to C (sf); previously on Jan. 27, 2010
     Aa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. I-X-2, Downgraded to C (sf); previously on Jan. 27, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. II-A-1, Downgraded to Caa3 (sf); previously on Jan. 27,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. II-A-2, Downgraded to C (sf); previously on April 16,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Underlying Rating: Downgraded to C (sf); previously on
     March 30, 2010 Caa2 (sf) Placed Under Review for Possible
     Downgrade

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

  -- Cl. II-X-1, Downgraded to C (sf); previously on Jan. 27, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. II-X-2, Downgraded to C (sf); previously on Jan. 27, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. II-X-3, Downgraded to C (sf); previously on Jan. 27, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. III-A-1, Downgraded to Ca (sf); previously on Jan. 27,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. III-A-2, Downgraded to C (sf); previously on April 16,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Underlying Rating: Downgraded to C (sf); previously on
     March 30, 2010 Caa2 (sf) Placed Under Review for Possible
     Downgrade

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

  -- Cl. III-X-1, Downgraded to C (sf); previously on Jan. 27,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IV-A-1, Downgraded to Ca (sf); previously on Jan. 27,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IV-A-2, Downgraded to C (sf); previously on Jan. 27, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IV-X-1, Downgraded to C (sf); previously on Jan. 27, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. IV-X-2, Downgraded to C (sf); previously on Jan. 27, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade


GSAA HOME: Moody's Downgrades Ratings on Eight Tranches
-------------------------------------------------------
Moody's Investors Service has downgraded the ratings of eight
tranches from one RMBS transaction, backed by Alt-A loans, issued
by GSAA Home Equity Trust 2005-11.

Issuer: GSAA Home Equity Trust 2005-11

  -- Cl. 1A1, Downgraded to B3 (sf); previously on Jan. 14, 2010
     Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1A2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2A1, Downgraded to B3 (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2A2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ba3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3A1, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3A2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ba3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3A5, Downgraded to Caa3 (sf); previously on Jan. 14, 2010
     Ba3 (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

In the rating action, Class 3-A-4, currently Ba2, remains on
review for downgrade.  There is a conflicting language in the
transaction's documents: According to the Pooling and Servicing
Agreement, after the Subordinate Certificates have been reduced to
zero, principal will be allocated to Classes 3A4 and 3A5
sequentially so long as a Group III Sequential Trigger Event is in
effect.  However, according to the Prospectus Supplement, after
the Subordinate Certificates have been reduced to zero, principal
will be paid pro-rata to Classes 3A4 and 3A5 even if a Group III
Sequential Trigger Event is in effect.  According to the trustee,
Goldman Sachs is in the process of amending one of these
documents.  Moody's will take final action in accordance with the
amended documentation.

                        Ratings Rationale

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

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 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.


ING INVESTMENT: S&P Raises Rating on Class D Notes to BB (sf)
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, C, and D notes from ING Investment Management CLO IV
Ltd., a collateralized loan obligation transaction managed by ING
Alternative Asset Management.  At the same time, S&P removed its
ratings on the class A-1 and A-2 notes from CreditWatch, where S&P
placed them with positive implications on Nov. 8, 2010.

The upgrades mainly reflect an improvement in the credit quality
available to support the notes since S&P downgraded the rated
notes on Oct. 23, 2009, following the initial application of
S&P's updated corporate collateralized debt obligation criteria.
As of the Jan. 12, 2011 trustee report, the transaction had
$4.54 million in defaulted assets.  This was down from
$21.32 million noted in the Sept. 14, 2009, trustee report,
which S&P referenced for S&P's October 2009 rating actions.

The transaction has also benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratios in the Jan. 12, 2011, monthly
report:

* The class A O/C ratio was 120.9%, compared with a reported ratio
  of 119.20% in October 2009;

* The class B O/C ratio was 113.5%, compared with a reported ratio
  of 111.9% in October 2009;

* The class C O/C ratio was 108.00%, compared with a reported
  ratio of 106.40% in October 2009; and

* The class D O/C ratio was 105.20%, compared with a reported
  ratio of 103.7% in October 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

               ING Investment Management CLO IV Ltd.

                           Rating
                           ------
             Class     To          From
             -----     --          ----
             A-1       AA+ (sf)    A+ (sf)/Watch Pos
             A-2       AA (sf)     A+ (sf)/Watch Pos
             B         A (sf)      BBB (sf)
             C         BBB (sf)    BB+ (sf)
             D         BB (sf)     B+ (sf)

Transaction Information
-----------------------
Issuer:              ING Investment Management CLO IV Ltd.
Collateral manager:  ING Alternative Asset Management
Underwriter:         Credit Suisse AG
Trustee:             U.S. Bank N.A.
Transaction type:    Cash flow CLO


ING INVESTMENT: S&P Raises Ratings on Various Classes of Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, C, and D notes from ING Investment Management CLO I
Ltd., a collateralized loan obligation transaction managed by ING
Alternative Asset Management LLC.  S&P removed four of those
ratings from CreditWatch with positive implications.

The upgrades reflect the improved performance S&P has observed in
the transaction's underlying asset portfolio since December 2009.
At that time, S&P lowered the ratings on all of the notes in the
transaction following a review using S&P's updated criteria for
rating corporate collateralized debt obligations.

At the time of S&P's last rating action, ING Investment Management
CLO I Ltd. held approximately $23.8 million in defaulted
obligations and $69.2 million in underlying assets from obligors
with ratings in the 'CCC' range, according to the Oct. 5, 2009
trustee report.  As of the Jan. 3, 2011, trustee report, the
transaction held $2.4 million in defaulted obligations and
$32.0 million in assets from underlying obligors with ratings in
the 'CCC' range.

Since the time of S&P's last rating action, a number of defaulted
obligors held in the deal emerged from bankruptcy, with some
receiving proceeds that were higher than their carrying value in
the transaction's overcollateralization ratio test calculation.
This, in combination with a reduction in assets with ratings in
the 'CCC' range, benefited the transaction's O/C ratio.  As of the
Jan. 3, 2011, the transaction was passing its senior O/C test and
senior interest coverage test with ratios of 119.6% and 901.7%
respectively.

Also, at the time of S&P's last rating action, the class D notes
failed to withstand the specified combination of underlying asset
defaults at the 'B' rating levels of the largest obligor default
test.  The largest obligor default test is no longer a
constraining factor for the rating on the class D notes.

S&P will continue to review its ratings on the notes and assess
whether, in its view, the ratings remain consistent with the
credit enhancement available to support them and take rating
actions as S&P deems necessary.

                  Rating And Creditwatch Actions

               ING Investment Management CLO I Ltd.

                                  Rating
                                  ------
     Class                   To           From
     -----                   --           ----
     A-1                     AAA (sf)     AA (sf)/Watch Pos
     A-2                     AAA (sf)     AA (sf)/Watch Pos
     B                       AA+ (sf)     A- (sf)/Watch Pos
     C                       A+ (sf)      BBB- (sf)/Watch Pos
     D                       BBB+ (sf)    CCC+ (sf)


JP MORGAN: Moody's Affirms Ratings on 22 Series 2004-C3 Certs.
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 22 classes of JP
Morgan Chase Commercial Mortgage Securities Corp. Commercial
Mortgage Pass-Through Certificates, Series 2004-C3:

  -- Cl. A-2, Affirmed at Aaa (sf); previously on Dec. 29, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3, Affirmed at Aaa (sf); previously on Dec. 29, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-4, Affirmed at Aaa (sf); previously on Dec. 29, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-5, Affirmed at Aaa (sf); previously on Dec. 29, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-1A, Affirmed at Aaa (sf); previously on Dec. 29, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-1, Affirmed at Aaa (sf); previously on Dec. 29, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-2, Affirmed at Aaa (sf); previously on Dec. 29, 2004
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-J, Affirmed at Aa3 (sf); previously on March 18, 2010
     Downgraded to Aa3 (sf)

  -- Cl. B, Affirmed at Baa1 (sf); previously on March 18, 2010
     Downgraded to Baa1 (sf)

  -- Cl. C, Affirmed at Baa2 (sf); previously on March 18, 2010
     Downgraded to Baa2 (sf)

  -- Cl. D, Affirmed at Ba1 (sf); previously on March 18, 2010
     Downgraded to Ba1 (sf)

  -- Cl. E, Affirmed at Ba3 (sf); previously on March 18, 2010
     Downgraded to Ba3 (sf)

  -- Cl. F, Affirmed at B3 (sf); previously on March 18, 2010
     Downgraded to B3 (sf)

  -- Cl. G, Affirmed at Caa2 (sf); previously on March 18, 2010
     Downgraded to Caa2 (sf)

  -- Cl. H, Affirmed at Caa3 (sf); previously on March 18, 2010
     Downgraded to Caa3 (sf)

  -- Cl. J, Affirmed at Ca (sf); previously on March 18, 2010
     Downgraded to Ca (sf)

  -- Cl. K, Affirmed at C (sf); previously on March 18, 2010
     Downgraded to C (sf)

  -- Cl. L, Affirmed at C (sf); previously on March 18, 2010
     Downgraded to C (sf)

  -- Cl. M, Affirmed at C (sf); previously on March 18, 2010
     Downgraded to C (sf)

  -- Cl. N, Affirmed at C (sf); previously on March 18, 2010
     Downgraded to C (sf)

  -- Cl. P, Affirmed at C (sf); previously on March 18, 2010
     Downgraded to C (sf)

  -- Cl. Q, Affirmed at C (sf); previously on March 18, 2010
     Downgraded to C (sf)

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
7.1% of the current balance.  At last review, Moody's cumulative
base expected loss was 7.9%.  Moody's stressed scenario loss is
16.6% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

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

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors.  Therefore,
the rating outcome may differ from the model output.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated March 17th, 2010.

                         Deal Performance

As of the January 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 12% to $1.3 billion
from $1.5 billion at securitization.  The Certificates are
collateralized by 131 mortgage loans ranging in size from less
than 1% to 5% of the pool, with the top ten loans representing 25%
of the pool.  Ten loans, representing 13% of the pool, have
defeased and are collateralized with U.S. Government securities.

Thirty-seven 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.

Three loans have been liquidated from the pool, resulting in an
aggregate $8.2 million loss (30% loss severity overall).  At last
review, the pool had experienced an aggregate $4.3 million
realized loss.  Sixteen loans, representing 11% of the pool, are
currently in special servicing.  Moody's has estimated an
aggregate $58.7 million loss (41.6% expected loss on average) for
the specially serviced loans.

Moody's has assumed a high default probability for ten poorly
performing loans representing 4% of the pool and has estimated a
$10.7 million aggregate loss (20% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2009 operating results for 74%
of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 100% compared to 99% at Moody's
prior review.  Moody's net cash flow reflects a weighted average
haircut of 11.6% to the most recently available net operating
income.  Moody's value reflects a weighted average capitalization
rate of 9.0%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.37X and 1.03X, respectively, compared to
1.41X and 1.03X 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 53 compared to 31 at Moody's prior review.

The top three performing conduit loans represent 13% of the pool
balance.  The largest loan is the 345 Park Avenue South Loan
($71.8 million -- 5.4%), which is secured by a 272,000 square foot
Class A office building located in Midtown Manhattan, New York.
The property was 97% leased as of September 2010 which is in line
with last review.  Performance has improved due to increased
rental revenues.  Moody's LTV and stressed DSCR are 103% and
0.92X, respectively, compared to 126% and 0.80X at last review.

The second largest loan is the Crossroads Shopping Center Loan
($61.3 million -- 4.6%), which is secured by a 311,000 square foot
retail center located in White Plains, New York.  The property was
94% leased as of September 2010, similar to last review.  The
largest tenant is A&P Supermarket.  A&P declared bankruptcy in
December 2010 and has announced that there will be store closings.
Moody's valuation reflects a stressed cash flow due to Moody's
concerns about the continued occupancy of A&P.  Moody's LTV and
stressed DSCR are 121% and 0.71X, respectively, compared to 114%
and 0.75X at last review.

The third largest loan is the Broadway Marketplace Loan
($41 million -- 3.1%), which is secured by a 387,000 square foot
retail center located in Denver, Colorado.  The property was 98%
leased as of September 2010, similar to last review Moody's LTV
and stressed DSCR are 102% and 0.91X, respectively, compared to
103% and 0.89X at last review.


JP MORGAN: Moody's Reviews 'B2' Ratings on Class A-2 Tranche
------------------------------------------------------------
Moody's has placed on review for possible downgrade class A-2
tranche from JP Morgan RV Marine Trust 2004-A.  The transaction is
serviced by Vericrest Financial, Inc.  Vericrest Financial, Inc.,
formerly known as CIT Group/Sales Financing, Inc., was acquired by
Lone Star Funds in 2009.

Issuer: JPMorgan RV Marine Trust 2004-A

  -- Cl. A-2, B2 (sf) Placed Under Review for Possible Downgrade;
     previously on June 3, 2009 Downgraded to B2 (sf)

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

  -- Underlying Rating: B2 (sf) Placed Under Review for Possible
     Downgrade; previously on June 3, 2009 Downgraded to B2 (sf)

                        Ratings Rationale

The review was prompted by updated higher loss expectations
relative to current levels of credit enhancement.  Unlike other
vehicle-backed ABS, the impact here has been more severe and long
lasting due to the non-essential nature of the underlying
collateral, and the longer financing terms, which on average range
between 170 and 185 months.  As a result, these transactions have
experienced more than one economic downturn during their lives.

Moody's expects JP Morgan RV Marine Trust 2004-Ato incur lifetime
cumulative net losses in the range of 13.50% to 14.50% of the
original pool balance, compared to expectations of 5.00% at
closing.  Total hard credit enhancement (excluding excess spread
of approximately 3.2% per annum) for class A-2 notes is
approximately 0.32% of the outstanding collateral pool balance.
Pool factor is 9.95% of original pool balance.

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

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


JP MORGAN: Moody's Takes Rating Actions on Series 2003-ML1 Notes
----------------------------------------------------------------
Moody's Investors Service upgraded three and affirmed 12 classes
of J.P. Morgan Chase Commercial Mortgage Securities Corp.,
Commercial Mortgage Pass-Through Certificates, Series 2003-ML1:

  -- Cl. A-1, Affirmed at Aaa (sf); previously on July 24, 2003
     Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2, Affirmed at Aaa (sf); previously on July 24, 2003
     Definitive Rating Assigned Aaa (sf)

  -- Cl. X-1, Affirmed at Aaa (sf); previously on July 24, 2003
     Definitive Rating Assigned Aaa (sf)

  -- Cl. B, Affirmed at Aaa (sf); previously on Jun 29, 2006
     Upgraded to Aaa (sf)

  -- Cl. C, Affirmed at Aaa (sf); previously on July 9, 2007
     Upgraded to Aaa (sf)

  -- Cl. D, Affirmed at Aaa (sf); previously on July 10, 2007
     Upgraded to Aaa (sf)

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

  -- Cl. F, Upgraded to Aa1 (sf); previously on Sept. 25, 2008
     Upgraded to A1 (sf)

  -- Cl. G, Upgraded to A1 (sf); previously on Sept. 25, 2008
     Upgraded to A3 (sf)

  -- Cl. H, Upgraded to Baa2 (sf); previously on July 24, 2003
     Definitive Rating Assigned Ba1 (sf)

  -- Cl. J, Affirmed at Ba2 (sf); previously on July 24, 2003
     Definitive Rating Assigned Ba2 (sf)

  -- Cl. K, Affirmed at Ba3 (sf); previously on July 24, 2003
     Definitive Rating Assigned Ba3 (sf)

  -- Cl. L, Affirmed at B1 (sf); previously on July 24, 2003
     Definitive Rating Assigned B1 (sf)

  -- Cl. M, Affirmed at B2 (sf); previously on July 24, 2003
     Definitive Rating Assigned B2 (sf)

  -- Cl. N, Affirmed at B3 (sf); previously on July 24, 2003
     Definitive Rating Assigned B3 (sf)

                        Ratings Rationale

The upgrades are due to the significant increase in subordination
due to loan payoffs and amortization and overall stable pool
performance.  The pool has paid down by 25% since Moody's last
review.  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
1.6% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.3%.  Moody's stressed scenario loss is
8.2% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 48 compared to 45 at Moody's prior full 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 July 10, 2007.

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

                         Deal Performance

As of the January 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 31% to
$640.3 million from $929.8 million at securitization.  The
Certificates are collateralized by 107 mortgage loans ranging in
size from less than 1% to 7% of the pool, with the top ten loans
representing 28% of the pool.  Seventeen loans, representing 25.0%
of the pool, have defeased and are collateralized with U.S.
Government securities.  One loan, representing 7% of the pool, has
an investment grade credit estimate.

Twenty-five loans, representing 18% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Five loans have been liquidated from the pool since
securitization, resulting in an aggregate $4.8 million loss (23%
loss severity on average).  Currently three loans, representing 3%
of the pool, are in special servicing.  The master servicer has
recognized a $864,905 appraisal reduction for one specially
serviced loan.  Moody's has estimated an aggregate loss of $2.5
million (15% expected loss on average) for all of the specially
serviced loans.

Moody's has assumed a high default probability for one poorly
performing loan representing 0.5% of the pool and has estimated a
$407,042 loss (13% 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 96% and 79%, respectively, of the non-
defeased performing pool.  Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 77% compared to
80% 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 9.4%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.79X and 1.65X, respectively, compared to
1.52X and 1.33X 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.

The loan with a credit estimate is the Hyatt Regency Hotel Loan
Loan ($45.1 million -- 7.0%), which is secured by a 686-room full
service hotel with a 53,000 square feet (SF) of flexible function
space located in Arlington, Virginia.  Despite the overall
downturn in the tourism industry, the hotel's performance only
slightly declined and is performing better than at last full
review.  The loan is amortizing on a 360-month schedule maturing
in January 2013 and has paid down 6% since last full review.
Moody's current credit estimate and stressed DSCR are Aa3 and
2.95X, respectively, compared to A3 and 2.15X at last full review.

The top three performing conduit loans represent 10% of the pool
balance.  The largest conduit loan is the JANAF Shopping Center
Loan ($30.7 million -- 4.8% of the pool), which is secured by a
583,000 SF retail center located in Norfolk, Virginia.  The
collateral comprises a retail center, two office buildings, an out
parcel strip retail building and pad sites.  The largest retail
tenants include Sports Authority (7% of the net rentable area
(NRA); lease expiration August 2016), TJ Maxx (6% of the NRA;
lease expiration January 2014), and Conway (6% of the NRA; lease
expiration May 2012).  The largest non-retail tenant is JANAF,
which leases 6% of the subject's total NRA through April 2020.
Norfolk demographic trends remain weak and thousands of jobs are
at risk due to the pending closure of the U.S. Joint Forces
Command (JFCOM) which may inhibit growth in consumer spending.
Due to slower anticipated recovery in this market, Moody's has
stressed this loan.  The loan is amortizing on a 300-month
schedule maturing in May 2012 and has paid down 8% since last full
review.  Moody's LTV and stressed DSCR are 77% and 1.36X,
respectively, compared to 71% and 1.44X at last review.

The second largest conduit loan is the 4820 Overland Avenue Loan
($17.7 million -- 2.8% of the pool), which is secured by a two-
story office building and a single-story R&D building totaling
158,585 SF located in Kearny Mesa, California.  The property was
100% leased to Overland Data, Inc. through February 2014.
However, the tenant has amended the lease to remove the entire
office building and 6,950 of the NRA of the R&D building from its
leasehold interest leaving 91,300 of the NRA in the R&D building.
Northrop-Grumman Systems Corporation (Moody's senior unsecured
rating of Baa1 - stable outlook) now occupies this space in a
lease through June and November 2015.  Property performance is
inline with Moody's original expectations.  The loan is amortizing
on a 360-month schedule maturing in August 2014 and has paid down
6% since last full review.  Moody's LTV and stressed DSCR are 74%
and 1.43X, respectively, compared to 73% and 1.40X at last full
review.

The third conduit largest loan is the Hershey Heritage Village
Loan ($14.4 million -- 2.2% of the pool), which is secured by a
517-unit multifamily property located in Lancaster, Pennsylvania.
The property was 95% leased as of August 2010 compared to 98% at
last review.  Property performance is stable.  The loan had a 59-
month interest-only period and is amortizing on a 353-month
schedule maturing in January 2013.  The loan has paid down 4%
since last full review.  Moody's LTV and stressed DSCR are 65% and
1.58X, respectively, compared to 59% and 1.64X at last full
review.


KATONAH III: Moody's Upgrades Ratings on Seven Classes of Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Katonah III, Ltd.:

  -- US$321,000,000 Class A Floating Rate Notes Due 2015 (current
     outstanding balance of $226,010,812.7), Upgraded to Aaa (sf);
     previously on November 23, 2010 Aa3 (sf) Placed Under Review
     for Possible Upgrade;

  -- US$17,000,000 Class B-1 Floating Rate Notes Due 2015,
     Upgraded to Baa1 (sf); previously on November 23, 2010 Ba1
     (sf) Placed Under Review for Possible Upgrade;

  -- US$23,000,000 Class B-2 Fixed Rate Notes Due 2015, Upgraded
     to Baa1 (sf); previously on November 23, 2010 Ba1 (sf) Placed
     Under Review for Possible Upgrade;

  -- US$13,000,000 Class C-1 Floating Rate Notes Due 2015,
     Upgraded to Ba2 (sf); previously on November 23, 2010 Caa2
     (sf) Placed Under Review for Possible Upgrade;

  -- US$4,000,000 Class C-2 Fixed Rate Notes Due 2015, Upgraded to
     Ba2 (sf); previously on November 23, 2010 Caa2 (sf) Placed
     Under Review for Possible Upgrade;

  -- US$12,000,000 Class D-1 Floating Rate Notes Due 2015,
     Upgraded to Caa2 (sf); previously on November 23, 2010 Ca
     (sf) Placed Under Review for Possible Upgrade;

  -- US$2,500,000 Class D-2 Fixed Rate Notes Due 2015, Upgraded to
     Caa2 (sf); previously on November 23, 2010 Ca (sf) Placed
     Under Review for Possible Upgrade.

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily due to an increase in the transaction's
overcollateralization ratios, and improvement in the credit
quality of the underlying portfolio since the rating action in
August 2009.

The overcollateralization ratios of the rated notes have improved
in part as a result of amortization of the Class A Notes, which
have been paid down by approximately $36.0 million or 14% since
the rating action in August 2009.  As of the latest trustee report
dated January 18, 2011, the Class A, Class B, Class C, and Class D
overcollateralization ratios are reported at 143.9%, 122.2%,
114.9%, and 109.3%, respectively, versus July 2009 levels of
130.9%, 113.6%, 107.5%, and 102.8%, respectively.

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.  Based on the
January 2011 trustee report, the weighted average rating factor is
2658 compared to 3022 in July 2009, and securities rated Caa1 and
below make up approximately 6% of the underlying portfolio versus
13% in July 2009.  The deal also experienced a decrease in
defaults.  In particular, the dollar amount of defaulted
securities has decreased to approximately $1.9 million from
$43.0 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 balance of $322 million, defaulted par of $4.3 million,
weighted average default probability of 22.5% (implying a WARF of
3414), a weighted average recovery rate upon default of 42.4%, and
a diversity score of 49.  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.

Katonah III, Ltd., issued on April 18, 2002, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed a number of sensitivity analyses to test the impact
on all rated notes, including these:

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on all
rated notes of various default probabilities.  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,
whereby a positive difference corresponds to lower expected
losses), assuming that all other factors are held equal:

Moody's Adjusted WARF - 20% (2731)

  -- Class A: +1
  -- Class B-1: +1
  -- Class B-2: +1
  -- Class C-1: +1
  -- Class C-2: +2
  -- Class D-1: +3
  -- Class D-2: +3

Moody's Adjusted WARF + 20% (4097)

  -- Class A: -1
  -- Class B-1: -2
  -- Class B-2: -2
  -- Class C-1: -2
  -- Class C-2: -2
  -- Class D-1: -2
  -- Class D-2: -2

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the managers'
investment strategy 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:

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 sell
   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.

4) 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 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.


KATONAH IX: Moody's Upgrades Ratings on Two Classes of Notes
------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Katonah IX CLO Ltd.:

  -- US$15,000,000 Class B-1L Floating Rate Notes, Due 2019,
     Upgraded to Caa2 (sf); previously on November 23, 2010 Caa3
     (sf) Placed Under Review for Possible Upgrade;

  -- US$15,000,000 Class B-2L Floating Rate Notes, Due 2019,
     Upgraded to Caa3 (sf); previously on November 23, 2010 Ca
     (sf) Placed Under Review for Possible Upgrade.

                        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 transaction's
overcollateralization ratios since the rating action in June 2009.

Improvement in the credit quality is observed through an
improvement in the average credit rating (as measured by the
weighted average rating factor) and a decrease in the proportion
of securities from issuers rated Caa1 and below.  In particular,
as of the latest trustee report dated January 12, 2011, the
weighted average rating factor is currently 2513 compared to 2888
in the May 2009 report, and securities rated Caa1 or lower make
up approximately 3.4% of the underlying portfolio versus 7.9%
in May 2009.  Additionally, defaulted securities total about
$10.6 million of the underlying portfolio compared to $35 million
in May 2009.

The overcollateralization ratios of the rated notes have also
improved since the rating action in June 2009.  The Senior Class
A, Class A-3L, Class B-1L, and Class B-2L overcollateralization
ratios are reported at 119.62%, 111.04%, 106.63%, and 102.55%,
respectively, versus May 2009 levels of 117.04%, 108.78%, 104.53%,
and 96.76%, respectively, and all related overcollateralization
tests are currently in compliance.  Moody's also notes that the
Class B-2L Notes are no longer deferring interest and that all
previously deferred interest has been paid in full.

While the transaction has benefited from improvement in the credit
quality of the underlying portfolio, Moody's noted that the
portfolio includes a number of investments in CLO tranches that
mature after the maturity date of the notes.  Based on the latest
trustee report in January 2011, securities that mature after the
maturity date of the notes make up approximately 4.2% of the
underlying portfolio.  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 balance of $400.7 million, defaulted par of
$13.6 million, a weighted average default probability of 23.47%
(implying a WARF of 3464), a weighted average recovery rate upon
default of 41.89%, and a diversity score of 65.  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.

Katonah IX CLO Ltd., issued in November 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on all
rated notes of various default probabilities.  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 loss),
assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2772)

  -- Class X: 0
  -- Class A-1LV: +2
  -- Class A-1L: +2
  -- Class A-2L: +3
  -- Class A-3L: +2
  -- Class B-1L: +4
  -- Class B-2L: +1

Moody's Adjusted WARF + 20% (4157)

  -- Class X: 0
  -- Class A-1LV: -2
  -- Class A-1L: -2
  -- Class A-2L: -1
  -- Class A-3L: -1
  -- Class B-1L: -2
  -- Class B-2L: -1

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the manager's
investment strategy 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:

* 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 sell 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.

* 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 and the asset's current market value.

* 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.

* Other collateral quality metrics: The deal is allowed to
  reinvest and the manager has the ability to deteriorate the
  collateral quality metrics' existing cushions against the
  covenant levels.  Moody's analyzed the impact of assuming lower
  of reported and covenanted values for weighted average rating
  factor, weighted average spread, weighted average coupon, and
  diversity score.


KATONAH V: S&P Raises Ratings on Various Classes of Notes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B-1, and B-2 notes from Katonah V Ltd., a collateralized
loan obligation transaction managed by INVESCO Senior Secured
Management Inc. At the same time, S&P removed those ratings from
CreditWatch with positive implications, where S&P placed them on
Nov. 8, 2010.  S&P also affirmed its 'CCC- (sf)' rating on the
class C notes and its 'CC (sf)' rating on the class D notes.

The transaction is in its amortization phase and principal
proceeds are used to pay down the notes in a sequential manner.
The current balance of the class A-1 notes is $59.015 million (32%
of its original balance), down from $107.812 million at the time
of the last rating action in May 2010.  According to the January
2011 monthly report, the overcollateralization ratios of all
tranches have improved from their levels noted in the March 2010
monthly report (prior to the March 2010 note payment report) that
S&P used in its previous analysis:

* The class A O/C ratio was 148.5%, compared with 121.3% in March
  2010;

* The class B O/C ratio was 117.75%, compared with 107.12% in
  March 2010;

* The class C O/C ratio was 106.16%, compared with 100.89% in
  March 2010; and

* The class D O/C ratio was 95.69%, compared with 95.01% in March
  2010

In addition, the January 2011 report discloses $4.7 million of
defaulted assets, down from $11.9 million in March 2010.

As a result of improved credit support due to the paydown and
lower defaults, S&P raised its ratings on the class A-1, A-2, B-1,
and B-2 notes.  S&P affirmed its ratings on the class C and D
notes to reflect the classes' adequate credit support at their
current rating 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

                          Katonah V Ltd.

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

                         Ratings Affirmed

                          Katonah V Ltd.

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

  Transaction Information
  -----------------------
Issuer:              Katonah V Ltd.
Coissuer:            Katonah V Inc.
Collateral manager:  INVESCO Senior Secured Management Inc.
Underwriter:         Credit Suisse AG
Trustee:             Bank of New York Mellon (The)
Transaction type:    Cash flow CLO


KINGSLAND IV: Moody's Upgrades Ratings on Various Classes of Notes
------------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Kingsland IV Ltd.:

  -- US$308,100,000 Class A-1 Senior Secured Floating Rate Notes
     Due 2021 (current balance of $304,300,554), Upgraded to Aa3
     (sf); previously on May 20, 2010 Upgraded to A1 (sf);

  -- US$60,000,000 Class A-1R Senior Secured Revolving Floating
     Rate Notes Due 2021 (current balance of $59,260,088),
     Upgraded to Aa3 (sf); previously on May 20, 2010 Upgraded to
     A1 (sf);

  -- US$22,900,000 Class B Senior Secured Floating Rate Notes Due
     2021, Upgraded to Baa1 (sf); previously on May 20, 2010
     Upgraded to Baa2 (sf);

  -- US$25,000,000 Class C Senior Secured Deferrable Floating Rate
     Notes Due 2021, Upgraded to Ba1 (sf); previously on May 20,
     2010 Upgraded to Ba2 (sf);

  -- US$18,000,000 Class D Senior Secured Deferrable Floating Rate
     Notes Due 2021, Upgraded to B2 (sf); previously on Nov. 23,
     2010 Caa1 (sf) Placed Under Review for Possible Upgrade;

  -- US$14,900,000 Class E Secured Deferrable Floating Rate Notes
     Due 2021, Upgraded to Caa3 (sf); previously on Nov. 23, 2010
     Ca (sf) Placed Under Review for Possible Upgrade.

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from an improvement in Moody's calculated
overcollateralization ratios since the rating action in July 2010.

The reported overcollateralization ratios of the rated notes have
improved slightly since the rating action in July 2010.  The Class
A/B, Class C, Class D, and Class E overcollateralization ratios
are reported at 119.44%, 112.19%, 107.48%, and 103.88%,
respectively, versus June 2010 levels of 119.03%, 111.80%, 107.11%
and 103.52%, respectively, and all related overcollateralization
tests are currently in compliance.  Notably, however, Moody's
analysis of collateral coverage is based on adjusted
overcollateralization ratios that have improved by more than the
trustee-reported improvement due to a decrease in the percentage
of securities with Ca or C ratings.  Consistent with its rating
surveillance assumptions, Moody's treated Ca or C-rated securities
as defaulted securities in its analysis leading to the rating
action in July 2010.  In its current analysis, Moody's is treating
such securities which have benefited from having their ratings
upgraded above previous Ca or C rating levels as performing
assets.  In particular, the current Moody's calculated
overcollateralization ratios for the Class A/B, Class C, Class D
and Class E are 119.42%, 112.17%, 107.47% and 103.86%,
respectively, versus July 2010 levels of 116.72%, 109.63%, 105.03%
and 101.51%, respectively.

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 balance, of $461 million, defaulted
par of $4 million, a weighted average default probability of
25.28% (implying a WARF of 3164), a weighted average recovery rate
upon default of 40.33%, and a diversity score of 50.  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 IV, Ltd., issued in February 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed sensitivity analysis to test the impact on all
rated notes of various default probabilities.  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% (2531)

  -- Class A1: +2
  -- Class A1R: +2
  -- Class B: +3
  -- Class C: +2
  -- Class D: +2
  -- Class E : +2

Moody's Adjusted WARF + 20% (3797)

  -- Class A1: -2
  -- Class A1R: -2
  -- Class B: -2
  -- Class C: -2
  -- Class D: -3
  -- Class E: -1

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the managers'
investment strategy 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 the recent U.S. bankruptcy court ruling on Lehman swap
termination in the Dante case.

Sources of additional performance uncertainties are:

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) 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 and the asset's current market
   value.

3) 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 sell
   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.

4) 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 spread, Moody's considered the impact of
   assuming the midpoint of the Moody's calculated weighted
   average spread and the covenant in its analysis.


LEAF RECEIVABLES: DBRS Puts 'B (Low) ' Rating on Class E-2 Notes
----------------------------------------------------------------
DBRS has assigned final ratings to the following classes issued by
LEAF Receivables Funding 6, LLC - Equipment Contract Backed Notes,
Series 2011-1:

    -- Series 2011-1, Class A Notes rated AAA (sf)
    -- Series 2011-1, Class B Notes rated AA (sf)
    -- Series 2011-1, Class C Notes rated 'A' (sf)
    -- Series 2011-1, Class D Notes rated BBB (sf)
    -- Series 2011-1, Class E-1 Notes rated BB (sf)
    -- Series 2011-1, Class E-2 Notes rated B (low) (sf)


LEHMAN MORTGAGE: Moody's Downgrades Ratings on 50 Tranches
----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 50
tranches and confirmed the ratings on three tranches from two RMBS
transactions, backed by Alt-A loans, issued by Lehman Mortgage
Trust in 2005.

                        Ratings Rationale

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

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: Lehman Mortgage Trust 2005-1

  -- Cl. 1-A1, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A2, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A3, Downgraded to Ca (sf); previously on Jan. 14, 2010
     Ba3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A1, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A2, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A3, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A4, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A5, Downgraded to C (sf); previously on Jan. 14, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A1, Downgraded to B3 (sf); previously on Jan. 14, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A2, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A3, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A4, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A5, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A6, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A7, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A8, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A9, Downgraded to Caa1 (sf); previously on Jan. 14,
     2010 Ba3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A10, Downgraded to C (sf); previously on Jan. 14, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 5-A1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 Ba1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 5-A2, Downgraded to C (sf); previously on Jan. 14, 2010
     B1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 6-A1, Downgraded to B3 (sf); previously on Jan. 14, 2010
     Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 7-A1, Downgraded to B3 (sf); previously on Jan. 14, 2010
     Ba2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. AX, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

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

  -- Cl. PAX, Downgraded to B1 (sf); previously on Jan. 14, 2010
     Aa3 (sf) Placed Under Review for Possible Downgrade

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

Issuer: Lehman Mortgage Trust 2005-3

  -- Cl. 1-A1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A2, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A3, Confirmed at Caa1 (sf); previously on Jan. 14, 2010
     Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A4, Downgraded to Ca (sf); previously on Jan. 14, 2010
     B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A5, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A6, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A7, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A8, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A9, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A10, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa1 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A11, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 1-A12, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A1, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A2, Downgraded to C (sf); previously on Jan. 14, 2010
     Ca (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A3, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A4, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A5, Current Rating at B3 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Underlying Rating: Downgraded to Caa2 (sf); previously on Feb
     20, 2009 Downgraded to B3 (sf)

  -- Financial Guarantor: MBIA Insurance Corporation (Downgraded
     to B3, Outlook Negative on Jun 25, 2009)

  -- Cl. 2-A6, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A7, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A8, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 2-A9, Downgraded to Caa2 (sf); previously on Jan. 14,
     2010 B3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 3-A1, Downgraded to Caa3 (sf); previously on Jan. 14,
     2010 Caa2 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A1, Downgraded to B3 (sf); previously on Jan. 14, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Cl. 4-A2, Downgraded to C (sf); previously on Jan. 14, 2010
     Caa2 (sf) Placed Under Review for Possible Downgrade

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

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

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


LONGHORN CDO: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B, C, D-1, and D-2 notes from Longhorn CDO III Ltd., a
collateralized loan obligation transaction managed by BlackRock
Financial Management Inc.  S&P removed its rating on the class B
notes from CreditWatch with positive implications.  At the same
time, S&P affirmed its ratings on the class A-1, A-2, and E notes.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio and significant paydown of the
class A-1 notes since its last rating action in November 2009.
The affirmations reflect the availability of credit support at the
class' current rating levels.

According to the Dec. 29, 2010 trustee report, the transaction
currently holds $3.7 million in 'CCC' rated assets, down from
$14.0 million noted in the Oct. 1, 2009, trustee report.  In
addition, the transaction holds $1.3 million in defaulted
securities, down from $6.5 million in October 2009.  The deal has
paid down $53.9 million to the class A-1 notes since the last
review.  Accordingly, the transaction's overcollateralization
ratios have improved.  The class A O/C ratio is 180.79% versus
139.32% in October 2009, the class B O/C ratio is 140.73% versus
120.12%, the class C O/C ratio is 115.21% versus 105.56%, the
class D O/C ratio is 104.28% versus 98.66%, and the class E O/C
ratio is 99.06% versus 95.20%.

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

                      Longhorn CDO III Ltd.

                             Rating
                             ------
            Class       To          From
            -----       --          ----
            B           AAA (sf)    AA (sf)/Watch Pos
            C           BBB+ (sf)   BB+ (sf)
            D-1         CCC+ (sf)   CCC- (sf)
            D-2         CCC+ (sf)   CCC- (sf)

                         Ratings Affirmed

                       Longhorn CDO III Ltd.

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


MADISON SQUARE: Fitch Downgrades Ratings on Three Classes of Notes
------------------------------------------------------------------
Fitch Ratings has downgraded three and affirmed four classes
issued by Madison Square 2004-1 as a result of negative credit
migration of the commercial mortgage back securities collateral.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs'.  The
ratings are not based on the Portfolio Credit Model given the high
obligor concentration and seasoning of the portfolio.  Instead,
the projected recovery estimate on the distressed collateral was
applied in accordance with the principal waterfall.  Additionally,
an asset by asset analysis was performed for the remaining assets
to determine the collateral coverage for the remaining
liabilities.

Since Fitch's last rating action in March 2010, approximately
75.5% of the portfolio has been downgraded.  Currently, 92.5% has
a Fitch derived rating below investment grade and 69.4% has a
rating in the 'CCC' rating category or lower, compared to 80.6%
and 51.1%, respectively, at last review.  The class L notes are
the most senior class and have paid down by $46.6 million since
the last review.  The portfolio has become increasingly
concentrated with eight obligors remaining.

Class L and M are assigned a Stable Outlook since they have
significant credit enhancement to withstand potential credit
migration.  The Negative Outlook on the class N through Q notes
reflects Fitch's expectation that underlying CMBS loans will
continue to face refinance risk.  The Loss Severity rating
indicates a tranche's potential loss severity given default, as
evidenced by the ratio of tranche size to the base-case loss
expectation for the collateral, as explained in 'Criteria for
Structured Finance Loss Severity Ratings'.  The LS rating should
always be considered in conjunction with the probability of
default for tranches.  Fitch does not assign LS ratings or
Outlooks to classes rated 'CCC' and below.

Madison Square 2004-1 is a commercial real estate collateralized
debt obligation that closed March 31, 2004.  The transaction is
collateralized by 21 assets from eight obligors from the 1996
through 1999 vintages.

Fitch has affirmed these classes and revised the Rating Outlooks
where indicated:

  -- $32,337,012 class L Notes at 'AAAsf/LS5'; Outlook to Stable
     from Negative;

  -- $18,473,000 class M notes at 'AA-sf/LS5'; Outlook to Stable
     from Negative;

  -- $29,029,000 class N notes at 'A+sf/LS5'; Outlook Negative;

  -- $18,501,489 class Q notes at 'Bsf/LS5'; Outlook Negative.

Fitch has downgraded these classes:

  -- $29,028,000 class O notes to 'BBsf/LS5' from 'BBBsf/LS5';
     Outlook Negative;

  -- $34,950,409 class P notes to 'Bsf/LS5' from 'BB-sf/LS5';
     Outlook Negative;

  -- $14,391,389 class S notes to 'CCCsf' from 'Bsf/LS5'.
     Classes A through K have paid in full.


MERRILL LYNCH: Moody's Affirms Ratings on 16 Classes of Certs.
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 16 classes of
Merrill Lynch Financial Assets Inc., Commercial Mortgage Pass-
Through Certificates, Series 2006-Canada 20:

  -- Cl. A-1 Certificate, Affirmed at Aaa (sf); previously on
     Oct. 27, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2 Certificate, Affirmed at Aaa (sf); previously on
     Oct. 27, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-3 Certificate, Affirmed at Aaa (sf); previously on
     Oct. 27, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. XP-1 Certificate, Affirmed at Aaa (sf); previously on
     Oct. 27, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. XP-2 Certificate, Affirmed at Aaa (sf); previously on
     Oct. 27, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. XC Certificate, Affirmed at Aaa (sf); previously on
     Oct. 27, 2006 Definitive Rating Assigned Aaa (sf)

  -- Cl. B Certificate, Affirmed at Aa2 (sf); previously on
     Oct. 27, 2006 Definitive Rating Assigned Aa2 (sf)

  -- Cl. C Certificate, Affirmed at A2 (sf); previously on Oct. 1,
     2009 Confirmed at A2 (sf)

  -- Cl. D Certificate, Affirmed at Baa3 (sf); previously on
     Oct. 1, 2009 Downgraded to Baa3 (sf)

  -- Cl. E Certificate, Affirmed at Ba2 (sf); previously on
     Oct. 1, 2009 Downgraded to Ba2 (sf)

  -- Cl. F Certificate, Affirmed at B1 (sf); previously on Oct. 1,
     2009 Downgraded to B1 (sf)

  -- Cl. G Certificate, Affirmed at B3 (sf); previously on Oct. 1,
     2009 Downgraded to B3 (sf)

  -- Cl. H Certificate, Affirmed at Caa1 (sf); previously on
     Oct. 1, 2009 Downgraded to Caa1 (sf)

  -- Cl. J Certificate, Affirmed at Caa2 (sf); previously on
     Oct. 1, 2009 Downgraded to Caa2 (sf)

  -- Cl. K Certificate, Affirmed at Caa3 (sf); previously on
     Oct. 1, 2009 Downgraded to Caa3 (sf)

  -- Cl. L Certificate, Affirmed at Ca (sf); previously on Oct. 1,
     2009 Downgraded to Ca (sf)

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
2.1% of the current pooled balance.  Moody's cumulative base
expected loss was 3.3% at last review.  Moody's stressed scenario
loss is 10.4% of the current pooled 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 25 compared to 26 at Moody's prior full 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.

                         Deal Performance

As of the January 12, 2011 distribution date, the transaction's
aggregate certificate balance decreased by 10% to $533.2 million
from $595.3 million at securitization.  The Certificates are
collateralized by 64 mortgage loans ranging in size from less than
1% to 7.4% of the pool, with the top ten loans representing 53% of
the pool.  One loan, representing 5% of the pool has an investment
grade credit estimate.  Two loans, representing less than 2% of
the pool, have defeased and are collateralized by Canadian
Government securities.

Nine loans, representing 11% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package.  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 losses since securitization.
There are currently two loans in special servicing.  The specially
serviced loans represent 6% of the pool.  One of the specially
serviced loans, Summit Properties ($7.9 million - 1% of pool),
paid off in full subsequent to the January 12, 2011 distribution
date.  The remaining specially serviced loan, Marriott Pooled
Senior Loan ($25.4 million - 5% of pool), is secured by five
Marriott flagged hotels in the Greater Toronto area.  The subject
loan represents a 50% pari passu interest in a $15.8 million first
mortgage loan.  The loan was transferred to the special servicer
in August 2009 for payment delinquency and is currently less than
30 days past due.  The loan's sponsor, Concord Hospitality, is
overseeing a Project Improvement Plan at three of the collateral
properties.  Moody's is not estimating a loss for the specially
serviced loans.

Moody's has assumed a high default probability for four poorly
performing loans representing 3% of the pool and has estimated a
$2.4 million loss (based on a 50% probability of default and 36%
loss given default on average) from these troubled loans.

Moody's was provided with full year 2009 operating results for 86%
of the pool.  Excluding troubled loans, Moody's weighted average
LTV is 88% compared to 93% at last full 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 9.2%.

Excluding troubled loans, Moody's actual and stressed DSCRs are
1.48X and 1.20X, respectively, as compared to 1.37X and 1.10X 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.

The loan with a credit estimate is the Westview Village
Manufactured Home Loan ($27.6 million - 5.2%), which is secured by
a 1,060 pad manufactured housing community located in Edmonton,
Alberta.  The property was virtually 100% leased as of September
2010 and has maintained a near 100% occupancy since
securitization.  Property performance has improved due to
increased rental revenues and amortization.  Moody's current
credit estimate and stressed DSCR are A1 and 1.65X, respectively,
compared to A3 and 1.48X at last review.

The top three performing conduit loans represent 21% of the pool
balance.  The largest conduit loan is the Station Tower Loan
($39.2 million - 7.4%), which is secured by a 218,000 square foot
(SF) Class A office building.  The property is located in Surrey,
which is a suburb of Vancouver, British Colombia.  The property
was 96% leased as of August 2010 compared to 99% at last review.
Moody's LTV and stressed DSCR are 76% and 1.21X, respectively,
compared to 84% and 1.09X at last review.

The second largest conduit loan is the Heritage Square Loan
($37.0 million - 6.9%), which is secured by a 316,000 SF Class A
office building located in the Acadia suburb of Calgary, Alberta.
The property was 98% leased as of October 2010, compared to 100%
at last review.  The largest tenant is AMEC, which is a leading
global engineering, project management and consultancy company.
AMEC's lease expires in August 2013.  Property performance has
improved due to increased base revenues and amortization.  Moody's
LTV and stressed DSCR are 55% and 1.93X, respectively, compared to
77% and 1.37X at last review.

The third largest conduit loan is the Carrefour Trois Rivieres/de
Recollets Loan ($35.5 million -- 6.7%), which is secured by two
anchored retail centers, totaling 475,000 SF, located in Trois
Rivieres, Quebec.  The weighted average occupancy was 95% on
December 31, 2009, compared to 90% at last review.  The loan
matures in July 2011.  Moody's LTV and stressed DSCR are 96% and
0.99X, respectively, compared to 97% and .97X at last review.


MERRILL LYNCH: Moody's Downgrades Ratings on Three Certificates
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of three classes
and affirmed 12 classes of Merrill Lynch Financial Assets Inc.,
Commercial Mortgage Pass-Through Certificates, Series 2005-Canada
17:

  -- Cl. A-1 Certificate, Affirmed at Aaa (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2 Certificate, Affirmed at Aaa (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. XP-1 Certificate, Affirmed at Aaa (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. XP-2 Certificate, Affirmed at Aaa (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. XC Certificate, Affirmed at Aaa (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. B Certificate, Affirmed at Aa2 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Aa2 (sf)

  -- Cl. C Certificate, Affirmed at A2 (sf); previously on Dec. 7,
     2005 Definitive Rating Assigned A2 (sf)

  -- Cl. D Certificate, Affirmed at Baa2 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Baa2 (sf)

  -- Cl. E Certificate, Affirmed at Baa3 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Baa3 (sf)

  -- Cl. F Certificate, Affirmed at Ba1 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Ba1 (sf)

  -- Cl. G Certificate, Affirmed at Ba2 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Ba2 (sf)

  -- Cl. H Certificate, Affirmed at Ba3 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned Ba3 (sf)

  -- Cl. J Certificate, Downgraded to B2 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned B1 (sf)

  -- Cl. K Certificate, Downgraded to B3 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned B2 (sf)

  -- Cl. L Certificate, Downgraded to Caa1 (sf); previously on
     Dec. 7, 2005 Definitive Rating Assigned B3 (sf)

                        Ratings Rationale

The downgrades are due to higher expected losses resulting from
anticipated losses from troubled loans and higher credit quality
dispersion.  Four loans, representing 23% of the pool, have a
Moody's loan to value ratio higher than 100% compared to 5% at
last review and 1% at securitization.

The affirmations are due to key parameters, including Moody's LTV
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
2.1% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.5%.  Moody's stressed scenario loss is
9.7% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

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

Moody's 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 14 compared to 15 at Moody's prior review.

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

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors.  Therefore,
the rating outcome may differ from the model output.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated December 3, 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 January 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 20% to
$402.0 million from $502.8 million at securitization.  The
Certificates are collateralized by 36 mortgage loans ranging in
size from less than 1% to 15% of the pool, with the top ten loans
representing 71% of the pool.  The pool includes two loans with
investment-grade credit estimates, representing 12% of the pool.

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

One loan has been liquidated from the pool, resulting in a
realized loss of $189,431 (11% loss severity).  There are
currently no loans in special servicing.

Moody's has assumed a high default probability for three poorly
performing loans representing 5% of the pool and has estimated an
aggregate $3.4 million loss (17% expected loss based on a 55%
probability default) from these troubled loans.

Moody's was provided with full year 2009 operating results for 91%
of the pool.  Excluding troubled loans, Moody's weighted average
LTV is 88% compared to 87% 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 9.2%.

Excluding troubled loans, Moody's actual and stressed DSCRs are
1.44X and 1.19X, respectively, compared to 1.47X and 1.18X 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 College Square Loan
($24.0 million -- 6.0% of the pool), which is secured by a 386,210
square foot anchored retail centre located in Ottawa, Ontario.
The center has maintained 100% occupancy since securitization.
The center is anchored by Home Depot and Loblaws.  Performance has
been stable.  Moody's current credit estimate and stressed DSCR
are Aaa and 1.86X, respectively, compared to Aaa and 1.77X at last
review.

The second loan with a credit estimate is the InnVest CMBS
Portfolio II Loan ($22.1 million -- 5.5% of the pool), which is
secured by ten limited service hotels with 781 rooms.  The hotels
are located in Quebec, Ontario, New Brunswick, and Nova Scotia.
Although NOI has declined since last review, performance is in
line with the Moody's expectations.  At last review, Moody's
analysis incorporated a stressed cash flow due to concerns about
weakness in the lodging industry.  Moody's current credit estimate
and stressed DSCR are A3 and 2.08X, respectively, compared to A3
and 1.98X at last review.

The top three performing conduit loans represent 37% of the pool
balance.  The largest loan is the TransGlobe Pooled Senior Loan
($59.8 million -- 14.9% of the pool) which is secured by 25
multifamily properties containing a total of 2,302 units located
across Ontario and Nova Scotia.  The loan represents a 55%
interest in a first mortgage loan of $107.7 million.  There is
also $11.1 million B note held outside the trust.  The loan
previously was in special servicing because the borrower obtained
subordinate financing without the lender's approval.  The loan has
been modified, three properties were released and subordinated
debt was paid in full.  The loan is currently on the servicer's
watchlist due to low DSCR.  Based on the year-end 2009 data, 17
out of 25 properties were performing below the DSCR threshold with
an overall DSCR of 1.02x.  Moody's LTV and stressed DSCR are 110%
and 0.84X, respectively, compared to 99% and 0.93X at last review.

The second largest loan is the Redbourne Office Portfolio Loan
($51.4 million -- 12.8% of the pool), which is secured by ten
office buildings with 710,498 square feet located in Quebec,
Canada.  The portfolio was 99% leased as of April 2010 compared to
94% at last review.  Performance has declined since last review
due to lower revenues and higher expenses.  Moody's LTV and
stressed DSCR are 83% and 1.3X, respectively, compared to 75% and
1.45X at last review.

The third largest loan is the Technoparc Portfolio Loan
($39.4 million -- 9.8% of the pool), which is secured by 13 office
buildings with 323,373 square feet located in the Technoparc
submarket of Saint-Laurent, Quebec.  The portfolio was 70% leased
as of October 2010 compared to 90% at last review.  Six of the
properties had occupancy less than 50%.  Moody's has incorporated
the recent increased vacancy in its analysis.  Moody's LTV and
stressed DSCR are 94% and 1.09X, respectively, compared to 86% and
1.19X at last review.


MERRILL LYNCH: Moody's Takes Rating Actions on Various Classes
--------------------------------------------------------------
Moody's Investors Service upgraded four and affirmed eleven
classes of Merrill Lynch Financial Assets Inc., Commercial
Mortgage Pass-Through Certificates, Series 2003-Canada 10:

  -- Cl. A-1 Certificate, Affirmed at Aaa (sf); previously on
     July 16, 2003 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2 Certificate, Affirmed at Aaa (sf); previously on
     July 16, 2003 Definitive Rating Assigned Aaa (sf)

  -- Cl. XC-2 Certificate, Affirmed at Aaa (sf); previously on
     July 16, 2003 Definitive Rating Assigned Aaa (sf)

  -- Cl. XC-1 Certificate, Affirmed at Aaa (sf); previously on
     July 16, 2003 Definitive Rating Assigned Aaa (sf)

  -- Cl. B Certificate, Affirmed at Aaa (sf); previously on
     Dec. 13, 2006 Upgraded to Aaa (sf)

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

  -- Cl. D-1 Certificate, Upgraded to Aa3 (sf); previously on
     Oct. 16, 2008 Upgraded to A2 (sf)

  -- Cl. D-2 Certificate, Upgraded to Aa3 (sf); previously on
     Oct. 16, 2008 Upgraded to A2 (sf)

  -- Cl. E-1 Certificate, Upgraded to Baa1 (sf); previously on
     Oct. 16, 2008 Upgraded to Baa2 (sf)

  -- Cl. E-2 Certificate, Upgraded to Baa1 (sf); previously on
     Oct. 16, 2008 Upgraded to Baa2 (sf)

  -- Cl. F Certificate, Affirmed at Ba1 (sf); previously on
     July 16, 2003 Definitive Rating Assigned Ba1 (sf)

  -- Cl. G Certificate, Affirmed at Ba2 (sf); previously on
     July 16, 2003 Definitive Rating Assigned Ba2 (sf)

  -- Cl. H Certificate, Affirmed at Ba3 (sf); previously on
     July 16, 2003 Definitive Rating Assigned Ba3 (sf)

  -- Cl. J Certificate, Affirmed at B3 (sf); previously on Oct. 1,
     2009 Downgraded to B3 (sf)

  -- Cl. K Certificate, Affirmed at Caa1 (sf); previously on
     Oct. 1, 2009 Downgraded to Caa1 (sf)

                        Ratings Rationale

The upgrades are due to increased subordination from loan payoffs
and amortization and the pool's overall improved performance.  The
pool has paid down 26% since securitization and 9% since last
review.

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 cumulative base expected 0f 2.3% of
the current balance compared to 1.8% at last review.  The current
stressed scenario loss is 3.4% of the current pooled 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 20 compared to 25 at Moody's prior full 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 January 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 26% to
$341.5 million from $460.4 million at securitization.  The
Certificates are collateralized by 51 mortgage loans ranging in
size from less than 1% to 8.5% of the pool, with the top ten loans
representing 45% of the pool.  Seven loans, representing 24% of
the pool, have defeased and are collateralized by Canadian
Government securities.  Two loans, representing 14% of the pool,
have investment grade credit estimates.

Seven 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.

The pool has not experienced any losses since securitization and
currently there are no loans in special servicing.

Moody's has assumed a high default probability for five of the
loans on the watchlist.  These five troubled loans represent 9% of
the pool.  Moody's has estimated a $4.5 million loss (based on a
50% probability of default and 29% loss given default on average)
from the troubled loans.

Moody's was provided with full year 2009 operating results for 85%
of the pool.  Excluding troubled loans, Moody's weighted average
LTV is 57% compared to 67% 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 9.8%.

Excluding troubled loans, Moody's stressed DSCR is 2.04X as
compared to 1.79X at last full review.  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 Sheridan Centre
Loan ($29 million - 8.5%), which is secured by a 549,000 square
foot retail and office complex located approximately 13 miles west
of Toronto in Mississauga, Ontario.  The retail portion accounts
for 55% of the property's net rentable area (NRA) and consists of
a community center anchored by Zellers and Dominion Food Store.
The largest tenant in the office portion is Royal & Sun Alliance,
which leases 38% of the collateral through 2018.  The center was
98% leased as of December 2009, the same as at last review.
Moody's current credit estimate and stressed DSCR are A1 and
1.88X, respectively, compared to A1 and 1.84X at last review.

The second loan with an underlying rating is the Richmond Centre
North Loan ($18.3 million -- 5.4%), which is secured by the
borrower's interest in a 716,000 square foot regional mall
(308,000 square feet of collateral) located immediately south of
Vancouver in Richmond, British Columbia.  The center is anchored
by The Bay, which leases 53% of the collateral's NRA though
September 2017.  The center was 98% leased as of March 2010 as
compared to 100% at last review.  Moody's current credit estimate
and stressed DSCR are Aaa and 3.08X, respectively, compared to Aaa
and 2.78X at last review.

The top three conduit loans represent 17% of the pool.  The
largest conduit loan is the RioCan Fairgrounds Loan ($22.8 million
-- 6.7%), which is secured by a 250,000 square foot power center
located approximately 50 miles northwest of Toronto in
Orangeville, Ontario.  Major tenants include Wal-Mart (leases 42%
of NRA through 2017), Price Chopper (17% of NRA though 2018) and
Galaxy Theatres (10% of NRA though 2021).  The center was 100%
leased as of January 2010, the same as at last review.  The loan
sponsor, RioCan Real Investment Trust (RioCan), is a large
Canadian REIT which owns properties representing 38 million square
feet.  Moody's LTV and stressed DSCR are 66% and 1.56X,
respectively, as compared to 71% and 1.44X at last review.

The second largest conduit loan is The Junction (Phase I) Loan
($17.9 million -- 5.3%), which is secured by the borrower's
interest in a 370,000 square foot power center (194,000 square
feet of collateral) located in Mission, British Columbia.  The
collateral is anchored by Sav on Foods, which leases 30% of the
NRA through 2018.  The property was 99% leased as of December
2009, the same as at last review.  The loan sponsor is a joint
venture between two large North American based REITs, RioCan and
Kimco Realty.  Moody's LTV and stressed DSCR are 58% and 1.73X,
respectively, as compared to 68% and 1.48X at last review.

The third largest conduit loan is the Lawrence Terrace Loan
($17.4 million -- 5.1%), which is secured by a 410-unit mid-rise
apartment complex located in Toronto, Ontario.  The property was
constructed in 1964.  Property performance has declined since
securitization due to increased operating expenses and a decline
in occupancy.  The most recent property inspection report
available (September 2008) indicates several areas of deferred
maintenance, including the underground parking structure.  Current
financial information for this loan is not available.  The loan is
on the master servicer's watchlist due to low debt service
coverage.  Given the property's age, poor physical condition, lack
of current financials and decline in performance since
securitization, Moody's included this loan as one of the five
troubled loans in this deal.  Moody's LTV and stressed DSCR are
149% and 0.69X, respectively, compared to 145% and 0.71X at last
review.


ML-CFC COMMERCIAL: Fitch Downgrades Ratings on 15 Certificates
--------------------------------------------------------------
Fitch Ratings downgrades and revises Rating Outlooks and Loss
Severity Ratings on 15 classes of ML-CFC Commercial Mortgage
Trust's commercial mortgage pass-through certificates, series
2007-5.

The downgrades reflect an increase in Fitch modeled losses across
the pool, which includes assumed losses on loans in special
servicing and on performing loans with declines in performance
indicative of a higher probability of default.  Fitch modeled
losses of 12.59% (12.97% cumulative transaction losses which
includes losses realized to date).  Fitch expects classes E
through Q to be fully depleted by losses on specially serviced
loans and class D to be affected.  As of January 2011, there are
cumulative interest shortfalls in the amount of $9.9 million
currently affecting classes C through Q.

As of the January 2011 distribution date, the pool's aggregate
principal balance was $4.28 billion, down from $4.42 billion at
issuance.  There are no defeased loans.

Fitch has identified 91 loans (43.2%) as Fitch Loans of Concern,
which includes 28 specially serviced loans (27.2%).

The largest contributor to losses was Peter Cooper
Village/Stuyvesant Town, which is in special servicing.  PCV/ST
comprises 56 multi-story buildings, situated on 80 acres, and
includes a total of 11,227 apartments.  The special servicer has
gained control of the property by acquiring the mezzanine debt of
the borrower.  The special servicer is working to stabilize the
asset and has engaged Rose Associates as property manager.  The
special servicer intends to renovate 570 vacant units in 2011.
Property performance continues to be below what is needed to
service the debt; however the securitized loan balance per unit
($267,213) is low relative to other NYC multi family properties.
The most recent servicer-reported debt service coverage ratio is
0.6 and occupancy is 95%.

The second largest contributor to losses was HAS Memphis
Industrial Portfolio, which transferred to special servicing in
September 2010 for imminent monetary default.  The loan is secured
by 15 office/flex/industrial properties with over 1.5 million
square feet disbursed across three industrial parks in Memphis,
TN.  Portfolio occupancy has been gradually declining due to a
high level of rollover and is currently 74%, down from 89% at
issuance.  As a result, the servicer-reported debt service
coverage ratio (based on net cash flow) had fallen to 0.86 times
at YE2009 and 0.83x in 1Q'10.  The special servicer plans to
foreclose on this asset.

The third largest contributor to losses was the Renaissance
Dallas, which is a 518 room full service hotel located in the
Dallas market center, which is 3.5 miles from the Dallas CBD.
Hotel amenities include two restaurants, 13 meeting rooms, a
lounge, an outdoor rooftop pool and whirlpool, a fitness center
and sauna, a gift shop and business center.  Property performance
has been significantly impacted by the downturn.  The servicer-
reported YTD June 2010 debt service coverage ratio, occupancy,
average daily rate, and revenue per available room were 0.51x,
62%, $103, and $64, respectively.

Fitch has downgraded these classes and revised Rating Outlooks
where indicated:

  -- $341.7 million class AM to 'AA/LS4' from 'AAA/LS3'; Outlook
     to Stable from Negative;

  -- $100 million class AM-FL to 'AA/LS4' from 'AAA/LS3'; Outlook
     to Stable from Negative;

  -- $211.5 million class AJ to 'B-/LS5' from 'BB/LS3'; Outlook
     Negative;

  -- $175 million class AJ-FL to 'B-/LS5' from 'BB/LS3'; Outlook
     Negative;

  -- $77.3 million class B to 'CCC/RR1' from 'BB/LS5';

  -- $33.1 million class C to 'CCC/RR1' from 'BB/LS5'

  -- $77.3 million class D to 'CCC/RR2' from 'B-/LS5';

  -- $38.6 million class E to 'CCC/RR6' from 'B-/LS5';

  -- $55.2 million class F to 'CC/RR6' from 'B-/LS5';

  -- $49.7 million class G to 'CC/RR6' from 'B-/LS5';

  -- $49.7 million class H to 'CC/RR6' from 'B-/LS5';

  -- $16.6 million class J to 'C/RR6' from 'B-/LS5';

  -- $11 million class K to 'C/RR6' from 'B-/LS5';

  -- $11 million class L to 'C/RR6' from 'B-/LS5';

  -- $5.5 million class N to 'C/RR6' from 'B-/LS5'.

Additionally, Fitch affirms these classes:

  -- $553,403 class A-1 at 'AAA/LS2'; Outlook Stable;
  -- $63.3 million class A-2 at 'AAA/LS2'; Outlook Stable;
  -- $35 million class A-2FL at 'AAA/LS2'; Outlook Stable;
  -- $25 million class A-2FX at 'AAA/LS2'; Outlook Stable;
  -- $153.4 million class A-3 at 'AAA/LS2'; Outlook Stable;
  -- $187.1 million class A-SB at 'AAA/LS2'; Outlook Stable;
  -- $1,200.2 million class A-1A at 'AAA/LS2'; Outlook Stable;
  -- $1,090.2 million class A-4 at 'AAA/LS2'; Outlook Stable;
  -- $245 million class A-4FL at 'AAA/LS2'; Outlook Stable.

Fitch does not rate the class M, class P or class Q certificates.
Fitch withdraws the ratings of the interest only class X.


MONROE COUNTY: S&P Raises Ratings on Revenue Bonds From 'BB+'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its long-term rating to
'BBB-' from 'BB+' on Monroe County Hospital Finance Authority,
Mich.'s series 2006 revenue bonds issued for Mercy Memorial
Hospital System Corp. Obligated Group.

The rating revision reflects Standard & Poor's assessment of
Mercy's improved operating performance in the past fiscal year and
the first six months of fiscal 2011, generating strong debt
service coverage, coupled with an improved balance sheet.  The
balance sheet was boosted by the unexpected receipt of
$18.1 million from the sale of private shares in January 2010 and
benefits from operational improvements.  In addition, the 'BBB-'
rating reflects Standard & Poor's view of Mercy's dominant
business position in Monroe County despite its location in the
competitive markets of Detroit and Ann Arbor, Mich., and Toledo,
Ohio.

Offsetting credit factors include high unemployment in Monroe
County, as well as competition and outmigration to larger
facilities in nearby Toledo, Detroit, and Ann Arbor.

"The positive outlook reflects S&P's expectation that Mercy will
likely sustain its operating improvements and at least maintain
its balance sheet strength over the next one- to two-years," said
Standard & Poor's credit analyst Jessica Goldman.

Standard & Poor's believes a higher rating is possible if
management is able to continue to demonstrate sustained operating
improvement and coverage while at least maintaining the balance
sheet as well as market share stability over the next few years as
health care reform unfolds.  While not expected, should Mercy
experience operating losses or the balance sheet deteriorates,
Standard & Poor's could consider a return to a stable outlook.

Mercy consists of Mercy Memorial Hospital Corp. and Monroe
Community Health Services.  Mercy operates a 238-licensed-bed
facility (179 staffed) in Monroe, Mich., about 40 miles south of
Detroit as well as a 70-bed skilled-nursing center.


MORGAN STANLEY: Fitch Issues Presale Report on 2011-C1 Certs.
-------------------------------------------------------------
Fitch Ratings has issued a presale report on Morgan Stanley
Capital I Trust 2011-C1 commercial mortgage pass-through
certificates.

Fitch expects to rate the transaction and assign Loss Severity
ratings, with a Stable Outlook:

  -- $87,863,000 class A-1 'AAAsf/LS1';
  -- $597,153,000 class A-2 'AAAsf/LS1';
  -- $105,120,000 class A-3 'AAAsf/LS1';
  -- $404,067,000 class A-4 'AAAsf/LS1';
  -- $1,194,203,000* class X-A 'AAAsf';
  -- $60,001,000 class B 'AAsf/LS3';
  -- $89,033,000 class C 'Asf/LS3';
  -- $85,162,000 class D 'BBBsf/LS3';
  -- $19,355,000 class E 'BBB-sf/LS5';
  -- $13,548,000 class F 'BB+sf/LS5';
  -- $15,484,000 class G 'BBsf/LS5'.
  * Notional amount and interest only.

The expected ratings are based on information provided by the
issuer as of Jan. 31, 2011.  Fitch does not expect to rate
the $13.5 million class H, the $15.5 million class J, the
$13.5 million class K, the $9.7 million class L, the $19.4 million
class M, or the interest-only class X-B.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 37 loans secured by 79 commercial
properties having an aggregate principal balance of approximately
$1.55 billion as of the cutoff date.  The loans were originated by
Morgan Stanley Mortgage Capital Holdings and Banc of America
Mortgage Capital Corporation.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 80.2% of the properties
by balance, cash flow analysis of 89.6% of the pool and asset
summary reviews on 89.6% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.20 times, a Fitch stressed loan-to value of 93.6%, and
a Fitch debt yield of 10.4%.  Fitch's aggregate net cash flow
represents a variance of 8.1% to issuer cash flows.

The transaction is concentrated by loan and sponsor.  The largest
10 loans account for 71.8% of the pool, and the largest 15 account
for 82%.  There is no material sponsor concentration across
multiple loans.

The Master Servicer and Special Servicer will be Bank of America,
N.A. and Midland Loan Services, Inc., rated 'CMS2+' and 'CSS1',
respectively, by Fitch.


MORGAN STANLEY: Fitch Downgrades Ratings on 13 2006-HQ9 Certs.
--------------------------------------------------------------
Fitch Ratings downgrades and removes from Rating Watch Negative 13
classes of Morgan Stanley Capital I Trust 2006-HQ9 commercial
mortgage pass-through certificates, primarily due to an increase
in specially serviced loans.

The downgrades reflect an increase in Fitch modeled losses across
the pool, which includes assumed losses on loans in special
servicing and on performing loans with declines in performance
indicative of a higher probability of default.  Fitch modeled
losses of 4.4% (4.9% cumulative transaction losses which includes
losses realized to date).  Fitch expects losses on specially
serviced loans to delete classes L through Q and a portion of
class K.  As of January 2010, there are cumulative interest
shortfalls in the amount of $4.95 million currently affecting
classes K through Q.

As of the January 2010 distribution date, the pool's aggregate
principal balance has been paid down by 2.77% to $2.49 billion
from $2.57 billion at issuance.  There are no defeased loans.

Fitch has identified 64 loans (26.2%) as Fitch Loans of Concern,
which includes 21 specially serviced loans (10.1%).

The largest contributor to modeled losses is the Center Point
Complex Portfolio loan (1.23%) which is collateralized by four
specialty trade-mart properties located in High Point, NC.  The
aggregate square footage for the portfolio is 460,681 square
feet (sf).  All of the tenants are in the furniture and home
improvement sectors.  The loan transferred to the special servicer
due to a decline in occupancy and a drop in market rents.  The
special servicer is negotiating a resolution with the borrower.
The city of High Point, NC is highly dependent on the furniture
industry and also contains the International Home Furnishings
Center which is the largest showroom center with approximately
2.7 million sf of showroom space.

The second largest contributor to modeled losses is the Gateway
Shopping Center loan (2.41%) which is collateralized by a 257,844
sf retail power center located in West Bloomfield, MI within the
Detroit MSA.  The property is anchored by Kohl's, Walgreens,
Staples, Petsmart and Whole Foods.  The loan transferred to the
special servicer due to performance issues related to the vacancy
of Linens N' Things.  The vacant space has since been leased to
Dunham's Sporting Goods in February 2009.  Occupancy is currently
at 97% as of December 2010 with debt service coverage ratio (DSCR)
of 1.18 times.  Year end 2010 net operating income (NOI) has
increased 3% from YE2009.

The third largest contributor to modeled losses is the 80
Broad Street loan (5.0%) which is collateralized by a 397,485
sf office building in the Financial District of Manhattan.
The loan transferred to the special servicer due to an event of
default concerning the borrower's failure to fund its tenant
improvement and leasing cost reserves to a predetermined amount
of $3.5 million as required by the loan documents.  As of November
2010 occupancy has declined to 83% from 95% at YE 2009.  DSCR has
also declined to 1.16x from 1.51x at YE2009.  The special servicer
has retained a broker to market the note for sale.

In total, there are currently 21 loans (10.1%) in special
servicing, which consists of four loans (0.96%) in foreclosure, 10
loans (3.08%) that are 90 days delinquent and seven loans (6.05%)
that are current.

At Fitch's last review there were 13 loans (3.9%) in special
servicing consisting of 11 loans (3.56%) that were 30 to 90 days
delinquent and two loans (0.31%) in foreclosure.

Fitch downgrades, removes from Rating Watch Negative and assigns
Recovery Ratings, Loss Severity ratings and Outlooks to these
classes as indicated:

  -- $35.3 million class C to 'Asf/LS5' from 'AAsf/LS5'; Outlook
     Stable;

  -- $22.4 million class E to 'BBBsf/LS5' from 'Asf/LS5'; Outlook
     Stable;

  -- $25.7 million class F to 'BBB-sf/LS5' from 'BBBsf/LS5';
     Outlook Stable;

  -- $25.7 million class G to 'BBsf/LS5' from 'BBB-sf/LS5';
     Outlook Stable;

  -- $28.9 million class H to 'Bsf/LS5' from 'BBsf/LS5'; Outlook
     Stable;

  -- $32.1 million class J to 'CCCsf/RR1' from 'Bsf/LS5';

  -- $25.7 million class K to 'CCCsf/RR2' from 'B-sf/LS5';

  -- $9.6 million class L to 'CCCsf/RR6' from 'B-sf/LS5';

  -- $3.2 million class M to 'CCCsf/RR6' from 'B-sf/LS5';

  -- $9.6 million class N to 'CCCsf/RR6' from 'B-sf/LS5';

  -- $6.4 million class O to 'CCsf/RR6' from 'B-sf/LS5'

  -- $3.2 million class P to 'CCsf/RR6' from 'B-sf/LS5';

  -- $9.6 million class Q to 'CCsf/RR6' from 'B-sf/LS5'.

Fitch affirms, removes from Rating Watch Negative and assigns Loss
Severity ratings and Outlooks to these classes as indicated:

  -- $256.5 million class A-M at 'AAAsf/LS3'; Outlook Stable;
  -- $202 million class A-J at 'AAsf/LS3'; Outlook Stable;
  -- $19.2 million class B at 'AAsf/LS5'; Outlook Stable
  -- $28.9 million class D at 'Asf/LS5'; Outlook Stable.

Additionally, Fitch affirms these classes, with a Stable Outlook:

  -- $23.4 million class A-1 at 'AAAsf/LS1'; Outlook Stable;
  -- $154.7 million class A-1A at 'AAAsf/LS1'; Outlook Stable;
  -- $92.9 million class A-2 at 'AAAsf/LS1'; Outlook Stable;
  -- $215 million class A-3 at 'AAAsf/LS1'; Outlook Stable;
  -- $84.6 million class A-AB at 'AAAsf/LS1'; Outlook Stable;
  -- $784.2 million class A-4 at 'AAAsf/LS1'; Outlook Stable;
  -- $350 million class A-4FL at 'AAAsf/LS1'; Outlook Stable;
  -- $214 thousand class ST-A at 'BBB-sf'; Outlook Stable;
  -- $2.9 million class ST-B at 'BBsf'; Outlook Stable;
  -- $1.1 million class ST-C at 'BB-sf'; Outlook Stable;
  -- $2.3 million class ST-D at 'Bsf'; Outlook Stable;
  -- $1.3 million class ST-E at 'B-sf'; Outlook Stable.

The ST classes are related to a non-pooled B-Note secured by 633
Indiana Ave NW.  Fitch affirms these classes as the underlying
collateral is a single-tenant building, 100% occupied by the
General Service Administration, on a long-term lease through
September 2020.

Fitch withdraws the ratings of the interest only classes X and X-
MP.  The interest only X-RC class has been paid in full.


MORGAN STANLEY: Moody's Takes Rating Actions on 1998-CF1 Notes
--------------------------------------------------------------
Moody's Investors Service upgraded the rating of one class and
affirmed five classes of Morgan Stanley Capital I Inc., Commercial
Mortgage Pass-Through Certificates, Series 1998-CF1:

  -- Cl. X Certificate, Affirmed at Aaa (sf); previously on
     Aug. 25, 1998 Assigned Aaa (sf)

  -- Cl. D Certificate, Affirmed at Aaa (sf); previously on
     April 15, 2009 Upgraded to Aaa (sf)

  -- Cl. E Certificate, Upgraded to Aa3 (sf); previously on
     April 15, 2009 Upgraded to A2 (sf)

  -- Cl. F Certificate, Affirmed at B2 (sf); previously on
     April 15, 2009 Upgraded to B2 (sf)

  -- Cl. G Certificate, Affirmed at C (sf); previously on Dec. 23,
     2003 Downgraded to C (sf)

  -- CL H Certificate, Affirmed at C (sf); previously on Dec. 23,
     2003 Downgraded to C (sf)

                        Ratings Rationale

The upgrade is due to overall improved pool performance and a
significant increase in subordination levels 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
8.0% of the current balance, the same as at last review.  Moody's
stressed scenario loss is 10.1% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a pay down analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade 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 17 compared to 22 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 April 15, 2009.

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

                         Deal Performance

As of the January 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 92% to
$92.5 million from $1.1 billion at securitization.  The
Certificates are collateralized by 44 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 57% of the pool.  Five loans, representing 10% of the
pool, have defeased and are collateralized by U.S. Government
securities.  There are no loans in the pool with investment grade
credit estimates.

Nine loans, representing 15% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package.  As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Twenty-four loans have been liquidated from the pool since
securitization, resulting in a $77.8 million loss.  At last review
the pool had experienced an aggregate $76.5 million loss.  Two
loans, representing 7% of the pool, are currently in special
servicing.  Moody's has estimated an aggregate $5.5 million loss
(90% expected loss on average) for the two specially serviced
loans.

Moody's has assumed a high default probability for three poorly
performing loans representing 5% of the pool and has estimated a
$534,000 loss (13% expected loss based on a 50% probability
default) from these troubled loans.

Moody's was provided with full year 2009 operating results for 84%
of the pool's non-defeased loans and partial year 2010 results for
61% of the pool's non-defeased loans.  Excluding specially
serviced and troubled loans, Moody's weighted average LTV is 56%
compared to 74% at Moody's prior review.  Moody's net cash flow
reflects a weighted average haircut of 10.2% to the most recently
available net operating income.  Moody's value reflects a weighted
average capitalization rate of 10.1%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 2.27X and 2.18X, respectively, compared to
1.42X and 1.81X 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 26% of the pool
balance.  The largest loan is the Bristol Market Place Loan
($9.4 million -- 10.2% of the pool), which is secured by a 99,256
square foot (SF) retail center located in Santa Ana, California.
Financial performance has declined due to lower occupancy at 90%
as of September 2010 versus 92% at last review.  Recent financial
performance suggests improved financial performance coupled with
5% amortization since last review.  Moody's LTV and stressed DSCR
are 72% and 1.44X, respectively, compared to 71% and 1.44X at last
review.

The second largest loan is the Preston Place Apartments Loan
($7.8 million -- 8.5% of the pool), which is secured by a 239-unit
apartment complex located in Plano, Texas.  Financial performance
has improved since last review due to higher occupancy.  The
property was 93% leased as of September 2010 compared to 88% at
last review.  The loan has amortized 15% since last review.
Moody's LTV and stressed DSCR are 36% and 3.0X, respectively,
compared to 50% and 2.18X at last review.

The third largest loan is the Van Dorn Station Loan ($7.1 million
-- 7.7% of the pool), which is secured by a 74,500 SF retail
center located in Alexandria, Virginia adjacent to a Metro stop.
The property's financial performance improved slightly since last
review despite a 2% drop in occupancy to 93% as of December 2009
from 95% as of December 2008.  There are presently re-leasing
efforts underway to fill the former Comcast space which expired
December 2010.  This loan has amortized 5% since last review.
Moody's LTV and stressed DSCR are 42% and 2.6X, respectively,
compared to 50% and 2.4X at last review.


MORGAN STANLEY: Moody's Downgrades Ratings on 2003-IQ6 Certs.
-------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes
and affirmed 13 classes of Morgan Stanley Capital I Trust,
Commercial Mortgage Pass-Through Certificates, Series 2003-IQ6:

  -- Cl. A-3 Certificate, Affirmed at Aaa (sf); previously on
     Jan. 19, 2011 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. A-4 Certificate, Affirmed at Aaa (sf); previously on
     Jan. 19, 2011 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. A-1A Certificate, Affirmed at Aaa (sf); previously on
     Jan. 19, 2011 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. X-1 Certificate, Affirmed at Aaa (sf); previously on
     Jan. 19, 2011 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. X-2 Certificate, Affirmed at Aaa (sf); previously on
     Jan. 19, 2011 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. X-Y Certificate, Affirmed at Aaa (sf); previously on
     Jan. 19, 2011 Aaa (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. B Certificate, Affirmed at Aa1 (sf); previously on
     Jan. 19, 2011 Aa1 (sf) Placed Under Review for Possible
     Downgrade

  -- Cl. C Certificate, Affirmed at A1 (sf); previously on Jan. 5,
     2007 Upgraded to A1 (sf)

  -- Cl. D Certificate, Affirmed at A3 (sf); previously on
     Dec. 19, 2003 Definitive Rating Assigned A3 (sf)

  -- Cl. E Certificate, Affirmed at Baa1 (sf); previously on
     Dec. 19, 2003 Definitive Rating Assigned Baa1 (sf)

  -- Cl. F Certificate, Affirmed at Baa2 (sf); previously on
     Dec. 19, 2003 Definitive Rating Assigned Baa2 (sf)

  -- Cl. G Certificate, Affirmed at Baa3 (sf); previously on
     Dec. 19, 2003 Definitive Rating Assigned Baa3 (sf)

  -- Cl. H Certificate, Affirmed at Ba1 (sf); previously on
     Dec. 19, 2003 Definitive Rating Assigned Ba1 (sf)

  -- Cl. J Certificate, Downgraded to Ba3 (sf); previously on
     Dec. 19, 2003 Definitive Rating Assigned Ba2 (sf)

  -- Cl. K Certificate, Downgraded to B2 (sf); previously on
     Dec. 19, 2003 Definitive Rating Assigned Ba3 (sf)

  -- Cl. L Certificate, Downgraded to B3 (sf); previously on
     Dec. 19, 2003 Definitive Rating Assigned B1 (sf)

  -- Cl. M Certificate, Downgraded to Caa2 (sf); previously on
     Sept. 18, 2008 Downgraded to B3 (sf)

  -- Cl. N Certificate, Downgraded to Caa3 (sf); previously on
     Sept. 18, 2008 Downgraded to Caa1 (sf)

                        Ratings Rationale

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

Moody's rating action reflects a cumulative base expected loss of
2.2% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.9%.  Moody's stressed scenario loss is
5.4% of the current balance.

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

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

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

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions.  Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score, a measure of loan level diversity, is a primary determinant
of pool level diversity and has a greater impact on senior
certificates.  Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 September 18, 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 January 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 16% to
$837.6 million from $997.7 million at securitization.  The
Certificates are collateralized by 166 mortgage loans ranging in
size from less than 1% to 13% of the pool, with the top ten loans
representing 46% of the pool.  The pool includes 77 loans with
investment grade credit estimates, representing 38% of the pool.
Loans secured by residential cooperative properties account for 72
of those loans and 13% of the pool.  Nine loans, representing 6%
of the pool, have defeased and are collateralized with U.S.
Government securities.

Twenty-one loans, representing 5% 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 trust since securitization.
Currently two loans, the Charleston Tower Office Building Loan
($11.5 million -- 1.4% of the pool) and Corn Exchange National
Bank Loan ($4.9 million -- 0.6% of the pool) are in special
servicing.  The Charleston Tower Office Building Loan transferred
to special servicing in January 2010 and the property became REO
in August 2010.  The Corn Exchange National Bank Loan was
transferred to special servicing in June 2010 due to payment
default.  Moody's has estimated an aggregate $7.1 million loss
(43% expected loss overall) for the specially serviced loans.

Moody's has assumed a high default probability for two poorly
performing loans representing 1.1% of the pool.  Moody's has
estimated a $2.2 million loss (25% expected loss based on a 50%
probability default) from the troubled loans.

Moody's was provided with full year 2009 operating results for 89%
of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV for the conduit component is 77%
compared to 80% 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 8.8%.

Excluding specially serviced and troubled loans, Moody's actual
DSCR for the conduit component is 1.49X, compared to 1.52X at last
review.  Moody's stressed DSCR for the conduit component is 1.38.
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 25 compared to 31 at Moody's prior review.

The largest loan with a credit estimate is the Mall at Tuttle
Crossing Loan ($112.5 million -- 13.4% of the pool), which is
secured by a 380,953 square foot mall located in Columbus, Ohio.
Anchor tenants include JC Penny, Sears and Macy's.  The loan is
sponsored by Simon Property Group.  As of September 2010, the
property was 90% leased compared to 83% at last review.  Due to an
increase in occupancy, performance has improved since last review.
Moody's credit estimate and stressed DSCR are A2 and 1.52X,
respectively, compared to A3 and 1.43X at last review.

The second loan with a credit estimate is the WestShore Plaza Loan
($30.0 million -- 3.6% of the pool), which represents a 34% pari
passu interest in a $88.1 million loan.  The loan is secured by a
1.1 million SF regional mall located in Tampa, Florida.  As of
September 2010, the property was 98% leased, which is the same as
at last review.  The loan is sponsored by Glimcher Properties.
Performance has been stable.  Moody's credit estimate and stressed
DSCR are A2 and 1.60X, respectively, compared to A2 and 1.55X at
last review.

The third loan with a credit estimate is the 3 Times Square Loan
($25.9 million -- 3.1% of the pool), which represents a 20.6% pari
passu interest in $145.5 million A-note.  The loan is
collateralized by a 883,405 SF class A office property located in
the Time Square District of New York City.  Major tenants include
Reuters (79% of the net rentable area; lease expiration November
2021) and Bank of Montreal (12% of the NRA; lease expiration
November 2021).  The property has been 100% leased since
securitization.  The loan is sponsored by the Rudin Management
Company and Reuters.  The loan was structured with a 218 month
amortization schedule and has amortized 11% since last review.
Moody's credit estimate and stressed DSCR are Aaa and 3.25X,
respectively, compared to Aaa and 2.74X at last review.

The fourth loan with a credit estimate is the 250 W 19th Street
Loan ($18.7 million -- 2.2% of the pool), which is secured by a
200 unit apartment building located in New York City's Chelsea
neighborhood.  As of October 2010, the property was 95% leased, a
slight decline from 98% at last review.  Performance has been
stable.  Moody's credit estimate and stressed DSCR are Aaa and
1.95X, respectively, compared to Aaa and 1.91X at last review.

The fifth loan with a credit estimate is the Country Club Mall
Loan ($17.7 million -- 2.1% of the pool), which is secured by a
392,139 SF mall located in Cumberland, Maryland.  The mall is
anchored by Sears (23% of the NRA; lease expiration October 2012),
Bon-Ton (19% of the NRA; lease expiration January 2012) and JC
Penny (18% of NRA; lease expiration March 2011).  The absence of
competing retail centers in the region offsets concerns about
upcoming lease expirations.  Moody's credit estimate and stressed
DSCR are Baa2 and 1.74X, respectively, compared to Baa2 and 1.65X
at last review.

The top three performing conduit loans represent 15.3% of
the pool.  The largest loan is the 840 North Michigan Loan
($55.5 million -- 6.6% of the pool), which is secured by an 87,136
SF retail center located on Chicago's Magnificent Mile, a shopping
and entertainment district.  Major tenants include H&M (53% of the
NRA; lease expiration August 2013), Escada (28% of the NRA; lease
expiration January 2013) and Casual Male (15% of the NRA; lease
expiration January 2013).  Occupancy at the property has remained
at 100% since securitization.  Performance has improved since last
review due to amortization and rent increases.  Moody's LTV and
stressed DSCR are 71% and 1.43X, respectively, compared to 79% and
1.13 at last review.

The second largest loan is the 88 Sidney Street Loan
($36.4 million -- 4.3% of the pool), which is collateralized by a
145,275 SF class A medical office building located in Cambridge,
Massachusetts.  The property is 100% leased to a single tenant,
Alkermes Inc., whose lease expires in June 2012.  Moody's utilized
a Lit/Dark analysis to reflect potential cash flow volatility due
to the single tenant's near term lease expiration.  The loan was
structured with a 300 month amortization schedule and has
amortized 6% since last review.  Moody's LTV and stressed DSCR are
78% and 1.31X, respectively, compared to 81% and 1.27X at last
review.

The third largest loan is the 609 Fifth Avenue Loan ($35.9 million
-- 4.3% of the pool), which represents a 37.3% pari passu interest
in a $96.4 million loan.  The loan is secured by a 147,958 SF
office and street retail property located in the Rockefeller
Center submarket of New York City.  Major tenants include American
Girl Place (34% of the NRA; lease expiration March 2018; retail
tenant), DZ Bank (29% of the NRA; lease expiration March 2017;
office tenant) and Reebok (10% of the NRA; lease expiration
November 2013; office tenant).  Performance has been stable.
Moody's LTV and stressed DSCR are 91% and 1.07X, respectively,
compared to 94% and 1.04X at last review.


MORGAN STANLEY: S&P Assigns Ratings to $1.55 Bil. 2011-C1 Certs.
----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Morgan Stanley Capital I Trust 2011-C1's $1.55 billion
commercial mortgage pass-through certificates.

The preliminary ratings are based on information as of Feb. 4,
2011.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

The preliminary ratings reflect the credit support provided by the
subordinate classes of certificates, the liquidity provided by the
trustee, and the underlying loans' economics, geographic
diversity, and property type diversity.  In its analysis, S&P
determined that, on a weighted average basis, the pool has a debt
service coverage of 1.20x based on a weighted average Standard &
Poor's Ratings Services loan constant of 8.46%, a beginning loan-
to-value ratio of 88.9%, and an ending LTV ratio of 78.5%.  To
calculate the number of loans, S&P considered each group of cross-
collateralized and cross-defaulted loans as one loan.

                   Preliminary Ratings Assigned

              Morgan Stanley Capital I Trust 2011-C1

            Class        Rating             Amount ($)
            -----        ------             ----------
            A-1          AAA (sf)           87,863,000
            A-2          AAA (sf)          597,153,000
            A-3          AAA (sf)          105,120,000
            A-4          AAA (sf)          404,067,000
            X-A*         AAA (sf)      1,194,203,000**
            X-B*         NR              354,197,430**
            B            AA (sf)            60,001,000
            C            A (sf)             89,033,000
            D            BBB (sf)           85,162,000
            E            BBB- (sf)          19,355,000
            F            BB+ (sf)           13,548,000
            G            BB (sf)            15,484,000
            H            BB- (sf)           13,549,000
            J            B+ (sf)            15,484,000
            K            B (sf)             13,548,000
            L            B- (sf)             9,678,000
            M            NR                 19,355,430
            R            NR                        N/A

     * Interest-only class.
     ** Notional amount.
     NR -- Not rated.
     N/A -- Not applicable.


MORGAN STANLEY: S&P Downgrades Ratings on Three Classes of Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class IA, IB, and IIA notes from Morgan Stanley Managed ACES'
series SPC 2007-11 to 'D (sf)'.

The lowered ratings follow a number of recent write-downs of
underlying reference entities, which have caused the notes to
incur partial principal losses.

                         Ratings Lowered

                 Morgan Stanley Managed ACES SPC
                         Series 2007-11

                                  Rating
                                  ------
               Class           To        From
               -----           --        ----
               IA              D (sf)    CCC- (sf)
               IB              D (sf)    CCC- (sf)
               IIA             D (sf)    CC (sf)


NATIONAL CITY: Fitch Withdraws Ratings on Six Classes of Notes
--------------------------------------------------------------
Fitch Ratings has withdrawn the ratings on six classes of National
City Mortgage Loan Trust 2005-1.

On Oct. 28, 2010, PNC Bank, N.A., exercised its option as the
sole holder of the outstanding certificates to terminate the
transaction and directed Wells Fargo Bank, N.A. the trustee, to
cancel all of the outstanding certificates.

Fitch has withdrawn the ratings on these classes:

  -- Class A (CUSIP: 635420AF9) 'CCsf/RR2';
  -- Class M1 (CUSIP: 635420AA0) 'Csf/RR6';
  -- Class M2 (CUSIP: 635420AB8) 'Csf/RR6';
  -- Class M3 (CUSIP: 635420AC6) 'Dsf/RR6';
  -- Class M4 (CUSIP: 635420AD4) 'Dsf/RR6';
  -- Class M5 (CUSIP: 635420AE2) 'Dsf/RR6'.


NEWCASTLE CDO: Moody's Downgrades Ratings on Class I-MM to 'B1'
---------------------------------------------------------------
Moody's has downgraded one class of Notes issued by Newcastle CDO
VI, Ltd., due to the deterioration in the credit quality of the
underlying portfolio as evidenced by an increase in the weighted
average rating factor, and and increase in Defaulted Securities.
The rating action is the result of Moody's on-going surveillance
of commercial real estate collateralized debt obligation
transactions.

  -- Class I-MM Floating Rate Notes, Downgraded to B1 (sf);
     previously on Feb. 24, 2010 Downgraded to Ba2 (sf)

                        Ratings Rationale

Newcastle CDO VI, Ltd., is a CRE CDO transaction backed by a
portfolio of conduit, large loan and rake classes of commercial
mortgage backed securities (60.5%), subprime residential mortgage
backed securities (20.6%), REIT debt (16.0%), term loans (2.5%),
and small business loans (0.4%).  As of the January 18, 2011
Trustee report, the aggregate Note balance of the transaction has
decreased to $419.2 million from $500.0 million at issuance, with
the principal paydown directed to the Class I-MM Notes.  The
paydowns are a result of the failure of the Class I, Class II,
Class II, and Class IV Par Value Tests.  Per the Indenture dated
April 5, 2005, upon the failure of any Par Value Test, all
scheduled interest and principal payments are directed to pay down
the notes in a senior sequential manner, until the failed Par
Value Test is satisfied.  Additionally, there is currently
approximately $5.4 million in accrued interest proceeds to Class
II, Class III, Class IV, and Class V notes.

There are twenty assets with par balance of $96.3 million (26.0%
of the current pool balance) that are considered Defaulted
Securities as of the January 18, 2010 Trustee report.  Thirteen of
these assets (37.0% of the defaulted balance) are RMBS, five
assets are CMBS (50.5%), one asset is REIT (12.5%), and one asset
is a small business loan (1.7%).  While there have been no
realized losses to date, Moody's does expect significant losses to
occur once they are realized.

Moody's has identified these parameters as key indicators of the
expected loss within CRE CDO transactions: WARF, weighted average
life, weighted average recovery rate, and Moody's asset
correlation.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's have completed updated credit estimates for the non-
Moody's rated reference obligations.  The bottom-dollar WARF is a
measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 2,362 (excluding defaulted
securities) compared to 1,603 at last review.  The distribution of
current ratings and credit estimates (excluding defaulted
securities) is: Aaa-Aa3 (14.1% compared to 5.5% at last review),
A1-A3 (12.0% compared to 9.2% at last review) Baa1-Baa3
(16.3%compared to 22.3% at last review), Ba1-Ba3 (19.6% compared
to 20.7% at last review), B1-B3 (19.3% compared to 18.2% at last
review), and Caa1-C (18.7% compared to 24.4% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL,
excluding defaulted securities, of 3.7 years compared to 4.5 years
at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled a fixed WARR,
excluding defaulted securities, of 22.0% compared to 22.7% at last
review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 12.7% compared to 25.6% at last review.
The low MAC is due to higher default probability collateral
concentrated within a small number of collateral names.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

The cash flow model, CDOEdge(R) v3.2.1.0, was used to analyze the
cash flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes.  However,
in many instances, a change in key parameter assumptions in
certain stress scenarios may be offset by a change in one or more
of the other key parameters.  Rated notes are particularly
sensitive to changes in recovery rate assumptions.  Holding all
other key parameters static, changing the recovery rate assumption
down from 22% to 12% or up to 32% would result in average rating
movement on the rated tranches of 1 notch downward and 1 notch
upward, respectively.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term.  From time to time, Moody's may, if warranted, change
these expectations.  Performance that falls outside the given
range may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated when the related
securities ratings were issued.  Even so, a deviation from the
expected range will not necessarily result in a rating action nor
does performance within expectations preclude such actions.  The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.  Primary sources of assumption
uncertainty are the current sluggish macroeconomic environment and
varying performance in the commercial real estate property
markets.  However, Moody's expects to see increasing or
stabilizing property values, higher transaction volumes, a slowing
in the pace of loan delinquencies and greater liquidity for
commercial real estate in 2011 The hotel and multifamily sectors
are continuing to show signs of recovery, while recovery in the
office and retail sectors will be tied to recovery of the broader
economy.  The availability of debt capital continues to improve
with terms returning toward market norms.  Moody's central global
macroeconomic scenario reflects an overall sluggish recovery
through 2012, amidst ongoing individual, corporate and
governmental deleveraging, persistent unemployment, and government
budget considerations.

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.


NORTHWOODS CAPITAL: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, A-3, A-4, B, C, D, and E notes from Northwoods Capital
VII Ltd., a collateralized loan obligation transaction managed by
Angelo, Gordon & Co. L.P.  At the same time, S&P removed its
ratings on the class A-1, A-2, A-3, A-4, and B notes from
CreditWatch with positive implications.

The upgrades reflect the improved performance S&P has observed in
the deal since December 2009, when S&P downgraded each of the
classes following a review of the transaction under its updated
criteria for rating corporate collateralized debt obligations.

At the time of S&P's last rating action, according to the trustee
report, the transaction was holding $104.43 million in assets
rated 'CCC+' or below, either by Standard & Poor's or another
rating agency.  This is compared with $73.62 million as of the
Dec. 12, 2010 monthly report.  In combination with a reduction
amount of assets rated 'CCC+' and below, the deal has also had an
increase it its overcollateralization (O/C) ratio.  As of December
2010, the class A/B O/C ratio had improved to 137.69% from 127.10%
in December 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

                    Northwoods Capital VII Ltd.

                               Rating
                               ------
        Class             To           From
        -----             --           ----
        A-1               AA+ (sf)     A+ (sf)/Watch Pos
        A-2               AA+ (sf)     A+ (sf)/Watch Pos
        A-3               AAA (sf)     AA+ (sf)/Watch Pos
        A-4               AA+ (sf)     A+ (sf)/Watch Pos
        B                 AA- (sf)     BBB+ (sf)/Watch Pos
        C                 A (sf)       BB+ (sf)
        D                 BBB (sf)     CCC+ (sf)
        E                 BB (sf)      CCC- (sf)

                          NR - Not rated.


OAK HILL: S&P Raises Ratings on Various Classes of Notes
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-2a, A-2b, B, C-1, C-2, D-1, D-2, and D-3 notes from Oak
Hill Credit Partners II Ltd., a collateralized loan obligation
transaction managed by Oak Hill Advisors L.P.  At the same time,
S&P removed its ratings on the class C-1, C-2, D-1, D-2, and D-3
notes from CreditWatch, where S&P placed them with positive
implications on Nov. 8, 2010.  S&P also affirmed its 'AAA (sf)'
ratings on the class A-1a and A-1b notes.

The upgrades reflect an improvement in the performance of the
transaction's underlying asset portfolio, as well as paydowns
to the pari passu class A-1a and A-1b notes since its Dec. 11,
2009, rating action, when S&P downgraded some of the rated notes
following the application of its September 2009 corporate CDO
criteria.  As of the January 2011 trustee report, the transaction
had $0.61 million of defaulted assets.  This was down from
$35.3 million noted in the November 2009 trustee report, which
S&P referenced for its December 2009 rating actions.  The
affirmations of S&P's ratings on the class A-1a and A-1b notes
reflect the availability of credit support at the current rating
levels.  Through the same time period, the pari passu class A-1a
and A-1b notes had been paid down by a total of $149 million,
leaving them at their current amount of 35% of their original
balance.

Subsequently, the transaction has benefited from an increase in
the overcollateralization available to support the rated notes.
The trustee reported these O/C ratios in the Jan. 1, 2011 monthly
report:

* The class A O/C ratio was 168.40%, compared with a reported
  ratio of 126.06% in November 2009;

* The class B O/C ratio was 140.29%, compared with a reported
  ratio of 115% in November 2009;

* The class C O/C ratio was 120.77%, compared with a reported
  ratio of 105.99% in November 2009; and

* The class D O/C ratio was 114.35%, compared with a reported
  ratio of 102.74% 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

                 Oak Hill Credit Partners II Ltd.

                          Rating
                          ------
            Class     To           From
            -----     --           ----
            A-2a      AAA (sf)     AA (sf)
            A-2b      AAA (sf)     AA (sf)
            B         AAA (sf)     A (sf)
            C1        A (sf)       BB+ (sf)/Watch Pos
            C2        A (sf)       BB+ (sf)/Watch Pos
            D1        BB+ (sf)     CCC+ (sf)/Watch Pos
            D2        BB+ (sf)     CCC+ (sf)/Watch Pos
            D3        BB+ (sf)     CCC+ (sf)/Watch Pos

                         Ratings Affirmed

                 Oak Hill Credit Partners II Ltd.

                Class                    Rating
                -----                    ------
                A-1a                     AAA (sf)
                A-1b                     AAA (sf)

  Transaction Information
  -----------------------
Issuer:             Oak Hill Credit Partners II Ltd.
Coissuer:           Oak Hill Credit Partners II Inc.
Collateral manager: Oak Hill Advisors L.P.
Underwriter:        Deutsche Bank Alex Brown
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CLO


OHA INTREPID: S&P Assigns Ratings on $364 Mil. Floating Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to OHA Intrepid Leveraged Loan Fund Ltd./OHA Intrepid
Leveraged Loan Fund Inc.'s $364.0 million floating-rate notes.

The preliminary ratings are based on information as of Feb. 7,
2011.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

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

* The credit enhancement provided to the preliminary rated notes
  through the subordination of cash flows that are payable to the
  subordinated notes;

* The transaction's cash flow structure, which Standard & Poor's
  assessed using the assumptions and methods outlined in its
  corporate collateralized debt obligation criteria, which
  can withstand the default rate projected by Standard & Poor's
  CDO Evaluator model;

* The transaction's legal structure, which is expected to be
  bankruptcy remote;

* The diversified collateral portfolio, which consists primarily
  of speculative-grade senior secured term loans;

* The collateral manager's experienced management team;

S&P's expectation of timely interest and ultimate principal
payments on the rated notes, which S&P assessed using its cash
flow analysis and assumptions that are commensurate with the
assigned preliminary ratings under various interest rate
scenarios, including LIBOR rates ranging from 0.344%-12.256%; and

The transaction's overcollateralization and interest coverage
tests, a failure of which will lead to the diversion of interest
and principal proceeds to reduce the outstanding balance of the
rated notes.

                  Preliminary Ratings Assigned

              OHA Intrepid Leveraged Loan Fund Ltd./
              OHA Intrepid Leveraged Loan Fund Inc.

          Class             Rating        Amount (mil. $)
          -----             ------        ---------------
          A                 AAA (sf)                265.0
          B                 AA (sf)                  26.0
          C (deferrable)    A (sf)                   35.0
          D (deferrable)    BBB (sf)                 18.0
          E (deferrable)    BB (sf)                  20.0
          Subordinated      NR                       49.0

                         NR - Not rated.


OSPREY CDO: Moody's Upgrades Ratings on Various Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Osprey CDO 2006-1 Ltd.:

  -- US$7,500,000 Class X Notes Due January 2014 (current balance
     of $4,062,500), Upgraded to Aaa (sf); previously on
     October 16, 2009 Downgraded to A1 (sf);

  -- US$184,000,000 Class A-1LA Floating Rate Notes Due 2022
     (current balance of $162,955,732), Upgraded to Baa1 (sf);
     previously on October 16, 2009 Downgraded to Ba1 (sf);

  -- US$28,000,000 Class A-1LB Floating Rate Notes Due 2022
     (current balance of $25,352,706), Upgraded to Ba1 (sf);
     previously on October 16, 2009 Downgraded to B1 (sf);

  -- US$34,000,000 Class A-2L Floating Rate Notes Due 2022,
     Upgraded to B1 (sf); previously on November 23, 2010 Caa2
     (sf) Placed Under Review for Possible Upgrade;

  -- US$15,000,000 Class A-3L Floating Rate Notes Due 2022,
     Upgraded to Caa1 (sf); previously on November 23, 2010 Caa3
     (sf) Placed Under Review for Possible Upgrade;

  -- US$10,000,000 Class B-1L Floating Rate Notes Due 2022
     (current balance of $9,373,000), Upgraded to Caa3 (sf);
     previously on November 23, 2010 Ca (sf) Placed Under Review
     for Possible Upgrade.

                        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 increase in the overcollateralization ratios of the
rated notes since the rating action in October 2009.

The deal has benefited from improvement in the credit quality of
the underlying portfolio since the rating action in October 2009.
Based on the December 2010 trustee report, the weighted average
rating factor is 2584 compared to 2771 in August 2009, and
securities rated Caa1 and below make up approximately 13% of the
underlying portfolio versus 16.3% in August 2009.  The deal also
experienced a decrease in defaults.  In particular, the dollar
amount of defaulted securities has decreased to $6.7 million from
approximately $19 million in August 2009.

The transaction is exposed to a significant concentration in
mezzanine and junior CLO tranches in the underlying portfolio.
Based on the latest trustee report, CLO Securities currently held
in the portfolio total about $105.9 million, accounting for
approximately 39.4% of the collateral balance.  Moody's observes
that recent credit qualities in mezzanine and junior CLO tranches
in the underlying portfolio have stabilized or improved.

Moody's notes that the overcollateralization ratios of the rated
notes have improved in part due to delevering of the Class A-1LA
and A-1LB Notes, which have been paid down by approximately 8.5%
or $17.6 million since the rating action in October 2009.
Available principal proceeds and excess spread are being diverted
to pay down the Class A-1LA and A-1LB Notes as a result of
continued failure of the Class B-2L overcollateralization ratio
test.  Furthermore, the overcollateralization ratios have also
improved due to a decrease in the number of defaulted CLO
tranches.  A number of CLO tranches were defaulted and carried at
depressed market values in the rating action in October 2009 but
are currently treated as performing securities due to improved
credit qualities.  As of the latest trustee report dated December
20, 2010, the Class A, Class B-1L, and Class B-2L
overcollateralization ratios are reported at 117.36%, 112.9%, and
99.62%, respectively, versus August 2009 levels of 108.69%,
104.83%, and 92.67%, respectively.

The rating actions on the Class X Notes and Class A-1LA Notes in
October 2009 took into consideration the increased risk of an
event of default, which has been mitigated since the last rating
action.  This is reflected in part in the upgrade rating actions
on the Class X and A-1LA Notes.

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 balance of $278.3 million, defaulted par of $7.7 million,
a weighted average default probability of 35.89% (implying a WARF
of 4375), a weighted average recovery rate upon default of 29.8%,
and a diversity score of 47.  These default and recovery
properties of the collateral pool are incorporated in Moody's 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.

Osprey CDO 2006-1 Ltd. issued on December 13, 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans and CLO securities.

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, due to the low
diversity of the collateral pool, CDOROM 2.6 was used to simulate
a default distribution that was then applied as an input in the
cash flow model.

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on all
rated notes of various default probabilities.  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,
whereby a positive difference corresponds to lower expected
losses), assuming that all other factors are held equal:

Moody's Adjusted WARF - 20% (3500)

  -- Class X: 0
  -- Class A-1LA: +2
  -- Class A-1LB: +2
  -- Class A-2L: +3
  -- Class A-3L: +3
  -- Class B-1L: +3

Moody's Adjusted WARF + 20% (5250)

  -- Class X: 0
  -- Class A-1LA: -3
  -- Class A-1LB: -2
  -- Class A-2L: -2
  -- Class A-3L: -2
  -- Class B-1L: 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 manager's
investment strategy 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:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels.  Further, the timing of
   recoveries and the manager's decision to work out versus sell
   defaulted assets create additional uncertainties.  Moody's
   analyzed defaulted recoveries assuming the lower of the market
   price and the recovery rate in order to account for potential
   volatility in market prices.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels.  Moody's analyzed the impact of assuming lower
   of reported and covenanted values for weighted average rating
   factor, weighted average spread, weighted average coupon, and
   diversity score.  In addition, as part of the base case,
   Moody's considered a lower diversity score due to the large
   concentration of CLO tranches.


PACIFICA CDO: S&P Affirms Junk Ratings on 3 Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B-1, and B-2 notes from Pacifica CDO II Ltd., a
collateralized loan obligation transaction managed by Alcentra
Ltd. At the same time, S&P removed its ratings on the class A-1
and A-2 notes from CreditWatch, where S&P placed them with
positive implications on Nov. 8, 2010.  S&P also affirmed its
'CCC+' (sf) ratings on the class C-1 and C-2 notes and its 'CCC-'
(sf) rating on the class D notes.

The upgrades reflect an improvement in the credit quality
available to support the notes since S&P's Oct. 23, 2009 rating
actions, when S&P downgraded most of the rated notes, following
the application of its September corporate CDO criteria and the
paydowns to the class A-1 notes.  Since October 2009, the
transaction has paid down approximately $99.46 million to the
class A-1 notes, including a $13 million payment on the Dec. 31,
2010 distribution date.  As of the Dec. 31, 2010 trustee report,
the transaction had $6.67 million in defaulted assets.  This was
down from $17.26 million noted in the Sept. 1, 2009 trustee
report.

Since the time of S&P's last rating action, a number of defaulted
obligors whose assets are held in the deal emerged from
bankruptcy, and some received proceeds that were higher than their
carrying value in the transaction's overcollateralization ratio
test calculation.  This, in combination with a $99.5 million
paydown to the class A-1 notes, has benefited the transaction's
O/C ratios.

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

                       Pacifica CDO II Ltd.

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

                         Ratings Affirmed

                        Class     Rating
                        -----     ------
                        C-1       CCC+ (sf)
                        C-2       CCC+ (sf)
                        D         CCC- (sf)

Transaction Information
-----------------------
Issuer:              Pacifica CDO II Ltd.
Coissuer:            Pacifica CDO II Inc.
Collateral manager:  Alcentra Ltd.
Underwriter:         Credit Suisse AG
Trustee:             The Bank of New York Mellon
Transaction type:    Cash flow CLO


PACIFICA CDO: S&P Raises Ratings on C-1 & C-2 Notes to B+
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2a, A-2b, B-1, B-2, C-1, and C-2 notes from Pacifica CDO III
Ltd., a collateralized loan obligation transaction managed by
Alcentra Ltd. At the same time, S&P removed its ratings on the
class A-2a and A-2b notes from CreditWatch, where S&P placed them
with positive implications on Nov. 8, 2010.  S&P also affirmed its
'AA+ (sf)' rating on the class A-1 notes.

The upgrades reflect an improvement in the credit quality
available to support the notes since S&P's Nov. 25, 2009, rating
action, when S&P downgraded most of the rated notes, following the
application of S&P's revised corporate CDO criteria and the
paydowns to the class A-1 notes.  Since November 2009, the
transaction has paid down approximately $49.27 million to the
class A-1 notes, including a $26 million payment on the Jan. 3,
2011, distribution date.  As of the Jan. 3, 2011, trustee report,
the transaction had $8.57 million in defaulted assets.  This was
down from $26.37 million noted in the Sept. 3, 2009, trustee
report.

Since the time of S&P's last rating action, a number of defaulted
obligors held in the deal emerged from bankruptcy, with some
receiving proceeds that were higher than their carrying value in
the overcollateralization ratio test calculation.  This, in
combination with a reduction in assets with ratings in the 'CCC'
range, benefited the transaction's O/C ratios.

The trustee reported these O/C ratios in the Jan. 3, 2011, monthly
report:

* The class A O/C ratio was 117.99%, compared with a reported
  ratio of 110.38% in Sept. 3 2009;

* The class B O/C ratio was 113.04%, compared with a reported
  ratio of 106.47% in Sept. 3 2009; and

* The class C O/C ratio was 104.66%, compared with a reported
  ratio of 99.71% in Sept. 3 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

                       Pacifica CDO III Ltd.

                        Rating
                        ------
             Class   To          From
             -----   --          ----
             A-2a    AA- (sf)    BBB+ (sf) /Watch Pos
             A-2b    AA- (sf)    BBB+ (sf) /Watch Pos
             B-1     A- (sf)     BBB (sf)
             B-2     A- (sf)     BBB (sf)
             C-1     B+ (sf)     CCC- (sf)
             C-2     B+ (sf)     CCC- (sf)

                          Rating Affirmed

                       Pacifica CDO III Ltd.

                        Class     Rating
                        -----     ------
                        A-1       AA+ (sf)

  Transaction Information
  -----------------------
Issuer:              Pacifica CDO III Ltd.
Coissuer:            Pacifica CDO III Inc.
Collateral manager:  Alcentra Ltd.
Underwriter:         Credit Suisse AG
Trustee:             Bank of New York Mellon (The)
Transaction type:    Cash flow CLO


PEGASUS 2007-1: Moody's Cuts Rating on Class A1 Notes to 'Ba1'
--------------------------------------------------------------
Moody's has downgraded one class of Notes issued by Pegasus 2007-
1, Ltd., due to the deterioration in the credit quality of the
underlying reference obligations as evidenced by an increase in
the weighted average rating factor.  The rating action is the
result of Moody's on-going surveillance of commercial real estate
collateralized debt obligation transactions.

  -- US$112M Cl. A1 Notes Notes, Downgraded to Ba1 (sf);
     previously on Feb. 19, 2010 Downgraded to Baa1 (sf)

                        Ratings Rationale

Pegasus 2007-1 Ltd. is a synthetic CRE CDO transaction backed
by commercial mortgage backed securities (100.0%) reference
obligations.  As of the January 18, 2011 Trustee report, the
aggregate Note balance of the transaction has remained
$112.0 million, the same as at issuance.

Moody's has identified these parameters as key indicators of the
expected loss within CRE CDO transactions: WARF, weighted average
life, weighted average recovery rate, and Moody's asset
correlation.  These parameters are typically modeled as actual
parameters for static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's have completed updated credit estimates for the non-
Moody's rated reference obligations.  The bottom-dollar WARF is a
measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 25 compared to 6 at last
review.  The distribution of current ratings and credit estimates
is: Aaa-Aa3 (89.3% compared to 96.4% at last review) and A1-A3
(10.7% compared to 3.6% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 5.1
years compared to 6.0 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled a fixed WARR
of 69.6% compared to 73.8% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 63.7% compared to 69.1% at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes.  However,
in many instances, a change in key parameter assumptions in
certain stress scenarios may be offset by a change in one or more
of the other key parameters.  Rated notes are particularly
sensitive to changes in recovery rate assumptions.  Holding all
other key parameters static, changing the recovery rate assumption
down from 70% to 60% or up to 80% would result in average rating
movement on the rated tranches of 0 to 1 notches downward and 0 to
1 notches upward, respectively.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term.  From time to time, Moody's may, if warranted, change
these expectations.  Performance that falls outside the given
range may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated when the related
securities ratings were issued.  Even so, a deviation from the
expected range will not necessarily result in a rating action nor
does performance within expectations preclude such actions.  The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.  Primary sources of assumption
uncertainty are the current sluggish macroeconomic environment and
varying performance in the commercial real estate property
markets.  However, Moody's expects to see increasing or
stabilizing property values, higher transaction volumes, a slowing
in the pace of loan delinquencies and greater liquidity for
commercial real estate in 2011.  The hotel and multifamily sectors
are continuing to show signs of recovery, while recovery in the
office and retail sectors will be tied to recovery of the broader
economy.  The availability of debt capital continues to improve
with terms returning toward market norms.  Moody's central global
macroeconomic scenario reflects an overall sluggish recovery
through 2012, amidst ongoing individual, corporate and
governmental deleveraging, persistent unemployment, and government
budget considerations.

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.


PHOENIX CDO: Moody's Upgrades Ratings on Two Classes of Notes
-------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of two classes of notes issued by Phoenix CDO II, Ltd.
The classes of notes affected by the rating action are:

  -- Class A First Priority Senior Secured Floating Rate Notes Due
     2035 (current balance of $22,711,703), Upgraded to A1 (sf);
     previously on August 21, 2009 Downgraded to Ba1 (sf)

  -- Class B Secondary Priority Senior Secured Floating Rate Notes
     Due 2035, Upgraded to Baa3 (sf); previously on August 21,
     2009 Downgraded to B1 (sf)

                        Ratings Rationale

According to Moody's, the rating actions taken on the notes result
primarily from the continuing amortization of the Class A Notes,
which have been paid off by 51.4 million since August 2009.  The
deal also benefits from the diversion of excess interest to
amortize the Class A Notes.  This benefit is magnified due to high
interest bearing fixed rate assets in the portfolio which are used
to pay floating rate liabilities.  The portfolio is primarily
backed by pre-2000 vintage ABS assets, which are expected to have
stable performance.

The deal experienced an Event of Default in 2003 and subsequently
declared acceleration.  Given the strict voting requirement for
liquidation (super majority of each class voting as a separate
class), the risk of a liquidation being declared is considered
low.

Phoenix CDO II, Ltd., is a collateralized debt obligation backed
primarily by a portfolio of CMBS, RMBS and ABS originated from
1997 to 2002.

Moody's performed a number of sensitivity analyses in addition to
the standard notching assumption applied to assets under review
for possible downgrade.  Moody's considered negative sensitivity
runs including downgrading all non-investment grade assets to Ca.
The model results for the notes worsened within three notches
compared to the standard assumption but were nevertheless still
better than the current rating.

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.6 to model the loss distribution for SF CDOs.  Within
this framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference.
Specifically, correlated defaults are simulated using a normal (or
"Gaussian") copula model that applies the asset correlation
framework.  Recovery rates for defaulted credits are generated by
applying within the simulation the distributional assumptions,
including correlation between recovery values.  Together, the
simulated defaults and recoveries across each of the Monte Carlo
scenarios define the loss distribution for the reference pool.

Once the loss distribution for the collateral has been calculated,
each collateral loss scenario derived through the CDOROM loss
distribution is associated with the interest and principal
received by the rated liability classes via the CDOEdge cash-flow
model.  The cash flow model takes into account these: collateral
cash flows, the transaction covenants, the priority of payments
(waterfall) for interest and principal proceeds received from
portfolio assets, reinvestment assumptions, the timing of
defaults, interest-rate scenarios and foreign exchange risk (if
present).  The Expected Loss for each tranche is the weighted
average of losses to each tranche across all the scenarios, where
the weight is the likelihood of the scenario occurring.  Moody's
defines the loss as the shortfall in the present value of cash
flows to the tranche relative to the present value of the promised
cash flows.  The present values are calculated using the promised
tranche coupon rate as the discount rate.  For floating rate
tranches, the discount rate is based on the promised spread over
Libor and the assumed Libor scenario.

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


PHOENIX CLO: Moody's Upgrades Ratings on Four Classes of Notes
--------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Phoenix CLO I, Ltd.:

  -- US$302,000,000 Class A Senior Secured Floating Rate Notes Due
     2018 (current outstanding balance of $287,346,915), Upgraded
     to Aa2 (sf); previously on June 17, 2009 Downgraded to A3
     (sf);

  -- US$39,500,000 Class B Second Priority Deferrable Floating
     Rate Notes Due 2018, Upgraded to Ba1 (sf); previously on
     June 17, 2009 Downgraded to B3 (sf);

  -- US$13,000,000 Class C Third Priority Deferrable Floating Rate
     Notes Due 2018, Upgraded to B1 (sf); previously on
     November 23, 2010 Ca (sf) Placed Under Review for Possible
     Upgrade;

  -- US$15,500,000 Class D Fourth Priority Deferrable Floating
     Rate Notes Due 2018 (current outstanding balance of
     $13,810,776), Upgraded to Caa2 (sf); previously on
     November 23, 2010 C (sf) Placed Under Review for Possible
     Upgrade.

                        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 transaction's
overcollateralization ratios since the rating action in June 2009.

Improvement in the credit quality is observed through an
improvement in the average credit rating (as measured by the
weighted average rating factor) and a decrease in the proportion
of securities from issuers rated Caa1 and below.  In particular,
as of the latest trustee report dated December 24, 2010, the
weighted average rating factor is currently 2514 compared to 2829
in the April 2009 report, and securities rated Caa1/CCC+ or lower
make up approximately 7.4% of the underlying portfolio versus
15.4% in June 2009.  Additionally, defaulted securities total
about $12.5 million of the underlying portfolio compared to
$28.9 million in April 2009.

The overcollateralization ratios of the rated notes have also
improved since the rating action in June 2009.  The Class A, Class
B, Class C and Class D overcollateralization ratios are reported
at 125.85%, 110.64%, 106.40% and 102.25%, respectively, versus
April 2009 levels of 114.66%, 101.36%, 97.63% and 93.84%,
respectively, and all related overcollateralization tests are
currently in compliance.  Moody's also notes that the Class B,
Class C and Class D Notes are no longer deferring interest and
that all previously deferred interest has been paid in full.

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 balance of $354.5 million, defaulted par of $16.6
million, a weighted average default probability of 26.02%
(implying a WARF of 3311), a weighted average recovery rate upon
default of 43.88%, 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.

Phoenix CLO I, Ltd., issued in October 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis, Moody's also performed
sensitivity analyses to test the impact on all rated notes of
various default probabilities.  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, whereby a
positive difference corresponds to lower expected losses),
assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2649)

  -- Class X: 0
  -- Class A: +2
  -- Class B: +3
  -- Class C: +2
  -- Class D: +2

Moody's Adjusted WARF + 20% (3973)

  -- Class X: 0
  -- Class A: -2
  -- Class B: -1
  -- Class C: -1
  -- Class D: -2

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the manager's
investment strategy 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:

1.  Recovery of defaulted assets: Market value fluctuations in
    defaulted assets reported by the trustee and those assumed to
    be defaulted by Moody's may create volatility in the deal's
    overcollateralization levels.  Further, the timing of
    recoveries and the manager's decision to work out versus sell
    defaulted assets create additional uncertainties.  Moody's
    analyzed defaulted recoveries assuming the lower of the market
    price and the recovery rate in order to account for potential
    volatility in market prices.

2.  Weighted average life: The notes' ratings are sensitive to the
    weighted average life assumption of the portfolio, which may
    be extended due to the manager's decision to reinvest into new
    issue loans or other loans with longer maturities and/or
    participate in amend-to-extend offerings.  Moody's tested for
    a possible extension of the actual weighted average life in
    its analysis.

3.  Other collateral quality metrics: The deal is allowed to
    reinvest and the manager has the ability to deteriorate the
    collateral quality metrics' existing cushions against the
    covenant levels.  Moody's analyzed the impact of assuming
    lower of reported and covenanted values for weighted average
    rating factor, weighted average spread, weighted average
    coupon, and diversity score.


PONTIAC BUILDING: Moody's Downgrades GO Limited Tax Rating to 'B2'
------------------------------------------------------------------
Moody's Investors Service has downgraded the general obligation
limited tax rating for Pontiac Building Authority (MI) to B2 from
B1 with negative outlook and placed the rating on review for
possible further downgrade.  The B2 rating applies to $615,000 of
outstanding lease rental bonds that are secured by the City of
Pontiac's general obligation limited tax pledge.

                        Ratings Rationale

                Further Narrowing Of Liquidity And
         Deterioration In Local Economy Drives Downgrade

The downgrade of the city's GOLT rating reflects the city's
extremely narrowed liquidity and unmanageable operating deficit,
exacerbated by General Fund support for special obligation tax
increment debt (not rated by Moody's), increasingly pressured
local employment and tax base profile, and uncertainty of
management plans to take swift and material action to stabilize
the city's financial position.

The city's General Fund performance has deteriorated in recent
years, including declining State Revenue Sharing funds, lagging
municipal income tax revenues, and increasing property
delinquencies and appeals.  As revenues have fallen, many
operating expenditures, such as health care and energy costs, have
increased significantly over the same period, exacerbating
operating deficits and increasing the city's structural budget
gaps.

In response to the city's financial distress, in early 2009, the
Governor appointed an Emergency Financial Manager to oversee all
of the city's financial operations for a one year period beginning
March 1, 2009.  A replacement EFM was appointed in June 2010 and a
deficit reduction plan was released on September 1, 2010.  Among
several options to address the General Fund's deficit position,
per statute, the EFM may recommend applying for federal bankruptcy
protection under Chapter 9 of the US Bankruptcy Code, although
this has not been considered to date.  Exacerbating the fiscal
pressures have been numerous instances of accounting and financial
reporting shortcomings, including a restatement of $8 million in
fiscal year 2004 for prior period adjustments.

Also, the EFM's September 1, 2010 report noted additional
liabilities not accounted for in the audit, including
uncollectible taxes and a pending tax appeal by General Motors.
Although the audit reports a modest $700,000 General Fund surplus,
this surplus is supported by several one-time revenues, and does
not include the tax liabilities noted by the EFM.  Although the
city initially passed a balanced budget for fiscal 2011, the EFM
currently projects an $8.8 million operating deficit in the
General Fund and has proposed several measures to narrow this gap.
These proposals include a request for GERS/VEBA contributions,
layoffs, privatization of various administrative processes, and
contracting for police services with Oakland County while
eliminating the city's police department.  The last item, the
transfer of the city's police force to the county, would have
saved the city $2 million on an annual basis; but this option was
dropped by the EFM after a lawsuit by the city's police officers
union.  Without implementation of any of the proposed reductions,
the EFM's report dated September 1, 2010, projects a $9.7 million
operating deficit in fiscal 2012 and a $13.2 million operating
deficit in fiscal 2013.  This would reduce the city's General Fund
in fiscal 2013 to a substantial negative $36 million, equivalent
to 107% of projected fiscal 2013 General Fund revenues.

The city's pressured financial operations is in part due to the
significantly adverse economic conditions.  Pontiac serves as the
county seat of Oakland County (GO rated Aaa), and has historically
been the major industrial center of the area.  Over the past five
decades, Pontiac's population has fallen by nearly 25% and its
demographic profile remains one of the weakest in the nation.
Despite a labor force which has declined, unemployment levels have
remained persistently high.  The city's October 2010 unemployment
rate was 28.9%, more than twice the states 12% rate for the same
period.

          Review For Further Downgrade Pending Review Of
Updated Deficit Elimination Plan For Fiscal 2011, 2012, And 2013

The review for possible downgrade reflects Moody's ongoing
assessment of the financial workout plan proposed by the state-
appointed Emergency Fiscal Manager.  In Moody's review of the
workout plan, Moody's will consider:

-- The city's plans to continue to support non-general obligation
    tax increment debt, which continues to underperform and drain
    scarce resources from city coffers.  Moody's will also
    consider the expected time frame and likelihood of default of
    tax increment debt payments in the context of the city's
    overall plan.

-- Assumptions related to key revenue items including property
    and income tax collections and state aid distributions for the
    remainder of fiscal 2011 and 2012.  Local tax revenues and
    intergovernmental aid comprised 56% and 26%, respectively, of
    fiscal 2010 General Fund revenues.

-- Feasibility of the EFM's gap closing measures for the
    projected $13 million General Fund gap for fiscal 2011.

-- Availability of internal liquidity and/or options for external
    liquidity to support overall operations and repayment of debt.

-- Implications of settlement with GM over property tax appeals

                 What Could Change The Rating Up?

-- Disciplined expenditure reductions coupled with strengthened
    on-going revenue streams to eliminate deficit position

-- Dramatic improvement in employment levels

-- Significant increases in property tax collection levels

-- Successful negotiation results with unions

                What Could Change The Rating Down?

-- Escalation of deficit position

-- Further tax base deterioration

-- Increased property tax appeals

-- Inability to make expenditure cuts

-- Difficulty making timely debt service payments on general
    obligation bonds


RESIX FINANCE: Fitch Withdraws Ratings on All Classes of Notes
--------------------------------------------------------------
Fitch Ratings has withdrawn the ratings on all classes in RESIX
Finance 2006-B and RESIX Finance 2007-A.

The affected classes have been written-off due to losses and have
no outstanding balances remaining.  The trustee has terminated the
deal based on all class balances being zero.

Fitch has withdrawn these ratings:

RESIX Finance Limited Partnership, Series 2006-B

  -- Class B7 'Dsf/RR6';
  -- Class B8 'Dsf/RR6';
  -- Class B9 'Dsf/RR6';
  -- Class B10 'Dsf/RR6';
  -- Class B11 'Dsf/RR6'.

EASIX Finance Limited Partnership, Series 2007-A

  -- Class B7 'Dsf/RR6';
  -- Class B8 'Dsf/RR6';
  -- Class B9 'Dsf/RR6';
  -- Class B10 'Dsf/RR6';
  -- Class B11 'Dsf/RR6';
  -- Class B12 'Dsf/RR6'.


SARATOGA CLO: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, C, and D notes from Saratoga CLO I Ltd., a collateralized
loan obligation transaction managed by INVESCO Senior Secured
Management Inc. S&P removed its ratings on the class A-2 and B
notes from CreditWatch with positive implications.  At the same
time, S&P affirmed its ratings on the class A-2 notes.

The upgrades reflect improved performance S&P has observed in the
deal's underlying asset portfolio since its last rating action in
November 2009.  The affirmation reflects the availability of
credit support at the class' current rating levels.

According to the Jan. 10, 2011, trustee report, the transaction
currently holds $21.9 million in 'CCC' rated assets, down from
$33.8 million noted in the Sept. 2, 2009, trustee report.  In
addition, the transaction holds $3.2 million in defaulted
securities, down from $32.6 million in September 2009.
Accordingly, the transaction's overcollateralization ratios
have improved:

* The class A O/C ratio is 125.22% versus 122.47% in September
  2009;

* The class B O/C ratio is 113.3% versus 110.81% in September
  2009;

* The class C O/C ratio is 108.45% versus 106.07% in September
  2009; and

* The class D O/C ratio is 106.32% versus 103.99% in September
  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

                        Saratoga CLO I Ltd.

                            Rating
                            ------
            Class       To          From
            -----       --          ----
            A-2         AA+ (sf)    A+ (sf)/Watch Pos
            B           BBB+ (sf)   BBB- (sf)/Watch Pos
            C           BB+ (sf)    B+ (sf)
            D           B+ (sf)     CCC+ (sf)

                          Rating Affirmed

                        Saratoga CLO I Ltd.

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


SATURN CLO: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-1S, A-1J, A-2, B, C, and D notes from Saturn CLO Ltd., a
collateralized loan obligation transaction managed by PineBridge
Investments LLC.  At the same time, S&P removed its ratings on the
class A-1, A-1S, A-1J, and A-2 from CreditWatch, where S&P placed
them with positive implications on Nov. 8, 2010.

The upgrades reflect an improvement in the credit quality
available to support the notes since S&P's Oct. 23, 2009 rating
action, when S&P downgraded the rated notes following the
application of its September 2009 corporate CDO criteria.  As of
the Jan. 3, 2011 trustee report, there were no defaulted assets in
the portfolio.  This was down from $17.42 million noted in the
Sep.  1, 2009 trustee report, which S&P referenced for S&P's
October 2009 rating actions.

The transaction has also benefited from an increase in
overcollateralization available to support the rated notes.  The
trustee reported these O/C ratios in the Jan. 3, 2011 monthly
report:

* The class A O/C ratio was 121.53%, compared with a reported
  ratio of 118.45% in August 2009;

* The class B O/C ratio was 114.19%, compared with a reported
  ratio of 111.30% in August 2009;

* The class C O/C ratio was 108.93%, compared with a reported
  ratio of 106.17% in August 2009; and

* The class D O/C ratio was 104.13%, compared with a reported
  ratio of 101.49% in August 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

                          Saturn CLO Ltd.

                          Rating
                          ------
            Class     To           From
            -----     --           ----
            A-1       AA+ (sf)     AA (sf) /Watch Pos
            A-1S      AAA (sf)     AA+ (sf) /Watch Pos
            A-1J      AA+ (sf)     AA (sf) /Watch Pos
            A-2       AA (sf)      A+ (sf) /Watch Pos
            B         A (sf)       BBB+ (sf)
            C         BBB (sf)     BB+ (sf)
            D         B+ (sf)      CCC- (sf)

Transaction Information
-----------------------
Issuer:              Saturn CLO Ltd.
Coissuer:            Saturn CLO Inc.
Collateral manager:  PineBridge Investments LLC
Underwriter:         JPMorgan Securities Inc.
Trustee:             Bank of New York Mellon (The)
Transaction type:    Cash flow CLO


SCHOONER TRUST: Moody's Affirms Ratings on 17 Certificates
----------------------------------------------------------
Moody's Investors Service affirmed the ratings of 17 classes of
Schooner Trust Commercial Mortgage Pass-Through Certificates,
Series 2005-3:

  -- Cl. A-1 Certificate, Affirmed at Aaa (sf); previously on
     July 19, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2 Certificate, Affirmed at Aaa (sf); previously on
     July 19, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. XP-1 Certificate, Affirmed at Aaa (sf); previously on
     July 19, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. XP-2 Certificate, Affirmed at Aaa (sf); previously on
     July 19, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. XC-1 Certificate, Affirmed at Aaa (sf); previously on
     July 19, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. XC-2 Certificate, Affirmed at Aaa (sf); previously on
     July 19, 2005 Definitive Rating Assigned Aaa (sf)

  -- Cl. B Certificate, Affirmed at Aa2 (sf); previously on
     July 19, 2005 Definitive Rating Assigned Aa2 (sf)

  -- Cl. C Certificate, Affirmed at A2 (sf); previously on
     July 19, 2005 Definitive Rating Assigned A2 (sf)

  -- Cl. D-1 Certificate, Affirmed at Baa2 (sf); previously on
     July 19, 2005 Definitive Rating Assigned Baa2 (sf)

  -- Cl. D-2 Certificate, Affirmed at Baa2 (sf); previously on
     July 19, 2005 Definitive Rating Assigned Baa2 (sf)

  -- Cl. E Certificate, Affirmed at Baa3 (sf); previously on
     July 19, 2005 Definitive Rating Assigned Baa3 (sf)

  -- Cl. F Certificate, Affirmed at Ba1 (sf); previously on
     July 19, 2005 Definitive Rating Assigned Ba1 (sf)

  -- Cl. G Certificate, Affirmed at Ba2 (sf); previously on
     July 19, 2005 Definitive Rating Assigned Ba2 (sf)

  -- Cl. H Certificate, Affirmed at Ba3 (sf); previously on
     July 19, 2005 Definitive Rating Assigned Ba3 (sf)

  -- Cl. J Certificate, Affirmed at B1 (sf); previously on
     July 19, 2005 Definitive Rating Assigned B1 (sf)

  -- Cl. K Certificate, Affirmed at B2 (sf); previously on
     July 19, 2005 Definitive Rating Assigned B2 (sf)

  -- Cl. L Certificate, Affirmed at B3 (sf); previously on
     July 19, 2005 Definitive Rating Assigned B3 (sf)

                        Ratings Rationale

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
1.3% of the current balance.  At last review, Moody's cumulative
base expected loss was 1.1%.  Moody's stressed scenario loss is
5.0% of the current balance.

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

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

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

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

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors.  Therefore,
the rating outcome may differ from the model output.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities transactions.  Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated March 31, 2010.

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

                         Deal Performance

As of the January 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 18% to
$324.7 million from $396 million at securitization.  The
Certificates are collateralized by 83 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 42% of the pool.  The pool contains two loans with
investment grade credit estimates that represent 6% of the pool.
Eight loans, representing 6% of the pool, have defeased and are
collateralized with Canadian Government securities.

Seven loans, representing 3% 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 realized any losses since securitization.  There
are no loans currently in special servicing.

Moody's was provided with full year 2009 operating results for 73%
of the pool.  Moody's conduit weighted average LTV is 69% compared
to 75% 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 8.8%.

Moody's conduit actual and stressed DSCRs are 1.55X and 1.50X,
respectively, compared to 1.46X 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.

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 29 at Moody's prior review.

The largest loan with a credit estimate is the 71 Rexdale
Boulevard Loan ($10.8 million -- 3.3%), which is secured by a
167,000 square foot single-tenant industrial building located in
Toronto, Ontario.  The property is 100% leased to Cargill Limited
through September 2012.  Moody's current credit estimate and
stressed DSCR are Baa3 and 1.27X, respectively, the same as at
last review.

The second loan with a credit estimate is the Vaughan Industrial
Portfolio ($8.1 million -- 2.5%), which is secured by 13
industrial buildings located in Vaughan, Ontario.  The portfolio
was 83% leased as of March 2010 compared to 76% at last review.
At securitization the portfolio included 17 properties, but four
have been released through defeasance.  Moody's current credit
estimate and stressed DSCR are A2 and 1.96X, respectively,
compared to Baa1 and 1.51X at last review.

The top three performing conduit loans represent 18% of the
pool balance.  The largest loan is the Portsmouth Place Loan
($21.8 million -- 6.7%), which is secured by a 400-unit
multifamily building located in Kingston, Ontario.  The
property was 99% leased as of February 2010 compared to 100%
at last review.  Moody's LTV and stressed DSCR are 76% and
1.10X, respectively, compared to 80% and 1.05X at last review.

The second largest loan is the Corner Brook Plaza Loan
($19.2 million -- 5.9%), which is secured by a 233,347 square
foot shopping center located in Corner Brook, Newfoundland.
The property was 96% leased as of February 2010, similar to
last review.  At last review Moody's was concerned about the
approaching lease expirations of two tenants representing 51% of
the center and stressed the cash flow to reflect potential decline
in income.  The tenants have renewed and performance has exceeded
Moody's previous expectations.  Moody's LTV and stressed DSCR are
75% and 1.36X, respectively, compared to 93% and 1.11X at last
review.

The third largest loan is the Metro Self Storage Portfolio
($17.3 million -- 5.3%), which is secured by seven self-storage
properties located in Halifax and Turo, Nova Scotia.  The
portfolio was 99% leased as of December 2009 compared to 93% at
last review.  Performance has improved due to increased rental
revenue.  Moody's LTV and stressed DSCR are 60% and 1.66X,
respectively, compared to 76% and 1.32X at last review.


SIERRA CLO: S&P Raises Ratings on Various Classes of Notes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1L, A-1LV, A-2L, A-3L, B-1L, and B-2L notes from Sierra CLO II
Ltd., a collateralized loan obligation transaction managed by
Churchill Pacific Asset Management LLC.  At the same time, S&P
removed its ratings on the class A-1L, A-1LV, A-2L, and A-3L notes
from CreditWatch, where S&P placed them with positive implications
on Nov. 8, 2010.  S&P also affirmed its 'AAA (sf)' rating on the
class X notes.

The upgrades reflect an improvement in the credit quality
available to support the notes since S&P's Jan. 29, 2010 rating
action, when S&P downgraded all of its rated notes, except the
class X notes, following the application of its revised corporate
CDO criteria.  As of the Dec. 13, 2010 trustee report, the
transaction had $9.46 million in defaulted assets.  This was
down from $25.44 million noted in the Dec. 11, 2009, trustee
report, which S&P referenced for its January 2010 rating
actions.  Furthermore, assets from obligors rated in the 'CCC'
category were reported at $12.3 million in December 2010,
compared with $25.97 million in December 2009.

The transaction has also benefited from an increase in
overcollateralization (O/C) available to support the rated notes.
The trustee reported the following O/C ratios in the Dec. 13, 2010
monthly report:

* The senior class A O/C ratio was 122.69%, compared with a
  reported ratio of 118.71% in December 2009;

* The class A O/C ratio was 114.58%, compared with a reported
  ratio of 110.91% in December 2009;

* The class B-1L O/C ratio was 109.69%, compared with a reported
  ratio of 106.20% in December 2009; and

* The class B-2L O/C ratio was 105.06%, compared with a reported
  ratio of 101.66% in December 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

                         Sierra CLO II Ltd.

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

                          Rating Affirmed

                         Sierra CLO II Ltd.

                      Class         Rating
                      -----         ------
                      X             AAA (sf)

Transaction Information
-----------------------
Issuer:              Sierra CLO II Ltd.
Coissuer:            Sierra CLO II (Delaware) Corp.
Collateral manager:  Churchill Pacific Asset Management LLC
Underwriter:         Bear Stearns Cos. LLC (The)
Trustee:             Bank of New York Mellon (The)
Transaction type:    Cash flow CLO


SOLAR TRUST: Moody's Upgrades Ratings on Six 2003-CC1 Certs.
------------------------------------------------------------
Moody's Investors Service upgraded the ratings of six classes and
affirmed eight classes of Solar Trust, Commercial Mortgage Pass-
Through Certificates, Series 2003-CC1:

  -- Cl. A-1 Certificate, Affirmed at Aaa (sf); previously on
     May 27, 2003 Definitive Rating Assigned Aaa (sf)

  -- Cl. A-2 Certificate, Affirmed at Aaa (sf); previously on
     May 27, 2003 Definitive Rating Assigned Aaa (sf)

  -- Cl. IO-1 Certificate, Affirmed at Aaa (sf); previously on
     May 27, 2003 Definitive Rating Assigned Aaa (sf)

  -- Cl. IO-2 Certificate, Affirmed at Aaa (sf); previously on
     May 27, 2003 Definitive Rating Assigned Aaa (sf)

  -- Cl. B Certificate, Affirmed at Aaa (sf); previously on
     July 27, 2006 Upgraded to Aaa (sf)

  -- Cl. C Certificate, Upgraded to Aaa (sf); previously on
     Sept. 25, 2008 Upgraded to Aa1 (sf)

  -- Cl. D-1 Certificate, Upgraded to A1 (sf); previously on
     Sept. 25, 2008 Upgraded to Baa1 (sf)

  -- Cl. D-2 Certificate, Upgraded to A1 (sf); previously on
     Sept. 25, 2008 Upgraded to Baa1 (sf)

  -- Cl. E Certificate, Upgraded to Baa1 (sf); previously on
     May 27, 2003 Definitive Rating Assigned Baa3 (sf)

  -- Cl. F Certificate, Upgraded to Baa2 (sf); previously on
     May 27, 2003 Definitive Rating Assigned Ba1 (sf)

  -- Cl. G Certificate, Upgraded to Ba1 (sf); previously on
     May 27, 2003 Definitive Rating Assigned Ba2 (sf)

  -- Cl. H Certificate, Affirmed at Ba3 (sf); previously on
     May 27, 2003 Definitive Rating Assigned Ba3 (sf)

  -- Cl. J Certificate, Affirmed at B3 (sf); previously on
     April 9, 2009 Downgraded to B3 (sf)

  -- Cl. K Certificate, Affirmed at Caa1 (sf); previously on
     April 9, 2009 Downgraded to Caa1 (sf)

                        Ratings Rationale

The upgrades are due to increased credit subordination due to
amortization and loans payoffs and overall improved pool
performance.

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.  At last review, Moody's cumulative
base expected loss was 5.1%.  Moody's stressed scenario loss is
3.8% 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
2011; Moody's expects overall a sluggish recovery in most of the
world's largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

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

Moody's 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 26 compared to 28 at Moody's prior 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 April 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 December 13, 2010 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 35%
to $305.3 million from $468.2 million at securitization.  The
Certificates are collateralized by 58 loans ranging in size from
less than 1% to 7% of the pool, with the top 10 loans representing
49% of the pool.  Six loans, representing 6% of the pool, have
defeased and are collateralized with Canadian Government
securities.

One loan, representing 1% of the pool, is on the master servicer's
watchlist.  There have been no realized losses since
securitization and there are currently no delinquent or specially
serviced loans.

Moody's was provided with full year 2009 operating statements for
64% of the pool.  Moody's LTV ratio is 63% compared to 78% 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 10.0%.

Moody's actual and stressed DSCRs are 2.17X and 2.32X,
respectively, compared to 1.45X and 1.54X 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 three largest loans represent 19% of the pool.  The largest
loan is the Eglinton Square Loan ($21.9 million -- 7.2%), which is
secured by a 275,000 square foot retail center located in the
Greater Toronto area.  The property was 95% leased as of March
2010 compared to 91% at last review.  Moody's LTV and stressed
DSCR are 63% and 1.68X, respectively, compared to 80% and 1.33X at
the last review.

The second largest loan is the Kirkland Centre Loan ($21.6 million
-- 7.1%), which is secured by a 225,000 square foot retail center
located in suburban Montreal.  The property was 98% leased as of
February 2010 compared to 92% at last review and 100% at
securitization.  Anchor tenants include Winners and Business
Depot, both of which are on long-term leases.  The loan is full
recourse to the sponsor, RioCan Real Investment Trust, Canada's
largest real estate investment trust.  Moody's LTV and stressed
DSCR are 66% and 1.47X, respectively, compared to 67% and 1.45X at
Moody's last review.

The third largest loan is the Matheson Boulevard Loan
($15.7 million -- 5.1%), which is secured by a 187,000 square foot
Class A suburban office building located in Mississauga, Ontario.
Performance has improved since last review due to increased
revenues and stable expenses.  The property has been 100% leased
since securitization, however, the lease for a tenant which
occupied 24% of the premises expired in December 2010.  Moody's
have not yet received confirmation of whether the tenant is still
in occupancy but Moody's analysis reflects a stressed cash flow to
reflect the potential loss of income from this tenant.  Moody's
LTV and stressed DSCR are 68% and 1.47X, respectively, compared to
84% and 1.45X at last review.


ST JOSEPH: S&P Withdraws 'CCC' Rating on Revenue Bonds
------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'CCC' long-term
rating on the St. Joseph County Hospital Authority, Indiana's
series 2005 and 1999 revenue bonds and series 1997 general
obligation economic development refunding bonds, issued for
Madison Center Inc., due to a lack of pertinent information from
Madison Center required to update the rating.  S&P had lowered the
rating to 'CCC' from 'BB+' and placed it on CreditWatch with
negative implications on Sept. 10, 2010.

Madison Center provides mental health and clinical dependency
services for adults and children living primarily in St. Joseph
County in northern Indiana.


SUFFIELD CLO: Fitch Upgrades Ratings on Three Classes of Notes
--------------------------------------------------------------
Fitch Ratings has upgraded three and affirmed four classes of
notes issued by Suffield CLO Ltd./Corp.  Fitch has also marked one
combination note as paid-in-full.  Rating Outlooks, Loss Severity
Ratings, and Recovery Ratings have been revised or maintained:

  -- $12,027,669 class II notes affirmed at 'AA+sf/LS3'; Outlook
     Stable;

  -- $42,000,000 class III-A notes upgraded to 'AAsf/LS2' from
     'Asf/LS3'; Outlook revised to Stable from Negative;

  -- $15,000,000 class III-B notes upgraded to 'AAsf/LS2 from
     'Asf/LS3'; Outlook revised to Stable from Negative;

  -- $35,000,000 class IV notes upgraded to 'Bsf/LS3' from
     'CCCsf/RR2'; Outlook Stable;

  -- $5,607,983 class V-A notes affirmed at 'Csf/RR6';

  -- $14,019,957 class V-B notes affirmed at 'Csf/RR5'.

Fitch has taken these actions on the combination notes of Suffield
CLO:

  -- $19,019,957 class K combination securities rated 'Bsf' are
     PIF;

  -- $14,700,000 class L combination securities affirmed at 'Csf'.

The upgrades of the class III-A and III-B notes and the class IV
notes are the result of the strong performance of the underlying
portfolio and the significant amortization of the capital
structure since Fitch's last rating action in January 2010.

The underlying loan portfolio has significantly improved in credit
quality since Fitch's last rating action.  Fitch currently
considers just 8.1% of the underlying portfolio to be rated 'CCC+'
or below, an improvement from 28.7% at the last review.  Defaults
have been minimal since the last action, and defaulted assets now
represent just 2.5% of the total portfolio, compared to 10.9% at
the last action.  Finally, Fitch estimates that over 35% of the
portfolio has been upgraded since the last rating action, while
just 6.4% has been downgraded.

The class I notes, which had approximately $36.7 million of
principal outstanding at the last rating action, have since been
paid in full while the class II notes have received almost
$41 million in principal payments, representing approximately
77.3% of their initial principal balance.  Currently, just over
$12 million of class II notes remain outstanding, while the
principal collection account has over $12.3 million in proceeds as
of the Dec. 20, 2010 trustee report.  The class II notes will
likely be paid in full at the March 2011 payment date, at which
time the class III notes would become the senior-most outstanding
class.  The class III notes now benefit from a higher degree of
credit enhancement and in Fitch's opinion are of very high credit
quality.

The strong performance and continued amortization of the
underlying portfolio has increased the relative likelihood of
ultimate repayment for the class III and IV notes.  The class IV
notes, however, remain sensitive to potential future negative
credit migration and therefore maintain a highly speculative
rating.

The class V-A and V-B (collectively, class V) notes are
undercollateralized, as displayed by a reported class V
overcollateralization ratio of 95.4%.  Although the failure of
this test is currently leading to the use of excess interest
proceeds to pay class V principal, Fitch expects these notes to
experience a principal loss at maturity.

The class K combination securities were rated to the ultimate
receipt of their $20 million initial principal balance.  The class
K combination securities receive 100% of the distributions to the
class V-B notes, and about 13.6% of any distributions to the
preferred shares.  Fitch calculates that the combined interest and
principal payments to these notes have totaled over $21.2 million
to date, indicating that the receipt of the initial principal
balance has been achieved.  Consequently, Fitch considers the
class K notes to be paid in full, as they have satisfied their
rating requirement.

The rating of the class L combination securities addresses the
likelihood that investors will receive the stated balance of
principal by the final maturity date, as well as a yield of 8.4%
on the original investment.  The class L combination notes receive
approximately 4.8% of distributions to the class III-A notes,
28.6% of distributions to the class IV notes, and 7.4% of
distributions to the preferred shares.  The floating-rate class
III-A and class IV notes have historically received coupons
significantly lower than the required 8.4% yield on the class L
combination securities, which has been exacerbated by the low
interest rate environment.  As a result, the class L combination
securities are not expected to be able to achieve this yield, and
are affirmed at 'C'.

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

Recovery Ratings for the class V-A and class V-B notes are based
on the total discounted future cash flows projected to be
available to these bonds in a base-case default scenario.  These
projections indicate cash flows representative of an 'RR6' (0% to
10% recoveries) and 'RR5' (11% to 30% recoveries) for the class V-
A and V-B notes, respectively, on Fitch's Recovery Rating scale.
Recovery Ratings are designed to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities rated 'CCCsf' or below.  For further
details on Recovery Ratings, please see Fitch's reports 'Global
Surveillance Criteria for Corporate CDOs' and 'Criteria for
Structured Finance Recovery Ratings'.

Suffield CLO is a cash flow collateralized loan obligation (CLO)
that closed on Sept. 13, 2000 and is managed by Babson Capital
Management LLC.  Suffield CLO exited its reinvestment period in
September 2005 and currently has a portfolio consisting of about
92.5% senior secured loans, with the balance consisting of second
lien and senior unsecured corporate debt assets, as well as
structured finance securities.  The CLO is scheduled to mature in
September 2014.


SWISS CHEETAH: Moody's Upgrades Ratings on 8B Bonds to 'B1'
-----------------------------------------------------------
Moody's Investors Service announced this rating action on Swiss
Cheetah LLC Asset Protection Transaction 8, a collateralized debt
obligation transaction.

The CSO, issued in 2003, references a portfolio of corporate
synthetic senior unsecured bonds.

Issuer: Swiss Cheetah LLC Asset Protection Transaction 8

  -- $37,500,000 Swiss Cheetah 8B Bond, Upgraded to B1 (sf);
     previously on Sept. 18, 2009 Downgraded to Caa2 (sf)

                         Rating Rationale

Moody's rating action is the result of the improving credit
profile of the transaction, the shortened time to maturity of the
CSO and the level of credit enhancement remaining in the
transaction.

Since the last rating review in September 2009, the 10-year
weighted average rating factor (WARF) of the portfolio improved
from 1277 to 1124, equivalent to Ba2.  There are 21 reference
entities with a negative outlook compared to three that are
positive, and one entity on watch for downgrade compared to none
on watch for upgrade.  At the time of the last action 35 entities
had a negative outlook compared to zero with a positive outlook
and five entities on watch for downgrade compared to three on
watch for upgrade.

The portfolio has experienced four credit events, equivalent to
approximately 1.3% percent of the portfolio based on the portfolio
notional value at closing.  After removing settled credit events
the transaction has approximately 5.2% credit enhancement
remaining.  There have been no additional credit events since the
previous rating action.  The CSO has a remaining life of 2.1
years.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios, discussed below.  Results are given in terms
of the number of notches' difference versus the base case, where
higher notches correspond to lower expected losses, and vice-
versa:

* Moody's reviews a scenario consisting of reducing the maturity
  of the CSO by 6 months, keeping all other parameters equal.  The
  result of this run is comparable to that of the base case.

* Market Implied Ratings are modeled in place of the corporate
  fundamental ratings to derive the default probability of the
  reference entities in the portfolio.  The gap between an MIR and
  a Moody's corporate fundamental rating is an indicator of the
  extent of the divergence in credit view between Moody's and the
  market.  The result of this run is 1.5 notches below that of the
  base case.

* Moody's performs a stress analysis consisting of defaulting all
  entities rated Caa1 and below.  The result of this run is
  approximately 5 notches lower than in the base case.

* Moody's conducts a sensitivity analysis consisting of notching
  down by one the ratings of reference entities in the Banking,
  Finance, Insurance and Real Estate sectors.  The result from
  this run is one notch below the one modeled under the base case.

* Removing the notch-down adjustment on ratings of all reference
  entities on negative outlook and/or on watch for downgrade
  generates a result that is comparable to the base case.

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

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

Moody's analysis of CSOs is subject to uncertainties, the primary
sources of which include 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
CSO liabilities, rating transitions in the reference pool may have
leveraged rating implications for the ratings of the 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 in
the corporate universe.  Should macroeconomics conditions evolve
towards a more severe scenario, such as a double dip recession,
the CSO rating will likely be downgraded to an extent that depends
on the expected severity of the worsening conditions.


TRIAD FINANCIAL: Moody's Takes Rating Actions on Two Classes
------------------------------------------------------------
Moody's has upgraded one tranche and confirmed another from two
auto loan securitizations sponsored by Triad Financial
Corporation.  Triad was acquired by Santander Consumer USA Inc. in
October 2009, and the transactions are currently serviced by
Santander.

Issuer: Triad Automobile Receivables Trust 2006-C

  -- Cl. A-4, Upgraded to Aaa (sf); previously on Dec. 6, 2010
     Baa3 (sf) Placed Under Review for Possible upgrade

  -- Financial Guarantor: Ambac Assurance Corporation Caa2;
     previously Confirmed on 11/23/2010

Issuer: Triad Automobile Receivables Trust 2007-A

  -- Cl. A-4, Confirmed at Aa3 (sf); previously on Dec. 6, 2009
     Aa3 (sf) Placed Under Review for Possible Upgrade

  -- Financial Guarantor: Assured Guaranty Municipal Corp.  (Aa3;
     previously Confirmed on 11/12/2009)

                        Ratings Rationale

The actions are a result of lower lifetime cumulative net loss
expectations and build-up in credit enhancement relative to
remaining losses due to the non-declining nature of reserve
accounts in the transactions.  All of the affected transactions
also benefit from monoline financial support.

In addition to collateral performance and available credit
enhancement, Moody's views the acquisition and assumption of
servicing by Santander as positive for the outstanding
transactions, providing financial strength and stability to the
servicing operations.

Moody's current lifetime CNL expectations (expressed as a
percentage of the original pool balances) for the Triad 2006-C
transaction is 18.75%.  The pool factor for this transaction is
approximately 12% of the original pool balance.  Hard credit
enhancement that does not include excess spread of approximately
9% per annum, for the Cl. A notes as a percentage of the remaining
collateral balance, is approximately 36%.

For the 2007-A transaction, Moody's current lifetime CNL
expectation is 16.25%.  The pool factor for this transaction is
approximately 20% of the original pool balance.  Hard credit
enhancement, that does not include excess spread of approximately
8% per annum , for the Cl. A notes as a percentage of the
remaining collateral balance, is approximately 23%.

Ratings on the affected notes could be upgraded (where applicable)
if the lifetime CNLs are lower by 10%, or downgraded if the
lifetime CNLs are higher by 10%.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term.  From time to time, Moody's may, if warranted, change
these expectations.  Performance that falls outside the given
range may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated when the related
securities ratings were issued.  Even so, a deviation from the
expected range will not necessarily result in a rating action nor
does performance within expectations preclude such actions.  The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.  Primary sources of assumption
uncertainty are the current macroeconomic environment, in which
unemployment continues to rise moderately, and strength in the
used vehicle market.  Moody's currently views the used vehicle
market as much stronger now than it was at the end of 2008 when
the uncertainty relating to the economy as well as the future of
the U.S auto manufacturers was significantly greater.  Overall,
Moody's expects a sluggish recovery in the U.S. economy, with
elevated fiscal deficits and persistent, high unemployment levels.

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

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.


VELOCITY CLO: S&P Raises Ratings on Four Classes of Notes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, C, and D notes from Velocity CLO Ltd., a collateralized loan
obligation transaction managed by TCW Asset Management Co.  S&P
removed two of those ratings from CreditWatch with positive
implications.

The upgrades reflect the improved performance S&P has observed in
the transaction's underlying asset portfolio since November 2009.
At that time, S&P lowered the ratings on all notes in the
transaction following a review using S&P's updated criteria for
rating corporate collateralized debt obligations.

At the time of S&P's last rating action, the transaction held
approximately $12.9 million in defaulted obligations and
$55.2 million in underlying obligors with a rating in the 'CCC'
range, according to the Sept. 15, 2009 trustee report.  As of the
Dec. 15, 2010 trustee report.  Velocity CLO Ltd. held $0.1 million
in defaulted obligations and $24.6 million in assets from
underlying obligors with ratings in the 'CCC' range.

Since the time of S&P's last rating action, a number of defaulted
obligors held in the deal emerged from bankruptcy, with some
receiving proceeds that were higher than their carrying value in
the overcollateralization (O/C) ratio test calculation.  This, in
combination with a reduction in assets with ratings in the 'CCC'
range assets and a $35.2 million dollar principal paydown to the
class A notes, benefited the transaction's O/C ratios.  The class
A O/C ratio increased to 133.0% as of the Dec. 15, 2010 report
from 123.3% as of Sept. 15, 2009, report.

At the time of S&P's last rating action, the class B, C, and D
notes failed to withstand the specified combination of underlying
asset defaults at the 'A', 'B', and 'CCC' rating levels of the
largest obligor default test respectively.  The largest obligor
default test is no longer a constraining factor for the ratings on
the class B, C, and D notes.

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

                  Rating And Creditwatch Actions

                         Velocity CLO Ltd.

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


VERICREST FINANCIAL: Moody's Downgrades Ratings on Four Tranches
----------------------------------------------------------------
Moody's has downgraded four tranches from three transactions
backed by recreational vehicle and marine installment sales
contracts serviced by Vericrest Financial, Inc.  Vericrest
Financial, Inc., formerly known as CIT Group/Sales Financing,
Inc., was acquired by Lone Star Funds in 2009.

Issuer: CIT RV Trust 1998-A

  -- Class B, Downgraded to B3 (sf); previously on Nov. 2, 2010
     Baa3 (sf) Placed Under Review for Possible Downgrade

  -- Certificates, Downgraded to C (sf); previously on Nov. 2,
     2010, Ca (sf) Placed Under Review for Possible Downgrade

Issuer: CIT RV Trust 1999-A

  -- Class B, Downgraded to Ca; previously on Nov. 2, 2010 Caa2
     (sf) Placed Under Review for Possible Downgrade

Issuer: CIT Marine Trust 1999-A

  -- Certificates, Downgraded to Ba2 (sf); previously on Nov. 2,
     2010 Baa2 (sf) Placed Under Review for Possible Downgrade

  -- Certificates, Underlying Downgraded to Ba2 (sf); previously
     on Nov. 2, 2010 Baa2 (sf) Placed Under Review for Possible
     Downgrade

  -- Financial Guarantor: MBIA Insurance Corporation (B3;
     previously on Feb. 18, 2009 Downgraded to B3 from Baa1)

                        Ratings Rationale

The actions were prompted by higher pool lifetime cumulative net
losses attributable mainly to continued U.S. economic weakness.
Unlike other vehicle-backed ABS, the negative effect on losses has
been more severe and long lasting due to the non-essential nature
of the underlying collateral.  As a result of longer financing
terms of between 170 and 180 days, these transactions have
experienced more than one economic downturn during their lives.

Moody's expects CIT RV Trust 1998-A to incur lifetime cumulative
net losses of 8.75% of the original pool balance.  The initial
expectation for this transaction at closing was 2.50%.  Total hard
credit enhancement (excluding excess spread of approximately 2.00%
per annum) for class B notes is approximately 4% of the
outstanding collateral pool balance.  The transaction is under-
collateralized by $ 5,756,729 which is equal to almost the entire
amount of the outstanding certificates.  The pool balance for
these transactions is approximately 2% of the original pool
balance.

For the CIT RV Trust 1999-A Moody's expects the lifetime CNL 9.80%
of the original pool balance, compared to expectations of 2.50% at
closing.  The transaction is under-collateralized by $18,980,814
and both the certificates and the class B notes are accruing
losses.  The pool balance for these transactions is approximately
3% of the original pool balance.

Moody's expects the CIT Marine Trust 1999-A to incur lifetime CNL
of 6.70% of the original pool balance, compared to expectations of
4.75% at closing.  Total hard credit enhancement (excluding excess
spread of approximately 1.5% per annum) for the certificates is
approximately 11% of the remaining collateral balance.  The pool
balance for these transactions is approximately 2% of the original
pool balance.

Ratings on the affected notes could be upgraded if the lifetime
CNLs are lower by 5%, or downgraded if the lifetime CNLs are
higher by 5%.

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

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

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.


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

  -- US$25,200,000 Class A-2 Second Priority Senior Secured
     Floating Rate Notes Due July 11, 2021, Upgraded to A1 (sf);
     previously on June 15, 2009 Downgraded to A2 (sf);

  -- US$15,200,000 Class B Third Priority Senior Secured Floating
     Rate Notes Due July 11, 2021, Upgraded to A3 (sf); previously
     on June 15, 2009 Downgraded to Baa1 (sf);

  -- US$20,600,000 Class C Fourth Priority Mezzanine Secured
     Floating Rate Deferrable Interest Notes Due July 11, 2021,
     Upgraded to Ba1 (sf); previously on June 15, 2009 Downgraded
     to Ba2 (sf);

  -- US$10,500,000 Class D Fifth Priority Mezzanine Secured
     Floating Rate Deferrable Interest Notes Due July 11, 2021,
     Upgraded to Ba3 (sf); previously on June 15, 2009 Downgraded
     to B3 (sf);

  -- US$9,500,000 Class E Sixth Priority Mezzanine Secured
     Floating Rate Deferrable Interest Notes Due July 11, 2021,
     Upgraded to Caa3 (sf); previously on November 23, 2010 Ca
     (sf) Placed Under Review for Possible Upgrade.

                        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 transaction's
overcollateralization ratios since the rating action in June 2009.
In Moody's view, these positive developments coincide with
reinvestment of sale 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 January 4, 2011, the
weighted average rating factor is currently 2525 compared to 2722
in the April 2009 report, and securities rated Caa1/CCC+ or lower
make up approximately 11.6% of the underlying portfolio versus
20.3% in April 2009.  Additionally, defaulted securities total
about $5.9 million of the underlying portfolio compared to
$22.3 million in April 2009.

The overcollateralization ratios of the rated notes have also
improved since the rating action June 2009.  The Class A/B, Class
C, Class D, and Class E overcollateralization ratios are reported
at 120.71%, 111.74%, 107.66%, and 104.22%, respectively, versus
April 2009 levels of 114.50%, 106.17%, 102.37%, and 99.16%,
respectively, and all related overcollateralization tests are
currently in compliance.  Moody's also notes that the Class D and
Class E Notes are no longer deferring interest and that all
previously deferred interest has been paid in full.

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 balance of $309 million, defaulted par of $6 million, a
weighted average default probability of 27.51% (implying a WARF of
3571), a weighted average recovery rate upon default of 43.24%,
and a diversity score of 60.  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.

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

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

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on all
rated notes of various default probabilities.  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,
whereby a positive difference corresponds to lower expected
losses), assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2857)

  -- Class A-1R: +1
  -- Class A-1T: +1
  -- Class A-2: +3
  -- Class B: +3
  -- Class C: +2
  -- Class D: +2
  -- Class E: +4

Moody's Adjusted WARF + 20% (4285)

  -- Class A-1R: -1
  -- Class A-1T: -1
  -- Class A-2: -1
  -- Class B: -2
  -- Class C: -2
  -- Class D: -3
  -- Class E: -1

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the manager's
investment strategy 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:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels.  Further, the timing of
   recoveries and the manager's decision to work out versus sell
   defaulted assets create additional uncertainties.  Moody's
   analyzed defaulted recoveries assuming the lower of the market
   price and the recovery rate in order to account for potential
   volatility in market prices.

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.  Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels.  Moody's analyzed the impact of assuming lower
   of reported and covenanted values for weighted average rating
   factor, weighted average spread, weighted average coupon, and
   diversity score.


VERITAS CLO: Moody's Downgrades Ratings on Five Classes of Notes
----------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of these notes issued by Veritas CLO I, Ltd.:

  -- US$229,000,000 Class A First Priority Senior Secured Floating
     Rate Notes due September 5, 2016 (current outstanding balance
     of $127,652,696), Upgraded to Aaa (sf); previously on
     November 23, 2010 A2 (sf) Placed Under Review for Possible
     Upgrade;

  -- US$19,000,000 Class B Second Priority Senior Secured Floating
     Rate Notes due September 5, 2016, Upgraded to A1 (sf);
     previously on November 23, 2010 Ba1 (sf) Placed Under Review
     for Possible Upgrade;

  -- US$16,000,000 Class C Third Priority Mezzanine Secured
     Floating Rate Deferrable Interest Notes due September 5,
     2016, Upgraded to Baa3 (sf); previously on November 23, 2010
     B3 (sf) Placed Under Review for Possible Upgrade;

  -- US$10,500,000 Class D Fourth Priority Mezzanine Secured
     Floating Rate Deferrable Interest due September 5, 2016,
     Upgraded to B3 (sf); previously on November 23, 2010 Ca (sf)
     Placed Under Review for Possible Upgrade;

  -- US$8,000,000 Class E Fifth Priority Mezzanine Secured
     Floating Rate Deferrable Interest Notes due September 5, 2016
     Upgraded to Caa3 (sf); previously on November 23, 2010 C
     (sf) Placed Under Review for Possible Upgrade.

                        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 44% or $99.8 million since the
rating action in June 2009.  As a result of the delevering, the
overcollateralization ratios have increased since the rating
action in June 2009.  As of the latest trustee report dated
December 31, 2010, the Class A/B, Class C, Class D, and Class E
overcollateralization ratios are reported at 126.97%, 114.48%,
107.54%, and 102.79%, respectively, versus April 2009 levels of
113.24%, 106.34%, 102.25%, and 99.34%, respectively, and all
related overcollateralization tests are currently in compliance.
Moody's also notes that the Class E notes are no longer deferring
interest and that all previously deferred interest has been paid
in full.

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.  Moody's adjusted
WARF has declined since the rating action in June 2009 due to a
decrease in the percentage of securities with ratings on "Review
for Possible Downgrade" or with a "Negative Outlook." In addition,
securities rated Caa1/CCC+ or lower make up approximately 12.3% of
the underlying portfolio in December 2010 versus 17.8% in April
2009.  The deal also experienced a decrease in defaults.  In
particular, defaulted securities total about $4.4 million of the
underlying portfolio compared to $9.9 million in April 2009.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" and "Annual Sector Review (2009): Global CLOs," key
model inputs used by Moody's in its analysis, such as par,
weighted average rating factor, diversity score, and weighted
average recovery rate, may be different from the trustee's
reported numbers.  In its base case, Moody's analyzed the
underlying collateral pool to have a performing par and principal
proceeds balance of $173 million, defaulted par of $8 million, a
weighted average default probability of 23.72% (implying a WARF of
3646), a weighted average recovery rate upon default of 41.42%,
and a diversity score of 54.  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.

Veritas CLO I, Ltd., issued in August 2004, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in August 2009.

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on all
rated notes of various default probabilities.  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,
whereby a positive difference corresponds to lower expected
losses), assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2917)

  -- Class A: 0
  -- Class B: +2
  -- Class C: +2
  -- Class D: +3
  -- Class E: +1

Moody's Adjusted WARF + 20% (4375)

  -- Class A: -1
  -- Class B: -2
  -- Class C: -2
  -- Class D: -3
  -- Class E: 0

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2012 and
2014 which may create challenges for issuers to refinance.  CDO
notes' performance may also be impacted by 1) the manager's
investment strategy 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:

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 deal's
   overcollateralization levels.  Further, the timing of
   recoveries and the manager's decision to work out versus sell
   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.


VERITAS CLO: S&P Raises Ratings on All Classes of Notes
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on all
notes from Veritas CLO I Ltd., a cash flow collateralized loan
obligation transaction, and removed the ratings on the class A,
B, and C notes from CreditWatch with positive implications.

The transaction is in its amortization phase and continues
to use its principal proceeds to paydown the notes in a
sequential manner.  The class A note balance is currently at
$127.65 million, about 56% of its original balance.  This is
down from $214.7 million in February 2010, the time of the last
rating action.

The reduced class A balance improved the overcollateralization
(O/C) ratios -- which includes a "haircut" if collateral exposure
to specific ratings exceed a threshold -- for all tranches.  The
trustee calculated the O/C ratios as of December 2010 to be
124.67% for the class A/B, 113.50% for the class C, 107.20% for
the class D, and 102.54% for the class E.  The corresponding O/C
ratios were 14.23%, 106.91%, 102.59%, and 99.37% in January 2010.
The class C and D OC ratios, which were failing in January 2010,
are currently passing.

In addition to the paydown to the class A note, the transaction
also benefited from a decrease in the level of defaults.  The
trustee currently reports $4.44 million par as defaults in the
December 2010 monthly report, compared with $15.75 million par
reported as of January 2010.  Standard & Poor's notes that the
class E note had a paid-in-kind balance that was paid off in the
December 2010 payment period.

The paydowns and the decrease in defaults improved the credit
support to the rated tranches leading to the upgrades.

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

                          Rating Actions

                         Veritas CLO I Ltd.

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


WEST PENN: Moody's Downgrades Rating on $748 Mil. Bonds to 'B2'
---------------------------------------------------------------
Moody's Investors Service has downgraded the bond rating for
West Penn Allegheny Health System (PA) to B2 from B1, affecting
$748 million of Series 2007 fixed rate bonds issued through the
Allegheny County Hospital Development Authority.  The outlook
remains negative.

Rating Rationale: The B2 rating and downgrade reflects
(1) significant and accelerating volume declines throughout
fiscal year 2010 and in the first quarter of fiscal year 2011,
reportedly due to the early effects of the system's restructuring
initiatives, the economy and growth in observation cases;
(2) operating performance, excluding non-recurring items, that
was significantly below expectations in fiscal year 2010 and a
large operating loss in the first quarter of fiscal year 2011;
and (3) significant execution risks and capital and operating
costs related to the system's strategy to downsize and restructure
its operations, especially in a difficult economic environment,
that raises the overall risk profile of the system until
successfully implemented.

Maintenance of the negative outlook reflects Moody's belief that
there are substantial execution and financial risks as the system
implements a large restructuring and the system's weak operating
performance and cash position leave it little flexibility to
absorb any unexpected challenges, such as continued volume
declines and/or further pension funding requirements.  While
Moody's believe the system's outline of a comprehensive strategy
has credibility and is necessary for the system's long-term
viability, implementation risks are high, particularly retaining
volumes as the organization restructures physician groups and
consolidates clinical services at its facilities.

Legal Security: Joint and several obligation of the Obligated
Group with mortgage lien on certain real property, including the
primary hospital facilities, and gross revenue pledge; debt
service reserve fund present; limitations on additional
indebtedness and withdrawal from obligated group permitted if a
combination of certain coverage and financial ratio tests are met.
Days cash on hand covenant liberal with definition including
project funds.

Interest Rate Derivatives: None

                            Challenges

* Execution risks associated with implementing a strategy to
  consolidate physician organizations and clinical services, while
  maintaining profitable volumes and focusing on financial
  turnaround during this transition phase; additionally, operating
  and capital costs related to the restructuring are anticipated
  to be very high

* Excluding a large FICA refund, operating performance in fiscal
  year 2010 was significantly less than expectations even before
  unanticipated restructuring costs in part due to volume losses.
  Excluding a gain on the sale of assets, the system reported a
  large $13.1 million operating loss in the first quarter of
  fiscal year 2011.

* Acute discharges declined significantly in fiscal year 2010 by
  7.4% compared with the prior year and the first quarter of
  fiscal year 2011 was down 9.9% from the prior year

* Weak unrestricted cash position of 42 days of cash on hand as of
  September 30, 2010 (excluding trustee-held project funds), which
  declined by $60 million (24%) since fiscal yearend 2010 in part
  due to pension funding and partially offset by $9.5 million
  received from asset sales

* As of fiscal yearend 2010, unfunded status of pension plan was
  large at almost $300 million, increasing from $222 million at
  fiscal yearend 2009; the system made a large required pension
  payment in the first quarter; future funding levels are
  uncertain until a new actuarial study is completed

* Heavy competition from UPMC Health System, which is the largest
  health system in the region and owns a large managed care plan,
  enabling UPMC to influence health plan membership and volumes

* Dependency on Highmark, the largest insurer in the region, for
  approximately 38% of system revenues including Highmark and
  Highmark Medicare Security Blue products

* High leverage relative to operating performance with weak
  maximum debt service coverage of 1.9 times and high 13.5 times
  debt-to-cashflow based on fiscal year 2010

* Challenging demographic service area with declining population
  trends in the primary service area and an aging patient base

                            Strengths

* Favorable debt structure with all fixed rate debt and no
  interest rate derivatives

* Notwithstanding enormous challenges, the system's strategic
  direction is more focused and, if implemented successfully,
  should better position it competitively and financially

* Availability of project funds to fund capital related to
  restructuring initiatives

* System's prominence as the second largest healthcare system in
  Pittsburgh with almost 71,000 acute discharges

                   Recent Developments/Results

While the system improved its operating performance in fiscal year
2010 compared with the prior year period, excluding a non-
recurring item, operating performance was significantly below
expectations even before restructuring costs.  As discussed in
Moody's last report in June 2010, volumes continue to be Moody's
major concern, as evidenced by an acceleration of admissions
declines in 2010 and the first quarter and strategic plans carry
significant execution risk.

Excluding a one-time FICA refund, West Penn had an operating loss
of $29.9 million (-1.8% margin) in fiscal year 2010, compared with
an operating loss of $38.5 million (-2.4% margin) in the prior
year.  Operating cashflow was $85.2 million (5.2%) in fiscal year
2010, compared with $76.1 million (4.7%) in the prior year period.
The year-over-year operating improvement reflects improvement
initiatives begun in 2009; however, given a $20 million reduction
in restructuring costs year-over-year, operating improvement was
expected to be greater.  The system is below expectations
primarily because of significant volume shortfalls and
unanticipated restructuring costs of $12 million.

The first quarter of fiscal year 2011 includes a $9.5 million gain
from the sale of a dialysis business.  Excluding this gain, the
system had a material $13.1 million operating loss (-3.2%),
compared with a $4.1 million operating loss (-1.0%) in the prior
year period.  Net patient revenue was down 3%.

Acute discharges declined 7.4% in fiscal year 2010, with the third
quarter experiencing a large decline of 8.5%.  Discharges were
down 9.9% in the first quarter of fiscal year 2011.  The decline
is reportedly due to volume losses from the consolidation and
closure of beds as part of the restructuring, the impact of the
economy, and a shift to observation cases.

The system's plan to downsize and restructure the operations is
necessary for the system's long-term viability.  However, there is
significant execution risk that raises the overall risk profile in
the short-term, restructuring costs are high, and the system has
little financial flexibility to absorb unexpected challenges.  The
system has been reconfiguring its clinical services, concentrating
tertiary services at AGH and moving obstetrics to West Penn and
psychiatry to Forbes.  With this consolidation, it will be a
challenge to manage the migration of volumes.  Finally, the
capital and operating costs to implement the restructuring are
likely to be large; the system anticipates using the project funds
($60 million as of September 30, 2010) as the primary source of
funding for capital costs.  The organization will be pursuing a
restructuring and consolidation of physician practices to better
align physicians and improve efficiencies, which involves risk in
being able to retain and recruit productive physicians during this
process.

West Penn's unrestricted cash (excluding project funds) grew to
$246 million (57 days cash on hand) as of fiscal yearend 2010 from
$195 million (45 days) as of fiscal yearend 2009 as a result of
limited pension funding and lower capital spending.  As of
September 30, 2010, unrestricted cash declined by $60 million to
$186 million (42 days cash on hand).  Cash would have declined
further without $9.5 million in proceeds from an asset sale.
Although West Penn's unrestricted asset allocation is fairly
conservative, investment returns could affect the ability to
maintain cash.  As of June 30, 2010, approximately 11% of
unrestricted investments are invested in equities or alternative
investments.

As a result of weaker cash levels, the system is reportedly
managing its capital spending in an effort to preserve cash.
Capital requirements to implement the restructuring are planned to
be covered with project funds.

The system's pension obligation increased as of fiscal yearend
2010 with an almost $300 million (56%) unfunded status, compared
with $222 million as of fiscal yearend 2009, due to a decline
in the discount rate and assumed returns.  The system funded
$51 million in the first quarter of 2011 as required.  A new
actuarial study is underway to determine future funding
requirements, based on a January 1, 2011 measurement date.  West
Penn's pension fund currently has a relatively high allocation to
equities, exposing future funding levels to market volatility.
However, in conjunction with the hiring of an outsourced Chief
Investment Officer, West Penn is in the process of implementing a
liability driven investment strategy (i.e. a long duration fixed
income allocation).

                             Outlook

Maintenance of the negative outlook reflects Moody's belief that
there are substantial execution and financial risks as the system
implements a large restructuring and the system's weak operating
performance and cash position leave it little flexibility to
absorb any unexpected challenges, such as continued volume
declines.  While Moody's believe the system's outline of a
comprehensive strategy has credibility and is necessary for the
system's long-term viability, implementation risks are high,
particularly retaining volumes as the organization restructures
physician groups and consolidates clinical services at its
facilities.

                What could change the rating -- Up

With a negative outlook, a rating upgrade in the near-term is not
likely.  Long-term, an upgrade would be considered with
significant and sustained improvement in operating cashflow for
several years, at least stability in volumes, significant growth
in unrestricted cash, stability or growth in medical staff and
successful completion of physician and facilities restructuring
strategies.

               What could change the rating -- Down

Decline in unrestricted cash (excluding project funds), continued
large operating losses and volume declines

                          Key Indicators

Assumptions & Adjustments:

  -- Based on financial statements for West Penn Allegheny Health
     System

  -- First number reflects audit year ended June 30, 2009

  -- Second number reflects audit year ended June 30, 2010

  -- Investment returns smoothed at 6% unless otherwise noted

  -- Non-recurring items: $10.7 million related to a FICA refund
     in 2010, added back to expenses

* Inpatient acute discharges: 76,464; 70,790

* Total operating revenues: $1.61 billion; $1.63 billion

* Moody's-adjusted net revenue available for debt service:
  $88.9 million; $101.1 million

* Total debt outstanding: $827 million; $813 million

* Maximum annual debt service (MADS): $53.9 million; $53.9 million
  (excluding balloon payments in 2015 and 2016 related to a
  financing for helicopters, which would increase MADS by
  approximately $5 million and $3 million, respectively, in these
  years)

* MADS coverage based on reported investment income: 1.8 times;
  1.9 times

* Moody's-adjusted MADS coverage with normalized investment
  income: 1.7 times; 1.9 times

* Debt-to-cash flow: 17.0 times; 13.5 times

* Days cash on hand (excluding project funds): 45 days; 57 days

* Cash-to-debt: 24%; 30%

* Operating margin: -2.4%; -1.8%

* Operating cash flow margin: 4.7%; 5.2%

                            Rated Debt

  - Series 2007 fixed rate bonds ($748 million): B2

The last rating action was on June 1, 2010, when the Ba3 rating
was downgraded to B1 and the negative outlook maintained.


WF-RBS COMMERCIAL: Fitch Issues Presale Report on 2011-C2 Certs.
----------------------------------------------------------------
Fitch Ratings has issued a presale report on WF-RBS Commercial
Mortgage Trust 2011-C2 commercial mortgage pass-through
certificates.

Fitch expects to rate the transaction and assign Loss Severity
ratings, with a Stable Outlook:

  -- $583,545,000 class A-1 'AAAsf/LS1';
  -- $493,220,000 class A-2 'AAAsf/LS1';
  -- $1,076,765,000* class X-A 'AAAsf';
  -- $38,978,000 class B 'AAsf/LS4';
  -- $43,850,000 class C 'Asf/LS5';
  -- $68,212,000 class D 'BBB-sf/LS5';
  -- $21,113,000 class E 'BBsf/LS5';
  -- $14,616,000 class F 'Bsf/LS5'.
  * Notional amount and interest only.

The expected ratings are based on information provided by the
issuer as of Feb. 1, 2011.  Fitch does not expect to rate the
$35.7 million class G, or the interest-only class X-B.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 50 loans secured by 96 commercial
properties having an aggregate principal balance of approximately
$1.30 billion as of the cutoff date.  The loans were originated by
Wells Fargo Bank National Association, The Royal Bank of Scotland
plc, RBS Financial Products Inc., Natixis Real Estate Capital LLC,
and Basis Real Estate Capital II, LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 85.9% of the properties
by balance, cash flow analysis of 83.9% of the pool and asset
summary reviews of 86.4% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.26 times, a Fitch stressed loan-to value of 89%, and a
Fitch debt yield of 10.3%.  Fitch's aggregate net cash flow
represents a variance of 6.8% to issuer cash flows.

The transaction is concentrated as the largest 10 loans account
for 56.6% of the pool, and the largest 15 account for 69.3%.
There is no material sponsor concentration across multiple loans.


WHITEHORSE I: S&P Raises Ratings on Various Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the A-
1LB, A-2L, A-3L, and B-1L notes from WhiteHorse I Ltd., a cash
flow collateralized loan obligation transaction.  At the same
time, S&P removed its rating on the class A-1LB notes from
CreditWatch with positive implications.  S&P also affirmed the
rating on the class A-1LA notes.

The transaction's reinvestment period ended in September 2009 and
is now in its amortization phase.  The collateral pool is static
and the transaction uses the principal proceeds to pay down the
notes in a sequential manner.  The current balance of the class A-
1LA notes is $44.27 million (36.89% of its original balance), down
from $111.95 million at the time of the last rating action in
February 2010.

As a result of the lower class A-1LA note balance, the
overcollateralization of all tranches has improved.  According to
the Jan. 6, 2011, trustee report, the senior class A, class A, and
class B-1L O/C ratios  were 126.39%, 113.52%, and 108.03%
respectively, compared with 115.95%, 108.97%, and 105.78% as of
the February 2010 monthly report.

The upgrades reflect increases in the O/C levels, which improved
the credit support available to the rated tranches at their prior
rating 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

                         WhiteHorse I Ltd.

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

                          Rating Affirmed

                         WhiteHorse I Ltd.

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


* Fitch Takes Rating Actions on New Orleans' Special Tax Bonds
--------------------------------------------------------------
Fitch Ratings takes this rating action on the New Orleans, LA
utility system revenue bonds and drainage special tax bonds
(issued on behalf of the New Orleans Sewerage and Water Board [the
board]) as part of its continuous surveillance effort:

  -- Approximately $172.8 million sewer system revenue bonds
     downgraded to 'BBB-' from 'BBB+';

  -- Approximately $34.6 million water system revenue bonds
     upgraded to 'BBB-' from 'B';

  -- Approximately $21.5 million drainage special tax bonds
     upgraded to 'A-' from 'BBB+'.

The Rating Outlook for all three securities is Stable.

Rating Rationale:

  -- The upgrade of the water revenue bond rating to 'BBB-' from
     'B' reflects the improved financial profile of the water
     system, due to a series of rate increases, a recent FEMA
     reimbursement for prior years' expenditures, and re-
     allocation of administrative costs between the board's three
     systems.

  -- Conversely, the sewer system has weakened financially over
     the past two fiscal years due in part to various accounting
     and reporting changes that have contributed to sizable
     increases in operating costs; the downgrade to 'BBB-' from
     'BBB+' is based on this weakened position, which has resulted
     in the sewer system violating its rate covenant.

  -- The upgrade of the drainage special tax bond rating to 'A-'
     from 'BBB+' reflects continued stable property tax
     collections, and moderate, steady growth in the tax base.

  -- A portion of the board's community disaster loan principal
     was forgiven by the federal government in November
     2010, and board officials are hopeful the remainder will be
     cancelled.

  -- The recent addition of two new senior staff members with
     extensive utility experience in other cities strengthens the
     caliber of board staff.

  -- Recessionary pressures continue to hinder the post-Katrina
     economic recovery in New Orleans; while employment totals
     have been increasing modestly in recent months as residents
     and businesses return to the city, the city's unemployment
     rate has climbed to levels higher than the state and U.S.
     averages.

  -- Significant amounts of money are still coming into New
     Orleans for various infrastructure projects; many are still
     in design stage, and the transition to construction should
     provide some positive economic momentum.

Key Rating Drivers:

  -- Anticipated additional water and sewer rate increases are
     critical to finance operations, comply with rate covenants,
     and begin to address massive capital needs; however,
     affordability likely will become a credit concern if rates
     climb substantially.

  -- As the area continues to recover -- albeit at an uneven pace
     -- Fitch anticipates that further population gains will help
     restore customer counts and needed cash flow to the board's
     operations.

  -- Capital needs for all three systems are extremely large, and
     the task of funding needed improvements will remain daunting
     for an extended period.

Security: The sewer revenue bonds are secured by a net pledge of
revenues of the board's sewer utility system; the water revenue
bonds are secured by a net pledge of revenues of the board's water
utility system; the drainage special tax bonds are payable from
and secured by the proceeds of a limited ad valorem tax.

Credit Summary:

The financial positions of the water fund and sewer fund have
shifted over the past 24 months, due to a number of factors.
First, water system revenues continue to increase as a steady
return of customers is augmented by a series of annual rate
increases that has increased the average residential bill by
nearly 50% since 2007.  On the expenditure side, ongoing cost
control measures have been accompanied by a recent FEMA
reimbursement of nearly $17 million.  These factors, along with a
shift in administrative costs between the water, sewer and
drainage funds that has reduced water system outlays, have
improved both liquidity and debt service coverage for the water
system; preliminary results for 2010 suggest coverage of roughly
1.50 times, a marked improvement from recent years.  (This
coverage calculation, along with sewer system coverage
calculations, excludes the forgiveness of a portion of the board's
CDL that is being booked in 2010 as an operating grant.)
Projected cash and investments at 2010 year-end total
$12.9 million, or roughly 90 days of expenditures.  This improved
financial performance has occurred despite an increase in the
provision for doubtful accounts for 2010 to nearly $4 million.
Fiscal 2010 coverage excluding the one-time spike in the provision
for doubtful accounts and an additional non-cash item for OPEB
accrual would be in excess of 3.0x.

Conversely, the financial profile of the sewer system has weakened
markedly as a result of the additional expenses for OPEB accrual,
the increased provision for doubtful accounts, and the shift in
administrative costs that have combined to apply upward pressure
on expenses.  The non-cash OPEB accrual and provision for doubtful
accounts expenses combined total roughly $10 million for 2010,
which significantly affects projected debt service coverage.
Coverage (again excluding the CDL loan forgiveness revenue entry)
is projected to be slightly below 1.0x for 2010, well below the
system's 1.30x rate covenant minimum.  According to staff, the
spike in provision for doubtful accounts is a one-time write-off
of receivables from accounts closed in 2007 (accounts that had
been kept open in late 2005 and 2006 following Katrina).  They
anticipate this expense will return to a more typical amount --
the sewer loss provision had averaged less than $1 million
annually prior to 2005 -- which should improve operating results
and coverage levels.  Coverage for 2010 excluding this increased
loss provision and the OPEB accrual would be roughly 1.35x.  Sewer
system liquidity also has weakened, which Fitch notes is a factor
in this rating action.  Projected cash and investments at 2010
year-end total only $2.3 million, or 16 days of spending.

The financial profile of the drainage system is satisfactory, and
has benefited from steady increases in taxable value and a return
of property tax collections to pre-2005 levels.  Taxable assessed
value (TAV) for 2010 was $2.76 billion, up 3% from the prior
year; this increase was consistent with gains in 2008 and 2009.
Likewise, property tax collections have climbed steadily since
2005 and at more than 85% current collections are consistent with
historical levels.  Outstanding drainage tax bonds are secured by
one of three taxes levied by the board for drainage purposes, and
2010 revenues from this millage levy totaled $16.6 million, well
in excess of annual debt service of $2.2 million.

Going forward, management recognizes the need to align recurring
sewer and water utility revenues with expenses, build up
liquidity, and generate funds for capital projects.  Toward that
end, the board selected an outside consultant to conduct a
comprehensive financial plan and rate study for the water, sewer
and drainage systems; initial results from the project are
expected in spring 2011.  Although Fitch believes that a
combination of rate hikes and a steady increase in customer count
will eventually further stabilize operations for both the water
and sewer systems, utility charge affordability likely will be a
concern given the relatively low wealth levels in the city.

All three systems have large future capital needs, which result
from a combination of storm damage and aging infrastructure.
Estimated capital costs for the water system through 2015 total
roughly $300 million, while costs for the sewer and drainage
systems total $445 million and $2.18 billion, respectively.
Funding for drainage projects will be financed in part with
federal monies -- currently projected at more than $1.2 billion
for this period.  Fitch notes that none of the systems are
generating surplus revenues sufficient to make a significant
contribution towards the sizable capital needs of each system.
As capital needs are deferred, the potential for service
interruptions and increased costs in the future climbs.  The
sewer system's debt level is relatively high at roughly $1,975
per customer, while the water and drainage systems debt loads
are fairly modest.  The debt total for all systems includes
$77.5 million in debt service assistance that was provided by the
state as authorized by the Gulf Opportunity Zone Act of 2005.  The
New Orleans Board of Liquidation serves as debt service custodian
for all board debt, as well as the authorizing agency on all bond
issuances, while contributing an advisory and oversight role on
rate matters.

Recessionary forces have affected News Orleans' tourism business
and retail activity, dampening the positive effect of ongoing
reconstruction activity in the city.  Also, the 2010 gulf oil
spill has affected offshore drilling activity and commercial
fishing and seafood processing.  Despite the weakened economic
climate, the city is registering employment gains and numerous
large-scale infrastructure projects are either in design or under
construction.  Fitch believes that the large amount of recovery
and rebuilding money flowing into the city and surrounding area
over the near term will provide a certain level of support to
economic activity and will establish a solid foundation for future
economic growth.  Notable projects include the new LSU-VA medical
complex under construction, a recently announced steel and iron
plant in nearby St. James Parish, and the scheduled re-opening of
the Hyatt Regency downtown hotel in fall 2011.  Meanwhile, state
and local officials are working to locate a new buyer/user for the
Avondale Shipyard; the area's largest employer with more than
4,000 workers, this facility is scheduled for closure by Northrop
Grumman in 2013.  While progress on various fronts continues,
Fitch notes that much work remains to be done in the critical
areas of housing, healthcare, education and public infrastructure;
the city still faces years of recovery ahead.

The most recent estimates put the city's population at roughly
355,000, or roughly 75% of the pre-storm total.  Employment
registered some moderate improvement in recent months, and October
2010 totals indicate a 2.5% increase in employment over the same
period in 2009.  Despite the recent gains, employment in the metro
area remains about 15% below pre-Katrina levels.  The latest city
unemployment rate of 9.8% (October 2010) was up from last year and
higher than the national (9.0%) average for the month.  The
current utility customer base of more than 120,000 has shown
steady growth since June 2008 when a program to aggressively
pursue and close inactive accounts peaked, and the customer count
now is approximately 87% of the pre-Katrina total of more than
140,000.


* S&P Downgrades Ratings on 43 Classes From Five CMBS Transactions
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 43
classes of commercial mortgage pass-through certificates from five
U.S. commercial mortgage-backed securities transactions due to
interest shortfalls.

The downgrades reflect current and potential interest shortfalls.
S&P lowered its ratings on 32 of these classes to 'D (sf)' because
S&P expects these interest shortfalls to continue.  Of the 32
classes that S&P downgraded to 'D (sf)', 31 have had accumulated
interest shortfalls outstanding for three or more months.  The
remaining class has had accumulated interest shortfalls
outstanding for two months.  The recurring interest shortfalls for
the respective certificates are primarily due to one or more of
these factors:

* Appraisal subordinate entitlement reduction amounts in effect
  for specially serviced loans;

* The lack of servicer advancing for loans where the servicer has
  made nonrecoverable advance declarations;

* Special servicing fees; and

* Interest rate reductions or deferrals resulting from loan
  modifications.

Standard & Poor's analysis primarily considered the ASER amounts
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 its view, to cause recurring interest
shortfalls.

The servicer implements ARAs and resulting ASER amounts 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 ASER
amounts 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.

S&P details the 43 downgraded classes from the five CMBS
transactions below.

      Banc of America Commercial Mortgage Inc. Series 2005-6

S&P lowered its ratings on the class L, M, N, O, and P
certificates from Banc of America Commercial Mortgage Inc.'s
series 2005-6 due to interest shortfalls resulting from ASER
amounts related to 10 ($76.8 million, 3.2% of the pooled trust
balance) of the 21 loans ($322.7 million, 13.4%) that are
currently with the special servicer, LNR Partners LLC, as well as
special servicing fees.  S&P also lowered its ratings on classes J
and K because S&P believes these two classes are susceptible to
future interest shortfalls.  As of the Jan. 10, 2011, trustee
remittance report, ARAs totaling $35.6 million were in effect for
10 loans.  The total reported ASER amount was $162,894, and the
reported cumulative ASER amount was $1.39 million.  Standard &
Poor's considered the 10 ASER amounts, all of which were based on
MAI appraisals, as well as current special servicing fees, in
determining its rating actions.  The reported monthly interest
shortfalls totaled $258,923 and have affected all of the classes
subordinate to and including class L.  Classes L, M, N, O, and P
have had accumulated interest shortfalls outstanding between three
and five months, and S&P expects these shortfalls to remain
outstanding for the foreseeable future.  Consequently, S&P lowered
the ratings on these classes to 'D (sf)'.

             Morgan Stanley Capital I Trust 2005-HQ6

S&P lowered its ratings on the class K, L, M, N, O, P, and Q
certificates from Morgan Stanley Capital I Trust 2005-HQ6 due to
interest shortfalls resulting from ASER amounts related to 12
($157.0 million, 6.4% of the pooled trust balance) of the 20 loans
($218.0 million, 8.9%) that are currently with the special
servicer, CWCapital Asset Management LLC, as well as special
servicing fees.  S&P also lowered its rating on class J because
S&P believes this class is susceptible to future interest
shortfalls.  As of the Jan. 13, 2011 trustee remittance report,
ARAs totaling $71.7 million were in effect for 14 loans.  The
total reported ASER amount was $349,196, and the reported
cumulative ASER amount was $1.96 million.  Standard & Poor's
considered 11 ASER amounts, all of which were based on MAI
appraisals, as well as current special servicing fees, in
determining its rating actions.  The reported monthly interest
shortfalls totaled $398,024 and have affected all of the classes
subordinate to and including class K.  Classes K, L, M, N, O, P,
and Q have had accumulated interest shortfalls outstanding between
four and seven months, and S&P expects these shortfalls to remain
outstanding for the foreseeable future.  Consequently, S&P lowered
the ratings on these classes to 'D (sf)'.

               Merrill Lynch Mortgage Trust 2006-C2

S&P lowered its ratings on the class G, H, J, K, L, and M
certificates from Merrill Lynch Mortgage Trust 2006-C2 due to
interest shortfalls resulting from ASER amounts related to 11
($80.2 million, 6.2% of the pooled trust balance) of the 15
loans ($171.4 million, 13.2%) that are currently with the
special servicer, J.E. Robert Co. Inc., as well as special
servicing fees and interest rate modification on the Casa
Carranza Mesa loan.  S&P also downgraded the class C, D, E,
and F certificates because S&P believes the recurring interest
shortfalls have reduced liquidity support available to these
classes.  As of the Jan. 12, 2011, trustee remittance report,
ARAs totaling $94.8 million were in effect for 15 loans.  The
total reported ASER amount was $196,002, and the reported
cumulative ASER amount was $1.86 million.  Standard & Poor's
considered 10 ASER amounts, all of which were based on MAI
appraisals, as well as current special servicing fees and the
interest rate reduction ($30,070) from the modification of the
Casa Carranza Mesa loan, in determining its rating actions.
Additionally, S&P's rating actions also considered that the master
servicer, Wells Fargo Bank N.A., expects an additional ASER amount
to be in effect by the February 2011 trustee remittance report for
the largest asset with the special servicer, the Mall at Whitney
Field asset.  The reported monthly interest shortfalls totaled
$259,536 and affected all of the classes subordinate to and
including class G.  Classes H, J, K, L, and M have had accumulated
interest shortfalls outstanding between six and 11 months, and S&P
expects these shortfalls to remain outstanding for the foreseeable
future.  Consequently, S&P downgraded these classes to 'D (sf)'.

JPMorgan Chase Commercial Mortgage Securities Trust 2006-CIBC16

S&P lowered its ratings on the class G, H, J, K, L, M, N, and P
certificates from JPMorgan Chase Commercial Mortgage Securities
Trust 2006-CIBC16 due to interest shortfalls resulting from ASER
amounts related to six ($124.8 million, 6.0% of the pooled trust
balance) of the 15 loans ($360.8 million, 17.5%) that are
currently with the special servicer, C-III Asset Management LLC,
as well as special servicing fees and interest rate modifications
on the Lakeshore Plaza and 3000 Lincoln loans.  S&P also
downgraded the class E and F certificates because S&P believes
these two classes are susceptible to future interest shortfalls.
As of the Jan. 12, 2011, trustee remittance report, ARAs totaling
$49.4 million were in effect for seven loans.  The total reported
ASER amount was $256,701, and the reported cumulative ASER amount
was $1.78 million.  Standard & Poor's considered five ASER
amounts, all of which were based on MAI appraisals, as well as
current special servicing fees and the interest rate reduction
($27,650) from the modifications of the two aforementioned loans,
in determining its rating actions.  The reported monthly interest
shortfalls, excluding the repayment of other expenses related to
the Sportsman's Warehouse loan, totaled $377,925.  Accumulated
interest shortfalls are outstanding on all classes subordinate to
and including class G.  Classes G, H, J, K, L, M, N, and P have
had accumulated interest shortfalls outstanding between two and 12
months, and S&P expects these shortfalls to remain outstanding for
the foreseeable future.  Consequently, S&P downgraded these
classes to 'D (sf)'.

            Morgan Stanley Capital I Trust 2007-TOP27

S&P lowered its ratings on the class H, J, K, L, M, N, and O
certificates from Morgan Stanley Capital I Trust 2007-TOP27 due to
interest shortfalls resulting from ASER amounts related to eight
($77.3 million, 2.9% of the pooled trust balance) of the 12 loans
($109.9 million, 4.1%) that are currently with the special
servicer, C-III, as well as special servicing fees and interest
not advanced.  S&P also downgraded the class G certificate because
S&P believes this class is susceptible to future interest
shortfalls.  As of the Jan. 13, 2011, trustee remittance report,
ARAs totaling $55.9 million were in effect for 10 loans.  The
total reported ASER amount was $203,590, and the reported
cumulative ASER amount was $1.81 million.  Standard & Poor's
considered seven ASER amounts, all of which were based on MAI
appraisals, as well as current special servicing fees and interest
not advanced ($98,395), in determining its rating actions.  The
reported monthly interest shortfalls totaled $324,435 and affected
all of the classes subordinate to and including class H.  Classes
H, J, K, L, M, N, and O have had accumulated interest shortfalls
outstanding between four and eight months, and S&P expects these
shortfalls to remain outstanding for the foreseeable future.
Consequently, S&P lowered its ratings on these classes to 'D
(sf)'.

                         Ratings Lowered

             Banc of America Commercial Mortgage Inc.
    Commercial mortgage pass-through certificates series 2005-6

                                                       Reported
          Rating                                  Interest Shortfalls ($)
          ------                                  -----------------------
Class  To        From         Credit enhancement   Current  Accumulated
-----  --        ----         ------------------   -------  -----------
J      B- (sf)   BB- (sf)     3.89                       0            0
K      CCC- (sf) B+ (sf)      2.76                       0            0
L      D (sf)    B (sf)       2.19                  40,130       95,087
M      D (sf)    B- (sf)      1.48                  70,366      295,148
N      D (sf)    CCC+ (sf)    1.34                  14,075       70,374
O      D (sf)    CCC (sf)     1.05                  28,145      140,727
P      D (sf)    CCC- (sf)    0.91                  14,075       70,374

             Morgan Stanley Capital I Trust 2005-HQ6
   Commercial mortgage pass-through certificates series 2005-HQ6

                                                       Reported
          Rating                                  Interest Shortfalls ($)
          ------                                  -----------------------
Class  To        From         Credit enhancement   Current  Accumulated
-----  --        ----         ------------------   -------  -----------
J      CCC+ (sf) B+ (sf)      5.03                       0            0
K      D (sf)    B (sf)       3.34                  74,617      192,489
L      D (sf)    B (sf)       2.92                  40,929      163,717
M      D (sf)    B- (sf)      2.50                  40,933      163,733
N      D (sf)    CCC+ (sf)    1.79                  68,221      284,521
O      D (sf)    CCC+ (sf)    1.65                  13,642       68,209
P      D (sf)    CCC (sf)     1.23                  40,933      204,667
Q      D (sf)    CCC- (sf)    0.80                  40,933      269,761

               Merrill Lynch Mortgage Trust 2006-C2
   Commercial mortgage pass-through certificates series 2006-C2

                                                       Reported
          Rating                                  Interest Shortfalls ($)
          ------                                  -----------------------
Class  To        From         Credit enhancement   Current  Accumulated
-----  --        ----         ------------------   -------  -----------
C      BB- (sf)  BBB- (sf)   10.68                       0            0
D      CCC (sf)  BB (sf)      8.60                       0            0
E      CCC- (sf) BB- (sf)     7.27                       0            0
F      CCC- (sf) B+ (sf)      5.35                       0            0
G      CCC- (sf) B (sf)       4.16                   5,117        5,117
H      D (sf)    B- (sf)      2.98                  78,874      328,710
J      D (sf)    B- (sf)      2.24                  43,574      264,946
K      D (sf)    CCC+ (sf)    1.95                  17,430      122,013
L      D (sf)    CCC+ (sf)    1.50                  26,143      233,051
M      D (sf)    CCC (sf)     1.21                  17,426      191,685

       JPMorgan Chase Commercial Mortgage Securities Trust
Commercial mortgage pass-through certificates series 2006-CIBC16

                                                       Reported
          Rating                                  Interest Shortfalls ($)
          ------                                  -----------------------
Class  To        From         Credit enhancement   Current  Accumulated
-----  --        ----         ------------------   -------  -----------
E      CCC+ (sf) B+ (sf)      5.83                (56,506)            0
F      CCC- (sf) B+ (sf)      4.40               (144,854)            0
G      D (sf)    B (sf)       3.10                  66,249      200,128
H      D (sf)    B- (sf)      1.93                 123,020      331,519
J      D (sf)    CCC+ (sf)    1.67                  23,534      164,739
K      D (sf)    CCC (sf)     1.15                  47,073      460,594
L      D (sf)    CCC- (sf)    0.76                  35,306      389,895
M      D (sf)    CCC- (sf)    0.63                  11,767      141,205
N      D (sf)    CCC- (sf)    0.37                  23,539      282,463
P      D (sf)    CCC- (sf)    0.11                  23,539      282,463

            Morgan Stanley Capital I Trust 2007-TOP27
  Commercial mortgage pass-through certificates series 2007-TOP27

                                                       Reported
          Rating                                  Interest Shortfalls ($)
          ------                                  -----------------------
Class  To        From         Credit enhancement   Current  Accumulated
-----  --        ----         ------------------   -------  -----------
G      CCC- (sf) B (sf)       2.77                       0            0
H      D (sf)    B- (sf)      1.89                  86,261      247,827
J      D (sf)    B- (sf)      1.76                  16,026       64,530
K      D (sf)    CCC+ (sf)    1.63                  16,022       70,784
L      D (sf)    CCC (sf)     1.38                  32,053      161,975
M      D (sf)    CCC (sf)     1.12                  32,048      161,951
N      D (sf)    CCC- (sf)    0.87                  32,048      163,433
O      D (sf)    CCC- (sf)    0.74                  16,022      123,078


* S&P Downgrades Ratings on 53 Certs. From Seven CMBS Transactions
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 53
classes of commercial mortgage pass-through certificates from
seven U.S. commercial mortgage-backed securities transactions.

The downgrades reflect current and potential interest shortfalls.
S&P lowered its ratings on 39 of these classes to 'D (sf)' because
S&P expects the recurring interest shortfalls to continue.

Thirty-seven of the 39 classes that S&P downgraded to 'D (sf)'
have had accumulated interest shortfalls outstanding for four or
more months.  The remaining two classes have had accumulated
interest shortfalls outstanding for three months.  The recurring
interest shortfalls for the respective certificates are primarily
due to one or more of these factors:

* Appraisal subordinate entitlement reduction amounts in effect
  for specially serviced loans;

* A lack of servicer advancing for loans where the servicer has
  made nonrecoverable advance declarations;

* Special servicing fees; and

* Interest rate reductions or deferrals resulting from loan
  modifications.

Standard & Poor's analysis primarily considered the ASER amounts
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 ASER amounts 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 ASER amounts 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.

S&P details the 53 downgraded classes from the seven CMBS
transactions below.

                    CD 2006-CD3 Mortgage Trust

S&P lowered its ratings on the class J, K, L, M, N, O, P, and Q
certificates from CD 2006-CD3 Mortgage Trust.  The lowered ratings
reflect accumulated interest shortfalls resulting from ASER
amounts related to 15 ($204.3 million, 6.0%) of the 28 loans
($575 million, 16.8%) that are currently with the special
servicer, J.E.  Robert Co., as well as special servicing fees.
An interest rate reduction on three loans (the Tennyson Office
Center loan, the Moody Texas Hotel Portfolio loan, and the Macdade
Terrace Apartments loan) also contributed to the interest
shortfalls.  As of the Jan. 18, 2011, trustee remittance report,
ARAs totaling $108.9 million were in effect for 24 loans.  The
total reported ASER amount on 15 loans was $402,013, and the
reported cumulative ASER amount was $3.5 million.  Standard &
Poor's considered 14 ASER amounts (totaling $293,683), all of
which were based on MAI appraisals, as well as current special
servicing fees and interest rate reduction of $133,551 resulting
from the modification of three loans (the Tennyson Office Center
loan, the Moody Texas Hotel Portfolio loan, and the Macdade
Terrace Apartments loan), in determining its rating actions.  The
reported monthly interest shortfalls totaled $595,500, and
accumulated interest shortfalls have affected class J and all of
the classes subordinate to it.  Classes K, L, M, N, O, P, and Q
have had accumulated interest shortfalls outstanding between eight
and 11 months, which S&P expects to remain outstanding for the
foreseeable future.  Consequently, S&P lowered its ratings on
these classes to 'D (sf)'.

      JPMorgan Chase Commercial Mortgage Securities Corp.'s
                         series 2005-LDP1

S&P lowered its ratings on the class K, L, M, N, and P
certificates from JPMorgan Chase Commercial Mortgage Securities
Corp.'s series 2005-LDP1.  The lowered ratings reflect accumulated
interest shortfalls resulting from ASER amounts related to 12
($36.9 million, 1.8%)  of the 19 ($149.4 million, 7.13%) loans
that are currently with the special servicer, Midland Loan
Services Inc., as well as special servicing fees.  An interest
rate reduction on three loans (the Redwood Tower loan, the Indian
River Office Building loan, and the Shops on Howard loan) also
contributed to the interest shortfalls.  As of the Jan. 18, 2011,
trustee remittance report, ARAs totaling $36.9 million were in
effect for 12 loans.  The total reported ASER amount on 11 loans
was $170,335, and the reported cumulative ASER amount was
$1.2 million.  Standard & Poor's considered five ASER amounts
(totaling $29,359), all of which were based on MAI appraisals, as
well as current special servicing fees and interest rate reduction
of $51,133 resulting from the modification of three loans (the
Redwood Tower loan, the Indian River Office Building loan, and the
Shops on Howard loan), in determining its rating actions.  The
reported monthly interest shortfalls totaled $197,607, and
accumulated interest shortfalls have affected class K and all of
the classes subordinate to it.  Classes L, M, N, and P have had
accumulated interest shortfalls outstanding between five and 11
months, which S&P expects to remain outstanding for the
foreseeable future.  Consequently, S&P lowered its ratings on
these classes to 'D (sf)'.

             LB-UBS Commercial Mortgage Trust 2007-C6

S&P lowered its ratings on the class H, J, K, L, M, N, P, Q, and S
certificates from LB-UBS Commercial Mortgage Trust 2007-C6.  The
lowered ratings reflect accumulated interest shortfalls resulting
from ASER amounts related to 12 ($523.1 million, 17.7%)) of the 17
($659.5 million, 22.8%) loans that are currently with the special
servicer, Midland, including the largest loan in the pool, the
Innkeepers Portfolio loan ($412.7 million, 14.0%), as well as
interest not advanced and special servicing fees.  As of the Jan.
18, 2011, trustee remittance report, ARAs totaling $152.4 million
were in effect for 15 loans.  The total reported ASER amount on 12
loans was $830,415, and the reported cumulative ASER amount was
$4.3 million.  Standard & Poor's considered nine ASER amounts
(totaling $172,242), all of which were based on MAI appraisals, as
well as current special servicing fees and interest not advanced
($11,083), in determining its rating actions.  The reported
monthly interest shortfalls totaled $925,147 and accumulated
interest shortfalls have affected class H and all of the classes
subordinate to it.  Classes L, M, N, P, Q, and S have had
accumulated interest shortfalls outstanding between four and eight
months, which S&P expects to remain outstanding for the
foreseeable future.  Consequently, S&P lowered its ratings on
these classes to 'D (sf)'.

             LB-UBS Commercial Mortgage Trust 2007-C7

S&P lowered its ratings on the class G, H, J, K, L, M, N, P, Q,
and S certificates from LB-UBS Commercial Mortgage Trust 2007-C7.
The lowered ratings reflect accumulated interest shortfalls
resulting from ASER amounts related to seven ($472.9 million,
15.0%) of the 10 loans ($657.7 million, 20.9%) that are currently
with the special servicer, LNR Partners LLC, including the largest
loan in the pool, the Innkeepers Portfolio loan, as well as
special servicing fees.  As of the Jan. 18, 2011, trustee
remittance report ARAs totaling $133.3 million were in effect
for seven loans.  The total reported ASER amount on seven loans
was $748,809, and the reported cumulative ASER amount was
$3.6 million.  Standard & Poor's considered four ASER amounts
(totaling $88,420), all of which were based on MAI appraisals, as
well as current special servicing fees in determining its rating
actions.  The reported monthly interest shortfalls totaled
$492,535, and accumulated interest shortfalls have affected class
H and all of the classes subordinate to it.  Classes K, L, M, N,
P, Q, and S have had accumulated interest shortfalls outstanding
between four and eight months, which S&P expects to remain
outstanding for the foreseeable future.  Consequently, S&P lowered
its ratings on these classes to 'D (sf)'.

             Morgan Stanley Capital I Trust 2007-IQ13

S&P lowered its ratings on the class F, G, H, J, K, and L
certificates from Morgan Stanley Capital I Trust 2007-IQ13.
The lowered ratings reflect accumulated interest shortfalls
resulting from ASER amounts related to seven ($89.0 million,
5.6%) of the 15 ($377.7 million, 23.6%) loans that are currently
with the special servicer, LNR, as well as special servicing fees.
As of the Jan. 18, 2011, trustee remittance report ARAs totaling
$52.6 million were in effect for eight loans.  The total reported
ASER amount on seven loans was $262,442, and the reported
cumulative ASER amount was $1.7 million.  Standard & Poor's
considered seven ASER amounts (totaling $262,442), all of which
were based on MAI appraisals, as well as current special servicing
fees in determining its rating actions.  The reported monthly
interest shortfalls totaled $379,663 and accumulated interest
shortfalls have affected class F and all of the classes
subordinate to it.  Classes G, H, J, K, and L have had accumulated
interest shortfalls outstanding between four and seven months,
which S&P expects to remain outstanding for the foreseeable
future.  Consequently, S&P lowered its ratings on these classes to
'D (sf)'.

     Wachovia Bank Commercial Mortgage Trust's series 2005-C17

S&P lowered its ratings on the class L, M, N, and O certificates
from Wachovia Bank Commercial Mortgage Trust's series 2005-C17.
The lowered ratings reflect accumulated interest shortfalls
resulting from ASER amounts related to six ($67.8 million, 2.9%)
of the 14 ($207.0 million, 8.9%) loans that are currently with the
special servicer, CWCapital Asset Management LLC, as well as
special servicing fees.  S&P lowered its ratings on the class H,
J, and K certificates because S&P believes these classes are
susceptible to future interest shortfalls.  As of the Jan. 18,
2011, trustee remittance report ARAs totaling $38.6 million were
in effect for seven loans.  The total reported ASER amount,
excluding an ASER recovery of $143,752 on the Deer Valley Office
Park loan, was $91,731, and the reported cumulative ASER amount
was $1.3 million.  Standard & Poor's considered five ASER amounts
(totaling $90,994), all of which were based on MAI appraisals, as
well as current special servicing fees in determining its rating
actions.  The reported monthly interest shortfalls totaled
$13,562, and accumulated interest shortfalls have affected class L
and all of the classes subordinate to it.  Classes L, M, N, and O
have had accumulated interest shortfalls outstanding for eight
months, which S&P expects to remain outstanding for the
foreseeable future.  Consequently, S&P lowered its ratings on
these classes to 'D (sf)'.

     Wachovia Bank Commercial Mortgage Trust's series 2005-C19

S&P lowered its ratings on the class H, J, K, L, M, N, and O
certificates from Wachovia Bank Commercial Mortgage Trust's
series 2005-C19.  The lowered ratings reflect accumulated
interest shortfalls resulting from ASER amounts related to three
($17.7 million, 1.4%) of the five ($126.3 million, 9.7%) loans
that are currently with the special servicer, Torchlight Investors
LLC, as well as special servicing fees.  An interest rate
reduction on the Centennial Tower loan also contributed to the
interest shortfalls.  S&P lowered its rating on the class G
certificate because S&P believes this class is susceptible to
future interest shortfalls.  As of the Jan. 18, 2011, trustee
remittance report ARAs totaling $17.7 million were in effect for
three loans.  The total reported ASER amount on three loans was
$73,787, and the reported cumulative ASER amount was $664,929.
Standard & Poor's considered three ASER amounts (totaling
$73,787), all of which were based on MAI appraisals, as well as
current special servicing fees and an interest rate reduction of
$111,765 resulting from the modification of the Centennial Tower
loan, in determining its rating actions.  The reported monthly
interest shortfalls totaled $226,366, and accumulated interest
shortfalls have affected class H and all of the classes
subordinate to it.  Classes J, K, L, M, N, and O have had
accumulated interest shortfalls outstanding between three and
four months, which S&P expects to remain outstanding for the
foreseeable future.  Consequently, S&P lowered its ratings on
these classes to 'D (sf)'.

                          Rating Actions

                    CD 2006-CD3 Mortgage Trust
           Commercial mortgage pass-through certificates

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From        Credit enhancement    Current  Accumulated
-----  --        ----        ------------------    -------  -----------
J      CCC- (sf) B (sf)        3.25                 74,922       74,922
K      D (sf)    B- (sf)       2.08                204,554    1,050,017
L      D (sf)    B- (sf)       1.69                 59,487      588,336
M      D (sf)    CCC+ (sf)     1.43                 39,655      396,552
N      D (sf)    CCC+ (sf)     1.03                 59,487      608,464
O      D (sf)    CCC+ (sf)     0.90                 19,828      218,104
P      D (sf)    CCC (sf)      0.51                 59,483      654,311
Q      D (sf)    CCC (sf)      0.38                 19,832      218,152

       JPMorgan Chase Commercial Mortgage Securities Corp.
  Commercial mortgage pass-through certificates series 2005-LDP1

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From        Credit enhancement    Current  Accumulated
-----  --        ----        ------------------    -------  -----------
K      CCC- (sf) B- (sf)       2.24                    659       71,150
L      D (sf)    CCC+ (sf)     1.73                 43,909      208,300
M      D (sf)    CCC (sf)      1.39                 29,270      146,349
N      D (sf)    CCC- (sf)     1.04                 29,274      213,094
P      D (sf)    CCC-(sf)      0.53                 43,905      482,553

             LB-UBS Commercial Mortgage Trust 2007-C6
          Commercial mortgage pass-through certificates

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From        Credit enhancement    Current  Accumulated
-----  --        ----        ------------------    -------  -----------
H      CCC- (sf) B (sf)        6.80                  4,084        4,084
J      CCC- (sf) B (sf)        5.41                213,067      657,483
K      CCC- (sf) B- (sf)       4.40                154,953      624,984
L      D (sf)    B- (sf)       2.88                190,428      761,713
M      D (sf)    B- (sf)       2.38                 63,478      255,431
N      D (sf)    CCC+ (sf)     2.00                 47,607      250,111
P      D (sf)    CCC (sf)      1.87                 15,866       95,197
Q      D (sf)    CCC (sf)      1.62                 31,741      227,968
S      D (sf)    CCC- (sf)     1.37                 31,737      253,893

             LB-UBS Commercial Mortgage Trust 2007-C7
          Commercial mortgage pass-through certificates

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From       Credit enhancement     Current  Accumulated
-----  --        ----       ------------------     -------  -----------
G      CCC+ (sf) B (sf)     5.43                   (91,194)           0
H      CCC- (sf) B- (sf)    4.55                   (60,680)     377,702
J      CCC- (sf) B- (sf)    3.80                    123,885     499,639
K      D (sf)    B- (sf)    2.92                    144,529     582,895
L      D (sf)    CCC+ (sf)  2.29                     75,013     300,050
M      D (sf)    CCC (sf)   1.91                     45,010     180,039
N      D (sf)    CCC-(sf)   1.53                     45,006     244,448
P      D (sf)    CCC- (sf)  1.40                     15,003      90,020
Q      D (sf)    CCC- (sf)  1.28                     15,003     119,676
S      D (sf)    CCC-(sf)   1.15                     15,003     120,026

             Morgan Stanley Capital I Trust 2007-IQ13
      Commercial mortgage pass-through certificates series

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From        Credit enhancement    Current  Accumulated
-----  --        ----        ------------------    -------  -----------
F      CCC- (sf) B- (sf)     4.79                   36,781     36,781
G      D (sf)    B- (sf)     3.89                   69,211    142,149
H      D (sf)    CCC+ (sf)   2.74                   88,988    456,590
J      D (sf)    CCC(sf)     2.22                   34,561    209,566
K      D (sf)    CCC- (sf)   2.10                    8,638     52,379
L      D (sf)    CCC- (sf)   1.84                   17,281    120,779

              Wachovia Bank Commercial Mortgage Trust
   Commercial mortgage pass-through certificates series 2005-C17

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From        Credit enhancement    Current  Accumulated
-----  --        ----        ------------------    -------  -----------
H      B+ (sf)   BB- (sf)      3.59                      0            0
J      CCC+ (sf) B+ (sf)       3.30                (65,644)           0
K      CCC- (sf) B (sf)        2.87               (127,356)           0
L      D (sf)    B- (sf)       2.28                (15,212)     351,340
M      D (sf)    CCC+ (sf)     1.99                 28,299      226,389
N      D (sf)    CCC (sf)      1.70                 28,299      226,389
O      D (sf)    CCC- (sf)     1.41                 28,299      226,389

             Wachovia Bank Commercial Mortgage Trust
  Commercial mortgage pass-through certificates series 2005-C19

                                                        Reported
          Rating                                  interest shortfalls ($)
          ------                                  -----------------------
Class  To        From        Credit enhancement    Current  Accumulated
-----  --        ----        ------------------    -------  -----------
G      B+ (sf)   BB+ (sf)      5.87                (5,331)            0
H      CCC- (sf) BB (sf)       4.33                (3,297)       87,666
J      D (sf)    BB- (sf)      3.71                 33,570       95,697
K      D (sf)    B+ (sf)       3.09                 33,570      100,711
L      D (sf)    B (sf)        2.63                 25,175       83,917
M      D (sf)    B (sf)        2.32                 16,783       67,132
N      D (sf)    B- (sf)       2.16                  8,392       33,566
O      D (sf)    CCC+ (sf)     1.85                 16,783       67,132


* S&P Downgrades Ratings on 182 Classes From 67 RMBS Transactions
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 182
classes from 67 U.S. residential mortgage-backed securities
transactions backed primarily by scratch-and-dent mortgage loan
collateral issued between 2001 and 2006.  S&P removed two of the
lowered ratings from CreditWatch with negative implications.  In
addition, S&P affirmed its ratings on 212 classes from 58 of the
downgraded transactions, as well as seven other transactions, and
removed 15 of the affirmed ratings from CreditWatch negative.  S&P
also withdrew its ratings on two other classes.

The "scratch-and-dent" collateral backing these transactions
originally consisted predominantly of reperforming first-lien,
fixed- and adjustable-rate, residential mortgage loans secured by
one- to four-family properties.

The downgrades and affirmations incorporate S&P's current and
projected losses, which S&P based on the dollar amounts of loans
currently in the transactions' delinquency, foreclosure, and real
estate owned pipelines, as well as S&P's projection of future
defaults.  S&P also incorporated cumulative losses to date in its
analysis when assessing rating outcomes.

S&P derived its loss assumptions using its criteria listed in the
"Related Criteria And Research".  As part of its analysis, S&P
considered the characteristics of the underlying mortgage
collateral, as well as macroeconomic influences.  For example,
S&P's view of the risk profile of the underlying mortgage pools
influences its default projections, while its outlook for housing-
price declines and the health of the housing market influence
S&P's loss severity assumptions.  Furthermore, S&P adjusted its
loss expectations for each deal based on upward trends in
delinquencies.

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

The lowered ratings reflect S&P's belief that the amount of credit
enhancement available for the downgraded classes is not sufficient
to cover losses at the previous rating levels, given its current
projected losses, due to increased delinquencies.  The
affirmations reflect S&P's belief that there is sufficient credit
enhancement to support the ratings at their current levels.

S&P monitors these transactions to incorporate updated losses and
delinquency pipeline performance to assess whether, in its view,
the applicable credit enhancement features are sufficient to
support the current ratings.  S&P will continue to monitor these
transactions and take additional rating actions in accordance with
its criteria.

                          Rating Actions

  C-BASS Mortgage Loan Asset-Backed Certificates Series 2002-CB2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       A-2        12489WER1   BBB- (sf)            AAA (sf)
       M-1        12489WET7   B- (sf)              AAA (sf)
       M-2        12489WEU4   CC (sf)              BBB (sf)
       B-1        12489WEV2   CC (sf)              CCC (sf)
       B-2        12489WEW0   CC (sf)              CCC (sf)

                          2002-CB4 Trust
                       Series      2002-CB4

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        12489WFD1   AA+ (sf)             AAA (sf)
       M-2        12489WFE9   B (sf)               AA (sf)
       B-1        12489WFF6   CC (sf)              CCC (sf)
       B-2        12489WFG4   CC (sf)              CCC (sf)

  C-BASS Mortgage Loan Asset Backed Certificates Series 2002-CB5

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        12489WFS8   AA- (sf)             AAA (sf)
       M-2        12489WFT6   B- (sf)              BB (sf)

                           2003-CB2 Trust
                       Series      2003-CB2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        04542BCW0   BB (sf)              A (sf)
       M-2        04542BCX8   CCC (sf)             BB (sf)
       B-1        04542BCY6   CC (sf)              B (sf)
       B-2        04542BCZ3   CC (sf)              CCC (sf)

                          2003-CB3 Trust
                       Series      2003-CB3

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        12489WGM0   BB+ (sf)             AAA (sf)
       M-2        12489WGN8   CC (sf)              BBB (sf)
       B-1        12489WGP3   CC (sf)              B (sf)
       B-2        12489WGQ1   CC (sf)              CCC (sf)

    ACE Securities Corp Home Equity Loan Trust Series 2004-SD1
                       Series      2004-SD1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        004421HF3   B (sf)               A (sf)
       M-3        004421HG1   CC (sf)              B- (sf)
       M-4        004421HH9   CC (sf)              CCC (sf)

   ACE Securities Corp. Home Equity Loan Trust, Series 2005-SD3
                       Series      2005-SD3

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        004421TQ6   BB+ (sf)             AA (sf)
       M-2        004421TR4   CCC (sf)             BBB (sf)
       M-3        004421TS2   CC (sf)              CCC (sf)

   ACE Securities Corp. Home Equity Loan Trust, Series 2005-SD1
                       Series      2005-SD1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        004421KL6   B- (sf)              A+ (sf)
       M-3        004421KM4   CC (sf)              BBB+ (sf)
       M-4        004421KN2   CC (sf)              B (sf)

       Bayview Financial Mortgage Pass Through Trust 2005-C
                       Series      2005-C

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-3        07325NBR2   A- (sf)              A (sf)
       M-4        07325NBS0   BB (sf)              A- (sf)
       B-1        07325NBT8   B- (sf)              BBB+ (sf)
       B-2        07325NBU5   CCC (sf)             BB (sf)
       B-3        07325NBV3   CC (sf)              CCC (sf)

   Bayview Financial Mortgage Pass Through Trust Series 2006-B
                        Series      2006-B

                                 Rating
                                 ------
  Class      CUSIP       To                   From
  -----      -----       --                   ----
  A-IO       07325NDJ8   AAA (sf)             AAA (sf)/Watch Neg
  1-A2       07325NDL3   AAA (sf)             AAA (sf)/Watch Neg
  1-A3       07325NDM1   AAA (sf)             AAA (sf)/Watch Neg
  1-A4       07325NDN9   AAA (sf)             AAA (sf)/Watch Neg
  1-A5       07325NDP4   AAA (sf)             AAA (sf)/Watch Neg
  2-A3       07325NDS8   AAA (sf)             AAA (sf)/Watch Neg
  2-A4       07325NDT6   AAA (sf)             AAA (sf)/Watch Neg
  M-1        07325NDU3   BB- (sf)             AA (sf)/Watch Neg
  M-2        07325NDV1   B- (sf)              BBB (sf)
  M-4        07325NDX7   CC (sf)              CCC (sf)
  B-1        07325NDY5   CC (sf)              CCC (sf)
  B-2        07325NDZ2   CC (sf)              CCC (sf)

       Bayview Financial Mortgage Pass-Through Trust 2006-A
                        Series      2006-A

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        07325NCY6   AA- (sf)             AA (sf)
       M-2        07325NCZ3   BBB (sf)             AA- (sf)
       M-3        07325NDA7   B- (sf)              A (sf)
       M-4        07325NDB5   CCC (sf)             A- (sf)
       B-1        07325NDC3   CCC (sf)             BBB+ (sf)
       B-2        07325NDD1   CC (sf)              BB (sf)
       B-3        07325NDE9   CC (sf)              B (sf)

       Bayview Financial Mortgage Pass-Through Trust 2006-C
                        Series      2006-C

                                 Rating
                                 ------
  Class      CUSIP       To                   From
  -----      -----       --                   ----
  1-A1       07325DAB0   AAA (sf)             AAA (sf)/Watch Neg
  1-A2       07325DAC8   AAA (sf)             AAA (sf)/Watch Neg
  1-A3       07325DAD6   BB (sf)              AA (sf)
  1-A4       07325DAE4   CCC (sf)             B (sf)
  1-A5       07325DAF1   B- (sf)              B (sf)
  2-A2       07325DAH7   AAA (sf)             AAA (sf)/Watch Neg
  2-A3       07325DAJ3   CCC (sf)             BB (sf)
  2-A4       07325DAK0   CCC (sf)             BB (sf)
  M-1        07325DAL8   CC (sf)              CCC (sf)

   Bayview Financial Mortgage Pass-Through Trust, Series 2005-B
                        Series      2005-B

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       B-2        07325NBD3   B- (sf)              BB (sf)

   Bayview Financial Mortgage Pass-Through Trust, Series 2005-D
                        Series      2005-D

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        07325NCD2   B+ (sf)              AA+ (sf)
       M-2        07325NCE0   CCC (sf)             AA (sf)
       M-3        07325NCF7   CCC (sf)             AA- (sf)
       M-4        07325NCG5   CC (sf)              A+ (sf)
       M-5        07325NCH3   CC (sf)              BBB (sf)
       M-6        07325NCJ9   CC (sf)              BB (sf)
       B-1        07325NCK6   CC (sf)              B (sf)
       A-F4       07325NCB6   AA (sf)              AAA (sf)

         Bear Stearns Asset Backed Securities Trust 2002-1
                        Series      2002-1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       B          07384YCZ7   CC (sf)              CCC (sf)

         Bear Stearns Asset Backed Securities Trust 2002-2
                        Series      2002-2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        07384YER3   A- (sf)              AA- (sf)

         Bear Stearns Asset Backed Securities Trust 2003-2
                        Series      2003-2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        07384YJV9   B+ (sf)              BBB (sf)
       B          07384YJW7   CC (sf)              CCC (sf)

         Bear Stearns Asset Backed Securities Trust 2003-3
                        Series      2003-3

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        07384YLU8   BBB+ (sf)            AA (sf)
       M-2        07384YLV6   CCC (sf)             A (sf)
       B          07384YLW4   CC (sf)              B (sf)

         Bear Stearns Asset Backed Securities Trust 2003-SD1
                        Series      2003-SD1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        07384YKN5   BBB+ (sf)            A (sf)
       B          07384YKP0   CCC (sf)             B (sf)

         Bear Stearns Asset Backed Securities Trust 2003-SD2
                        Series      2003-SD2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       B-1        07384YLL8   A (sf)               AA+ (sf)
       B-2        07384YLM6   B- (sf)              BB (sf)

        Bear Stearns Asset Backed Securities Trust 2003-SD3
                      Series      2003-SD3

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       B          07384YNE2   B- (sf)              B (sf)

        Bear Stearns Asset Backed Securities Trust 2004-1
                        Series      2004-1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        07384YSZ0   B- (sf)              BB (sf)
       M-3        07384YTF3   CCC (sf)             B (sf)
       B-2        07384YTB2   CC (sf)              CCC (sf)

        Bear Stearns Asset Backed Securities Trust 2004-2
                        Series      2004-2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        073879GZ5   AA (sf)              AA+ (sf)
       M-2        073879HA9   CCC (sf)             BB (sf)
       M-3        073879HB7   CC (sf)              B (sf)
       B          073879HC5   CC (sf)              CCC (sf)

        Bear Stearns Asset Backed Securities Trust 2004-SD1
                       Series      2004-SD1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        07384YSG2   BBB- (sf)            A (sf)
       M-3        07384YSH0   CC (sf)              B (sf)
       B          07384YSJ6   CC (sf)              CCC (sf)

        Bear Stearns Asset Backed Securities Trust 2004-SD2
                       Series      2004-SD2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       B-2        07384YTN6   BBB+ (sf)            A (sf)
       B-3        07384YTP1   CCC (sf)             B (sf)

        Bear Stearns Asset Backed Securities Trust 2004-SD3
                       Series      2004-SD3

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        073879GB8   A (sf)               AA (sf)
       M-2        073879GC6   B- (sf)              BBB (sf)
       M-3        073879GD4   CC (sf)              B (sf)
       B          073879GE2   CC (sf)              CCC (sf)

        Bear Stearns Asset Backed Securities Trust 2004-SD4
                       Series      2004-SD4

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        073879ME5   BBB- (sf)            A (sf)
       B          073879MG0   CCC (sf)             B (sf)

        Bear Stearns Asset Backed Securities Trust 2006-2
                        Series      2006-2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        07388FAD5   A- (sf)              AA (sf)
       M-2        07388FAE3   BBB- (sf)            AA- (sf)
       M-3        07388FAF0   B- (sf)              BBB (sf)
       M-4        07388FAG8   CCC (sf)             BB (sf)
       M-5        07388FAH6   CCC (sf)             B (sf)
       M-6        07388FAJ2   CCC (sf)             B- (sf)

                      C-BASS 2003-RP1 Trust
                      Series      2003-RP1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        124860DT1   CCC (sf)             AA (sf)
       M-2        124860DU8   CC (sf)              CCC (sf)

                      C-Bass Trust 2001-CB3
                      Series      2001-CB3

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       B-1        12489WDV3   CC (sf)              CCC (sf)

                Citigroup Mortgage Loan Trust Inc.
                      Series      2005-HE2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        17307GSU3   A+ (sf)              AA (sf)
       M-2        17307GSV1   B- (sf)              A (sf)

                Citigroup Mortgage Loan Trust Inc.
                      Series      2005-SHL1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        17307GR67   BBB- (sf)            AA (sf)
       M-2        17307GR75   B- (sf)              A (sf)

                Citigroup Mortgage Loan Trust Inc.
                      Series      2006-SHL1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       A          17309UAA3   A (sf)               AAA (sf)
       M-1        17309UAB1   B- (sf)              A (sf)
       M-3        17309UAD7   CC (sf)              CCC (sf)
       M-4        17309UAE5   CC (sf)              CCC (sf)
       M-5        17309UAF2   CC (sf)              CCC (sf)

               Countrywide Home Loan Trust 2003-SD2
                       Series      2003-SD2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        126671ZF6   BB+ (sf)             AA (sf)
       M-2        126671ZG4   CCC (sf)             BBB (sf)
       B-1        126671ZH2   CC (sf)              CCC (sf)

               Countrywide Home Loan Trust 2004-SD2
                       Series      2004-SD2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        1266716Z4   B- (sf)              AA (sf)
       B-1        1266717A8   CC (sf)              BB (sf)
       B-2        1266717B6   CC (sf)              B (sf)

              Countrywide Home Loan Trust 2004-SD1
                       Series      2004-SD1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        1266712J4   A (sf)               AA+ (sf)
       M-2        1266712K1   CCC (sf)             BBB (sf)
       B-1        1266712L9   CC (sf)              BB (sf)
       B-2        1266712M7   CC (sf)              CCC (sf)

                       CSFB Trust 2004-CF1
                       Series      2004-CF1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        22541SBY3   B- (sf)              BBB (sf)
       B          22541SBZ0   CC (sf)              B (sf)

                      CSFB Trust 2005-CF1
                      Series      2005-CF1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       B          225458M70   B+ (sf)              BBB (sf)

                      CSMC Trust 2006-CF1
                      Series      2006-CF1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       B-1        225470UB7   BBB (sf)             BBB+ (sf)
       B-2        225470UC5   BB (sf)              BBB (sf)
       B-3        225470UD3   B- (sf)              BBB- (sf)

                       CSMC Trust 2006-CF2
                       Series      2006-CF2

                                 Rating
                                 ------
  Class      CUSIP       To                   From
  -----      -----       --                   ----
  A-1        12638EAA2   AAA (sf)             AAA (sf)/Watch Neg
  M-1        12638EAE4   AA (sf)              AA (sf)/Watch Neg
  M-3        12638EAG9   B+ (sf)              A (sf)

                        CSMC Trust 2006-CF3
                        Series      2006-CF3

                                 Rating
                                 ------
  Class      CUSIP       To                   From
  -----      -----       --                   ----
  A-1        12638GAA7   AAA (sf)             AAA (sf)/Watch Neg
  M-3        12638GAD1   CC (sf)              CCC (sf)

            CWABS Asset-Backed Notes Trust 2004-SD4
                       Series      2004-SD4

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        126673SE3   AA (sf)              AA+ (sf)
       M-2        126673SF0   B- (sf)              BB (sf)
       M-3        126673SG8   CC (sf)              B (sf)
       B-1        126673SH6   CC (sf)              CCC (sf)

             CWABS Asset-Backed Notes Trust 2005-SD1
                       Series      2005-SD1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-1        126673G30   AA- (sf)             AA+ (sf)
       M-2        126673G48   CCC (sf)             BB (sf)
       M-3        126673G55   CC (sf)              B (sf)
       B-1        126673G63   CC (sf)              CCC (sf)

             CWABS Asset-Backed Notes Trust 2005-SD2
                       Series      2005-SD2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-3        1266734Y5   B (sf)               A+ (sf)
       M-4        1266734Z2   CCC (sf)             B (sf)
       M-5        1266735A6   CC (sf)              CCC (sf)

                 EMC Mortgage Loan Trust 2004-B
                        Series      2004-B

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       A-1        268668DW7   NR                   AAA (sf)
       A-2        268668DX5   A- (sf)              A (sf)

                  EMC Mortgage Loan Trust 2005-A
                        Series      2005-A

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       A          268668EK2   B+ (sf)              AAA (sf)
       M-1        268668EM8   CCC (sf)             B (sf)
       M-2        268668EP1   CC (sf)              CCC (sf)

                  EMC Mortgage Loan Trust 2005-B
                        Series      2005-B

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       A          268668EW6   B- (sf)              AAA (sf)
       M-1        268668EX4   CCC (sf)             B- (sf)
       M-2        268668EY2   CC (sf)              CCC (sf)

                  EMC Mortgage Loan Trust 2006-A
                        Series      2006-A

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       A          268668FD7   B (sf)               AAA (sf)
       M-1        268668FE5   CCC (sf)             B (sf)
       B          268668FG0   CC (sf)              CCC (sf)

                  Fannie Mae REMIC Trust 2002-W1
                       Series      2002-W1

                                 Rating
                                 ------
  Class      CUSIP       To                   From
  -----      -----       --                   ----
  B-2        31392CMN1   BBB (sf)             BBB (sf)/Watch Neg

                 Financial Asset Securities Corp.
                       Series      2004-RP1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       I-B-3      92922FYQ5   CCC (sf)             BBB (sf)

           Security National Mortgage Loan Trust 2004-1
                        Series      2004-1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       AF-3       81441PBR1   A+ (sf)              AAA (sf)
       M-1        81441PBT7   CCC (sf)             BBB (sf)
       M-2        81441PBU4   CC (sf)              B (sf)

           Security National Mortgage Loan Trust 2004-2
                        Series      2004-2

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       AF-3       81441PBZ3   A- (sf)              AAA (sf)
       AV         81441PCA7   AA- (sf)             AAA (sf)
       M-1        81441PCB5   B- (sf)              A (sf)

           Security National Mortgage Loan Trust 2005-1
                        Series      2005-1

                                      Rating
                                      ------
       Class      CUSIP       To                   From
       -----      -----       --                   ----
       M-2        81441PCJ8   BBB- (sf)            A (sf)
       B-1        81441PCK5   B- (sf)              BBB (sf)
       B-2        81441PCL3   CCC (sf)             BB (sf)

           Security National Mortgage Loan Trust 2006-1
                        Series      2006-1

                            &nb