TCR_Public/110417.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, April 17, 2011, Vol. 14, No. 106

                            Headlines

AMER.OPP.HSG: Moody's Cuts Rating on Housing Revenue Bonds to 'B1'
BANC OF AMERICA: Moody's Affirms 25 CMBS Classes of BACM 2008-LS1
BELLEMONT VICTORIA: Moody's Holds Ba3 Bond Rating; Outlook Stable
BEXAR COUNTY HOUSING: Moody's Affirms 'B3' Rating On Rev. Bonds
CAPITALSOURCE REAL: Moody's Affirms All CRE CDO Classes

CARYLE VEYRON: S&P Affirms Class D Notes 'BB+' Rating
CENTERLINE 2007-1: Moody's Cuts Affirms Ratings of 13 CRE CDO
CENTEX HOME: Moody's Cuts Rating on $62 million of Subprime RMBS
CIT HOME: Moody's Cuts Rating on $90 Million of Subprime RMBS
CITY OF INDIANAPOLIS: Moody's Confirms Ba2 Rating on Revenue Bonds

CMBSPOKE 2006-I: Moody's Junks Ratings on Three CRE CDO Classes
CONSECO FINANCE: Moody's Cuts Rating of Class BV-2 to 'B1'
CRYSTAL RIVER: Moody's Affirms Ratings on Eight CRE CDO
DA-LITE SCREEN: S&P Maintains 'B' Corporate Credit Rating
DEUTSCHE MORTGAGE: Moody's Junks Ratings of 2 Classes of Certs.

DIVERSIFIED GLOBAL: S&P Lowers Class B Notes Rating to 'BB-'
ESSEX PROPERTY: Fitch Puts 'BB+' Ratings on $65MM Preferred Stock
ESSEX PROPERTY: S&P Assigns 'BB+' Rating to $65MM Preferred Shares
FTA SANTANDER: DBRS Puts 'B' Provisional Rating to Series B Notes
GALAXY VI: S&P RAISES Class D Notes From 'BB+' to 'BBB'

GS MORTGAGE: DBRS Assigns Final Rating of Class E at 'BB'
HARBORVIEW MORTGAGE: Moody's Cuts Rating of Class B9 to 'C'
HELIOS FINANCE: Moody's Ups Rating on Securities From Auto Loans
HUDSON CANYON: Moody's Upgrades Rating on US$5MM Notes to 'B1'
JPMORGAN CHASE: S&P Places Ratings on 11 Classes on Watch Negative

JPMORGAN RV: Moody's Junks Rating on 2004 JPMorgan RV
LB-UBS COMM'L: Moody's Cuts Ratings on 4 Classes of CMBS Certs.
LB-UBS COMM'L: Moody's Holds Rating on 19 CMBS Classes of Certs.
LNR CDO IV LTD: Moody's Affirms Ratings on 13 CRE CDO
MARATHON FINANCING: S&P Affirms Ratings on Two Classes From 'BB+'

MASTER STUDENT: Moody's Cuts Ratings on Five Notes to 'Ca'
MBIA INSURANCE: S&P Incorrectly Lowers Series 1995-1 Rating
MORGAN STANLEY: S&P Affirms Rating on Class O Notes to 'B+'
PPLUS TRUST: S&P Lowers Ratings on Two Classes of Cert. to 'BB'
PREFERREDPLUS TRUST: S&P Raises Rating on $40MM Certs. to 'BB-'

PREFERREDPLUS TRUST: S&P Raises Rating on 8% Certs. to 'BB-'
PRUDENTIAL SECURITIES: Moody's Ups Ratings on 2 Classes of Certs.
REGIONAL DIVERSIFIED: Moody's Junks Rating on US$62MM Notes
RENAISSANCE HOME: Moody's Cuts Ratings on $24MM Subprime RMBS
REVE SPC: S&P Corrects Rating on Class B Notes to 'B'

SEAWALL 2006-4: Moody's Affirms Ratings on Six CRE CDO
SEAWALL 2006-4A: Moody's Affirms Six CRE CDO Classes
SOLOSO CDO: Moody's Junks Ratings on Class A-1LA & A-1LB Notes
SORIN REAL ESTATE: Moody's Affirms Ratings on Five CRE CDO
STRUCTURED ASSET: S&P Downgrades Rating on Class A1 to 'BB'

TUCKAHOE CREDIT: S&P Affirms 'BB' Rating on Pass-through Certs.
VALEO INVESTMENT: Moody's Ups 2 Classes of Notes Ratings to Caa3
WACHOVIA BANK: Moody's Holds Ratings of 23 CMBS Classesof Certs.
WACHOVIA BANK: Moody's Holds Ratings on 31 CMBS Classes of Certs.
WESTERN EXPRESS: S&P Junks Corporate Credit Rating; Outlook Stable

WHITNEY CLO: S&P Raises Class B-1LB Rating to 'B+' From 'CCC-'
ZAIS INVESTMENT: Moody's Ups Rating on US$285MM Notes to 'B1'

* S&P Affirms Ratings on 18 Classes of COMM 2006-CNL2 Certs.
* S&P Affirms Ratings on 28 Classes From 21 RMBS Transactions
* S&P Lowers Ratings on 15 Classes to 'D'
* S&P Lowers Ratings on 18 Classes From 6 CMBS Transactions to 'D'
* S&P Lowers Ratings on 191 Classes From 50 RMBS Transactions

* S&P Withdraws Ratings on 52 Classes on CMBS & CDO Transactions

                            *********

AMER.OPP.HSG: Moody's Cuts Rating on Housing Revenue Bonds to 'B1'
------------------------------------------------------------------
Moody's Investors Service has downgraded to B1 from Ba1 the rating
on the Bexar County (TX) Housing Finance Corporation Multifamily
Housing Revenue Bonds (American Opportunity for Housing-Dublin,
Kingswood, and Waterford Apartments Project) Senior Series 2001A
and downgraded to B3 from Ba2 the rating on the Subordinate Series
2001B.  The outlook on the rating remains negative.  The Junior
Subordinate Series C bonds are not rated.  The rating for the
senior and subordinate bonds have been downgraded due to an
increased dependence on owner contributions to support the bond's
debt service.

Ratings Rationale

Dublin, Waterford, and Kingswood Manor apartments are three
separate multi-family rental properties located in San Antonio,
Texas with 156, 133, and 129 units respectively.  The properties
are located approximately 8 to 12 miles north of downtown San
Antonio with good access to the city's principal traffic arteries.

Legal Security: The bonds are secured by a lien on and pledge and
assignment of a security interest in the Trust Estate.

Strengths

   * Fully funded debt service reserve funds for both the Series
     A, B bonds and C (unrated) bonds.

   * Bonds are secured by the revenues from all three properties,
     instead of relying on revenues from one property to cover
     debt service on the bonds. Moody's views this diversification
     of revenues as a credit strength.

Challenges

   * Both physical and economic occupancy at the properties
     continue to be a challenge.

   * The projects have been relying on owner contributions in
     order to cover debt service and expenses.

   * There is further financial stress from a February 2009 fire
     at Dublin apartments.

Both physical and economic occupancy at the properties continue to
be a challenge.  Current physical occupancy for the properties was
uneven, with 79% at the Dublin property, 96.69% at the Kingswood
property and 84.21% at the Waterford property.  In terms of
current economic occupancy, Dublin property maintained a 73%
economic occupancy, the Kingswood property a 78% economic
occupancy and the Waterford project a 88% economic occupancy.

The projects have been relying on owner contributions in order to
cover debt service and expenses.  Contributions have been
increasing since the fire in 2009.  Contributions are expected to
be approximately $140,000 for the next debt service date.

There is further financial stress from a February 2009 fire at
Dublin apartments.  The property experienced a fire that destroyed
12 units (8% of the property's units and 3% of the units across
all three properties).  Partial Insurance proceeds have been
received, although the remaining insurance funds are on hold
pending a lawsuit with a neighboring property.  Project revenues
and coverage have suffered as a result of the delay in payment of
the insurance proceeds.
Outlook

The rating outlook for the rating remains negative.  The negative
outlook reflects the uncertainty around the timing of claims
payments and the rebuilding of down units.

What could change the rating up:

   -- Improvement in physical and economic occupancy rates,
      leading to increased rental revenue and growth in debt
      service coverage.

   -- Insurance proceeds being received

What could change the rating down:

   -- Material deterioration in debt service coverage; tapping any
      of the debt service reserve funds.

The principal methodology used in this rating was Global Housing
Projects published in July 16, 2010.


BANC OF AMERICA: Moody's Affirms 25 CMBS Classes of BACM 2008-LS1
-----------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed these ratings of
25 CMBS classes of Banc of America Commercial Mortgage Inc.,
Commercial Mortgage Pass-Through Certificates, Series 2008-LS1:

   -- Cl. A-2, Affirmed at Aaa (sf); previously on Mar 24, 2008
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-3, Affirmed at Aaa (sf); previously on Mar 24, 2008
      Definitive Rating Assigned Aaa (sf)

   -- Cl. XW, Affirmed at Aaa (sf); previously on Mar 24, 2008
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-4A, Affirmed at Aaa (sf); previously on Apr 28, 2010
      Confirmed at Aaa (sf)

   -- Cl. A-4B, Affirmed at Aa1 (sf); previously on Apr 28, 2010
      Downgraded to Aa1 (sf)

   -- Cl. A-4BF, Affirmed at Aa1 (sf); previously on Apr 28, 2010
      Downgraded to Aa1 (sf)

   -- Cl. A-1A, Affirmed at Aa1 (sf); previously on Apr 28, 2010
      Downgraded to Aa1 (sf)

   -- Cl. A-SM, Affirmed at Aa3 (sf); previously on Apr 28, 2010
      Downgraded to Aa3 (sf)

   -- Cl. A-M, Affirmed at A1 (sf); previously on Apr 28, 2010
      Downgraded to A1 (sf)

   -- Cl. A-J, Affirmed at Baa2 (sf); previously on Apr 28, 2010
      Downgraded to Baa2 (sf)

   -- Cl. B, Affirmed at Ba1 (sf); previously on Apr 28, 2010
      Downgraded to Ba1 (sf)

   -- Cl. C, Affirmed at Ba3 (sf); previously on Apr 28, 2010
      Downgraded to Ba3 (sf)

   -- Cl. D, Affirmed at B3 (sf); previously on Apr 28, 2010
      Downgraded to B3 (sf)

   -- Cl. E, Affirmed at Caa2 (sf); previously on Apr 28, 2010
      Downgraded to Caa2 (sf)

   -- Cl. F, Affirmed at Caa3 (sf); previously on Apr 28, 2010
      Downgraded to Caa3 (sf)

   -- Cl. G, Affirmed at Ca (sf); previously on Apr 28, 2010
      Downgraded to Ca (sf)

   -- Cl. H, Affirmed at Ca (sf); previously on Apr 28, 2010
      Downgraded to Ca (sf)

   -- Cl. J, Affirmed at Ca (sf); previously on Apr 28, 2010
      Downgraded to Ca (sf)

   -- Cl. K, Affirmed at Ca (sf); previously on Apr 28, 2010
      Downgraded to Ca (sf)

   -- Cl. L, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. M, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. N, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. O, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. P, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. Q, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

Ratings Rationale

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

Moody's rating action reflects a cumulative base expected
loss of 10.2% of the current balance.  At last review,
Moody's cumulative base expected loss was 10.8%.  Moody's
stressed scenario loss is 21% of the current balance.  Moody's
provides a current list of base and stress scenario losses
for conduit and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the current
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.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. CMBS Conduit Transactions," published
September 2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 level are driven by
property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value).  Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl score
(Herf), a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 49 compared to 66 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 (CMBS) 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 29, 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 March 10, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 4% to $2.26 billion
from $2.35 billion at securitization.  The Certificates are
collateralized by 227 mortgage loans ranging in size from less
than 1% to 7% of the pool, with the top ten loans representing 30%
of the pool. The pool does not contain any defeased loans or loans
with credit estimates.

Seventy-one loans, representing 22% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package.  As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Eleven loan have been liquidated from the pool resulting in a
$34 million loss (51% average loss severity).  There are 27 loans,
representing 16% of the pool, in special servicing. The largest
specially serviced exposure is the Memphis and Orlando Industrial
Portfolio ($59 million -- 3% of the pool).  This portfolio
contains two cross-collateralized, cross-defaulted loans that
are secured by six industrial properties (three in Memphis and
three in Orlando). The Memphis Loan is current, but the Orlando
Loan is 90+ days delinquent. The portfolio's consolidated
occupancy has decreased from 97% at securitization to 80% as of
December 2009. The servicer has recognized a combined $31 million
appraisal reduction for this portfolio.  The remaining 25
specially serviced loans are secured by a mix of commercial and
multifamily properties. Moody's has estimated a $132 million loss
(37% expected loss based on an 82% probability of default) for all
of the specially serviced loans.  The servicer has recognized a
$124 million aggregate appraisal reduction for 19 of the 27
specially serviced loans.

Moody's has assumed a high default probability for 39 poorly
performing loans representing 14% of the pool and has estimated an
aggregate $48 million loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Based on the most recent remittance statement, Classes K
through S have experienced cumulative interest shortfalls
totaling $6.6 million.  Moody's anticipates that the pool
will continue to experience interest shortfalls because of
the high exposure to specially serviced and troubled loans.
Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, appraisal subordinate
entitlement reductions (ASERs) and extraordinary trust expenses.

Moody's was provided with full year 2009 and partial year
2010 operating results for 99% and 87% of the pool's loans,
respectively.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 109% compared to 122% 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 9.3%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.36X and .97X, respectively, compared to
1.18X and .91X at last review.  Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing conduit loans represent 15% of the
pool balance. The largest loan is the COPT Office Portfolio
Loan ($150 million - 7% of the pool), which is secured by 694,000
square feet (SF) of office space in the Westfields Corporate
Center.  The loan's sponsor, Corporate Office Properties, owns a
total of nine buildings totaling 1.5 million SF in Westfields
Corporate Center, which is located in Chantilly, Virginia.  The
loan was on the watchlist at last review because leases for over
30% of the net rentable area (NRA) expired within 12 months.
Occupancy has declined from 99% at last review to 87% as of
September 2010, however, lease rollover risk is no longer a
concern.  Although the portfolio's 2010 net operating income (NOI)
declined by 5% from 2009, Moody's prior analysis incorporated a
stressed cash flow due to Moody's conerns about potential income
volatility due to upcoming lease expirations.  Moody's LTV and
stressed DSCR are 132% and .74X, respectively, compared to 203%
and .51X at last review.

The second largest loan is the 600 West Chicago Loan ($134 million
-- 6% of the pool), which is secured by a 1.6 million SF Class A
office complex located on the edge of River North in Chicago's
central business district.  The loan is pari passu with CGCMT
2007-C6 & MLMT 2007-C1.  The collateral is the former Montgomery
Ward & Co. catalog building and is a landmarked asset.  It also
serves as Groupon's headquarters.  Although Groupon has recently
signed leases in surrounding buildings, the company has publically
stated that it would eventually like to consolidate its operations
to 600 West.  Property occupancy and performance continue to
improve.  The property was 94% leased as of September 2010
compared to 92% at last review and 84% at securitization. Moody's
LTV and stressed DSCR are 121% and .83X, respectively, compared to
138% and .76X at last review.

The third largest loan is the Hallmark Building Loan ($64 million
-- 3% of the pool), which is secured by a 305,000 SF office
building located in Dulles, Virginia. The Dulles Hilton Hotel is
attached to the Hallmark Building, but it is not part of the
collateral.  The property is current, but is on the watchlist due
to low DSCR.  As of October 2010 the property was 89% leased as
compared to 84% at last review.  An additional 5% of the leases
expire in 2011.  Moody's has identified this loan as a troubled
loan because of its poor performance.  Moody's LTV and stressed
DSCR are 192% and .53X, compared to 236% and .46X at last review.


BELLEMONT VICTORIA: Moody's Holds Ba3 Bond Rating; Outlook Stable
-----------------------------------------------------------------
Moody's Investors Service has affirmed the Ba3 rating for
Louisiana Local Government Environmental Facility and Community
Development Authority Multifamily Housing Revenue bonds (Park
East/Bellemont Victoria/Bellemont Victoria II Apartments) Senior
Series 2002A and the Ba3 rating for Subordinate Series 2002C
bonds.

Rating Rational

The rating outlook for the Senior and Subordinate bonds has been
affirmed at stable.  This rating action is based on review of
unaudited 2010 operating statements for the Park East, Bellemont
Victoria, and Bellemont Victoria II Apartments, coupled with
Moody's review of MBIA Inc. and MBIA Insurance Corporation
(currently rated Ba3/ NEG and B3 / NEG, respectively), which hold
the debt service reserve fund of the Projects in a Guaranteed
Investment Contract (GIC).  Non-performance of the GIC provider is
a risk to bondholders in transactions where bond payments rely
wholly or partially on a GIC.

Strengths

   -- Sufficient debt service coverage ratio at the current rating
      level

Challenges

   -- Debt service reserve fund invested with a low rated provider

Detailed Credit Discussion

The Park East project was built in 1972 and consists of 192 units
in 25 two-story buildings.  Bellemont Victoria is a 195 unit
project of 4 two-story buildings and the Bellemont Victoria II
facility is made up of 27 buildings with 198 units.  All three
properties enjoy a high physical occupancy, averaging 97% for Park
East, 98% for Bellemont Victoria, and 99% for Bellemont Victoria
II in 2010.  The FY2010 unaudited operating statements demonstrate
projects' operating performance in line with the prior year.  The
properties have also accumulated a sizable surplus reserve fund,
with operating reserves of $17,485 and excess reserves of $499,814
as of March 2011, which acts as a cushion for the projects.

Outlook

The rating outlook for the Senior and Subordinate bonds has
been affirmed at stable, given the stable debt service coverage
ratio and high occupancy rates at the three projects.

What Could Change the Rating Up:

   -- Several reporting periods that show consistent revenue
      growth and continued strong occupancy

   -- Replacement of the debt service reserve fund with a highly
      rated provider

What Could Change the Rating Down:

   -- Any erosion of current occupancy levels or increases in
      expenses that affect debt service coverage

The principal methodology used in this rating was Global Housing
Projects published in July 2010.


BEXAR COUNTY HOUSING: Moody's Affirms 'B3' Rating On Rev. Bonds
---------------------------------------------------------------
Moody's Investors Service has affirmed B3 rating on Bexar
County Housing Finance Corporation's (Honey Creek/Austin Point
Apartments) Multifamily Housing Revenue Bonds Series 2000A and
C rating on Series 2000C bonds.  The outlook on the Series 2000A
remains negative.

Rating Rational

This rating action is based on the continued weak operating
performance in 2010, and failure to pay debt service on the
Series 2000C bonds.  The negative outlook reflects continued
deteriorating performance of the project and incorporates
forecasts for weak occupancy for the submarket in the near
term.

Legal Security: The bonds are limited obligations payable solely
from the revenues, receipts and security pledged in the Trust
Indenture.

Strengths

   -- Stabilizing, albeit low, occupancy at the project

Challenges

   -- Non-payment of debt service on the Series 2000C bonds

   -- Continued operating challenges at the project

Detailed Credit Discussion

Although occupancy at the project began to stabilize at
approximately 90-92% range in 2010 it still remains low.  The
average occupancy for the North Central San Antonio submarket,
is forecasted to remain weak, averaging approximately 95% in 2011,
according to CB Richard Ellis.

As per the interim 2010 operating statements debt service
coverage remained weak, indicating continued challenged operating
performance of the project.  Furthermore, due to the reserve and
replacement fund remaining underfunded capital expenditures are
likely being funded from operations.  Furthermore, debt service
on the Series 2000C bonds has not been paid since April 1, 2010.
The Series 2000A debt service reserve fund remains fully funded.
Series 2000C debt service and debt service reserve funds remain
underfunded.

Moody's affirmation of 2000A bonds at the B3 rating level reflects
continued low occupancy and continued operating challenges at the
project.  Moody's current C rating on the Series 2000C bonds
reflects failure to pay debt service on the bonds since April 1,
2010, and low potential for recovery.

Outlook

   * The outlook for the Series 2000A bonds remains negative based
     upon continued weak financial position of the project.

What Could Change the Rating Up:

   * Several reporting periods that show significant increases in
     debt service coverage

   * Payment of debt service on the Series 2000C bonds

What Could Change the Rating Down:

   * Any erosion of current occupancy levels or increases in
     expenses that affect debt service coverage

The principal methodology used in this rating was Global Housing
Projects published in July 2010.


CAPITALSOURCE REAL: Moody's Affirms All CRE CDO Classes
-------------------------------------------------------
Moody's has affirmed all classes of Notes issued by CapitalSource
Real Estate Loan Trust 2006-A. The key indicators of the expected
loss within CRE CDO transactions: WARF, weighted average life
(WAL), weighted average recovery rate (WARR), and Moody's asset
correlation (MAC) are all performing within levels commensurate
with the existing ratings levels.

   -- Cl. A-1A, Affirmed at A3 (sf); previously on Nov 12, 2009
      Downgraded to A3 (sf)

   -- Cl. A-1R, Affirmed at A3 (sf); previously on Nov 12, 2009
      Downgraded to A3 (sf)

   -- Cl. A-2A, Affirmed at Aa2 (sf); previously on Nov 12, 2009
      Downgraded to Aa2 (sf)

   -- Cl. A-2B, Affirmed at Baa3 (sf); previously on Nov 12, 2009
      Downgraded to Baa3 (sf)

   -- Cl. B, Affirmed at B2 (sf); previously on Nov 12, 2009
      Downgraded to B2 (sf)

   -- Cl. C, Affirmed at Caa2 (sf); previously on Nov 12, 2009
      Downgraded to Caa2 (sf)

   -- Cl. D, Affirmed at Caa3 (sf); previously on Nov 12, 2009
      Downgraded to Caa3 (sf)

   -- Cl. E, Affirmed at Caa3 (sf); previously on Nov 12, 2009
      Downgraded to Caa3 (sf)

   -- Cl. F, Affirmed at Caa3 (sf); previously on Nov 12, 2009
      Downgraded to Caa3 (sf)

   -- Cl. G, Affirmed at Caa3 (sf); previously on Nov 12, 2009
      Downgraded to Caa3 (sf)

   -- Cl. H, Affirmed at Caa3 (sf); previously on Nov 12, 2009
      Downgraded to Caa3 (sf)

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

The rating action is the result of Moody's on-going surveillance
of commercial real estate collateralized debt obligation (CRE CDO)
transactions.  Moody's prior full review is summarized in a press
release dated November 12, 2009.

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.

The principal methodologies used in these ratings were "Moody's
Approach to Rating SF CDOs" published in November 2010, and "CMBS:
Moody's Approach to Revolving Facilities in CDOs Backed by
Commercial Real Estate Interests" published in July 2004.


CARYLE VEYRON: S&P Affirms Class D Notes 'BB+' Rating
-----------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C(Def) and D(Def) notes from Carlyle Veyron CLO Ltd., a cash flow
corporate collateralized loan obligation (CLO) managed by Carlyle
Investment Management LLC.  "At the same time, we affirmed
and removed our ratings on the transaction's class A1-B, A-2, and
B tranches from CreditWatch, where we placed them with positive
implications on Jan. 3, 2011, and affirmed our ratings on the
class A-1-A and A-1-R(Rev) notes," S&P related.

"The rating actions reflect the improved credit of the
underlying assets that has occurred since our Dec. 29, 2009
rating action, when we downgraded the class A-1-B, A-2, B, C,
and D notes.  Since that date, the amount of assets considered
to have defaulted has decreased to 0.99% ($4.5 million) in
February 2011, which we referenced in today's rating action,
from 5.45% ($25.6 million), which was reported in the Nov. 3,
2009 monthly report we referenced in our December 2009 rating
action," S&P noted.

The transaction has also benefited from an increase in the
overcollateralization (O/C) available to support the rated notes.
The trustee reported a senior O/C ratio of 122.66% in the Feb. 3,
2011 monthly report, which is up from 116.24% that was reported in
November 2009.

"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 we deem necessary," S&P added.

Rating and CreditWatch Actions

Carlyle Veyron CLO Ltd.
                 Rating
Class        To         From
A-1-B        AA+ (sf)   AA+ (sf)/Watch Pos
A-2          AA+ (sf)   AA+ (sf)/Watch Pos
B            A+ (sf)    A+ (sf)/Watch Pos
C(Def)       A- (sf)    BBB+ (sf)
D(Def)       BB+ (sf)   CCC- (sf)

Ratings Affirmed
Carlyle Veyron CLO Ltd.
Class        Rating
A-1-A        AAA (sf)
A-1-R(Rev)   AAA (sf)


CENTERLINE 2007-1: Moody's Cuts Affirms Ratings of 13 CRE CDO
-------------------------------------------------------------
Moody's has downgraded one and affirmed thirteen classes of
Certificates issued by Centerline 2007-1 Resecuritization Trust
due to the deterioration in the credit quality of the underlying
portfolio as evidenced by an increase in the weighted average
rating factor (WARF) and realized losses as well as a decrease in
the Interest Coverage (IC) Ratio since last review.  The rating
action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO)
transactions.

   -- Cl. A-1, Downgraded to C (sf); previously on Apr 28, 2010
      Downgraded to Ca (sf)

   -- Cl. A-2, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. B, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. C, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. D, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. E, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. F, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. G, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. H, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. J, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. K, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. L, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. M, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. N, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

Ratings Rationale

Centerline 2007-1 Resecuritization Trust is a static CRE CDO
transaction backed by a portfolio of commercial mortgage backed
securities (CMBS) (86.1% of the current pool balance) and CRE
CDOs (13.9%). As of the March 22, 2011 Trustee report, the
aggregate Certificate balance of the transaction has decreased to
$747.2 million from $985.6 million at issuance, with the paydown
directed to the Class A-1 Certificates, partial realized losses to
the Class N Certificates and full realized losses to the Class O
and Class P Certificates.  The IC Ratio is 3.3% as of the
March 22, 2011 Trustee report compared to 22.9% at last review.

While there have been realized losses of $237.4 million to date,
Moody's does expect significant losses to occur on the remaining
collateral pool once they are realized.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: WARF, weighted
average life (WAL), weighted average recovery rate (WARR), and
Moody's asset correlation (MAC).  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.
We 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 9,516 compared to 8,961 at last
review.  The distribution of current ratings and credit estimates
is as follows: Ba1-Ba3 (0.0% compared to 0.4% at last review), B1-
B3 (3.8% compared to 5.9% at last review), and Caa1-C (96.2%
compared to 93.7% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 8.7
years compared to 9.3 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled a fixed WARR
of 0.6% compared to 0.7% 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 99.9% compared to 0.0% at last review.
The high MAC is due to the low ratings variability of very-high
risk 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. However, in light of the
performance indicators noted above, Moody's believes that it is
unlikely that the ratings announced today are sensitive to further
change.

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.

The principal methodologies used in these ratings were "Moody's
Approach to Rating SF CDOs" published in November 2010 and "CMBS:
Moody's Approach to Rating Static CDOs Backed by Commercial Real
Estate Securities" published in June 2004.

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.


CENTEX HOME: Moody's Cuts Rating on $62 million of Subprime RMBS
----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 6 tranches
from Centex Home Equity Loan Trust 2004-A.  The collateral backing
this deal primarily consists of first and second lien, fixed and
adjustable rate Subprime residential mortgages.

Ratings Rationale

The actions are a result of deteriorating performance of Subprime
pools securitized before 2005.  Although most of these pools have
paid down significantly, the remaining loans are affected by the
housing and macroeconomic conditions that remain under duress.

The actions reflect Moody's updated loss expectations on Subprime
pools issued from prior 2005.

The principal methodology used in these ratings was "Pre-2005 US
RMBS Surveillance Methodology" published in January 2011.

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 primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market.  Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in late 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: Centex Home Equity Loan Trust 2004-A

   -- Cl. M-1, Downgraded to Ba1 (sf); previously on Apr 8, 2010
      Aa2 (sf) Placed Under Review for Possible Downgrade

   -- Cl. M-2, Downgraded to B2 (sf); previously on Apr 8, 2010 A1
      (sf) Placed Under Review for Possible Downgrade

   -- Cl. M-3, Downgraded to Caa1 (sf); previously on Apr 8, 2010
      A2 (sf) Placed Under Review for Possible Downgrade

   -- Cl. M-4, Downgraded to Caa2 (sf); previously on Apr 8, 2010
      A3 (sf) Placed Under Review for Possible Downgrade

   -- Cl. M-5, Downgraded to Caa3 (sf); previously on Apr 8, 2010
      Baa1 (sf) Placed Under Review for Possible Downgrade

   -- Cl. B, Downgraded to Ca (sf); previously on Apr 8, 2010 Baa2
      (sf) Placed Under Review for Possible Downgrade

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF242979

A list of updated estimated pool losses and sensitivity analysis
is being posted on an ongoing basis for the duration of this
review period and may be found at:

   http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237255


CIT HOME: Moody's Cuts Rating on $90 Million of Subprime RMBS
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 7 tranches
from CIT Home Equity Loan Trust 2002-2.  The collateral backing
these deals primarily consists of first-lien, fixed and adjustable
rate Subprime residential mortgages.

Ratings Rationale

The actions are a result of deteriorating performance of Subprime
pools securitized before 2005.  Although most of these pools have
paid down significantly, the remaining loans are affected by the
housing and macroeconomic conditions that remain under duress.

The actions reflect Moody's updated loss expectations on Subprime
pools securitized before 2005.

The principal methodology used in these ratings was "Pre-2005 US
RMBS Surveillance Methodology" published in January 2011.

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 primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market.  Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in late 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: CIT Home Equity Loan Trust 2002-2

   -- Cl. AF, Downgraded to Baa2 (sf); previously on Apr 8, 2010
      Aaa (sf) Placed Under Review for Possible Downgrade

   -- Cl. AV, Downgraded to Baa1 (sf); previously on Sep 3, 2002
      Assigned Aaa (sf)

   -- Cl. MF-1, Downgraded to B3 (sf); previously on Apr 8, 2010
      Baa1 (sf) Placed Under Review for Possible Downgrade

   -- Cl. MF-2, Downgraded to C (sf); previously on Apr 8, 2010
      Ba3 (sf) Placed Under Review for Possible Downgrade

   -- Cl. BF, Downgraded to C (sf); previously on Apr 8, 2010 Ca
      (sf) Placed Under Review for Possible Downgrade

   -- Cl. MV-1, Downgraded to B3 (sf); previously on Apr 8, 2010
      Baa2 (sf) Placed Under Review for Possible Downgrade

   -- Cl. MV-2, Downgraded to C (sf); previously on Apr 8, 2010 B2
      (sf) Placed Under Review for Possible Downgrade

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF241986

A list of updated estimated pool losses and sensitivity analysis
is being posted on an ongoing basis for the duration of this
review period and may be found at:

   http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237255


CITY OF INDIANAPOLIS: Moody's Confirms Ba2 Rating on Revenue Bonds
------------------------------------------------------------------
Moody's Investors Service has confirmed the Ba2 rating of
Indianapolis (City of), IN, Multifamily Housing Revenue Bonds
(Marcy Village Apartments Project), Series 2001, and removed the
bonds from Watchlist, following a review of the transactions
ability to maintain cash flow sufficiency assuming a 0%
reinvestment rate.  This action affects approximately $7 million
of outstanding debt.

Rating Rationale

The transaction is secured by a mortgage that is guaranteed by
credit enhancement from Fannie Mae. The transaction does not have
Guaranteed Investment Contracts (GICs) that assures a fixed rate
of return on invested cash, and therefore, are subject to interest
rate risk on retained revenues.  As a result, revenue from the
monthly mortgage receipts, interest earned on those receipts from
money market funds or other short-term investments, and monthly
mortgage payments need to be sufficient to support debt service on
the bonds.  Moody's analyzed the transaction's projected mortgage
revenue, assuming no reinvestment earnings on the monthly mortgage
receipts and determined that there would be debt service coverage
consistent with a Ba2 rating.

What Could Change the Rating Up

   -- A contribution of funds by the borrower to correct the
      likelihood of a future debt service shortfall

What Could Change the Rating Down

   -- Determination that there will be a shortfall in the
      cashflows

   -- Asset-to-Parity Ratio Lower Than 100%.

The principal methodology used in this rating was Moody's
Methodology Update: Change in Interest Rate Assumptions for
Housing Transactions

Which Rely on Investment Earnings Prompted by Unprecedented Low
Interest Rates, published in November 2009.


CMBSPOKE 2006-I: Moody's Junks Ratings on Three CRE CDO Classes
---------------------------------------------------------------
Moody's has downgraded three classes of Notes issued by
CMBSpoke 2006-I Segregated Portfolio (CMBSpoke 2006-I) due
to the deterioration in the credit quality of the underlying
portfolio as evidenced by an increase in the weighted average
rating factor (WARF).  The rating action is the result of Moody's
on-going surveillance of commercial real estate collateralized
debt obligation (CRE CDO) transactions.

   -- Cl. A, Downgraded to Caa1 (sf); previously on May 12, 2010
      Downgraded to B2 (sf)

   -- Cl. B, Downgraded to Caa1 (sf); previously on May 12, 2010
      Downgraded to B2 (sf)

   -- Cl. C, Downgraded to Caa2 (sf); previously on May 12, 2010
      Downgraded to B3 (sf)

Ratings Rationale

CMBSpoke 2006-I is a static synthetic CRE CDO transaction backed
by a credit default swap on a portfolio of commercial mortgage
backed securities (CMBS) (100% of the pool balance).  As of the
March 24, 2011 Trustee report, the aggregate issued Note balance
of the transaction was $100 million, the same as that at issuance.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: WARF, weighted
average life (WAL), weighted average recovery rate (WARR), and
Moody's asset correlation (MAC).  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 has 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 122 compared to 38 at last review.
The distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (79.2% compared to 86.6% at last review), A1-A3
(6.9% compared to 10.0% at last review), Baa1-Baa3 (6.9% compared
to 3.4% at last review) and Ba1-Ba3 (6.9% compared to 0.0% at last
review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 3.0
years compared to 3.7 years at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool.  Moody's modeled a variable
WARR with a mean of 60% compared to 63% 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 35.2% compared to 39.3% 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 rating changes within the reference obligation pool.
Holding all other key parameters static, stressing the current
ratings and credit estimates of the reference obligations by one
notch downward negatively affects the model results by
approximately 1 notch downward.

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.


CONSECO FINANCE: Moody's Cuts Rating of Class BV-2 to 'B1'
----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 2 tranches
and confirmed the ratings of 3 tranches from 1 Subprime deal
issued by Conseco Finance Home Equity Loan Trust.  The collateral
backing these deals primarily consists of first-lien, fixed and
adjustable rate Subprime residential mortgages.

Ratings Rationale

The actions are a result of deteriorating performance of Subprime
pools securitized before 2005.  Although most of these pools have
paid down significantly, the remaining loans are affected by the
housing and macroeconomic conditions that remain under duress.

The actions reflect Moody's updated loss expectations on Subprime
pools securitized before 2005.

The principal methodology used in these ratings was " Pre-2005 US
RMBS Surveillance Methodology" published in January 2011.

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 primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market. Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in late 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: Conseco Finance Home Equity Loan Trust 2002-C

   -- Cl. MV-1, Confirmed at Aa2 (sf); previously on Apr 8, 2010
      Aa2 (sf) Placed Under Review for Possible Downgrade

   -- Cl. MV-2, Confirmed at A2 (sf); previously on Apr 8, 2010 A2
      (sf) Placed Under Review for Possible Downgrade

   -- Cl. BV-1, Downgraded to Ba1 (sf); previously on Apr 8, 2010
      Baa2 (sf) Placed Under Review for Possible Downgrade

   -- Cl. BV-2, Downgraded to B1 (sf); previously on Apr 8, 2010
      Ba2 (sf) Placed Under Review for Possible Downgrade

   -- Cl. BF-2, Confirmed at Ba2 (sf); previously on Apr 8, 2010
      Ba2 (sf) Placed Under Review for Possible Downgrade

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF242960

A list of updated estimated pool losses and sensitivity analysis
is being posted on an ongoing basis for the duration of this
review period and may be found at:

  http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237255


CRYSTAL RIVER: Moody's Affirms Ratings on Eight CRE CDO
-------------------------------------------------------
Moody's has downgraded one and affirmed eight classes of Notes
issued by Crystal River Resecuritization 2006-1 Ltd. due to the
deterioration in the credit quality of the underlying portfolio
as evidenced by an increase in the weighted average rating factor
(WARF) and Defaulted Securities since last review.  The rating
action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO)
transactions.

   -- Cl. A, Downgraded to C (sf); previously on Apr 28, 2010
      Downgraded to Ca (sf)

   -- Cl. B, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. C, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. D, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. E, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. F, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. G, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. J, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

   -- Cl. K, Affirmed at C (sf); previously on Apr 28, 2010
      Downgraded to C (sf)

Ratings Rationale

Crystal River Resecuritization 2006-1 Ltd. is a static CRE CDO
transaction backed by a portfolio of commercial mortgage backed
securities (CMBS) (100% of the current pool balance).  As of the
March 22, 2011 Trustee report, the aggregate Note balance of the
transaction has decreased to $388.4 million from $390.3 million at
issuance, with the paydown directed to the Class A Note.

There are fifty-five assets with par balance of $272.8 million
(73.7% of the current pool balance) that are considered Defaulted
Securities as of the March 22, 2011 Trustee report.  While there
have been limited realized losses to date, Moody's does expect
significant losses to occur once they are realized.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: WARF, weighted
average life (WAL), weighted average recovery rate (WARR), and
Moody's asset correlation (MAC).  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.
We 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 9,523 compared to 7,613 at last
review.  The distribution of current ratings and credit estimates
is as follows: Baa1-Baa3 (0.0% compared to 3.3%), Ba1-Ba3 (0.0%
compared to 4.3% at last review), B1-B3 (3.9% compared to 17.4% at
last review), and Caa1-C (96.1% compared to 75.0% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of
7.4, the same as that 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 0.2% compared to 2.0% 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 99.9%, the same as that at last review.
The high MAC is due to the low ratings variability of very-high
risk 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.  However, in
light of the performance indicators noted above, Moody's believes
that it is unlikely that the ratings announced today are sensitive
to further change.

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.

The principal methodologies used in these ratings were "Moody's
Approach to Rating SF CDOs" published in November 2010 and "CMBS:
Moody's Approach to Rating Static CDOs Backed by Commercial Real
Estate Securities" published in June 2004.

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.


DA-LITE SCREEN: S&P Maintains 'B' Corporate Credit Rating
---------------------------------------------------------
Standard & Poor's Ratings Services said it revised its recovery
rating on Warsaw, Ind.-based Da-Lite Screen Company Inc.'s senior
unsecured notes to '3' from '4', although the issue level rating
of 'B' for these notes remains unchanged.

"The recovery rating revision reflects our belief that recovery
prospects have improved for these notes as a result of recent
repurchases of some of these notes, as well as higher EBITDA,"
said Standard & Poor's credit analyst Stephanie Harter.

At the same time, Standard & Poor's affirmed all of the ratings on
Da-Lite, including the 'B' corporate credit rating.  The ratings
are based on Standard & Poor's opinion that the company has a
vulnerable business risk profile which includes a narrow business
focus, competitive operating environment, and exposure to
technology risk.

The outlook is negative.  "Although we expect continued operating
improvement and meaningful cash flow generation through 2011, Da-
Lite's future financial policies are unclear following the
announced merger," said Ms. Harter.  "We could lower the ratings
if Da-Lite's performance and/or liquidity position weakens, or if
financial policies post-merger become more aggressive."

Standard & Poor's will continue to evaluate the impact of
the pending merger on Da-Lite's ratings as more details emerge
and management provides more information on future financial
policies. "Given our assessment of Da-Lite's vulnerable business
risk and the uncertainty of the company's future financial
policies, we currently view an upgrade as unlikely," S&P related.


DEUTSCHE MORTGAGE: Moody's Junks Ratings of 2 Classes of Certs.
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of the
classes A-1 and A-X issued by Deutsche Mortgage Securities, Inc.
Re-REMIC Trust Certificates, Series 2007-RS6 from B1 to Caa3.

Issuer: Deutsche Mortgage Securities, Inc. Re-REMIC Trust
        Certificates, Series 2007-RS6

   -- Cl. A-1, Downgraded to Caa3 (sf); previously on Jan 29, 2010
      B1 (sf) Placed Under Review for Possible Downgrade

   -- Cl. A-X, Downgraded to Caa3 (sf); previously on Jan 29, 2010
      B1 (sf) Placed Under Review for Possible Downgrade

Ratings Rationale

The actions are a result of the bonds not having sufficient credit
enhancement to maintain the current ratings when compared to the
revised loss expectation on the pools of mortgages backing the
underlying certificates.

The resecuritization is backed by 28 underlying certificates
issued primarily by CWALT, Inc. Mortgage Pass-Through
Certificates, Deutsche Alt-B Securities Mortgage Loan Trust,
Lehman Mortgage Trust, RALI, and WaMu Mortgage Pass-Through
Certificates.  The underlying certificates are backed primarily by
first-lien, Alt-A and Option-Arm residential mortgage loans.

The class A-1 issued by Deutsche 2007-RS6 is a senior class,
supported by a subordinated bond Class A-2, which receives
principal payments after class A-1 but absorbs losses before Class
A-1.  The class A-X is an interest only bond whose notional amount
is linked to the Class A-1.

Moody's ratings on the resecuritization notes are based on:

  (i) The updated expected loss on the pools of loans backing the
      underlying certificates and the updated ratings on the
      underlying certificates.  Moody's current loss expectation
      on the Alt-A pools backing the underlying certificates and
      the current ratings of these underlying certificates can be
      found at

http://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBS_S
F196023.

      Moody's current loss expectation on the Option-Arm pools
      backing the underlying certificates and the current ratings
      of these underlying certificates can be found at

http://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBS_S
F225686.

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

(iii) The structure of the resecuritization transaction.

Moody's first updated its loss assumption on the underlying pools
of mortgage loans (backing the underlying certificates) and then
arrived at updated ratings on the underlying certificates. The
ratings on the underlying certificates are based on expected
recoveries on the bonds under ninety-six different combinations of
six loss levels, four loss timing curves and four prepayment
curves.  The volatility in losses experienced by a tranche due to
small increments in losses on the underlying mortgage pool is
taken into consideration when assigning ratings.  For details
regarding Moody's approach to estimating losses on Alt-A and
Option-Arm pools, please refer to the methodology publications
"Alt-A RMBS Loss Projections Update: 2010" and "Option ARM RMBS
Loss Projection Update: March 2010" respectively, available on
Moodys.com.

In order to determine the ratings of the resecuritized bonds,
losses on the underlying certificates were ascribed to the
resecuritized classes, according to the structure of the
resecuritized transaction.  The losses on the resecuritized
certificates are allocated "bottom up" with the subordinate class
taking losses ahead of the senior class.  Principal payments to
the certificates are allocated sequentially, with the senior class
being paid ahead of the subordinate class.

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

As part of the sensitivity analysis, we stressed the updated
expected loss on the pools of loans backing the underlying
certificates by an additional 10% and found that the implied
ratings of the resecuritized bonds do not change.

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

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF240071


DIVERSIFIED GLOBAL: S&P Lowers Class B Notes Rating to 'BB-'
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class B and C notes from Diversified Global Securities Ltd. II, a
static cash flow collateralized debt obligation (CDO) of CDO
transaction.  "At the same time, we removed our ratings on the
class B and C notes from CreditWatch, where we placed them with
negative implications on Jan. 3, 2011.  We also affirmed our
rating on the class A notes," S&P noted.

The underlying CDOs remaining in the collateral portfolio are
primarily backed by corporate loans, and a smaller portion is
backed by residential mortgage-backed securities (RMBS), emerging
market securities, and commercial mortgage-backed securities
(CMBS).

"We lowered our ratings on the class B and C notes to reflect the
small pool of assets in the collateral portfolio and the increased
concentration risk (exposure to each issuer has increased as the
pool size has decreased in size).  The downgrades also reflect a
modest decline in the credit quality of the underlying assets
since we lowered our ratings on the class B and C notes on May 17,
2010.  As of the Feb. 10, 2011, trustee report, the transaction
held approximately $21.86 million (47.98%) in assets from obligors
with ratings in the 'CCC' range, compared with approximately
$17.00 million (36.96%) reported in the March 10, 2010 trustee
report, which we referenced for our May 2010 rating actions.  We
affirmed the rating on the class A notes to reflect our opinion
that the class has sufficient credit support at the current rating
level," S&P related.

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 it deems necessary.

Rating and CreditWatch Actions

Diversified Global Securities II Ltd.
              Rating
Class     To           From
B         BB- (sf)     A+ (sf)/Watch Neg
C         CCC+ (sf)    B+ (sf)/Watch Neg

RATING AFFIRMED

Diversified Global Securities II Ltd.

Class     Rating
A         AAA (sf)


ESSEX PROPERTY: Fitch Puts 'BB+' Ratings on $65MM Preferred Stock
-----------------------------------------------------------------
Fitch Ratings has assigned a 'BB+' rating to the $65 million
7.125% coupon rate series H cumulative redeemable preferred stock
issued by Essex Property Trust, Inc.  Net proceeds from the
offering of approximately $63 million before the exercise of the
underwriters' overallotment option are expected to be used to
redeem a portion of Essex Portfolio L.P.'s (the operating
partnership of ESS) $80 million of 7.875% series B preferred
units.

Essex Property Trust's Issuer Default Rating (IDR) is 'BBB'.  The
Rating Outlook is Stable.

Essex Property Trust is a multifamily real estate investment trust
(REIT) that acquires, develops, redevelops, and manages apartment
communities in supply-constrained markets.  The company went
public in 1994 and currently has ownership interests in 147
apartment communities, and has an additional two properties in
various stages of development.


ESSEX PROPERTY: S&P Assigns 'BB+' Rating to $65MM Preferred Shares
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its 'BB+' rating to
Essex Property Trust Inc.'s $65 million of series H 7.125%
perpetual preferred shares.  The real estate investment trust
(REIT) plans to use the $63 million in net proceeds after an
underwriting discount to repay, in whole or in part, its
$80 million of series B preferred units.

Palo Alto-based Essex (BBB/Stable/--) has a portfolio of
approximately $4.4 billion (undepreciated) in multifamily
properties.  The company's assets are geographically concentrated
in West Coast markets, with the majority of net operating income
(NOI) generated in California (54% in Southern California and
32% in the San Francisco Bay area) and the remaining 14% in the
Seattle metro market.

The transaction marginally reduces Essex's dividend payout
obligations, and should provide a negligible benefit to fixed-
charge and total coverage metrics.

Ratings List

Essex Property Trust Inc.
  Corporate Credit Rating                    BBB/Stable/--

Essex Portfolio L.P.
  Corporate Credit Rating                    BBB/Stable/--
  Senior Unsecured                           BBB-

Ratings Assigned

Essex Property Trust Inc.
  $65 Mil. Series H Preferred Stock          BB+


FTA SANTANDER: DBRS Puts 'B' Provisional Rating to Series B Notes
-----------------------------------------------------------------
DBRS Ratings Limited has assigned the provisional ratings of AAA
(sf) to the EUR4,226.50 million Series A Notes and B (sf) to the
EUR1,123.50 million Series B Notes issued by F.T.A. Santander
Empresas 9.  The transaction is a cash flow securitization
collateralized primarily by a portfolio of bank loans originated
by Banco Santander, S.A. to Spanish enterprises and small-and
medium-sized enterprises.  The transaction has a portfolio
notional amount of EUR5,350 million.  As of 18 March 2011, the
transaction included 29,306 loans with a weighted average time to
maturity of 2.7 years.

The ratings are provisional.  Final ratings will be issued upon
receipt of executed versions of the governing transaction
documents.  To the extent that the documents and information
provided by F.T.A Santander Empresas 9, Santander de Titulizacion,
S.G.F.T., S.A., and Banco Santander, S.A., to DBRS as of this date
differ from the executed versions of the governing transaction
documents, DBRS may assign lower final ratings to the Notes, or
may avoid assigning final ratings to the Notes altogether.

These ratings are based upon DBRS' review of the following
analytical considerations:

* Transaction structure, the form and sufficiency of available
  credit enhancement.

  -- Credit enhancement is in the form of subordination and a
     reserve funded through a subordinated loan.  The current
     credit enhancement level of 41.00% is sufficient to support
     AAA (sf) rating for the Series A Notes and the current credit
     enhancement level of 20.00% is sufficient to support B (sf)
     rating for the Series B Notes.

  -- Funded at the beginning of the transaction through the
     issuance of a subordinated loan granted by Banco Santander,
     the cash reserve, initially set at 20%, which is equivalent
     to EUR1,070.00 million of the aggregate balance of the Series
     A Notes and the Series B Notes, is available to pay
     shortfalls in the expenses senior to the replenishment of the
     Reserve Fund in the Priority of Payments, and interest and
     principal throughout the life of the Series A and Series B
     Notes.

  -- The Reserve Fund cannot be reduced, except for required
     payments to cover interest and principal shortfalls, unless:

       -- The transaction is at least two years old;

       -- The Reserve Fund is at least 40% of the outstanding
          aggregate balance of the Series A and Series B Notes;
          and

       -- The Reserve Fund balance is greater than 10% of the
          initial aggregate balance of the Series A and Series B
          Notes (EUR535.00 million).

  -- In addition, the Reserve Fund will not be eligible for
     further pay downs, the above notwithstanding, if:

       -- The balance of the Reserve Fund was not at the minimum
          required level the at the previous period; or

       -- The outstanding balance of the non-failed assets, which
          are more than 90 days in arrears, is greater than 1% of
          the outstanding balance of the total non-failed assets.

* The ability of the transaction to withstand stressed cash flow
  assumptions and repay investors according to the approved terms.
  For this transaction, the provisional rating of the Series A
  Notes addresses the timely payments of interest, as defined in
  the transaction documents, and the timely payments of principal
  on each Payment Date during the transaction and, in any case, at
  their Legal Final Maturities on March 16, 2048.  The provisional
  rating of the Series B Notes addresses the ultimate payment of
  interest, as defined in the transaction documents, and the
  ultimate payment of principal on each Payment Date during the
  transaction and, in any case, at their Legal Final Maturities on
  March 16, 2048.  Interest and principal payments on the notes
  will be made quarterly, generally on the 16th day of March,
  June, September and December, with the first payment date on 16
  June 2011.

* The transaction parties' financial strength and capabilities to
  perform their respective duties, and the quality of origination,
  underwriting and servicing practices.

* Soundness of the legal structure and presence of legal opinions
  which address the true sale of the assets to the trust and the
  non-consolidation of the special purpose vehicle, as well as the
  consistency with the DBRS Legal Criteria for European Structured
  Finance Transactions.

The principal methodology is Master European Granular Corporate
Securitisations (SME CLOs), which can be found on our website
under Methodologies.

The sources of information used for these ratings include
parties involved in the rating, including but not limited to
F.T.A. SANTANDER EMPRESAS 9, Santander de Tituliza‘ion, S.G.F.T.,
S.A. and Banco Santander, S.A. DBRS considers the information
available to it for the purposes of providing this rating was of
satisfactory quality.

These are the first DBRS ratings on these financial instruments.






GALAXY VI: S&P RAISES Class D Notes From 'BB+' to 'BBB'
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1, A-2, B, C-1, C-2, and D notes from Galaxy VI CLO Ltd.
(Galaxy VI), a cash flow corporate collateralized loan obligation
(CLO), and the class A notes from Liston Funding 2009-2 Ltd., a
repackaging of Galaxy VI CLO Ltd.'s class A-2 note.  "At the same
time, we removed our ratings on three of these classes from
CreditWatch with positive implications, where we had placed them
on Jan. 3, 2011," S&P noted.

"The rating actions reflect the improvement in the credit
performance of the underlying assets that support Galaxy VI since
the Sept. 2, 2009, trustee report, which we referenced in our
Sept. 24, 2009 downgrades.  The March 2, 2011 monthly report
indicated that the assets rated in the 'CCC' range decreased to
6.66% ($31.1 million) from 12.18% ($58.9 million), and the assets
treated as defaulted decreased to 0.65% ($3.0 million) from 3.92%
($19.0 million).

Glaxy VI has also benefited from an increase in the
overcollateralization (O/C) available to support the
rated notes.  The trustee reported the O/C ratios in
the March 2, 2011 monthly report:

    * The senior O/C ratio (which includes the class A and B
      notes) was 118.95%, compared with the reported ratio of
      114.67% in September 2009;

    * The class C O/C ratio was 113.18%, compared with the
      reported ratio of 109.11% in September 2009; and

    * The class D O/C ratio was 107.78%, compared with the
      reported ratio of 103.9% in the September 2009 report.  The
      September 2009 report was referenced in S&P's September 2009
      downgrades.

"We upgraded Liston Funding 2009-2 Ltd.'s class A notes to reflect
the improved credit support available to support the class A-2
notes from Galaxy VI to which they are linked," S&P related.

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 it deems necessary.

Rating and CreditWatch Actions

Galaxy VI CLO 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-1          A- (sf)    BBB+ (sf)
C-2          A- (sf)    BBB+ (sf)
D            BBB (sf)   BB+ (sf)

Liston Funding 2009-2 Ltd.
                 Rating
Class        To         From
A            AA+ (sf)   AA (sf)


GS MORTGAGE: DBRS Assigns Final Rating of Class E at 'BB'
---------------------------------------------------------
DBRS has assigned final ratings to these classes of GS Mortgage
Securities Trust, Series 2011-GC3.  The trends are Stable.

  -- Class A-1 at AAA (sf)
  -- Class A-2 at AAA (sf)
  -- Class A-3 at AAA (sf)
  -- Class A-4 at AAA (sf)
  -- Class X at AAA (sf)
  -- Class B at AA (high) (sf)
  -- Class C at A (high) (sf)
  -- Class D at BBB (sf)
  -- Class E at BB (sf)
  -- Class F at B (sf)
  -- Class G at NR (sf)

The collateral consists of 57 fixed-rate loans secured by 111
multifamily, mobile home parks and commercial properties.  The
portfolio has a balance of $1,400,625,368.  The pool benefits from
low leverage financing with a DBRS weighted- average Term DSCR and
debt yield of 1.57x and 10.6%, respectively, based on the trust
amount.  The pool also benefits from strong amortization as 12.3 %
of the pool amortizes down by maturity.

DBRS shadow-rates two loans, representing 5.8% of the pool,
investment grade.  The investment-grade shadow-rated loans
indicate the long-term stability of the underlying assets.


HARBORVIEW MORTGAGE: Moody's Cuts Rating of Class B9 to 'C'
-----------------------------------------------------------
Moody's Investors Service has downgraded the rating of Class
B9 issued by HarborView Mortgage Loan Trust 2006-4.  The
collateral backing the transaction consists of Option ARM
residential mortgage loans.  The action is a result of the
rapidly deteriorating performance of Option ARM pools in
conjunction with the write down of Class B-9 tranche.

Today's rating action reflects that Class B-9 has a $0 outstanding
balance because it took $6.0 million of realized losses.  However,
Class B-9 could recover some principal payment at the end of the
deal's life.

Complete Rating Actions are:

   Issuer: HarborView Mortgage Loan Trust 2006-4

   -- Cl. B-9, Downgraded to C (sf); previously on Jan 27, 2010 Ca
      (sf) Placed Under Review for Possible Downgrade

A list of these actions including CUSIP identifiers may be found
at http://is.gd/u1M8Tm

A list of updated estimated pool losses, sensitivity analysis, and
tranche recovery details is being posted on an ongoing basis for
the duration of this review period and may be found at:

    http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF225686


HELIOS FINANCE: Moody's Ups Rating on Securities From Auto Loans
----------------------------------------------------------------
Moody's has upgraded two credit-linked notes issued by HELIOS
Finance Limited Partnership 2007-S1 and HELIOS Finance Corporation
2007-S1 as co-issuers.  The Notes were issued in connection with a
credit default swap tied to a reference portfolio, under which
Wachovia Bank, National Association is the protected party.  The
reference portfolio consists of loans originated and serviced by
Wells Fargo Bank, N.A. (as successor by merger to Wachovia Bank,
N.A.), a direct wholly-owned subsidiary of Wells Fargo & Company.

Ratings

Issuer: HELIOS Finance Limited Partnership 2007-S1/HELIOS Finance
Corporation 2007-S1 - Synthetic Auto Loan Transaction

   -- Cl. B-2, Upgraded to Aaa (sf); previously on Feb 10, 2011 A2
      (sf) Placed Under Review for Possible Upgrade

   -- Cl. B-3, Upgraded to Caa2 (sf); previously on Feb 10, 2011 C
      (sf) Placed Under Review for Possible Upgrade

Ratings Rationale

The actions are the result of the build-up in credit enhancement
relative to remaining losses.  Moody's currently anticipates the
transaction to incur lifetime cumulative net losses of 5.35% which
is at the high end of the previous range of 5.25% to 5.40% when
the securities were placed on review in February. Total credit
enhancement for Class B-2 note is approximately 18% of the
outstanding collateral balance.  While the B-3 note is already
incurring losses (losses to the tranches are allocated in reverse
sequential order of seniority), Moody's expects that the tranche
is likely to lose between 10% to 15% of the outstanding balance.

As a synthetic, the structure of this transaction has unique
elements when compared to other auto loan ABS.  For the first
twelve months, principal payments (notional reductions in the case
of the retained risk positions) were allocated in sequential order
of seniority (A-1, then A-2 and so on).  Thereafter, principal
payments depend on certain delinquency and cumulative net loss
(CNL) based schedules of monthly performance triggers.  The
delinquency trigger schedule is common for all tranches, while the
CNL trigger schedules are specific to each tranche.  If the
trigger level for a certain tranche is breached (actual
delinquency or CNL level is higher than the specified trigger
level), it no longer receives any principal payment until that
trigger event is cured.  Due to the weaker than expected
performance and the resulting breach of CNL triggers, the
transaction remained sequential for an additional fifteen months.
The transaction is currently paying principal to the A-1, A-2, A-
3, B-1 and B-2 tranches pro rata based on their outstanding
balances.  These tranches are benefitting from the lock out of the
B-3 tranche since the current CNL is already higher than the
highest monthly CNL trigger level for that specific tranche.

Ratings on the affected notes could be upgraded 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, 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.

The principal methodology used in these notes was "Moody's
Approach to Rating U.S. Auto Loan-Backed Securities" rating
methodology published in June 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.


HUDSON CANYON: Moody's Upgrades Rating on US$5MM Notes to 'B1'
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Hudson Canyon Funding II, Ltd.:

   -- US$46,000,000 Class B Third Priority Mezzanine Secured
      Deferrable Floating Rate Notes Due October 27, 2020,
      Upgraded to Baa3 (sf); previously on June 17, 2009 Confirmed
      at Ba3 (sf);

   -- US$5,000,000 Class C Fourth Priority Mezzanine Secured
      Deferrable Floating Rate Notes Due October 27, 2020,
      Upgraded to B1 (sf); previously on June 17, 2009 Confirmed
      at B3 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes
result primarily from improvement in the credit quality of the
underlying portfolio and an increase in the 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 March 17, 2011, the weighted
average rating factor is currently 2773 compared to 2851 in the
May 2009 report, and securities rated Caa1/CCC+ or lower make up
approximately 9.34% of the underlying portfolio versus 12.78% in
May 2009.  Moody's adjusted WARF has also 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."  Additionally, defaulted securities total
less than $1 million of the underlying portfolio compared to
$42.8 million in May 2009.

The overcollateralization ratios of the rated notes have also
improved since the rating action in June 2009.  The Class A,
Class B and Class C overcollateralization ratios are reported at
134.84%, 116.23% and 114.51%, respectively, versus May 2009 levels
of 129.44%, 111.95% and 110.33%, respectively, and all related
overcollateralization tests are currently in compliance.  Moody's
also notes that the Class C 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 $382.6 million, defaulted par of $5.2 million,
a weighted average default probability of 22.04% (implying a WARF
of 3605), a weighted average recovery rate upon default of 44.6%,
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.

Hudson Canyon Funding II, Ltd., issued in April 2008, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations," published in
August 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.

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% (2884)

   -- Class A-1: +1

   -- Class A-2: +3

   -- Class B: +2

   -- Class C: +3

Moody's Adjusted WARF + 20% (4326)

   -- Class A-1: -1

   -- Class A-2: -2

   -- Class B: -2

   -- Class C: -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. 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. 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 covenant values for weighted average
      rating factor, weighted average spread, weighted average
      coupon, and diversity score.  However, as part of the base
      case, Moody's considered spread levels higher than the
      covenant levels due to the large difference between the
      reported and covenant levels.


JPMORGAN CHASE: S&P Places Ratings on 11 Classes on Watch Negative
------------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 11
classes of U.S. commercial mortgage-backed securities (CMBS) from
JPMorgan Chase Commercial Mortgage Securities Corp.'s series 2005-
LDP2 on CreditWatch with negative implications.

"The CreditWatch placements reflect our preliminary analysis of
the transaction using our conduit/fusion criteria.  Our
preliminary analysis also considered the decline in the credit
quality of the transaction and the underlying collateral since
January 2010," S&P related.

According to the March 2011 trustee report, there are 23 assets
($246.3 million, 10.0%) with the special servicer, LNR Partners
Inc. (LNR), 17 of which have appraisal reduction amounts (ARAs)
in effect totaling $104.9 million.  "We calculated a weighted-
average debt service coverage (DSC) of 1.41x for the loans in the
pool based on the reported financial information from the master
servicer, Wachovia Bank.  Financial information was reported for
92.4% of the nondefeased loans in the pool, which was primarily
based on full-year 2009, interim-2010, and full-year 2010
financial reporting.  Finally, the pool has experienced
$35.8 million in realized losses on 19 loans, including
$27.9 million since January 2010," S&P stated.

In contrast, the January 2010 trustee report noted 15 loans
($115.6 million, 4.1%) in the pool with the special servicer
including nine loans ($34.3 million) that were subsequently
resolved at a weighted average loss severity of 47%.  Four of
the specially serviced loans in January 2010 trustee report
had ARAs in effect totaling $19.4 million at that time.
"Furthermore, we calculated a weighted-average DSC of 1.52x
for the pool based primarily on full-year 2008 and interim-
2009 reported financial information," S&P noted.

Standard & Poor's expects to resolve its CreditWatch placements
after completing a full review of the transaction including the
underlying collateral.

Ratings Placed on CreditWatch Negative

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2005-LDP2
                Rating
Class   To                    From    Credit enhancement (%)
A-M     AAA (sf)/Watch Neg    AAA (sf)                 22.67
A-MFL   AAA (sf)/Watch Neg    AAA (sf)                 22.67
A-J     A- (sf)/Watch Neg     A- (sf)                  13.93
B       BBB+ (sf)/Watch Neg   BBB+ (sf)                13.18
C       BBB (sf)/Watch Neg    BBB (sf)                 11.52
D       BBB- (sf)/Watch Neg   BBB- (sf)                10.46
E       BB+ (sf)/Watch Neg    BB+ (sf)                  9.41
F       BB (sf)/Watch Neg     BB (sf)                   8.20
G       BB- (sf)/Watch Neg    BB- (sf)                  7.15
H       B- (sf)/Watch Neg     B- (sf)                   5.34
J       CCC- (sf)/Watch Neg   CCC- (sf)                 4.13


JPMORGAN RV: Moody's Junks Rating on 2004 JPMorgan RV
-----------------------------------------------------
Moody's has downgraded class A-2 tranche from JP Morgan RV Marine
Trust 2004-A.  The transaction is serviced by Vericrest Financial,
Inc. (Vericrest).  Vericrest Financial, Inc., formerly known as
CIT Group/Sales Financing, Inc., was acquired by Lone Star Funds
in 2009.

Ratings

Issuer: JPMorgan RV Marine Trust 2004-A

   -- Cl. A-2, Downgraded to Caa3 (sf); previously on Feb 2, 2011
      B2 (sf) Placed Under Review for Possible Downgrade

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

Underlying Rating: Downgraded to Caa3 (sf); previously on Feb 2,
2011 B2 (sf) Placed Under Review for Possible Downgrade

Ratings Rationale

The actions are a result of weaker credit performance than
previously expected and depletion of hard credit enhancement
(cash reserve and overcollateralization) to support the affected
tranche.  Moody's currently anticipates the transaction to incur
lifetime cumulative net losses of 14% which is at the midpoint
of the previously published range of 13.50% to 14.50% when the
securities were placed on review in February.  Moody's prior loss
expectation for the transaction was 11% to 12%.  Unlike other
vehicle-backed ABS, the impact of the weakened economy on a RV and
marine transaction 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, the transaction has experienced more than
one economic downturn during its life.

Moody's expects the affected tranche to lose approximately 20% to
30% of its outstanding balance.  Credit enhancement available to
the tranche as of the current distribution date comprises entirely
of excess spread, which is approximately 6% per annum.  Pool
factor for the transaction is approximately 9% of original
collateral balance.

Ratings on the affected notes could be upgraded 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, and weakness in the
RV and marine market.  Overall, Moody's central global scenario
remains "Hook-shaped" for 2010 and 2011; we 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.

The principal methodology used in these notes was "Moody's
Approach to Rating U.S. Auto Loan-Backed Securities" rating
methodology published in June 2007.  Other methodologies and
factors that may have been considered in the process of rating
these notes can also be found on Moody's website.  Further
information on Moody's analysis of this transaction is available
on www.moodys.com.

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.


LB-UBS COMM'L: Moody's Cuts Ratings on 4 Classes of CMBS Certs.
---------------------------------------------------------------
Moody's Investors Service (Moody's) downgraded these ratings of
four classes and affirmed 16 classes of LB-UBS Commercial Mortgage
Trust 2002-C2, Commercial Mortgage Pass-Through Certificates,
Series 2002-C2:

   -- Cl. A-3, Affirmed at Aaa (sf); previously on Jul 9, 2002
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-4, Affirmed at Aaa (sf); previously on Jul 9, 2002
      Definitive Rating Assigned Aaa (sf)

   -- Cl. X-CL, Affirmed at Aaa (sf); previously on Jul 9, 2002
      Definitive Rating Assigned Aaa (sf)

   -- Cl. X-D, Affirmed at Aaa (sf); previously on Jul 9, 2002
      Definitive Rating Assigned Aaa (sf)

   -- Cl. B, Affirmed at Aaa (sf); previously on Mar 9, 2006
      Upgraded to Aaa (sf)

   -- Cl. C, Affirmed at Aaa (sf); previously on Mar 9, 2006
      Upgraded to Aaa (sf)

   -- Cl. D, Affirmed at Aaa (sf); previously on May 2, 2007
      Upgraded to Aaa (sf)

   -- Cl. E, Affirmed at Aaa (sf); previously on Nov 8, 2007
      Upgraded to Aaa (sf)

   -- Cl. F, Affirmed at Aa3 (sf); previously on Nov 8, 2007
      Upgraded to Aa3 (sf)

   -- Cl. G, Affirmed at A1 (sf); previously on Nov 8, 2007
      Upgraded to A1 (sf)

   -- Cl. H, Affirmed at A2 (sf); previously on Nov 8, 2007
      Upgraded to A2 (sf)

   -- Cl. J, Affirmed at Baa1 (sf); previously on Nov 8, 2007
      Upgraded to Baa1 (sf)

   -- Cl. K, Affirmed at Baa3 (sf); previously on Jul 9, 2002
      Definitive Rating Assigned Baa3 (sf)

   -- Cl. L, Affirmed at Ba1 (sf); previously on Jul 9, 2002
      Definitive Rating Assigned Ba1 (sf)

   -- Cl. M, Downgraded to B1 (sf); previously on Nov 4, 2010
      Downgraded to Ba3 (sf)

   -- Cl. N, Downgraded to B3 (sf); previously on Nov 4, 2010
      Downgraded to B2 (sf)

   -- Cl. P, Downgraded to Caa1 (sf); previously on Nov 4, 2010
      Downgraded to B3 (sf)

   -- Cl. Q, Downgraded to Caa3 (sf); previously on Nov 4, 2010
      Downgraded to Caa2 (sf)

   -- Cl. S, Affirmed at C (sf); previously on Nov 4, 2010
      Downgraded to C (sf)

   -- Cl. T, Affirmed at C (sf); previously on Nov 4, 2010
      Downgraded to C (sf)

Ratings Rationale

The downgrades are due to increased interest shortfalls.  Recently
interest shortfalls spiked from Class P to Class L.  The increase
was caused by the recovery of servicer advances from a loan that
was liquidated in December 2010 (Oak Creek Apartments Loan;
$4.1 million).  The sales proceeds were not sufficient to recover
all of the servicer's outstanding advances.  The servicer has
recouped all of its advances on this loan over the past three
months and it is anticipated that cumulative interest shortfalls
will be less starting with the April remittance payment.  Moody's
anticipate that Class L will recover accrued but unpaid interest
within the next two months and Classes M and N will recover unpaid
interest within four to eight months, assuming that there are no
further reductions in the amount of interest available to
certificate holders.  However, Moody's anticipates that Classes P,
Q and S will continue to experience interest shortfalls for an
indeterminate period.  Interest shortfalls are caused by special
servicing fees, including workout and liquidation fees, appraisal
subordinate entitlement reductions (ASARs) and extraordinary trust
expenses.

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

Moody's rating action reflects a cumulative base
expected loss of 1.9% of the current balance.  At last
review, Moody's cumulative base expected loss was 2.3%.
Moody's stressed scenario loss is 4.4% of the current balance.
Moody's provides a current list of base and stress scenario
losses for conduit and fusion CMBS transactions on moodys.com
at http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the current
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.

The principal methodologies used in this rating were "CMBS:
Moody's Approach to Rating Fusion Transactions " published in
April 2005, and "CMBS: Moody's Approach to Rating Large Loan
Transactions" published in July 2000.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity.  Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40. The
pool has a Herf of 11 compared to 11 at Moody's prior review.

In cases where the Herf falls below 20, Moody's employs also the
large loan/single borrower methodology.  This methodology uses 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 (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated November 4, 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 March 17, 2011 distribution date, the
transaction's aggregate certificate balance has decreased
by 32% to $818.9 million from $1.21 billion at securitization.
The Certificates are collateralized by 75 mortgage loans ranging
in size from less than 1% to 19% of the pool, with the top ten
non-defeased loans representing 57% of the pool.  The pool
includes four loans with investment grade credit estimates,
representing 41% of the pool. Eighteen loans, representing 19% of
the pool, have defeased and are collateralized with U.S.
Government securities.  The pool faces significant refinance risk
as loans representing 81% of the current pool balance mature
within the next 24 months.

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

Eight loans have been liquidated from the pool, resulting in
an aggregate realized loss of $8.1 million (14% loss severity
overall).  Four loans, representing 2.2% of the pool, are
currently in special servicing.  The master servicer has
recognized an aggregate $4.7 million appraisal reduction for
four specially serviced loans.  Moody's has estimated an
aggregate $7.5 million loss (41% expected loss on average)
for the specially serviced loans.

Moody's has assumed a high default probability for two poorly
performing loans representing 0.5% of the pool and has estimated
a $981,000 loss (25% expected loss based on a 50% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 94% and 70% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 82%, essentially the same as at Moody's prior
review.  Moody's net cash flow reflects a weighted average haircut
of 14% 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 1.28X and 1.34X, respectively, compared to
1.27X and 1.31X at last review.  Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the Dadeland Mall Loan
($152.1 million -- 18.6%), which is secured by the borrower's
interest in a 1.4 million square foot super regional mall located
in Miami, Florida.  The property is the dominant mall in the
region and is anchored by Macy's, Macy's Home Gallery & Kids, J.C.
Penney, Nordstrom and Saks Fifth Avenue.  The property was 98%
leased as of December 2010, essentially the same as at last review
and securitization.  Performance has been very strong since
securitization. Moody's current credit estimate and stressed DSCR
are Aaa and 2.19X, respectively, compared to Aaa and 2.14X at last
review.

The second loan with a credit estimate is the Square One
Mall Loan ($83.9 million -- 10.3%), which is secured by the
borrower's interest in a 865,400 square foot regional mall
located approximately eight miles northeast of Boston in
Saugus, Massachusetts.  The property is anchored by Sears,
Macy's, T.J.Maxx and Filene's Basement. The property was 95%
leased as of December 2010, compared to 92% at last review.
Performance has been stable.  Moody's current credit estimate
and stressed DSCR are Baa1 and 1.65X, respectively, compared
to Baa1 and 1.64X at last review.

The third loan with a credit estimate is the 250 Park Avenue Loan
($65.1 million -- 7.9%), which is secured by a 448,000 square foot
Class A office building located in New York City.  The property
was 77% leased as of June 2010 compared to 100% at securitization.
The loan is on the servicer's watchlist due to low occupancy.
Moody's current credit estimate and stressed DSCR are Aaa and
1.88X, respectively, compared to Aaa and 1.86X at last review.

The fourth loan with a credit estimate is the 21 Chelsea
Loan ($31.1 million -- 3.8%), which is secured by a 209-unit
multifamily complex located in New York City.  The property was
97% leased as of September 2010 compared to 98% at securitization.
Performance has been stable. Moody's current credit estimate and
stressed DSCR are A1 and 1.65X, respectively, compared to A1 and
1.64X at last review.

The top three conduit loans represent 12% of the pool
balance.  The largest loan is the 1750 Pennsylvania Avenue
Loan ($44.9 million -- 5.5%), which is secured by a 259,000
square foot Class A office building located in Washington,
D.C.  The property was 97% leased as of December 2010 compared
to 98% at securitization.  The loan is on the servicer's watchlist
due to upcoming lease rollover.  The property is over 70% occupied
by the US Government. Moody's LTV and stressed DSCR are 81% and
1.24X, respectively, compared to 87% and 1.15X at last review.

The second largest loan is the Bank of America Tower Loan
($30.9 million - 3.1%), which is secured by a 299,700 square
foot office building located in St. Petersburg, Florida.  The
property was 85% leased as of September 2010 compared to 82%
at last review. However in December 2010 the Bank of America,
which leased 14% of the net rentable area (NRA), vacated at the
expiration of its lease.  Moody's LTV and stressed DSCR are 112%
and 0.92X, respectively, compared to 99% and 1.04X at last review.

The third largest loan is the White Flint Plaza Loan
($25.0 million -- 3.1%), which is secured by a 194,975 square
foot community shopping center located in Rockville, Maryland.
The property was 94% leased as of December 2010 compared to
83% at last review. Although, occupancy increased since last
review, performance has been stable.  Moody's LTV and stressed
DSCR are 92% and 1.18X, respectively, compared to 92% and 1.17X
at last review.


LB-UBS COMM'L: Moody's Holds Rating on 19 CMBS Classes of Certs.
----------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 19
classes of LB-UBS Commercial Mortgage Trust 2005-C1, Commercial
Mortgage Pass-Through Certificates, Series 2005-C1 as:

   -- Cl. A-2, Affirmed at Aaa (sf); previously on Feb 10, 2005
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-3, Affirmed at Aaa (sf); previously on Feb 10, 2005
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-AB, Affirmed at Aaa (sf); previously on Feb 10, 2005
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-4, Affirmed at Aaa (sf); previously on Feb 10, 2005
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-1A, Affirmed at Aaa (sf); previously on Feb 10, 2005
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-J, Affirmed at Aa2 (sf); previously on Jul 29, 2010
      Downgraded to Aa2 (sf)

   -- Cl. B, Affirmed at Aa3 (sf); previously on Jul 29, 2010
      Downgraded to Aa3 (sf)

   -- Cl. C, Affirmed at A2 (sf); previously on Jul 29, 2010
      Downgraded to A2 (sf)

   -- Cl. D, Affirmed at A3 (sf); previously on Jul 29, 2010
      Downgraded to A3 (sf)

   -- Cl. E, Affirmed at Baa2 (sf); previously on Jul 29, 2010
      Downgraded to Baa2 (sf)

   -- Cl. F, Affirmed at Baa3 (sf); previously on Jul 29, 2010
      Downgraded to Baa3 (sf)

   -- Cl. G, Affirmed at Ba3 (sf); previously on Jul 29, 2010
      Downgraded to Ba3 (sf)

   -- Cl. H, Affirmed at B3 (sf); previously on Jul 29, 2010
      Downgraded to B3 (sf)

   -- Cl. J, Affirmed at Caa3 (sf); previously on Jul 29, 2010
      Downgraded to Caa3 (sf)

   -- Cl. K, Affirmed at Ca (sf); previously on Jul 29, 2010
      Downgraded to Ca (sf)

   -- Cl. L, Affirmed at C (sf); previously on Jul 29, 2010
      Downgraded to C (sf)

   -- Cl. M, Affirmed at C (sf); previously on Jul 29, 2010
      Downgraded to C (sf)

   -- Cl. X-CL, Affirmed at Aaa (sf); previously on Feb 10, 2005
      Definitive Rating Assigned Aaa (sf)

   -- Cl. X-CP, Affirmed at Aaa (sf); previously on Feb 10, 2005
      Definitive Rating Assigned Aaa (sf)

Ratings Rationale

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

Moody's rating action reflects a cumulative base expected loss of
5.7% of the current balance.  At last review, Moody's cumulative
base expected loss was 5.2%.  Moody's stressed scenario loss is
13.4% of the current balance.  Moody's provides a current list of
base and stress scenario losses for conduit and fusion CMBS
transactions on moodys.com at http://is.gd/INmyw5. 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 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.

The principal methodologies used in this rating were: "Moody's
Approach to Rating Fusion Transactions", published on April 19,
2005 and "Moody's Approach to Rating Large Loan/Single Borrower
Transactions" published in July 2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 level are driven
by property type, Moody's actual and stressed DSCR, and Moody's
property quality grade (which reflects the capitalization rate
used by Moody's to estimate Moody's value). Conduit model results
at the B2 level are driven by a paydown analysis based on the
individual loan level Moody's LTV ratio.  Moody's Herfindahl
score (Herf), a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis.  Based on the model pooled credit
enhancement levels at Aa2 and B2, the remaining conduit classes
are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points.  For fusion deals, the credit enhancement for loans
with investment-grade credit estimates is melded with the conduit
model credit enhancement into an overall model result.  Fusion
loan credit enhancement is based on the 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 16 compared to 17 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 (CMBS) 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 29, 2010.  Please see
the ratings tab on the issuer/entity page on moodys.com for the
last rating action and the ratings history.

Moody's Investors Service 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 March 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 23% to
$1.18 billion from $1.52 billion at securitization.  The
Certificates are collateralized by 72 mortgage loans ranging in
size from less than 1% to 13% of the pool, with the top ten loans
representing 66% of the pool.  The pool contains four loans with
investment grade credit estimates, representing 28% of the pool.

Eighteen loans, representing 12% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package.  As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Five loans have been liquidated from the pool, resulting in a
realized loss of $6.6 million (18% loss severity overall).
Currently six loans, representing 7% of the pool, are in special
servicing.  The largest specially serviced loan is the Atlantic
Building Loan ($28.0 million -- 2.4% of the pool), which is
secured by a 315,993 square foot (SF) office building located in
Philadelphia, Pennsylvania.  The loan was transferred to special
servicing in April 2010 due to monetary default.  The borrower
submitted a loan modification proposal that was later rejected by
the special servicer.  The borrower subsequently consented to
receivership and foreclosure and a receiver was appointed in
February 2011. Foreclosure is expected to be completed by June
2011.

The remaining five specially serviced properties are secured
by a mix of property types.  Moody's estimates an aggregate
$40.7 million loss for the specially serviced loans (52%
expected loss on average).

Moody's has assumed a high default probability for five poorly
performing loans representing 2% of the pool and has estimated an
aggregate $4.2 million loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2009 operating results for 81%
of the pool.  Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 92% compared to 97% at Moody's
prior review.  Moody's net cash flow reflects a weighted average
haircut of 7% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.53X and 1.09X, respectively, compared to
1.46X and 1.03X at last review.  Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the 11 West 42nd Street
Loan ($154.5 million -- 13.1% of the pool), which is secured by a
877,138 SF Class A office building located in the Grand Central
submarket of New York City.  The property is also encumbered by a
$48.5 million mezzanine loan.  The largest tenants include CIT
(17% of the net rentable area (NRA); lease expiration October
2021) and New York University (12% of the NRA; lease expiration
September 2021).  As of January 2011 the property was 87% leased
compared to 96% at the prior review.  Martha Stewart downsizing
along with Syska and Hennessey vacating its space at lease
maturity attributed to the increase in vacancy since the prior
review.  Moody's underlying rating and stressed DSCR are Baa2 and
1.44X, respectively, compared to Baa2 and 1.49X at last review.

The second largest loan with a credit estimate is the Mall Del
Norte Loan ($113.4 million -- 9.6% of the pool), which is secured
by the borrower's interest in a 1.2 million SF regional mall
(683,493 SF as collateral) located in Laredo, Texas.  The largest
tenants include Dillard's, Inc. (13% of the NRA; lease expiration
December 2035), Sears, Roebuck and Co (10% of the NRA; lease
expiration December 2035) and JC Penny Co. Inc. (10% of the NRA;
lease expiration December 2035).  As of January 2011 the property
was 99% leased, the same as at the prior review.  The loan is
interest only for its entire 10 year term. Moody's underlying
rating and stressed DSCR are Baa3 and 1.38X, respectively,
compared to Baa3 and 1.36X at last review.

The third largest loan with a credit estimate is the IBM
Gaithersburg Loan ($46.4 million -- 3.9% of the pool), which is
secured by a 393,000 SF office building located in Gaithersburg,
Maryland.  The building is 100% leased to IBM Corporation (senior
unsecured rating A1; stable outlook) through March 2016 and
functions as a mission critical data center.  The loan is interest
only for its entire seven year term.  Moody's underlying rating
and stressed DSCR are A1 and 1.47X, respectively, the same as at
last review.

The fourth largest loan with a credit estimate is the United
States District Courthouse Loan ($14.9 million -- 1.3% of the
pool), which is secured by a 46,813 SF office building located in
El Centro, California.  The building is 100% leased to the US
Magistrate Courthouse through September 2019.  Moody's underlying
rating and stressed DSCR are Aaa and 1.45X, respectively, compared
to Aaa and 1.49X at last review.

The top three conduit loans represent 28% of the pool. The largest
conduit loan is the 2100 Kalakaua Avenue Loan ($130.0 million --
11.1% of the pool), which is secured by a 92,671 SF anchored
retail shopping center located in Honolulu, Hawaii.  The property
is also encumbered by a $15.0 million mezzanine loan.  The largest
tenants include Gucci (20% of the NRA; lease expiration November
2027), Chanel (20% of the NRA; lease expiration October 2027) and
Tiffany & Co. (12% of the NRA; lease expiration October 2027).
The property was 85% leased as of January 2011, the same as the
prior review.  The high end retail market in Hawaii is highly
dependent on Japanese tourism.  Although performance has been
stable since securitization, Moody's anticipates that there may be
a decline in 2011 due to an expected drop in Japanese tourism.
Moody's LTV and stressed DSCR are 81% and 1.06X, respectively, the
same as at last review.

The second largest conduit loan is the Wilshire Rodeo Plaza
Portfolio Loan ($112.7 million -- 9.6% of the pool), which is
secured by a 208,145 SF office building and a 56,855 SF anchored
retail building located in Beverly Hills, California.  The largest
tenants include United Talent Agency (30% of the NRA; lease
expiration August 2017), UBS Financial Services (27% of the NRA;
lease expiration February 2015) and Merrill Lynch (14% of the NRA;
lease expiration February 2015).  The property was 96% leased as
of January 2011 compared to 97% at the prior review.  Moody's LTV
and stressed DSCR are 104% and 0.88X, respectively, compared to
111% and 0.83X at last review.

The third largest conduit loan is the Macquarie DDR Portfolio Loan
($85.0 million -- 7.2% of the pool), which is secured by four
retail properties located in Texas, Colorado and South Carolina.
The four community centers contain approximately 1.9 million SF
(collateral is approximately 799,898 SF).  Approximately 136,715
SF of the portfolio is subject to ground leases.  The portfolio
was 84% leased as of January 2011, essentially the same as the
prior review. Moody's LTV and stressed DSCR are 91% and 1.04X,
respectively, compared to 102% and 0.93X at last review.


LNR CDO IV LTD: Moody's Affirms Ratings on 13 CRE CDO
-----------------------------------------------------
Moody's has downgraded one and affirmed thirteen classes of
Notes issued by LNR CDO IV Ltd. The transaction declared an
event of default on 4/2/2010 in which the counterparty is owed a
termination penalty.  The current balance as of the Februrary 23,
2011 Trustee Report is $57.6 million.  As a result, all of the
Notes are shorted their current interest payments.

The rating action is the result of Moody's on-going surveillance
of commercial real estate collateralized debt obligation (CRE CDO)
transactions.  Moody's prior full review is summarized in a press
release dated April 6, 2010.  Please see the ratings tab on the
issuer / entity page on moodys.com for the last rating action and
the ratings history.

   -- Cl. A, Downgraded to C (sf); previously on Apr 6, 2010
      Downgraded to Ca (sf)

   -- Cl. B-FX, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. B-FL, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. C-FX, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. C-FL, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. D-FX, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. D-FL, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. E, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. F-FL, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. F-FX, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. G, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. H, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. J, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

   -- Cl. K, Affirmed at C (sf); previously on Apr 6, 2010
      Downgraded to C (sf)

Ratings Rationale

LNR CDO IV Ltd. is a static CRE CDO transaction 100% backed by
commercial mortgage backed securities (CMBS), of which 80.3%
were issued in 2005.  On April 2, 2010 the deal experienced
an Event of Default (EOD) caused by a default in the interest
payment to the Non-PIKable Class B Notes.  Since then all rated
classes, including the Class A Notes have been accruing interest.
As of the March 23, 2011 Trustee Report date, the aggregate
collateral balance of the transaction is $1.2 billion compared
to $1.6 billion at issuance, representing $407.6 million of
realized losses to date.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: WARF, weighted
average life (WAL), weighted average recovery rate (WARR), and
Moody's asset correlation (MAC).  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 has 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 9,074compared to 7,681 at last
review.  The distribution of current ratings and credit estimates
is as follows: Baa1-Baa3 (3.7% compared to 2.0% at last review),
Ba1-Ba3 (1.6% compared to 0.5% at last review), B1-B3 (3.9%
compared to 14.6% at last review), and Caa1-C (90.8% compared to
82.9% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time.  Moody's modeled to a WAL of 6.6
years compared to 7.7 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 3.2% compared to 2.7% 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 99.9%, the same as 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.

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.

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.


MARATHON FINANCING: S&P Affirms Ratings on Two Classes From 'BB+'
-----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1, A-2, A-3, senior revolving, B-1, C-1, and mezzanine
term loan notes from Marathon Financing I B.V., a collateralized
loan obligation (CLO) transaction managed by Marathon Asset
Management LLC.  "At the same time, we removed our ratings on
the class A-1, A-2, A-3, senior revolving, and B-1 notes from
CreditWatch, where they were placed with positive implications
on Jan. 3, 2011," S&P stated.

"The upgrades reflect the improved performance we have observed in
the transaction and paydowns on the class A and senior revolving
outstanding note balances since our March 2010 rating actions.
According to the Feb. 18, 2011 trustee report, the transaction
held approximately $15 million in defaulted assets, down from
$73 million noted in the Feb. 19, 2010, trustee report," S&P said.
Additionally, the class A-1, A-2, A-3, and senior revolving notes
have paid down $99 million, $41 million, $32 million, and
$96 million, respectively, since February 2010.

The transaction has further benefited from an increase in the
overcollateralization (O/C) available to support the rated notes.
The trustee reported the O/C ratios in the Feb. 18, 2011 monthly
report:

    * The senior O/C ratio was 298.23%, compared with a reported
      ratio of 176.22% in February 2010;

    * The second senior O/C ratio was 208.51%, compared with a
      reported ratio of 149.89% in February 2010; and

    * The mezzanine O/C ratio was 160.28%, compared with a
      reported ratio of 130.41% in February 2010.

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 it deems necessary.

Rating and CreditWatch Actions

Marathon Financing I B.V.
                    Rating
Class           To          From
A-1             AAA (sf)    AA+ (sf)/Watch Pos
A-2             AAA (sf)    AA+ (sf)/Watch Pos
A-3             AAA (sf)    AA+ (sf)/Watch Pos
Senior revolv   AAA (sf)    AA+ (sf)/Watch Pos
B-1             AA (sf)     A- (sf)/Watch Pos
C-1             A (sf)      BB+ (sf)
Mezz term loan  A (sf)      BB+ (sf)


MASTER STUDENT: Moody's Cuts Ratings on Five Notes to 'Ca'
----------------------------------------------------------
Moody's Investors Service has downgraded the 2003AR-11, 2003AR-12,
2003AR-13, 2003AR-14, 2003AR-15, 2003AR-16 notes of the National
Collegiate Master Student Loan Trust I (2001 Indenture)
transaction.

Ratings Rationale

The rating actions on the notes reflect a correction to the
previous rating actions where the notes were given benefit
for a guaranty policy from Ambac Assurance Corporation.  In March
2010, these six notes became part of Ambac's Segregated Account.
According to a Moody's press release dated March 26, 2010, as a
result of the establishment of the account, wrapped transactions
allocated to the segregated account are rated based solely on the
underlying rating.  As a result, the rating action is being taken
on the notes to reflect the intrinsic credit quality of the notes
in the absence of the guarantee.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. Private Student Loan-Backed Securities"
published in January 2010.

Moody's Investors Service did receive and 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: The National Collegiate Master Student Loan Trust I
   (2001 Indenture)

   -- NCT-2003AR-11, Downgraded to Caa3 (sf); previously on
      Sept. 30, 2010 Caa2 (sf)

   -- NCT-2003AR-12, Downgraded to Ca (sf); previously on Sept 30,
      2010 Caa2 (sf)

   -- NCT-2003AR-13, Downgraded to Ca (sf); previously on Sept 30,
      2010 Caa2 (sf)

   -- NCT-2003AR-14, Downgraded to Ca (sf); previously on Sept 30,
      2010 Caa2 (sf)

   -- NCT-2005AR-15, Downgraded to Ca (sf); previously on Sept 30,
      2010 Caa2 (sf)

   -- NCT-2005AR-16, Downgraded to Ca (sf); previously on Sept 30,
      2010 Caa2 (sf)


MBIA INSURANCE: S&P Incorrectly Lowers Series 1995-1 Rating
-----------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on class
A-4 from Security Pacific Acceptance Corp.'s series 1995-1 to 'A
(sf)' from 'BBB- (sf)'.

S&P incorrectly lowered its rating to 'BBB- (sf)' on class A-4
from Security Pacific Acceptance Corp. 1995-1 on June 5, 2009.
S&P also incorrectly lowered the rating on series 1995-1 with the
rating on MBIA Insurance Corp. (B/Negative/--) on Feb. 25, 2009,
due to an error in S&P's analysis regarding the Standard & Poor's
underlying rating (SPUR) for this class.

MBIA provides a financial guarantee insurance policy covering full
payments of principal and interest to class A-4.  "Under our
criteria, the issue credit rating on a fully credit-enhanced bond
issue is the higher of the rating on the credit enhancer or the
SPUR on the class.  A SPUR is our opinion of the stand-alone
creditworthiness of an obligation -- that is, the capacity to pay
debt service on a debt issue in accordance with its terms --
without considering an otherwise applicable bond insurance
policy," S&P stated.

The loss allocation for the A classes in this transaction
distributes all losses first to class A-5, and then pro rates any
remaining losses to classes A-1 through A-4.  Due to an error, the
SPUR on the class A-4 did not reflect the subordination provided
by the A-5 class.

Rating Corrected

Security Pacific Acceptance Corp.
Series 1995-1
                                Rating
Class                    To                From
A-4                      A                 BBB-


MORGAN STANLEY: S&P Affirms Rating on Class O Notes to 'B+'
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on two
classes of commercial mortgage-backed securities (CMBS) from
Morgan Stanley Capital I Trust 2004-HQ3. "At the same time, we
affirmed our ratings on 17 classes from the same transaction,"
S&P noted.

"Our ratings actions follow our analysis of the transaction using
our U.S. conduit/fusion CMBS criteria and included our review of
the remaining collateral in the pool, the deal structure, and the
liquidity available to the trust.  The raised ratings reflect
increased credit enhancement levels resulting from principal
paydowns to the trust," S&P stated.

"Our analysis included a review of the credit characteristics of
all of the loans in the pool.  Using servicer-provided financial
information, we calculated an adjusted debt service coverage (DSC)
of 1.45x and a loan-to-value (LTV) ratio of 85.6%. We further
stressed the loans' cash flows under our 'AAA' scenario to yield
a weighted average DSC of 1.13x and an LTV ratio of 107.6%.  The
implied defaults and loss severity under the 'AAA' scenario were
23.9% and 38.3%, respectively.  The DSC and LTV calculations
we noted above exclude the pool's seven defeased loans
($86.4 million; 11.1%)," according to S&P.

"We affirmed our rating on the class X-1 and X-2 interest only
(IO) certificate based on our current criteria," S&P noted.

                        Transaction Summary

As of the March 2011 trustee remittance report, the transaction
had an aggregate trust balance of $778.8 million (75 loans),
compared with $1.32 billion (89 loans) at issuance.  The master
servicer, Wells Fargo Bank N.A. (Wells Fargo) provided financial
information for 99.6% of the nondefeased trust balance.  All of
the servicer-provided financial information was full-year 2009
data or partial-year 2010 data.

"We calculated a weighted average DSC of 1.53x for the nondefeased
loans in the pool based on the reported figures.  Our adjusted DSC
and LTV were 1.45x and 85.6%, respectively, and exclude the pool's
seven defeased loans.  There are no assets with the special
servicer.  Twenty-three loans ($133.6 million, 17.2%) are on the
master servicer's watchlist.  Three loans ($28.9 million, 3.7%)
have reported DSC between 1.00x and 1.10x, and 13 loans
($80.9 million, 10.4%) have a reported DSC of less than 1.00x.
The trust has experienced $5.2 million of principal losses on
two loans to date," S&P explained.

               Summary of Top 10 Real Estate Loans

The top 10 loans secured by real estate have an aggregate
outstanding balance of $419.1 million (53.8%).  "Using servicer-
reported information, we calculated a weighted average DSC of
1.67x for the top 10 real estate loans in the pool.  Our adjusted
DSC and LTV figures for the top 10 real estate loans were 1.53x
and 80.5%, respectively.  Two of the top 10 real estate loans are
on the master servicer's watchlist," S&P said.

The 3699 Wilshire Boulevard loan ($21.9 million; 2.8%) is the
sixth-largest nondefeased loan in the pool and the largest loan on
the watchlist.  The loan is secured by a 323,000-sq.-ft. office
property in Los Angeles.  The loan, which is current, is on the
master servicer's watchlist due to a decrease from 100% occupancy
at issuance.  As of the nine months ended Sept. 30, 2010, the
reported occupancy and DSC were 76.0% and 1.80x.

The Pacific Medical Portfolio 1 Roll-Up loan ($16.5 million;
2.1%) is the ninth-largest nondefeased loan in the pool and the
second-largest loan on the watchlist.  The loan is secured by a
three-building office portfolio of health care/medical use
properties totaling 145,864-sq.-ft.  The properties are located
in Northridge, Calif., Gilbert, Ariz., and Sun Lakes, Ariz.  The
loan, which is current, is on Wells Fargo's watchlist due to low
occupancy.  As of the nine months ended Sept. 30, 2010, the
reported occupancy and DSC ratio were 72.0% and 1.11x,.

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

                      Ratings Raised

Morgan Stanley Capital I Trust 2004-HQ3
Commercial mortgage pass-through certificates series 2004-HQ3
            Rating
Class    To        From        Credit enhancement (%)
C        AAA (sf)  AA+ (sf)                    20.60
D        AA+ (sf)  AA (sf)                     18.90

Ratings Affirmed

Morgan Stanley Capital I Trust 2004-HQ3
Commercial mortgage pass-through certificates series 2004-HQ3

Class    Rating    Credit enhancement (%)
A-3      AAA (sf)                  24.85
A-4      AAA (sf)                  24.85
B        AAA (sf)                  22.73
E        A+ (sf)                   16.35
F        A (sf)                    14.65
G        A- (sf)                   12.52
H        BBB+ (sf)                 10.39
J        BBB (sf)                   8.91
K        BBB- (sf)                  5.93
L        BB+ (sf)                   5.08
M        BB (sf)                    4.23
N        BB- (sf)                   3.38
O        B+ (sf)                    2.74
P        B (sf)                     2.31
Q        B- (sf)                    1.89
X-1      AAA (sf)                    N/A
X-2      AAA (sf)                    N/A


PPLUS TRUST: S&P Lowers Ratings on Two Classes of Cert. to 'BB'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on PPLUS
Trust Series EQ-1's $25 million class A and B certificates to 'BB'
from 'BBB-' and removed them from CreditWatch, where it placed
them with negative implications on April 27, 2010.

"Our ratings on the certificates are dependent on the rating on
the underlying security, Embarq Corp.'s 7.995% notes due June 1,
2036 ('BB')," S&P pointed out.

"The rating actions follow our April 1, 2011, lowering of our
rating on the underlying security to 'BB' from 'BBB-' and its
removal from CreditWatch with negative implications.  We may take
subsequent rating actions on the class A and B certificates due to
changes in our rating on the underlying security," S&P related.


PREFERREDPLUS TRUST: S&P Raises Rating on $40MM Certs. to 'BB-'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on
PreferredPLUS Trust Series QWS-1's $40 million 7.75% trust
certificates to 'BB-' from 'B+' and removed it from CreditWatch
with positive implications.

The rating on the certificates is dependent on the rating on the
underlying security, Qwest Capital Funding Inc.'s 7.75% notes due
Feb. 15, 2031 ('BB-/NM').

"The rating action follows our April 1, 2011, upgrade on the
underlying security to 'BB-' from 'B+' and its removal from
CreditWatch with positive implications.  We may take subsequent
rating actions on the certificates due to changes in our rating
assigned to the underlying security," S&P related.


PREFERREDPLUS TRUST: S&P Raises Rating on 8% Certs. to 'BB-'
------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating
on PreferredPLUS Trust Series QWS-2's $38.75 million
8.00% trust certificates to 'BB-' from 'B+' and removed it from
CreditWatch with positive implications.

The rating on the certificates is dependent on the rating on the
underlying security, Qwest Capital Funding Inc.'s 7.75% notes due
Feb. 15, 2031 ('BB-/NM').

"The rating action follows our April 1, 2011 upgrade on the
underlying security to 'BB-' from 'B+' and its removal from
CreditWatch with positive implications.  We may take subsequent
rating actions on the certificates due to changes in our rating
assigned to the underlying security," S&P stated.


PRUDENTIAL SECURITIES: Moody's Ups Ratings on 2 Classes of Certs.
-----------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of two
classes and affirmed three classes of Prudential Securities
Secured Financing Corporation, Commercial Mortgage Pass-Through
Certificates, Series 1999-NRF1:

   -- Cl. A-EC, Affirmed at Aaa (sf); previously on Mar 9, 2011
      Confirmed at Aaa (sf)

   -- Cl. G, Upgraded to A1 (sf); previously on Nov 1, 2007
      Upgraded to Baa3 (sf)

   -- Cl. H, Upgraded to Ba1 (sf); previously on Nov 4, 2010
      Downgraded to B2 (sf)

   -- Cl. J, Affirmed at Caa2 (sf); previously on Nov 4, 2010
      Downgraded to Caa2 (sf)

   -- Cl. K, Affirmed at C (sf); previously on Nov 4, 2010
      Downgraded to C (sf)

Ratings Rationale

The upgrades are due to significant increase in credit
subordination levels due to loan payoffs and amortization.  The
pool has amortized 42% since last review.

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

Moody's rating action reflects a cumulative base expected
loss of 19.6% of the current balance.  At last review,
Moody's cumulative base expected loss was 30.1%.  Moody's
stressed scenario loss is 20.3% of the current balance.
Moody's provides a current list of base and stress scenario
losses for conduit and fusion CMBS transactions on moodys.com
at http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.  If future performance materially declines,
the expected level of credit enhancement and the priority in the
cash flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the current
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.

The principal methodologies used in these ratings were: "CMBS:
Moody's Approach to Rating U.S. Conduit Transactions " published
in September 2000, and " CMBS: Moody's Approach to Rating Large
Loan Transactions" published in July 2000.

Moody's review incorporated the use of the excel-based
CMBS Conduit Model v 2.50 which is used for both conduit
and fusion transactions.  Conduit model results at the Aa2
level are driven by property type, Moody's actual and stressed
DSCR, and Moody's property quality grade (which reflects the
capitalization rate used by Moody's to estimate Moody's value).
Conduit model results at the B2 level are driven by a paydown
analysis based on the individual loan level Moody's LTV ratio.
Moody's Herfindahl score (Herf), a measure of loan level
diversity, is a primary determinant of pool level diversity
and has a greater impact on senior certificates.  Other
concentrations and correlations may be considered in Moody's
analysis.  Based on the model pooled credit enhancement levels at
Aa2 and B2, the remaining conduit classes are either interpolated
between these two data points or determined based on a multiple
or ratio of either of these two data points.  For fusion deals,
the credit enhancement for loans with investment-grade credit
estimates is melded with the conduit model credit enhancement into
an overall model result.  Fusion loan credit enhancement is based
on the 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 10 compared to 9 at Moody's prior review.

In cases where the Herf falls below 20, Moody's employs also the
large loan/single borrower methodology.  This methodology uses 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 (CMBS) transactions.
Moody's monitors transactions on a monthly basis through two sets
of quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review.  Moody's prior full review
is summarized in a press release dated November 4, 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 March 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 95% to
$45.4 million from $928.9 million at securitization. The
Certificates are collateralized by 17 mortgage loans ranging
in size from less than 1% to 23% of the pool, with the top ten
loans representing 83% of the pool.  The pool faces significant
refinancing risk, as loans representing 54% of the pool, have
matured or will mature within the next six months.

Four loans, representing 23% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) 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 $28.1 million realized loss (44% loss severity
on average). At Moody's last review the pool had realized an
aggregate loss of $11.8 million.  Currently there are six loans
representing 31% of the pool in special servicing. All of the
specially serviced loans are maturity defaults.  The largest
specially serviced loan is the Cambridge Place Loan ($3.9 million
-- 8.8%), which is secured by a 62-unit healthcare facility
located in Great Falls, Montana.  The loan was transferred to
special servicer on January 24, 2008.  The property sponsor was
Sunwest Co., which filed for bankruptcy.  In July 2010, the Court
approved Sunwest's Chapter 11 Reorganization Plan and this asset
was sold to the Blackstone Group effective September 2, 2010. The
loan is in the process of modification.

The second largest specially serviced loan is the Riverrain
Terrace Apartments Loan ($3.9 million -- 8.7%), which is
secured by a 120-unit multifamily property located in Ypsilanti,
Michigan.  The loan was transferred to special servicer on January
4, 2008. The property was 100% leased as of December 2010.  The
borrower has requested a loan extension to provide more time to
secure new financing.  The remaining four specially serviced loans
are secured by a mix of property types.  The master service has
recognized appraisal reductions totaling $2.9 million for two of
the specially serviced loans.  Moody's has estimated an aggregate
$3.9 million loss (28% expected loss on average) for the specially
serviced loans.

Moody's has assumed a high default probability for one poorly
performing loan representing 8% of the pool and has estimated
an aggregate $950,000 loss (25% expected loss based on a 50%
probability default) from this troubled loan.

Moody's was provided with full year 2009 and partial year 2010
operating results for 90% and 89% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 93% compared to 65% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 16%
to the most recently available net operating income.  Moody's
value reflects a weighted average capitalization rate of 10.3%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.39X and 1.96X, respectively, compared to
1.77X and 2.35X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing loans represent 39% of the pool
balance.  The largest loan is the Kansas City FBI Building Loan
($10.3 million -- 22.8%), which is secured by a 87,000 square foot
office building located in Kansas City, Missouri.  At last review
the loan was in special servicing due to the borrower's bankruptcy
filing; the reorganization plan was accepted and the loan maturity
was extended until September 15, 2011.  The property is 100%
leased to GSA through June 18, 2013.  The property was appraised
for $8.7 million in April 2010.  Although the property is 100%
leased, Moody's is concerned about refinancing risk associated
with this loan due to the weak Kansas City market and the
relatively short term remaining on the GSA lease.  Moody's
valuation incorporates a lit/dark analysis.  Moody's LTV and
stressed DSCR are 149% and 0.76X, respectively, the same as at
last review.

The second largest loan is the Hall Group Industrial Buildings
Loan (3.8 million -- 8.4%), which is secured by a 66,000 square
foot office/industrial property located in Novi, Michigan.  The
property was 67% leased as of June 2010.  The loan is current
although performance has been weak for a few years. The loan is
on the servicer's watchlist due to low DSCR and occupancy.  Due
to its weak performance, Moody's has recognized this loan as a
troubled loan.  Moody's LTV and stressed DSCR are 144% and 0.79X,
respectively, compared to 147% and 0.77X at last review.

The third largest loan is the Eagle Run Apts. Phase I Loan
($3.7 million -- 8.2% of the pool), which is secured by a
204-unit multifamily property located in Atlanta, Georgia.  The
property was 67% leased as of September 2010 compared to 76% at
last review.  Net Operating Income (NOI) has decreased by 27%
since last review.  The loan is on the servicer's watchlist due
to low DSCR and occupancy.  Moody's LTV and stressed DSCR are 114%
and 0.9X, respectively, compared to 70% and 1.47X at last review.


REGIONAL DIVERSIFIED: Moody's Junks Rating on US$62MM Notes
-----------------------------------------------------------
Moody's Investors Service has downgraded one class of notes issued
by Regional Diversified Funding 2004-1 Ltd.:

   -- US$62,000,000 Class A-2 Floating Rate Senior Notes Due
      2034 Notes (Current balance $62 million), Downgraded to Caa3
      (sf); previously on January 7, 2010 Downgraded to B1 (sf)

Ratings Rationale

Regional Diversified Funding 2004-1 Ltd. issued on March 3, 2004,
is a collateral debt obligation backed by a portfolio of bank
trust preferred securities (the 'TRUP CDO').  The last rating
action for this transaction was on January 7, 2010.  At that time,
Moody's downgraded two classes of notes as a result of the
application of revised and updated key modeling assumptions, as
well as the deterioration in the credit quality of the
transaction's underlying portfolio.

Moody's indicated that the rating action on the notes is primarily
the result of an increase in the assumed defaulted amount of the
pool and continuation of an event of default.  The defaults
increased by $49.5 mm since the last rating action on January 7,
2010.  Moody's cumulative assumed default amount currently totals
$167.5 million (53% of the portfolio).  All of the assumed
defaulted assets are carried at zero recovery in Moody's analysis.
The remaining assets in the portfolio also experienced a slight
deterioration on the credit quality of the pool, as indicated by a
WARF increase to 2523, from 2347 as of the last rating action
date.  This current WARF accounts for a credit estimate stress,
described in Moody's Rating Methodology "Updated Approach to the
Usage of Credit Estimates in rated Transactions", October 2009.

The par loss due to the increase in the assumed defaulted
amount has resulted in loss of overcollateralization
for the tranche affected and an increase of its expected
loss since the last rating action.  In addition, the
overcollateralization tests continue to breach their
triggers, resulting in a diversion of excess spreads to
pay down Class A-1 notes.  As of the latest trustee report
dated January 31, 2011, the Senior Overcollateralization
Test was reported at 103.10% (limit of 125.0%), and the
Senior Subordinate Overcollateralization Test was reported
at 61.94% (limit of 105.57%).

In Moody's analysis, Moody's assume that there are no prepayments
and the assets amortize at their final maturity.  The weighted
average life of the portfolio is approximately 23 years.

The credit deterioration exhibited by the TRUP CDO portfolio is
a reflection of the continued pressure in the banking sector as
the number of bank failures and interest deferrals of bank trust
preferred securities has continued to increase.  According to FDIC
data, 26 banks failed in 2011, 157 banks failed in 2010, 140 banks
failed in 2009 and 25 banks failed in 2008.

This portfolio is composed of trust preferred securities issued by
small to medium sized U.S. community bank that are generally not
publicly rated by Moody's.  To evaluate their credit quality,
Moody's uses RiskCalc model, an econometric model developed by
Moody's KMV, to derive credit scores for these non-publicly rated
trust preferred securities.  Moody's evaluation of the credit risk
for a majority of obligors in the pool relies on FDIC financial
data received as of Q3-2010.

Moody's evaluates the sensitivity of the rated transactions to the
volatility of the credit estimates, as described in Moody's Rating
Methodology "Updated Approach to the Usage of Credit Estimates in
Rated Transactions," October 2009.  For each credit score or
credit estimate where the related exposure constitutes more than
3% of the collateral pool, Moody's applied a 2-notch equivalent
assumed downgrade (but on the CEs representing in aggregate the
largest 30% of the pool) in lieu of the aforementioned stresses.
Notwithstanding the foregoing, in all cases the lowest assumed
rating equivalent is Caa3.  The effect of stress testing of these
credit scores varies between one and three notches, depending on
the total amount and relative size of these securities in the
collateral pool.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  Moody's considers as well the structural
protections in each transaction, Event of Default (EoD) risk, 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.

The principal methodologies used in rating this were "Moody's
Approach to Rating U.S. Bank Trust Preferred Security CDOs"
published in June 2010.

Due to the impact of revised and updated key assumptions
referenced in these rating methodologies, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers.  In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

The transaction's portfolio was modeled, according to Moody's
rating approach, using CDOROM v.2.8 to develop the loss
distribution from which the Moody's Asset Correlation parameter
was obtained.  This parameter was then used as an input in a cash
flow model using CDOEdge.  CDOROM v.2.8 is available on moodys.com
under Products and Solutions -- Analytical models, upon return of
a signed free license agreement.

Other methodologies and factors that may have been considered in
the process of rating this issue can also be found in the Credit
Policies & Methodologies directory.

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.


RENAISSANCE HOME: Moody's Cuts Ratings on $24MM Subprime RMBS
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of five
tranches from Renaissance Home Equity Loan Trust 2003-1.  The
collateral backing these deals primarily consists of first-lien,
fixed and adjustable rate Subprime residential mortgages.

Ratings Rationale

The actions are a result of deteriorating performance of Subprime
pools securitized before 2005.  Although most of these pools have
paid down significantly, the remaining loans are affected by the
housing and macroeconomic conditions that remain under duress.

The actions reflect Moody's updated loss expectations on Subprime
pools securitized before 2005.

The principal methodology used in these ratings was "Pre-2005 US
RMBS Surveillance Methodology" published in January 2011.

Moody's final rating actions are based on current levels of credit
enhancement, collateral performance and updated pool-level loss
expectations.  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.

In addition to adjustments to reflect updated loss expectations,
Moody's has also adjusted the rating of tranche Class B-A to
address the resolution of a previous credit enhancement
miscalculation.  Moody's previous rating action mistakenly
reflected additional credit enhancement to Class B-A from Class
B-F; in fact the Pooling and Servicing Agreement and Prospectus
allocate losses to Classes B-A and B-F on a pro-rata basis.
Classes B-A and B-F should thus have same amount of credit
enhancement, and the rating of Class B-A has been adjusted
accordingly.

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

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market.  Overall,
Moody's assumes a further 5% decline in home prices with
stabilization in late 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: Renaissance Home Equity Loan Trust 2003-1

   -- A, Downgraded to Aa2 (sf); previously on Jun 4, 2003
      Assigned Aaa (sf)

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

   -- Underlying Rating: Downgraded to Aa2 (sf); previously on Jul
      16, 2008 Assigned Aaa (sf)

   -- M-1, Downgraded to Baa2 (sf); previously on Apr 8, 2010 Aa2
      (sf) Placed Under Review for Possible Downgrade

   -- M-2, Downgraded to B3 (sf); previously on Apr 8, 2010 A2
      (sf) Placed Under Review for Possible Downgrade

   -- B-A, Downgraded to Ca (sf); previously on Apr 8, 2010 Baa2
      (sf) Placed Under Review for Possible Downgrade

   -- B-F, Downgraded to Ca (sf); previously on Apr 8, 2010 Ba1
      (sf) Placed Under Review for Possible Downgrade

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF241353

A list of updated estimated pool losses and sensitivity analysis
is being posted on an ongoing basis for the duration of this
review period and may be found at:

   http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237255


REVE SPC: S&P Corrects Rating on Class B Notes to 'B'
-----------------------------------------------------
Standard & Poor's Ratings Services corrected its rating
on the class B notes from REVE SPC's series 26, a synthetic
collateralized debt obligation (CDO) transaction, by lowering
it to 'B (sf)' from 'A- (sf)' due to an error with the recovery
rate assumptions.

"Due to an error, we used incorrect recovery rate assumptions.
After correcting the recovery rate assumptions, we are lowering
the rating on the tranche to its appropriate rating level,
pursuant to our criteria," S&P related.

Rating Corrected

REVE SPC
Series 26
           Rating
Class     To           From
B         B (sf)       A- (sf)


SEAWALL 2006-4: Moody's Affirms Ratings on Six CRE CDO
------------------------------------------------------
Moody's has downgraded four classes and affirmed six classes of
Notes issued by Seawall 2006-4, Ltd. due to the deterioration in
the credit quality of the underlying portfolio of reference
obligations as evidenced by an increase in the weighted average
rating factor (WARF) and a decrease in the weighted average
recovery rate (WARR).  The rating action is the result of Moody's
on-going surveillance of commercial real estate collateralized
debt obligation (CRE CDO) transactions.

Moody's rating action is:

   -- Super Senior, Downgraded to Caa3 (sf); previously on May 13,
      2010 Downgraded to Ba2 (sf)

   -- Cl. A, Downgraded to Ca (sf); previously on May 13, 2010
      Downgraded to Caa3 (sf)

   -- Cl. B, Downgraded to C (sf); previously on May 13, 2010
      Downgraded to Ca (sf)

   -- Cl. C, Downgraded to C (sf); previously on May 13, 2010
      Downgraded to Ca (sf)

   -- Cl. D-1, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. D-2, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. E-1, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. E-2, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. E-3, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. E-4, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

Ratings Rationale

Seawall 2006-4, Ltd. is a synthetic CRE CDO transaction backed
by a portfolio of commercial mortgage backed securities (CMBS)
reference obligations (100.0% of the pool balance).  All of the
CMBS referenced obligations were securitized between 2005 and
2006.  The aggregate Note balance of the transaction is
$300 million, the same as at securitization.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: WARF, weighted
average life (WAL), weighted average recovery rate (WARR), and
Moody's asset correlation (MAC).  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 has 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 7,720 compared to 2,326 at last
review. The distribution of current ratings and credit estimates
is as follows: Baa1-Baa3 (0.0% compared to 23.3% at last review),
Ba1-Ba3 (3.3% compared to 33.3% at last review), B1-B3 (16.7%
compared to 36.7% at last review), and Caa1-C (80.0% compared to
6.7% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 5.5
years compared to 6.0 years at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool.  Moody's modeled a variable
WARR with a mean of 1.2% compared to 9.8% 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 99.9% compared to 33.6% at last review.
The high MAC is due to high 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.

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.  In general, the rated Notes are
particularly sensitive to rating changes within the collateral
pool. Holding all other key parameters static, stressing non-
Moody's rated reference obligations' credit estimates by one notch
downward , the resulting impact negatively affects the model
results between 0 to 0.05 notches downward on average.

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.

The principal methodologies used in these ratings were "Moody's
Approach to Rating SF CDOs" published in November 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.


SEAWALL 2006-4A: Moody's Affirms Six CRE CDO Classes
----------------------------------------------------
Moody's has affirmed six classes of Notes issued by Seawall 2006-
4a, Ltd.  The key indicators of the expected loss within CRE CDO
transactions: weighted average rating factor (WARF), weighted
average life (WAL), weighted average recovery rate (WARR), and
Moody's asset correlation (MAC) are all performing within levels
commensurate with the existing ratings levels.

Moody's rating action is:

   -- Cl. D-1, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. D-2, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. E-1, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. E-2, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. E-3, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

   -- Cl. E-4, Affirmed at C (sf); previously on May 13, 2010
      Downgraded to C (sf)

The rating action is the result of Moody's on-going surveillance
of commercial real estate collateralized debt obligation (CRE CDO)
transactions. Moody's prior full review is summarized in a press
release dated May 13, 2010.

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.

The principal methodologies used in these ratings were "Moody's
Approach to Rating SF CDOs" published in November 2010.


SOLOSO CDO: Moody's Junks Ratings on Class A-1LA & A-1LB Notes
--------------------------------------------------------------
Moody's Investors Service has downgraded three classes of notes
issued by Soloso CDO 2007-1, Ltd.:

   -- US$263,000,000 Class A-1LA Floating Rate Notes Due
      October 2037 (current balance $254,166,676.5), Downgraded
      to Caa2(sf); previously on 10/30/2009 downgraded to Ba1(sf);

   -- US$83,000,000 Class A-1LB Floating Rate Notes Due October
      2037 (current balance $83,047,555.58 including interest
      shortfall), Downgraded to Ca(sf); previously on 10/30/2009
      downgraded to B1(sf);

   -- US$68,000,000 Class A-2L Deferrable Floating Rate Notes
      Due October 2037 (current balance $68,905,670.39 including
      interest shortfall), Downgraded to C(sf); previously on
      10/30/2009 downgraded to Ca(sf);

Ratings Rationale

Soloso CDO 2007-1, Ltd., issued on June 28, 2007, is a collateral
debt obligation backed by a portfolio of bank trust preferred
securities (the 'TRUP CDO').  The last rating action for this
transaction was on October 30, 2009.  At that time, Moody's
downgraded five classes of notes as a result of the application of
revised and updated key modeling assumptions, as well as the
deterioration in the credit quality of the transaction's
underlying portfolio.

Moody's indicated that the rating actions on the notes are
primarily the result of an increase in the assumed defaulted
amount of the pool.  The defaults increased by $108M since the
last rating action on October 30, 2009.  Moody's assumed defaulted
amount currently totals $242.00 million (46% of the portfolio).
All of the assumed defaulted assets are carried at zero recovery
in Moody's analysis.  The remaining performing assets in the
portfolio have also experienced a slight improvement on the credit
quality of the pool, as indicated by a WARF reduction to 916, from
1703as of the last rating action date.  This current WARF accounts
for a credit estimate stress, described in Moody's Rating
Methodology "Updated Approach to the Usage of Credit Estimates in
Rated Transactions", October 2009.

The par loss due to the increase in the assumed defaulted
amount has resulted in loss of overcollateralization for
the tranches affected and an increase of their expected
losses since the last rating action.  As of the latest trustee
report dated January 7, 2011, the Senior Overcollateralization
Ratio is reported at 99.61% (limit of 131.02%), the Class A2
Overcollateralization Ratio at 82.74% (limit of 117.05%),
the Class A3 Overcollateralization Ratio at 70.71% (limit of
104.81%) and the Class B Overcollateralization Ratio at 67.41%
(limit of 102.99%).  Moody's has noticed that the transaction
continues to be negatively impacted by large imbalanced fixed-
floating interest rate swaps, that results in significant
payments to the hedge counterparty.  In this case, the magnitude
of the imbalance between the cash inflows and outflows due to the
presence of over-hedging has been magnified by the increase in the
defaulted assets in the collateral portfolio.  In its analysis,
Moody's has accounted for the reduction of cash available to pay
the notes due to the significant swap payments to the hedge
counterparty.

The rating action also takes into consideration that the
transaction triggered an Event of Default on October 7, 2010,
arising from default in the payment of the Periodic Interest
Amount due on the Class A-1 Notes which continued for a period
of four business days, which resulted in an Event of Default.

In Moody's analysis, Moody's assumes that there are no prepayments
and the assets amortize at their final maturity.  The weighted
average life of the portfolio is approximately 26 years.

The credit deterioration exhibited by TRUP CDO portfolios is a
reflection of the continued pressure in the banking sector as the
number of bank failures and interest deferrals of bank trust
preferred securities has continued to increase.  According to
FDIC data, 26 U.S. banks have failed so far in 2011, while 157
U.S. banks failed in all of 2010, 140 U.S. banks failed in 2009
and 25 in 2008.

This portfolio is composed of trust preferred securities issued by
small to medium sized U.S. community bank that are generally not
publicly rated by Moody's.  To evaluate their credit quality,
Moody's derives credit scores for these non-publicly rated trust
preferred securities.  Moody's evaluation of these assets relies
on financial data received for a majority of obligors in the pool
as of Q3-2010.

The financial data is used by Moody's to assess the credit quality
of obligors in the pool, relying on RiskCalc, an econometric model
developed by Moody's KMV.  The results obtained from the RiskCalc
model have been translated to Moody's rating scale and adjusted by
one notch where necessary in order to compensate for the absence
of credit indicators such as rating reviews, outlooks and
adjustments factoring in cyclical developments in the economy.

Moody's evaluates the sensitivity of the rated transactions to the
volatility of the credit estimates, as described in Moody's Rating
Methodology "Updated Approach to the Usage of Credit Estimates in
Rated Transactions," October 2009.  For each credit score or
credit estimate where the related exposure constitutes more than
3% of the collateral pool, Moody's applied a 2-notch equivalent
assumed downgrade (but on the CEs representing in aggregate the
largest 30% of the pool) in lieu of the aforementioned stresses.
Notwithstanding the foregoing, in all cases the lowest assumed
rating equivalent is Caa3.  The effect of stress testing of these
credit scores varies between one and three notches, depending on
the total amount and relative size of these securities in the
collateral pool.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations.  Moody's considers as well the structural
protections in each transaction, risk Event of Default (EoD),
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.

The principal methodologies used in rating this were "Moody's
Approach to Rating U.S. Bank Trust Preferred Security CDOs"
published in June 2010, and "Updated Approach to the Usage of
Credit Estimates in Rated Transactions" published in October 2009.

Due to the impact of revised and updated key assumptions
referenced in these rating methodologies, key model inputs used
by Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers.  In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

The transaction's portfolio was modeled, according to Moody's
rating approach, using CDOROMTM v.2.8 to develop the loss
distribution from which the Moody's Asset Correlation parameter
was obtained. This parameter was then used as an input in a
cash flow model using CDOEdge. CDOROMTM v.2.8 is available on
moodys.com under Products and Solutions -- Analytical models,
upon return of a signed free license agreement.

Other methodologies and factors that may have been considered in
the process of rating this issue can also be found in the Credit
Policy & Methodologies directory.

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.


SORIN REAL ESTATE: Moody's Affirms Ratings on Five CRE CDO
----------------------------------------------------------
Moody's has affirmed one and downgraded five classes of Notes
issued by Sorin Real Estate CDO III Ltd. due to an increase in
weighted average rating factor (WARF), an increase in Defaulted
Securities, and the current and forecasted levels of interest
shortfalls.  The rating action is the result of Moody's on-going
surveillance of commercial real estate collateralized debt
obligation (CRE CDO) transactions.

   -- Cl. A-1B, Downgraded to Caa2 (sf); previously on Aug 13,
      2010 Assigned B3 (sf)

   -- Cl. A-2, Affirmed at C (sf); previously on May 19, 2010
      Downgraded to C (sf)

   -- Cl. B, Affirmed at C (sf); previously on May 19, 2010
      Downgraded to C (sf)

   -- Cl. D, Affirmed at C (sf); previously on May 19, 2010
      Downgraded to C (sf)

   -- Cl. C-FX, Affirmed at C (sf); previously on May 19, 2010
      Downgraded to C (sf)

   -- Cl. C-FL, Affirmed at C (sf); previously on May 19, 2010
      Downgraded to C (sf)

Ratings Rationale

Sorin Real Estate CDO III Ltd. is a CRE CDO transaction backed by
a portfolio of commercial mortgage backed securities (CMBS) (63.4%
of the pool balance), asset backed securities (25.4%) that are
primarily subprime residential mortgage-backed securities, CRE
CDOs (10.0%) and real estate investment trust bond (REITs) (1.4%).

As of the March 7, 2011 Trustee report, the aggregate Note balance
of the transaction has decreased to $962.5 million from $971.3
million at issuance, with the paydown directed to the Class A-1B
Notes; a result of failing the Class A/B overcollateralization
test.  A portion of the principal proceeds is currently being used
to pay interest and counterparty payments on the transaction,
diverting money that would be utilized to pay principal on Class
A-1B.

There are nineteen assets with par balance of $152.7 million
(16.2% of the current pool balance) that are considered Non-
Performing Securities as of the March 7, 2011 Trustee report.
Fourteen of these assets (72.4% of the defaulted balance) are ABS,
two assets are CMBS (19.3%), and three assets are CDOs (8.4%).
Defaulted Securities are defined as assets which are in default of
regular principal or interest receipt or are rated Ca or below.
While there have been limited realized losses date, Moody's does
expect significant losses to occur once they are realized.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: weighted average
recovery rate (WARF), weighted average life (WAL), weighted
average recovery rate (WARR), and Moody's asset correlation (MAC).
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.
We 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 2,625 compared to 1,811 at last
review.  The distribution of current ratings and credit estimates
is as follows: Aaa-Aa3 (13.7% compared to 20.0% at last review),
A1-A3 (11.1% compared to 20.3% at last review), Baa1-Baa3 (22.7%
compared to 19.1% at last review), Ba1-Ba3 (14.9% compared to 9.7%
at last review), B1-B3 (14.7% compared to 13.7% at last review),
and Caa1-C (23.0% compared to 17.2% 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 5.0
years compared to 5.5 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool.  Moody's modeled a fixed WARR
of 25.6% compared to 28.4% 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 9.5% compared to 6.7% 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.

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 26% to 16% or up to 36% 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.

The principal methodologies used in these ratings were "Moody's
Approach to Rating SF CDOs" published in November 2010", and
"CMBS: Moody's Approach to Rating Static CDOs Backed by Commercial
Real Estate Securities published on June 17, 2004" published in
July 2004.

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.


STRUCTURED ASSET: S&P Downgrades Rating on Class A1 to 'BB'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on class A1
from Structured Asset Securities Corp. Reverse Mortgage Loan Trust
2005-RM1 (SASCO 2005-RM1) to 'BB (sf)' from 'AAA (sf)' and removed
it from CreditWatch with negative implications.  We subsequently
withdrew our rating on class A1.  We also withdrew our rating on
class A-IO from the same transaction," S&P said

"The lowering and CreditWatch removal of our rating on class A1
reflect our belief that the amount of credit enhancement available
for this class will not be sufficient to cover projected losses
for scenarios at the higher rating level based on the available
information.  We withdrew the rating on class A1 because we did
not receive sufficient information to maintain surveillance on
this class.

"We withdrew the rating on class A-IO because it falls below the
applicable 'AA- (sf)' rating threshold, according to our criteria,
"Global Methodology For Rating Interest-Only Securities,"
published April 15, 2010," S&P noted.

S&P continued, "We previously placed the ratings on these classes
on CreditWatch negative as part of a larger review of reverse
mortgage transactions issued by Structured Asset Securities Corp.
(SASCO).  We were unable to conduct a full rating analysis on
class A1 because we did not receive requested information from the
issuer.  Lacking the sufficient pool-specific information, we
based our downgrade of class A1 to 'BB (sf)' from 'AAA (sf)' on
our view of the available market information and the structure of
the transaction."

The collateral backing this transaction consists of reverse
mortgage loans that are secured by first mortgages, deeds of
trust, or other similar security instruments creating first liens
on one- to four-family residential properties.

Rating Actions

Structured Asset Securities Corp. Reverse Mortgage Loan Trust
2005-RM1
Series 2005-RM1
                              Rating
Class   CUSIP       To        Interim       From
A1      863576AX2   NR        BB (sf)       AAA (sf)/Watch Neg
A-IO    863576AZ7   NR                      AAA (sf)/Watch Neg



TUCKAHOE CREDIT: S&P Affirms 'BB' Rating on Pass-through Certs.
---------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its 'BB' rating on
Tuckahoe Credit Lease Trust 2001-CTL1's credit lease-backed pass-
through certificates and removed it from CreditWatch with positive
implications.  S&P assigned a stable outlook.

The rating action reflects the announcement that CenturyLink
Inc. (CenturyLink) has agreed to acquire Qwest Communications
International Inc. (Qwest) in a stock-for-stock transaction.
According to regulatory filing documents submitted to the
Securities and Exchange Commission (SEC) on April 6, 2011,
Qwest will continue as a wholly owned subsidiary of CenturyLink.
The rating on Tuckahoe Credit Lease Trust 2001-CTL1 is dependent
on the rating on CenturyLink (BB/Stable/B).

Tuckahoe Credit Lease Trust 2001-CTL1's credit lease-backed
certificates are collateralized by a first mortgage and
assignment of lease encumbering a condominium interest in
a two-story industrial building in Yonkers, N.Y.  The entire
property is leased to Qwest Communications Corp. (QCC), a wholly
owned subsidiary of Qwest, on a triple-net-basis, with QCC
responsible for all operating and maintenance costs.


VALEO INVESTMENT: Moody's Ups 2 Classes of Notes Ratings to Caa3
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Valeo Investment Grade CDO II Ltd:

   -- $443,750,000 Class A-1 Floating Rate Senior Subordinated
      Notes Due June 1, 2013 (current balance $83,948,520),
      Upgraded to Aa1 (sf); previously on November 12, 2009
      Confirmed at Aa3 (sf);

   -- $18,500,000 Class A-2 Floating Rate Senior Subordinated
      Notes Due June 1, 2013, Upgraded to Baa2 (sf); previously on
      May 20, 2009 Downgraded to B3 (sf);

   -- $13,750,000 Class B-1 Floating Rate Senior Subordinated
      Notes Due June 1, 2013, Upgraded to Caa3 (sf); previously on
      May 20, 2009 Downgraded to Ca (sf);

   -- $9,000,000 Class B-2 8.697% Fixed Rate Senior Subordinated
      Notes Due June 1, 2013, Upgraded to Caa3 (sf); previously on
      May 20, 2009 Downgraded to Ca (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes
result primarily from the deleveraging of the Class A-1 Notes,
which have been paid down by approximately 65% or $160 million
since May 2009.  As a result of the deleveraging, the Senior
Overcollateralization Ratio has increased since the 2009 rating
action.  As of the trustee report dated February 22, 2011, the
Senior Overcollateralization Ratio Test is reported at 124.41
versus 110.95. It is currently in compliance.

The rating on the Class A-1 Notes reflects the actual underlying
rating of the Class A-1 Notes.  This underlying rating is based
solely on the intrinsic credit quality of the Class A-1 Notes
in the absence of the guarantee from Assured Guaranty Municipal
Corp. whose insurance financial strength rating is currently Aa3.
The above action on the Class A-1 Notes is a result of, and is
consistent with, Moody's modified approach to rating structured
finance securities wrapped by financial guarantors as described
in the press release dated November 10, 2008, titled "Moody's
modifies approach to rating structured finance securities wrapped
by financial guarantors."

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" and "Annual Sector Review (2009): Global CLOs,"
key model inputs used by Moody's in its analysis, such as par,
weighted average rating factor, diversity score, and weighted
average recovery rate, may be different from the trustee's
reported numbers.  In its base case, Moody's analyzed the
underlying collateral pool to have a performing par balance of
$91 million, defaulted par of $4 million, a weighted average
default probability of 13% (implying a WARF of 3375), a weighted
average recovery rate upon default of 23% and a diversity score
of 13.  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.

Valeo Investment Grade CDO II Ltd., issued May 2001, is a
collateralized bond obligation backed primarily by a portfolio of
senior unsecured bonds.  The trustee reports 23 obligors and a
diversity score of 15.

The principal methodology used in these ratings was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
August 2009.  This publication incorporates rating criteria that
apply to both collateralized loan obligations and collateralized
bond obligations.

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 2.8 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.  This 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% (2700)

   -- Class A-1: +2
   -- Class A-2: +2
   -- Class B-1: +1
   -- Class B-2: +1

Moody's Adjusted WARF +20% (4050)

   -- Class A-1: -2
   -- Class A-2: -1
   -- Class B-1: 0
   -- Class B-2: 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) Deleveraging: The amount and pace of deleveraging from
      principal proceeds is uncertain.  Deleveraging may
      accelerate due to high prepayment levels in the bond market
      and/or collateral sales by the manager, which may have
      significant impact on the notes' ratings.

   2) Recovery of defaulted assets: Market value fluctuations in
      defaulted assets reported by the trustee and those assumed
      to be defaulted by Moody's may create volatility in the
      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) Lack of portfolio granularity: Due to the deal's low
      diversity score and lack of granularity, Moody's
      supplemented its typical Binomial Expansion Technique
      analysis with a simulated default distribution using Moody's
      CDOROMTM software and/or individual scenario analysis.

   4) Long-dated assets: The presence of assets that mature beyond
      the CBO'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.


WACHOVIA BANK: Moody's Holds Ratings of 23 CMBS Classesof Certs.
----------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 23
classes of Wachovia Bank Commercial Mortgage Trust, Commercial
Mortgage Pass-Through Certificates, Series 2006-C23 as:

   -- Cl. A-4, Affirmed at Aaa (sf); previously on Mar 13, 2006
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-5, Affirmed at Aaa (sf); previously on Mar 13, 2006
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-PB, Affirmed at Aaa (sf); previously on Mar 13, 2006
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-1A, Affirmed at Aaa (sf); previously on Mar 13, 2006
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-M, Affirmed at Aaa (sf); previously on Jul 8, 2010
      Confirmed at Aaa (sf)

   -- Cl. X-P, Affirmed at Aaa (sf); previously on Mar 13, 2006
      Definitive Rating Assigned Aaa (sf)

   -- Cl. X-C, Affirmed at Aaa (sf); previously on Mar 13, 2006
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-J, Affirmed at A2 (sf); previously on Jul 8, 2010
      Downgraded to A2 (sf)

   -- Cl. B, Affirmed at A3 (sf); previously on Jul 8, 2010
      Downgraded to A3 (sf)

   -- Cl. C, Affirmed at Baa1 (sf); previously on Jul 8, 2010
      Downgraded to Baa1 (sf)

   -- Cl. D, Affirmed at Baa2 (sf); previously on Jul 8, 2010
      Downgraded to Baa2 (sf)

   -- Cl. E, Affirmed at Baa3 (sf); previously on Jul 8, 2010
      Downgraded to Baa3 (sf)

   -- Cl. F, Affirmed at Ba1 (sf); previously on Jul 8, 2010
      Downgraded to Ba1 (sf)

   -- Cl. G, Affirmed at Ba2 (sf); previously on Jul 8, 2010
      Downgraded to Ba2 (sf)

   -- Cl. H, Affirmed at B2 (sf); previously on Jul 8, 2010
      Downgraded to B2 (sf)

   -- Cl. J, Affirmed at Caa1 (sf); previously on Jul 8, 2010
      Downgraded to Caa1 (sf)

   -- Cl. K, Affirmed at Caa3 (sf); previously on Jul 8, 2010
      Downgraded to Caa3 (sf)

   -- Cl. L, Affirmed at Ca (sf); previously on Jul 8, 2010
      Downgraded to Ca (sf)

   -- Cl. M, Affirmed at Ca (sf); previously on Jul 8, 2010
      Downgraded to Ca (sf)

   -- Cl. N, Affirmed at C (sf); previously on Jul 8, 2010
      Downgraded to C (sf)

   -- Cl. O, Affirmed at C (sf); previously on Jul 8, 2010
      Downgraded to C (sf)

   -- Cl. P, Affirmed at C (sf); previously on Jul 8, 2010
      Downgraded to C (sf)

   -- Cl. Q, Affirmed at C (sf); previously on Jul 8, 2010
      Downgraded to C (sf)

Ratings Rationale

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

Moody's rating action reflects a cumulative base expected loss of
5.9% of the current balance.  At last review, Moody's cumulative
base expected loss was 5.7%.  Moody's stressed scenario loss is
21.4% of the current balance.  Moody's provides a current list of
base and stress scenario losses for conduit and fusion CMBS
transactions on moodys.com at http://is.gd/INmyw5. 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 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.

The principal methodology used in this rating was "CMBS: Moody's
Approach to Rating Fusion Transactions" published in April 2005.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.  The
pool has a Herf of 50, essentially the same as 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 (CMBS) 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 8, 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 March 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 11% to
$3.74 billion from $4.23 billion at securitization.  The
Certificates are collateralized by 294 mortgage loans ranging
in size from less than 1% to 8% of the pool, with the top ten
loans representing 32% of the pool.  The pool includes two
loans with credit estimates, representing 1% of the pool.  Two
loans, representing less than 1% of the pool, have defeased and
are collateralized with U.S. Government securities.

Sixty-two loans, representing 29% of the pool, are on the master
servicer's watchlist.  The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) 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 $29.0 million loss
(10% loss severity on average).  The pool had not experienced
any losses at last review. Seventeen loans, representing 6%
of the pool, are currently in special servicing.  The master
servicer has recognized an aggregate $54.1 million appraisal
reduction for ten of the specially serviced loans.  Moody's
has estimated an aggregate $109.1 million loss (47% expected
loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for 13 poorly
performing loans representing 5% of the pool and has estimated a
$25.8 million aggregate loss (15% expected loss based on a 30%
probability default) from these troubled loans.

As of the most recent remittance statement date, the transaction
has experienced unpaid accumulated interest shortfalls totaling
$7.8 million affecting Classes N through S.  Interest shortfalls
are caused by special servicing fees, appraisal reductions,
extraordinary trust expenses and interest payment reductions due
to loan modifications.  Moody's expects interest shortfalls to
increase due to the pool's high exposure to specially serviced
loans.

Moody's was provided with full or partial year 2010 operating
results for 80% of the pool.  Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 104% compared to
108% 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 9.0%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.37X and 1.01X, respectively, compared to
1.24X and 0.93X at last review.  Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the Cavalier Country
Club Apartment Loan ($25.9 million -- 0.7% of the pool), which is
secured by a 32-building apartment complex. Comprised of 744
units, the complex is located in Newark, Delaware.  As of June
2010, the property was 94% leased, essentially the same as at last
review.  The property's performance remains in-line with last
review.  The loan matures in January 2016 and is amortizing on a
360-month schedule.  Moody's current credit estimate and stressed
DSCR are Baa3 and 1.3X, respectively, essentially the same as at
last review.

The second loan with a credit estimate is the 594 Broadway Loan
($24.0 million -- 0.6% of the pool), which is secured by a 12-
story, 217,000 SF Class B office building located at the corner of
Broadway and Houston Street in SoHo.  As of February 2011, the
property was 95% leased compared to 93% at last review.  The
property is predominantly leased to small tenants that occupy no
more than 5% of the net rentable area (NRA).  Performance remains
in-line with last review.  The loan matures in February 2016 and
is full term interest only.  Moody's current credit estimate and
stressed DSCR are A3 and 1.73X, respectively, essentially the same
as at last review.

The top three performing conduit loans represent 18% of the
pool balance.  The largest loan is the Prime Outlet Pool Loan
($301.6 million -- 8% of the pool), which is secured by ten
outlet centers located across eight states.  The total gross
leasable area (GLA) is 3.5 million SF.  The loan represents a 50%
interest in a $603 million first mortgage loan.  As of June 2010,
the portfolio was 92% leased compared to 90% at last review.  The
largest tenants are Vanity Fair Outlet (4% of the GLA; leases
expire in 2014); The Gap (3% of the GLA; leases expire in 2013,
2014 and 2019) and Nike (2% of the GLA; lease expires in 2011).
The loan matures in July 2016 and is amortizing on a 360-month
schedule.  The sponsor is Simon Property Group. Performance is
stable.  Moody's LTV and stressed DSCR are 98% and 1.03X,
respectively, compared to 100% and 1.01X at last review.

The second largest loan is the 620 Avenue of the Americas Loan
($205.0 million -- 5% of the pool), which is secured by a 7-story,
670,000 SF mixed-use building located in the Flatiron/Chelsea sub-
market of Manhattan.  The loan is encumbered with a $30.0 million
B-note and $30.0 million of mezzanine debt.  As of December 2010
the property was 93% leased compared to 84% at last review.
Filene's Basement, which previously occupied 6% of the NRA,
vacated when its leased expired in March 2010 and Marshall's
leased the space on a lease expiring in October 2020.  Local Union
SEIU 32BJ is the largest tenant (42% of the NRA; lease expires in
December 2013).  Moody's LTV and stressed DSCR are 117% and 0.79X,
respectively compared to 119% and 0.77X as at last review.

The third largest loan is the Hyatt Center Loan ($161.8 million --
4% of the pool), which is secured by a 49-story, 1.47 million SF,
Class A office building located in the West Loop sub-market of
Chicago. The loan represents a 50% interest in a $323.6 million
first mortgage loan. In addition, the loan is encumbered with
$75 million of mezzanine debt.  The largest tenants are Mayer
Brown LLP (27% of the NRA; lease expires in June 2020); the Hyatt
Corporation (14% of the NRA; lease expires in January 2020) and
Goldman Sachs (10% of the NRA; lease expires in March 2020).  As
of September 2010 the property was 95% leased essentially the same
as at last review. Moody's LTV and stressed DSCR are 109% and
0.84X, respectively, essentially the same as at last review.


WACHOVIA BANK: Moody's Holds Ratings on 31 CMBS Classes of Certs.
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 19 pooled
classes and 12 non-pooled rake classes of Wachovia Bank
Commercial Mortgage Securities, Inc., Commercial Mortgage Pass-
Through Certificates, Series 2004-C15 as:

   -- Cl. A-2, Affirmed at Aaa (sf); previously on Dec 21, 2004
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-3, Affirmed at Aaa (sf); previously on Dec 21, 2004
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-1A, Affirmed at Aaa (sf); previously on Dec 21, 2004
      Definitive Rating Assigned Aaa (sf)

   -- Cl. A-4, Affirmed at Aaa (sf); previously on Dec 21, 2004
      Definitive Rating Assigned Aaa (sf)

   -- Cl. X-P, Affirmed at Aaa (sf); previously on Dec 21, 2004
      Definitive Rating Assigned Aaa (sf)

   -- Cl. X-C, Affirmed at Aaa (sf); previously on Dec 21, 2004
      Definitive Rating Assigned Aaa (sf)

   -- Cl. B, Affirmed at Aa2 (sf); previously on Dec 21, 2004
      Definitive Rating Assigned Aa2 (sf)

   -- Cl. C, Affirmed at Aa3 (sf); previously on Dec 21, 2004
      Definitive Rating Assigned Aa3 (sf)

   -- Cl. D, Affirmed at A2 (sf); previously on Dec 21, 2004
      Definitive Rating Assigned A2 (sf)

   -- Cl. E, Affirmed at A3 (sf); previously on Dec 21, 2004
      Definitive Rating Assigned A3 (sf)

   -- Cl. F, Affirmed at Baa2 (sf); previously on Jun 30, 2010
      Downgraded to Baa2 (sf)

   -- Cl. G, Affirmed at Baa3 (sf); previously on Jun 30, 2010
      Downgraded to Baa3 (sf)

   -- Cl. H, Affirmed at B1 (sf); previously on Jun 30, 2010
      Downgraded to B1 (sf)

   -- Cl. J, Affirmed at B3 (sf); previously on Jun 30, 2010
      Downgraded to B3 (sf)

   -- Cl. K, Affirmed at Caa1 (sf); previously on Jun 30, 2010
      Downgraded to Caa1 (sf)

   -- Cl. L, Affirmed at Caa2 (sf); previously on Jun 30, 2010
      Downgraded to Caa2 (sf)

   -- Cl. M, Affirmed at Caa3 (sf); previously on Jun 30, 2010
      Downgraded to Caa3 (sf)

   -- Cl. N, Affirmed at Ca (sf); previously on Jun 30, 2010
      Downgraded to Ca (sf)

   -- Cl. O, Affirmed at C (sf); previously on Jun 30, 2010
      Downgraded to C (sf)

   -- Cl. 180ML-G, Affirmed at B2 (sf); previously on Dec 21, 2004
      Definitive Rating Assigned B2 (sf)

   -- Cl. 175WJ-E, Affirmed at B3 (sf); previously on Mar 27, 2007
      Downgraded to B3 (sf)

   -- Cl. 175WJ-A, Affirmed at Ba2 (sf); previously on Mar 27,
      2007 Downgraded to Ba2 (sf)

   -- Cl. 175WJ-B, Affirmed at Ba3 (sf); previously on Mar 27,
      2007 Downgraded to Ba3 (sf)

   -- Cl. 175WJ-C, Affirmed at B1 (sf); previously on Mar 27, 2007
      Downgraded to B1 (sf)

   -- Cl. 175WJ-D, Affirmed at B2 (sf); previously on Mar 27, 2007
      Downgraded to B2 (sf)

   -- Cl. 180ML-A, Affirmed at Baa2 (sf); previously on Dec 21,
      2004 Assigned Baa2 (sf)

   -- Cl. 180ML-B, Affirmed at Baa3 (sf); previously on Dec 21,
      2004 Assigned Baa3 (sf)

   -- Cl. 180ML-C, Affirmed at Ba1 (sf); previously on Dec 21,
      2004 Assigned Ba1 (sf)

   -- Cl. 180ML-D, Affirmed at Ba2 (sf); previously on Dec 21,
      2004 Assigned Ba2 (sf)

   -- Cl. 180ML-F, Affirmed at B1 (sf); previously on Dec 21, 2004
      Assigned B1 (sf)

   -- Cl. 180ML-E, Affirmed at Ba3 (sf); previously on Dec 21,
      2004 Assigned Ba3 (sf)

Ratings Rationale

The affirmations of the pooled classes are due to key parameters,
including Moody's loan to value (LTV) ratio, Moody's stressed DSCR
and the Herfindahl Index (Herf), remaining within acceptable
ranges.  Based on Moody's current base expected loss, the credit
enhancement levels for the affirmed classes are sufficient to
maintain their current ratings.  The affirmations of the non-
pooled, or rake classes, are due to the stable performance of the
underlying collateral supporting these classes.

Moody's rating action reflects a cumulative base expected loss
of 2.8% of the current balance.  At last full review, Moody's
cumulative base expected loss was 3.3%.  Moody's stressed scenario
loss is 8.4% of the current balance. Moody's provides a current
list of base and stress scenario losses for conduit and fusion
CMBS transactions on moodys.com at http://is.gd/INmyw5. 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
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.

The principal methodology used in this rating was: "Moody's
Approach to Rating Fusion Transactions" published in April 2005.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances.  The credit neutral Herf score is 40.
The pool has a Herf of 21, the same as 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 (CMBS) transactions.
Moody's monitors transactions on a monthly basis through two sets
of quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated June 30, 2010.

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

Deal Performance

As of the March 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 14% to
$1.10 billion from $1.28 billion at securitization.  The
Certificates are collateralized by 82 mortgage loans ranging
in size from less than 1% to 11% of the pool, with the top
ten loans representing 53% of the pool.  The pool includes two
loans with investment grade credit estimates, representing 18%
of the pool, the same as at last review.  Four loans, representing
4.8% of the pool, have defeased and are collateralized with U.S.
Government securities.

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

Two loans have been liquidated from the pool, resulting in a
$6.5 million loss (40% loss severity on average).  Currently
four loans, representing 8% of the pool, are in special servicing.
The largest specially serviced loan is the IRS Building Loan
($45.2 million -- 4.6% of the pool), which is secured by a 180,000
square foot office building located in Fresno, California.  The
property is 100% leased to the U.S. Government through November
2018. The loan was transferred to special servicing in January
2010 due to a bankruptcy filing by the borrower and indemnitor.
The loan emerged from bankruptcy in September 2010 and lockbox
funds have been applied to all past due interest, principal and
reserve payments.  The loan is current through March 2011;
however, the borrower has been given a second Notice of Default
for other items.  Moody's is not currently estimating a loss from
this loan. The remaining three specially serviced loans are
secured by retail, hotel, and multifamily properties.  The master
servicer has recognized an aggregate $10.4 million appraisal
reduction for the specially serviced loans.  Moody's has estimated
an aggregate loss of $10.3 million (32% expected loss on average)
for three of the specially serviced loans.

Moody's has assumed a high default probability for four poorly
performing loans representing 2% of the pool and has estimated a
$4.7 million loss (20% expected loss based on a 40% probability
default) from these troubled loans.

Moody's was provided with full year 2009 and partial year 2010
operating results for 99% and 93%, respectively, of the performing
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV is 92% compared to 93% at last review.
Moody's net cash flow reflects a weighted average haircut of 14%
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 1.35X and 1.11X, respectively, compared to
1.32X and 1.08X at last review.  Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the 180 Maiden Lane
Loan ($93.0 million -- 9.5% of the pool), which represents a 50%
interest in a $186.0 million first mortgage loan.  The loan is
secured by a 1.1 million square foot (SF) Class A office building
located in the Financial District of New York City.  The property
is anchored by AIG which leases 74% of the net rentable area (NRA)
though April 2014.  The property was 98% leased as of January 2011
compared to 100% at last review.  The property is also encumbered
by a $69.5 million B-Note which serves as collateral for non-
pooled Classes 180ML-A, 180ML-B, 180ML-C, 180ML-D, 180ML-E, 180ML-
F and 180ML-G.  The loan was modified in December 2009 with a 36-
month term extension, and is interest only for its entire 98-month
term maturing in November 2012.  Moody's credit estimate and
stressed DSCR are Baa1 and 1.36X, respectively, compared to Baa1
and 1.32 at last review.

The second loan with a credit estimate is the Coastal Grand Mall
Loan ($85.0 million -- 8.7% of the pool), which is secured by the
borrower's interest in a 882,700 SF regional mall located in
Myrtle Beach, South Carolina.  The property is anchored by
Dillard's, Sears and Belk, all of which own their own
improvements.  The mall was 100% leased as of December 2010,
similar to at last review.  Moody's credit estimate and stressed
DSCR are Baa1 and 1.43X, respectively, compared to Baa1 and 1.38X
at last review.

The top three performing loans represent 22% of the pool balance.
The largest performing loan is the 175 West Jackson Loan ($107.5
million -- 11.0% of the pool), which represents a 50%
participation interest in a $215.0 million first mortgage loan.
The loan is secured by 1.5 million SF Class A office building
located in the Chicago CBD.  The building is also encumbered by a
$52.5 million B-Note, which serves as collateral for non-pooled
Classes 175WJ-A, 175WJB, 175WJ-C, 175WJ-D and 175WJ-E.  The
property was 96% leased as of December 2010, the same as at last
review.  The largest tenants are Classified Ventures (10% of the
NRA; lease expiration June 2017), Aon Service Corp. (9% of the
NRA; lease expiration April 2012) and Grant Thornton (9% of the
NRA; lease expiration October 2017).  Property performance has
improved since last review due to increased base rents and other
income.  Moody's LTV and stressed DSCR are 66% and 1.43X,
respectively, compared to 73% and 1.30X at last review.

The second largest performing loan is the Gale Portfolio Loan
($68.9 million -- 7.1% of the pool), which is secured by four
suburban office properties located in northern New Jersey. The
portfolio totals 574,000 SF.  The portfolio was 82% leased as of
September 2010 compared to 86% at last review.  The loan has been
on the master servicer's watchlist since September 2010 due to low
DSCR.  Property performance has declined due to several tenants
not renewing upon lease expiration.  Moody's LTV and stressed DSCR
are 110% and 0.93X, respectively, compared to 105% and 0.98X at
last review.

The third largest performing loan is the ADG Portfolio Loan
($39.6 million -- 4.1% of the pool), which is secured by 25 mobile
home communities located in Wisconsin and Maryland.  The portfolio
was 87% leased as of September 2010 compared to 85% at last
review.  Performance has been stable.  Moody's LTV and stressed
DSCR are 91% and 1.09X, respectively, compared to 93% and 1.05X at
last review.


WESTERN EXPRESS: S&P Junks Corporate Credit Rating; Outlook Stable
------------------------------------------------------------------
Standard & Poor's Ratings Services said it has lowered its
corporate credit rating on Western Express Inc. to 'CCC+' from
'B-'.  The outlook is stable.

"The ratings on Western Express reflect the truckload carrier's
highly leveraged financial profile and participation in the
capital-intensive and cyclical trucking sector, which is subject
to pricing pressure and intense competition," said Standard &
Poor's credit analyst Anita Ogbara.  "The company's midsize market
position and good customer diversity only partially offset these
weaknesses.  Western Express operates a company-owned fleet of
about 2,400 tractors, 6,700 trailers, and 13 service centers
across 10 states, primarily on the East Coast.  The company's
fleet consists of dry-van, flatbed, and dedicated truckloads."

The company maintains a respectable market position but operates
in a highly fragmented industry, where the top 10 truckload (TL)
companies account for less than 5% of the total for-hire truckload
market.  As a result, Western Express faces intense competition
and pricing pressure from other large industry players such as
Swift Corp., US Xpress Enterprises Inc., and J.B. Hunt Transport
Services Inc.  The company does benefit from good customer
diversity, with no single customer accounting for more than 6% of
revenues in 2010.  However, Western Express has substantial
exposure to more-cyclical end markets such as building materials,
paper, and steel (mostly through its flatbed operations), which
the recent housing downturn has adversely affected.

Over the past few quarters, there have seen signs of an
improving operating environment due to tight capacity in the TL
spot market, higher fleet utilization, fewer empty miles (driving
without freight loads), and stabilizing pricing trends.  However,
rising costs resulting from Comprehensive Safety Analysis 2010
requirements, as well as higher recruiting costs and wages arising
from the current driver shortage, could hamper earnings
improvement in the TL sector.

The outlook is stable.  "We expect earnings and operating results
to improve as tonnage and pricing strengthens in the TL sector and
maintenance costs decline due to the new fleet additions," Ms.
Ogbara continued.  "We could lower the ratings if earnings fail to
improve, or if liquidity becomes constrained and revolver access
falls below $10 million.  Given the company's depressed
earnings and weak credit metrics, we believe a ratings upgrade is
unlikely over the next several quarters."


WHITNEY CLO: S&P Raises Class B-1LB Rating to 'B+' From 'CCC-'
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1L, A-1LB, A-2L, A-2F, A-3L, B-1LA, and B-1LB notes from Whitney
CLO I Ltd., a collateralized loan obligation (CLO) transaction
managed by Apidos Capital Management LLC.  "At the same time, we
affirmed our 'AAA(sf)' ratings on the class A-1LA, P1, and P2
notes.  Concurrently, we removed our ratings on the class A-1L, A-
1LB, A-2L, A-2F, and A-3L notes from CreditWatch, where we placed
them with positive implications on Jan. 3, 2011," S&P related.

"The upgrades mainly reflect an improvement in the performance of
the transaction's underlying asset portfolio, since our March 17,
2010, rating actions, when we downgraded most of the rated notes
following the application of our September 2009 corporate CDO
criteria.  As of the February 2011 trustee report, the transaction
had $7.62 million of defaulted assets.  This was down from $28.09
million noted in the January 2010 trustee report, which we
referenced for our March 2010 rating actions.  Furthermore, assets
from obligors rated in the 'CCC' category were reported at $10.49
million in February 2011, compared with $25.31 million in January
2010," S&P stated.

The transaction has further benefited from an increase in the
overcollateralization (O/C) available to support the rated notes.
The trustee reported the following O/C ratios in the Feb. 17,
2011, monthly report:

    * The senior class A O/C ratio was 123.89%, compared with a
      reported ratio of 120.05% in January 2010;

    * The class A O/C ratio was 115.52%, compared with a reported
      ratio of 112.01% in January 2010;

    * The class B-1LA O/C ratio was 108.63%, compared with a
      reported ratio of 105.38% in January 2010; and

    * The class B-1LB O/C ratio was 104.81%, compared with a
      reported ratio of 101.75% in January 2010.

"The affirmations of our ratings on the class A-1LA, P1, and P2
notes reflect the availability of credit support at the current
rating levels," S&P noted.

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 it deems necessary.

Rating and CreditWatch Actions

Whitney CLO I Ltd.
              Rating
Class     To           From
A-1L      AAA (sf)     AA+ (sf)/Watch Pos
A-1LB     AAA (sf)     AA+ (sf)/Watch Pos
A-2L      AA (sf)      A+ (sf)/Watch Pos
A-2F      AA (sf)      A+ (sf)/Watch Pos
A-3L      A+ (sf)      BBB+ (sf)/Watch Pos
B-1LA     BBB (sf)     BB- (sf)
B-1LB     B+ (sf)      CCC- (sf)

RATINGS AFFIRMED

Whitney CLO I Ltd.
Class                    Rating
A-1LA                    AAA (sf)
P1                       AAA (sf)
P2                       AAA (sf)


ZAIS INVESTMENT: Moody's Ups Rating on US$285MM Notes to 'B1'
-------------------------------------------------------------
Moody's Investors Service has upgraded the rating of one class of
notes issued by ZAIS Investment Grade Limited V.  The class of
notes affected by the rating actions is:

   -- US$285,000,000 Class A-1 Senior Secured Floating Rate
      Notes (current balance of $193,882,862), Upgraded to B1
      (sf); previously on June 4, 2010, Downgraded to Caa2 (sf);

Ratings Rationale

According to Moody's, the rating action taken on the notes results
primarily from the delevering of the Class A-1 Notes and the
improvement of the credit quality of the portfolio.

The Class A-1 Notes have been paid down by approximately
$44 million since the last rating action in June 2010.  As a
result of the delevering, the overcollateralization ratios have
increased since that time.  As of the latest trustee report dated
March 3, 2011, the Class A and Class B overcollateralization
ratios are reported at 89.40% and 73.52%, respectively, versus May
2010 levels of 64.66% and 54.42%, respectively.  The transaction
triggered an EOD on April 27, 2009 and, subsequently, acceleration
was declared on August 6, 2009.  Therefore, the Class A-1 is
receiving all interest and principal payments and the Class A-2,
B-1 and B-2 are currently deferring interest.

Moody's also notes that the deal has benefited from improvement in
the credit quality of the underlying portfolio since the rating
action in May 2010.  Based on the March 2011 trustee report, the
weighted average rating factor is 3958 compared to 4654 in May
2010.  About $107mm of collateral was upgraded since the last
rating action including $26mm of Ca rated CLOs that were upgraded
to Caa3 and above.

ZAIS Investment Grade Limited V is a collateralized debt
obligation backed primarily by a portfolio of CLOs,.

The principal methodology used in this rating was "Moody's
Approach to Rating SF CDOs" published in November 2010.

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 the following:
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 (EL) 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.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios, discussed below. Results are 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 Caa3 bucket notched down to Ca:

   -- Class A-1: -3

   -- Class A-2a: -1

   -- Class B-1: 0

   -- Class B-2: 0

Moody's Caa3 bucket notched up to Caa1:

   -- Class A-1: +1

   -- Class A-2a: +1

   -- Class B-1: 0

   -- Class B-2: 0


* S&P Affirms Ratings on 18 Classes of COMM 2006-CNL2 Certs.
------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on 18
classes of commercial mortgage-backed certificates from COMM 2006-
CNL2, a U.S. commercial mortgage-backed securities
(CMBS) transaction.

"The affirmations follow our analysis of the transaction,
which included our revaluations of the five lodging properties
securing the sole fixed-rate interest-only (IO) loan that
serves as collateral for the trust.  Our revised valuations,
in aggregate, are comparable with the levels we assessed in our
last review on Feb. 25, 2010," S&P related.

"We affirmed our ratings on the class X-1 and X-2 IO certificates
based on our current criteria," S&P noted.

"We based our analysis, in part, on a review of the borrower's
operating statements for the year ended Dec. 31, 2010, the
borrower's 2011 budgets, available Smith Travel Research (STR)
reports, and CBRE Econometric Advisors' revenue per available
room (RevPAR) projections for each available submarket.  We
also discussed each property's condition, including deferred
maintenance needs and local market conditions with the special
servicer, Midland Loan Services (Midland).  Our adjusted
valuations on the collateral properties, in aggregate, are
comparable with the levels we assessed in our last review.  The
reported year-end 2010 combined occupancy and average daily rate
(ADR) for the lodging properties were 65.0% and $220.57,
respectively, yielding a RevPAR of $143.38.  This was up 7.8%
from year-end 2009.  Our analysis yielded a 122.2% in-trust
stressed loan-to-value (LTV) ratio and a 186.4% total debt
stressed LTV ratio.  The master servicer, also Midland, reported
a combined debt service coverage (DSC) of 0.82x for the year
ended Dec. 31, 2009," S&P related.

The mortgage loan was transferred to Midland on Oct. 21, 2009,
due to imminent default following the borrower's loan modification
submission.  Subsequently, the mortgage loan borrowers and their
affiliates filed voluntary petitions for relief under Chapter 11
of the U.S. Bankruptcy Code on Feb. 1, 2011, the mortgage loan's
final maturity date.  Midland stated that a court hearing was
held on March 16, 2011, and has filed a cash collateral order to
ensure timely monthly debt service payments on the senior mortgage
loan that collateralizes the trust.  According to Midland, the
bankruptcy court automatically granted the current owner, CNL-AB
LLC -- which is a joint venture between Paulson & Co. Inc.,
Winthrop Realty Trust, Morgan Stanley, and Capital Trust Inc. -- a
120-day exclusivity to file its reorganization plan.  Midland
indicated that it has ordered updated appraisals through its legal
counsel.

As of the April 5, 2011 trustee remittance report, the mortgage
loan has a trust and whole-loan balance of $1.0 billion and is
secured by five upscale luxury resort hotels totaling 3,287 rooms
in Hawaii, California, Florida, and Arizona.  The IO loan had a
5.5699% fixed interest rate and matured on Feb. 1, 2011.  The
rated final distribution date for each class of offered
certificates is in February 2019.  In addition, the equity
interests in the borrower secure four floating-rate mezzanine
loans totaling $525.0 million held outside the trust.  Details of
the five collateral properties securing this loan are as
follows:

    * The Grand Wailea Resort Hotel and Spa is a 780-room, full-
      service luxury resort hotel on 37 acres in Maui, Hawaii.
      Amenities include six restaurants, 80,600 sq. ft. of meeting
      space, and a 50,000-sq.-ft. spa.  As of year-end 2010, the
      reported occupancy and ADR for the property were 74.9% and
      $377.57, respectively, yielding a RevPAR of $282.80,
      compared with a reported occupancy of 70.2% and ADR of
      $380.32 as of year-end 2009.

    * The La Quinta Resort & Club and PGA West is a 796-room,
      full-service luxury resort and golf community on 2,180
      acres, which includes nine 18-hole golf courses, several
      restaurants, a retail center, 47,850 sq. ft. of meeting
      space, and a 23,000-sq.-ft. spa in La Quinta, Calif.  As of
      year-end 2010, the reported occupancy and ADR for the
      property were 47.4% and $170.43, respectively, yielding a
      RevPAR of $80.79, compared with a reported occupancy
      of 49.8% and ADR of $165.93 as of year-end 2009.

    * The Arizona Biltmore Resort & Spa is a 739-room, full-
      service luxury conference resort destination on 30 acres in
      Phoenix, Ariz. Amenities include a 22,000-sq.-ft. spa and
      93,200 sq. ft. of conference space.  As of year-end 2010,
      the reported occupancy and ADR for the property were 67.1%
      and $168.06, respectively, yielding a RevPAR of $112.77,
      compared with a reported occupancy of 57.6% and ADR of
      $174.59 as of year-end 2009.

    * The Doral Golf Resort & Spa is a 693-room, full-service
      luxury hotel in Doral, Fla. Amenities include 15,000 sq. ft.
      of retail space, 67,350 sq. ft. of conference space, five
      18-hole golf courses, five restaurants, and 50,000 sq. ft.
      of fitness and spa facilities. As of year-end 2010, the
      reported occupancy and ADR for the property were 70.6% and
      $144.01, respectively, yielding a RevPAR of $101.67,
      compared with a reported occupancy of 56.1% and ADR of
      $155.31 as of year-end 2009.

    * The Claremont Resort & Spa is a 279-room, full-service
      luxury resort, with amenities that include 27,000 sq. ft. of
      meeting space, three restaurants, and a 20,000-sq.-ft. spa
      on 20 acres in Berkeley Hills, Calif.  As of year-end 2010,
      the reported occupancy and ADR for the property were 68.1%
      and $171.58, respectively, yielding a RevPAR of $116.85,
      compared with a reported occupancy of 61.3% and ADR of
      $167.50 as of year-end 2009.

Ratings Affirmed

COMM 2006-CNL2
Commercial mortgage-backed certificates

Class     Rating
A-1       AAA (sf)
A-2FX     A (sf)
A-2FL     A (sf)
A-JFX     BBB- (sf)
A-JFL     BBB- (sf)
BFX       BB (sf)
BFL       BB (sf)
CFX       BB- (sf)
CFL       BB- (sf)
D         B+ (sf)
E         B- (sf)
F         CCC+ (sf)
G         CCC (sf)
H         CCC- (sf)
J         CCC- (sf)
K         CCC- (sf)
X-1       A (sf)
X-2       A (sf)


* S&P Affirms Ratings on 28 Classes From 21 RMBS Transactions
-------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on 28
classes of certificates from 21 U.S. residential mortgage-backed
securities (RMBS) transactions issued between 2002 and 2008 and
removed them from CreditWatch negative.

"The affirmations reflect our assessment of actual reimbursements
of interest shortfalls on the affected classes during recent
remittance periods," S&P related.

"We had placed our ratings on these classes on CreditWatch with
negative implications because of our assessment that potential
interest shortfalls being reported by the trustee on the affected
classes would likely have a negative impact on them," S&P noted.

The collateral supporting the affected transactions consists of
prime jumbo, subprime, Alternative-A (Alt-A), and reperforming
combinations of fixed, hybrid, and adjustable-rate mortgage (ARM)
loans secured by first liens on one- to four-family residential
properties.

Ratings Actions

Alternative Loan Trust 2004-J11
Series 2004-J11
                                 Rating
Class      CUSIP         To                  From
3-A-1      12667FXN0     A+ (sf)             A+ (sf)/Watch Neg

Banc of America Funding 2005-H
Series 2005-H
                                 Rating
Class      CUSIP         To                  From
4-A1       05946XH97     BB (sf)             BB (sf)/Watch Neg

Bear Stearns ALT-A Trust 2003-3
Series 2003-3
                                 Rating
Class      CUSIP         To                  From
II-A       07386HCT6     AAA (sf)            AAA (sf)/Watch Neg

CHL Mortgage Pass-Through Trust 2003-56
Series 2003-56
                                 Rating
Class      CUSIP         To                  From
1-A-1      12669FAR4     AAA (sf)            AAA (sf)/Watch Neg

CHL Mortgage Pass-Through Trust 2005-HYB8
Series 2005-HYB8
                                 Rating
Class      CUSIP         To                  From
3-A-1      126694QG6     BBB+ (sf)           BBB+ (sf)/Watch Neg

Citigroup Mortgage Loan Trust Series 2005-CB8
Series 2005-CB8
                                 Rating
Class      CUSIP         To                  From
AF-5       12489WQG2     B (sf)              B (sf)/Watch Neg

Credit Suisse First Boston Mortgage Securities Corp.
Series 2003-17
                                 Rating
Class      CUSIP         To                  From
IV-A-1     22541QHV7     AAA (sf)            AAA (sf)/Watch Neg

CSFB Mortgage-Backed Trust Series 2005-6
Series 2005-6
                                 Rating
Class      CUSIP         To                  From
I-A-3      225458XH6     BBB+ (sf)           BBB+ (sf)/Watch Neg
I-A-4      225458XJ2     A (sf)              A (sf)/Watch Neg

GSMPS Mortgage Loan Trust 2005-RP3
Series 2005-RP3
                                 Rating
Class      CUSIP         To                  From
B2         362341LU1     A (sf)              A (sf)/Watch Neg

GSR Mortgage Loan Trust 2004-14
Series 2004-14
                                 Rating
Class      CUSIP         To                  From
5A1        36242DPM9     A- (sf)             A- (sf)/Watch Neg
5A2        36242DPN7     A- (sf)             A- (sf)/Watch Neg
2B1        36242DPT4     B- (sf)             B- (sf)/Watch Neg

GSR Mortgage Loan Trust 2005-AR2
Series 2005-AR2
                                 Rating
Class      CUSIP         To                  From
2B1        36242DJ61     B+ (sf)             B+ (sf)/Watch Neg

PHH Mortgage Trust, Series 2008-CIM1
Series 2008-CIM1
                                 Rating
Class      CUSIP         To                  From
I-2A-1     69337LAC6     AAA (sf)            AAA (sf)/Watch Neg
I-2A-2     69337LAD4     A (sf)              A (sf)/Watch Neg
I-B1       69337L9G9     B+ (sf)             B+ (sf)/Watch Neg

RALI Series 2002-QS17 Trust
Series 2002-QS17
                                 Rating
Class      CUSIP         To                  From
M-2        76110GZ95     AA- (sf)            AA- (sf)/Watch Neg

RBSGC Mortgage Loan Trust
Series 2005-RP1
                                 Rating
Class      CUSIP         To                  From
II-B-1     74927UAL2     AA (sf)             AA (sf)/Watch Neg
II-B-2     74927UAM0     A (sf)              A (sf)/Watch Neg
II-B-3     74927UAN8     BBB (sf)            BBB (sf)/Watch Neg

Residential Asset Securitization Trust 2002-A12
Series 2002-L
                                 Rating
Class      CUSIP         To                  From
B-2        45660NJB2     AAA (sf)            AAA (sf)/Watch Neg

RFMSI Series 2006-SA1 Trust
Series 2006-SA1
                                 Rating
Class      CUSIP         To                  From
I-A-1      76111XG72     B (sf)              B (sf)/Watch Neg

Structured Adjustable Rate Mortgage Loan Trust, Series 2005-1
Series 2005-1
                                 Rating
Class      CUSIP         To                  From
6-A        863579LG1     BB- (sf)            BB- (sf)/Watch Neg

Structured Asset Mortgage Investments II Trust 2007-AR7
Series 2007-AR7
                                 Rating
Class      CUSIP         To                  From
III-A-1    86364KAG9     B (sf)              B (sf)/Watch Neg

Structured Asset Mortgage Investments Trust 2003-AR2
Series 2003-AR2
                                 Rating
Class      CUSIP         To                  From
A-2        86358HTZ2     AAA (sf)            AAA (sf)/Watch Neg

Structured Asset Securities Corp.
Series 2005-RF2
                                 Rating
Class      CUSIP         To                  From
B1         86359DEZ6     AA (sf)             AA (sf)/Watch Neg

Structured Asset Securities Corp.
Series 2006-RF1
                                 Rating
Class      CUSIP         To                  From
B1         86359DXS1     BB+ (sf)            BB+ (sf)/Watch Neg


* S&P Lowers Ratings on 15 Classes to 'D'
-----------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 19
classes of commercial mortgage pass-through certificates from
three U.S. commercial mortgage-backed securities (CMBS)
transactions.

The downgrades reflect current and potential interest shortfalls.
"We lowered our ratings on 15 of these classes to 'D (sf)' because
we expect the interest shortfalls will continue.  Of the 15
classes that we downgraded to 'D (sf)', eight have had accumulated
interest shortfalls outstanding for seven or more months," S&P
related.  The recurring interest shortfalls for the certificates
are primarily due to one or more of the factors:

    * Appraisal subordinate entitlement reduction (ASER) 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 (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals.  "We
also considered servicer nonrecoverable advance declarations and
special servicing fees that are likely, in our view, to cause
recurring interest shortfalls," S&P noted.

The servicer implements ARAs and resulting ASER amounts according
to 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.  "We 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," S&P related.

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.

              ML-CFC Commercial Mortgage Trust 2006-2

"We lowered our ratings to 'D (sf)' on the class J, K, L, M, N,
and P certificates from ML-CFC Commercial Mortgage Trust 2006-2
due to interest shortfalls resulting from ASER amounts related to
12 ($74.6 million; 4.4% of the pooled trust balance) of the 18
loans ($236.3 million; 13.8%) that are currently with the special
servicer, CW Capital Asset Management LLC, as well as special
servicing fees, an interest rate modification on one loan
($13.3 million; 0.7%), and nonrecoverable determinations.  We
also downgraded the class H certificates to 'CCC- (sf)' because
the class has experienced interest shortfalls for two months and
due to the reduced liquidity available to the trust," S&P related.

As of the March 14, 2011 trustee remittance report, ARAs totaling
$36.6 million were in effect for 16 loans.  The total reported
ASER amount was $91,411, and the reported cumulative ASER amount
was $996,763. Standard & Poor's considered 12 ASER amounts, all of
which were based on MAI appraisals, as well as current special
servicing fees and an interest rate modification on one loan
($13.3 million; 0.7%) and nonrecoverable determinations, in
determining its rating actions.  "The reported monthly interest
shortfalls totaled $120,578 (including $50,329 total excess
allocated to the certificates) and affected all of the classes
subordinate to and including class H. Classes J, K, L, M, N, and
P have had accumulated interest shortfalls outstanding between
two and seven months, and we expect these shortfalls to remain
outstanding for the foreseeable future.  Consequently, we lowered
our ratings on these classes to 'D (sf)'," S&P stated.

             ML-CFC Commercial Mortgage Trust 2007-8

"We downgraded to 'D (sf)' the class H, J, K, and L
certificates from ML-CFC Commercial Mortgage Trust 2007-8 due
to interest shortfalls resulting from ASER amounts related to
17 ($196.4 million; 8.2% of the pooled trust balance) of the 24
loans ($777.8 million; 32.5%) that are currently with the special
servicer, LNR Partners LLC, as well as special servicing fees.
We downgraded class G to 'CCC (sf)' due to reduced liquidity
available to the trust resulting from the recurring interest
shortfalls," S&P noted.

As of the March 14, 2011 trustee remittance report, ARAs totaling
$94.0 million were in effect for 19 loans.  The total reported
ASER amount was $400,795, and the reported cumulative ASER amount
was $4.49 million. Standard & Poor's considered 17 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 $636,721
(including a $38,188 recovered ASER amount) and affected all of
the classes subordinate to and including class H. Classes H, J, K,
and L have had accumulated interest shortfalls outstanding between
two and 10 months, and we expect these shortfalls to remain
outstanding for the foreseeable future.  Consequently, we
lowered our ratings on these classes to 'D (sf)'," S&P related.

           Morgan Stanley Capital I Trust 2005-IQ9

"We lowered our ratings to 'D (sf)' on the class K, L, M, N,
and O certificates from Morgan Stanley Capital I Trust 2005-IQ9
principally due to accumulated interest shortfalls that we
expect to remain outstanding for the foreseeable future.  The
accumulated interest shortfalls outstanding primarily resulted
from the liquidation of one asset, the Mariemont Promenade loan
($3.9 million; 0.3%), that reported a loss severity of
approximately 120% and caused interest shortfalls to affect
all classes up to class B as reflected in the February remittance
report.  The lowered ratings also reflect interest shortfalls
resulting from ASER amounts related to two ($5.1 million; 0.4%)
of the 11 loans ($40.5 million; 3.1%) that are currently with the
special servicer, Midland Loan Services Inc., as well as special
servicing fees and an interest rate modification on one loan
($10.1 million; 0.8%).  We also downgraded the class H and J
certificates to 'CCC+ (sf)' and 'CCC (sf)', because each of these
classes experienced interest shortfalls for two months and due to
the reduced liquidity available to the trust," S&P noted.

As of the March 15, 2011, trustee remittance report, ARAs
totaling $7.1 million were in effect for four loans.  The total
reported ASER amount was $10,737, and the reported cumulative
ASER amount was $273,452.  In addition to considering accumulated
interest shortfalls attributed to the liquidation of one asset
($3.9 million; 0.3%), Standard & Poor's considered two ASER
amounts, both of which were based on MAI appraisals, as well as
current special servicing fees and an interest rate modification
on one loan ($10.1 million; 0.8%), in determining its rating
actions.  The reported monthly interest shortfalls totaled
$39,465.  These shortfalls in combination with the interest
losses related to the liquidation of one asset ($3.9 million;
0.3%) affected all of the classes subordinate to and including
class F. Classes F, G, H, J, K, L, and M have had accumulated
interest shortfalls outstanding for two months.  In addition,
classes N and P have had accumulated interest shortfalls
outstanding for three and 13 months.  "We expect the accumulated
interest shortfalls outstanding for the class K certificates and
all certificates subordinate to it to remain outstanding for the
foreseeable future.  Consequently, we lowered our ratings on these
classes to 'D (sf)'," S&P added.

Ratings Lowered

ML-CFC Commercial Mortgage Trust 2007-8
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement    Interest Shortfalls ($)
Class  To        From           (%)     Current  Accumulated
G      CCC (sf)  B+ (sf)      6.09           0            0
H      D (sf)    B (sf)       4.69     118,832      214,555
J      D (sf)    CCC+ (sf)    3.68     121,050      323,528
K      D (sf)    CCC- (sf)    3.04      75,655      654,377
L      D (sf)    CCC- (sf)    2.40      65,564      629,523

ML-CFC Commercial Mortgage Trust 2006-2
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement   Interest Shortfalls ($)
Class  To        From          (%)    Current  Accumulated
H      CCC- (sf) CCC+ (sf)    2.29     26,547      132,343
J      D (sf)    CCC (sf)     1.75     43,119      129,358
K      D (sf)    CCC- (sf)    1.48     21,562       64,686
L      D (sf)    CCC- (sf)    1.08     32,338      189,903
M      D (sf)    CCC- (sf)    0.94     10,781       75,467
N      D (sf)    CCC- (sf)    0.67     21,562      150,934
P      D (sf)    CCC- (sf)    0.40     21,557      150,902

Morgan Stanley Capital I Trust 2005-IQ9
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement   Interest Shortfalls ($)
Class  To        From          (%)    Current  Accumulated
H      CCC+ (sf) BB- (sf)     2.83     82,394      165,163
J      CCC (sf)  B+ (sf)      2.39     22,067       44,218
K      D (sf)    B (sf)       1.81     29,423       58,960
L      D (sf)    B- (sf)      1.36     22,067       44,218
M      D (sf)    B- (sf)      0.92     22,067       44,218
N      D (sf)    CCC+ (sf)    0.63     14,714       43,009
O      D (sf)    CCC (sf)     0.19     22,067      214,040


* S&P Lowers Ratings on 18 Classes From 6 CMBS Transactions to 'D'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 22
classes of commercial mortgage pass-through certificates from six
U.S. commercial mortgage-backed securities (CMBS) transactions due
to interest shortfalls.

"The downgrades reflect current and potential interest shortfalls.
We lowered our ratings on 18 of these classes to 'D (sf)' because
we expect the interest shortfalls will continue.  Each of the 18
classes that we downgraded to 'D (sf)' have had accumulated
interest shortfalls outstanding for five or more months," S&P
related.  The recurring interest shortfalls for the certificates
are primarily due to one or more of the factors:

    * Appraisal subordinate entitlement reduction (ASER) 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 (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals.  "We
also considered servicer nonrecoverable advance declarations and
special servicing fees that are likely, in our view, to cause
recurring interest shortfalls," S&P related.

The servicer implements ARAs and resulting ASER amounts according
to 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.  "We 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," S&P noted.

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 22 downgraded classes from the six CMBS
transactions.

               Banc of America Commercial Mortgage
                      Inc.'s series 2005-1

"We lowered our ratings to 'D (sf)' on the class H certificates
from Banc of America Commercial Mortgage Inc.'s series 2005-1.
The lowered ratings on this class reflect accumulated interest
shortfalls resulting from ASER amounts related to five
($102.4 million, 6.7%) of the eight assets ($113.0 million,
7.4%) that are currently with the special servicer, J.E. Robert
Co. Inc., as well as special servicing fees, and shortfalls due
to interest rate modifications.  We also lowered our ratings on
the class G certificates to 'B (sf)' due to reduced liquidity
support available to the class," S&P related.

As of the March 10, 2011 trustee remittance report, ARAs totaling
$49.1 million were in effect for seven loans.  The total reported
ASER amount was $174,712, and the reported cumulative ASER amount
was $975,554.  Standard & Poor's considered all five ASER amounts,
each of which were based on MAI appraisals, as well as current
special servicing fees, and interest rate reduction shortfalls
from the modification of two loans, in determining its rating
actions.  The reported monthly interest shortfalls totaled
$261,101, and accumulated interest shortfalls have affected all of
the classes subordinate to and including class H.  "Class H has
had accumulated interest shortfalls outstanding for 12 months, and
we expect these shortfalls to remain outstanding for the
foreseeable future," S&P noted.

                   Bear Stearns Commercial Mortgage
                    Securities Trust 2004-TOP16

"We lowered our ratings to 'D (sf)' on the class N and O
certificates from Bear Stearns Commercial Mortgage Securities
Trust 2004-TOP16.  The lowered ratings on these classes reflect
accumulated interest shortfalls resulting from ASER amounts
related to two ($22.6 million, 2.5% of the pooled trust balance)
of the 3 loans ($26.0 million, 2.8%) that are currently with the
special servicer, C-III Asset Management LLC (C-III), as well as
special servicing fees," S&P continued.

As of the March 14, 2011 trustee remittance report, ARAs totaling
$3.08 million were in effect for two loans.  The total reported
ASER amount was $13,654 and the reported cumulative ASER amount
was $ 120,418.  Standard & Poor's considered both ASER amounts,
each 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 $18,726, and have
affected all of the classes subordinate to and including class N.
Classes N and O have had accumulated interest shortfalls
outstanding for the past 12 months, and S&P expects these
shortfalls to remain outstanding for the foreseeable future.

                  JPMorgan Chase Commercial Mortgage
                   Securities Trust 2007-CIBC18

"We lowered our ratings to 'D (sf)' on the class G, H, J, K, L, M,
and N certificates from JPMorgan Chase Commercial Mortgage
Securities Trust 2007-CIBC18.  The lowered ratings on these
classes primarily reflect interest shortfalls resulting from
ASER amounts related to 12 ($197.3 million, 5.3%) of the 23
($324.7 million, 8.7%) assets that are currently with the
special servicer, C-III, as well as special servicing fees,
and nonrecoverable advance determinations.  We also lowered
our ratings to 'CCC- (sf)' on the class F certificates due to
reduced liquidity support available to the class," S&P stated.

As of the March 14, 2011 trustee remittance report, ARAs totaling
$86.6 million were in effect for 21 loans.  The total reported
ASER amount was $273,085, and the reported cumulative ASER amount
was $3.9 million. Standard & Poor's considered all 12 ASER
amounts, all of which were based on MAI appraisals, as well as
current special servicing fees, and nonrecoverable advance
determinations ($276,240) on seven loans, in determining its
rating actions.  The reported monthly interest shortfalls totaled
$666,299, and accumulated interest shortfalls have affected all of
the classes subordinate to and including class F.  "Classes G, H,
J, K, L, M, and N have had accumulated interest shortfalls
outstanding between five and 13 months, which we expect to
remain outstanding for the foreseeable future," according to S&P.

                  JPMorgan Chase Commercial Mortgage
                    Securities Trust 2007-LDP12

"We lowered our ratings to 'D (sf)' on the class L, M, N, P, Q,
and T certificates from JPMorgan Chase Commercial Mortgage
Securities Trust 2007-LDP12.  The lowered ratings on these classes
primarily reflect interest shortfalls resulting from ASER amounts
related to five ($75.3 million, 3.0% of the pooled trust balance)
of the 21 loans ($333.2 million, 13.4%) that are currently with
the special servicer, C-III, as well as special servicing fees
and interest not advanced.  We also lowered our ratings to 'CCC-
(sf)' on class K due to reduced liquidity support available to
these classes.  As of the March 15, 2011 trustee remittance
report, ARAs totaling $47.2 million were in effect for seven
loans.  The total reported ASER amount was $191,606, and the
reported cumulative ASER amount was $2.59 million.  Standard
& Poor's considered all five ASER amounts, each of which were
based on an MAI appraisal, as well as current special servicing
fees and interest not advanced ($45,399), and shortfalls ($52,987)
due to rate modifications, in determining its rating actions.  The
reported monthly interest shortfalls totaled $352,522 and have
affected all of the classes subordinate to and including class K.
Classes L, M, N, P, Q, and T have had accumulated interest
shortfalls outstanding for five months or more, and we expect
these shortfalls to remain outstanding for the foreseeable
future," S&P elaborated.

            Morgan Stanley Capital I Trust 2005-TOP17

"We lowered our ratings to 'D (sf)' on the class O certificates
from Morgan Stanley Capital I Trust 2005-TOP17.  The lowered
rating on this class reflects accumulated interest shortfalls
resulting from ASER amounts related to three ($11.1 million, 1.3%
of the pooled trust balance) of the five loans that are currently
with the special servicer, C-III, as well as special servicing
fees," S&P stated.

As of the March 14, 2011 trustee remittance report, ARAs totaling
$5.1 million were in effect for three loans.  The total reported
ASER amount was $21,586, and the reported cumulative ASER amount
was $430,454.  Standard & Poor's considered all three ASER
amounts, each 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 $35,909 and
affected all of the classes subordinate to and including class N.
Class O has had accumulated interest shortfalls outstanding for
ten months and S&P expects these shortfalls to remain outstanding
for the foreseeable future.

               Wachovia Bank Commercial Mortgage
                    Trust's series 2006-C28

"We lowered our ratings to 'D (sf)' on the class H certificates
from Wachovia Bank Commercial Mortgage Trust's series 2006-C28.
The lowered rating on this class reflects interest shortfalls
resulting from ASER amounts related to 21 ($398.1 million, 11.3%)
of the 27 ($617.2 million, 17.5%) loans that are currently with
the special servicer, CWCapital Asset Management, as well as
special servicing fees, and interest shortfalls due to a rate
modification.  We also lowered our ratings on the class G
certificates to 'CCC+ (sf)' due to reduced liquidity support
available to the class," S&P noted.

As of the March 17, 2011, trustee remittance report, ARAs totaling
$175.7 million were in effect for 23 loans.  The total reported
ASER amount was $753,810, and the reported cumulative ASER amount
was $10.5 million.  Standard & Poor's considered all 21 ASER
amounts, each of which were based on MAI appraisals, as well as
current special servicing fees, and interest shortfalls ($59,121)
due to a rate modification on one loan, in determining its rating
actions.  "The reported monthly interest shortfalls totaled
$852,905, and accumulated interest shortfalls have affected all of
the classes subordinate to and including class H. Class H has had
accumulated interest shortfalls outstanding for the past 11
months, which we expect to remain outstanding for the foreseeable
future," S&P stated.

Ratings Lowered

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2005-1
                             Credit         Reported
          Rating        enhancement   interest shortfalls ($)
Class  To        From          (%)    Current  Accumulated
G      B (sf)    BB- (sf)     4.33          0           0
H      D (sf)    CCC- (sf)    2.04    131,333     431,777

Bear Stearns Commercial Mortgage Securities Trust 2004-TOP16
Commercial mortgage pass-through certificates ser 2004-TOP16
                             Credit         Reported
          Rating        enhancement    interest shortfalls ($)
Class  To        From          (%)    Current  Accumulated
N      D (sf)    CCC- (sf)    0.75      5,410      66,278
O      D (sf)    CCC- (sf)    0.45     10,821     132,555

JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC18
Commercial mortgage pass-through certificates ser 2007-CIBC18
                              Credit           Reported
          Rating         enhancement     interest shortfalls ($)
Class  To         From          (%)     Current  Accumulated
F     CCC- (sf)   B (sf)       3.80     13,617       13,617
G     D (sf)      B- (sf)      2.63    209,516      257,195
H     D (sf)      CCC+ (sf)    1.45    209,512    1,573,394
J     D (sf)      CCC (sf)     1.19     42,037      378,336
K     D (sf)      CCC- (sf)    0.80     63,050      567,446
L     D (sf)      CCC- (sf)    0.41     63,054      572,756
M     D (sf)      CCC- (sf)    0.15     42,033      546,430
N     D (sf)      CCC- (sf)    0.01     21,017      273,215

JPMorgan Chase Commercial Mortgage Securities Trust 2007-LDP12
Commercial mortgage pass-through certificates ser 2007-LDP12
                            Credit          Reported
          Rating       enhancement    interest shortfalls ($)
Class  To        From          (%)    Current  Accumulated

K      CCC- (sf) CCC (sf)    3.02     32,791      105,402
L      D (sf)    CCC (sf)    2.64     40,112      156,937
M      D (sf)    CCC (sf)    2.26     40,116      383,980
N      D (sf)    CCC (sf)    2.01     26,740      294,137
P      D (sf)    CCC- (sf)   1.76     26,744      298,389
Q      D (sf)    CCC- (sf)   1.50     26,744      320,928
T      D (sf)    CCC- (sf)   1.38     13,372      160,464

Morgan Stanley Capital I Trust 2005-TOP17
Commercial mortgage pass-through certificates
                            Credit          Reported
          Rating       enhancement     interest shortfalls ($)
Class  To        From          (%)     Current  Accumulated
O      D (sf)    CCC- (sf)   0.76       9,510       62,727


Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C28
                            Credit          Reported
           Rating      enhancement      interest shortfalls ($)
Class  To         From         (%)      Current   Accumulated
G      CCC+ (sf)  B- (sf)    5.62             0            0
H      D (sf)     CCC-(sf)   4.47       135,862      448,311


* S&P Lowers Ratings on 191 Classes From 50 RMBS Transactions
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 191
classes from 50 U.S. residential mortgage-backed securities (RMBS)
transactions backed by prime jumbo mortgage loans issued in 2003-
2004.  "In addition, we affirmed our ratings on 402 classes from
49 of the downgraded transactions.  We also withdrew our ratings
on four interest-only classes and five additional classes from six
transactions," S&P related.

"In our review of these transactions, we applied the assumptions
we discussed in 'Methodology And Assumptions For U.S. RMBS Issued
Before 2005,' published on March 12, 2009, on RatingsDirect," S&P
said.

"The downgrades reflect our opinion that projected credit support
for the affected classes is insufficient to maintain the previous
ratings, given our current projected losses, due to increased
delinquencies," S&P explained.

"The rating affirmations reflect our belief that the amount of
credit enhancement available for these classes is sufficient to
cover losses associated with these rating levels," S&P related.

"We withdrew our ratings on four interest-only classes based on
our current criteria.  We withdrew our ratings on an additional
five classes because they have received their full amount of
scheduled principal and currently have a zero balance," S&P noted.

S&P continued, "To assess the creditworthiness of each class, we
review the respective transaction's ability to withstand
additional credit deterioration and the effect that projected
losses will have on each class.  In order to maintain a 'B' rating
on a class, we assess whether the class can withstand the
additional base-case loss assumptions we use in our analysis.  To
maintain an 'AAA' rating, we assess whether the class can
withstand approximately 235% of our additional base-case loss
assumptions, subject to individual caps and qualitative factors
applied to specific transactions.  To maintain a rating in
categories between 'B' (the base case) and 'AAA', we assess
whether the class can withstand losses exceeding the additional
base-case assumption at a percentage specific to each rating
category, up to 235% for a 'AAA' rating.  For example, we would
assess whether one class could withstand approximately 130% of our
base-case loss assumptions to maintain a 'BB' rating, while we
would assess whether a different class could withstand
approximately 155% of our base-case loss assumptions to maintain a
'BBB' rating."

Subordination provides credit support for the effected
transactions.  The underlying collateral for these deals consists
of fixed- and adjustable-rate U.S. prime jumbo mortgage loans
secured by first liens on one- to four-family residential
properties.

A complete list of the rating actions published on April 11, 2011
is available for free at:

     http://bankrupt.com/misc/S&P_0411RatingActions.pdf


* S&P Withdraws Ratings on 52 Classes on CMBS & CDO Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 52
classes from 43 commercial mortgage-backed securities (CMBS), and
commercial real estate collateralized debt obligation (CRE CDO)
transactions.

"We withdrew our ratings on 45 classes from 37 CMBS and CRE CDO
transactions following the repayment of each class's principal
balance as noted in each transaction's February and March 2011
remittance reports.  We withdrew our ratings on six interest-only
(IO) classes from six transactions following the reductions of the
classes' notional balances as noted in the transactions' March
2011 remittance reports," S&P related.

"We also withdrew our rating on one additional IO class following
the repayment of all principal and interest paying classes rated
'AA- (sf)' or higher from the CMBS transaction, in accordance with
our criteria for rating IO securities," S&P added.

Ratings Withdrawn Following Repayment or Reduction of Notional
Balance

Asset Securitization Corp.
Comm mtg pass-thru certs ser 1997-D5
                                 Rating
Class                    To                  From
A-1D                     NR                  AAA (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2000-2
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)
E                        NR                  AAA (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2004-1
                                 Rating
Class                    To                  From
XP                       NR                  AAA (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2004-5
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Banc of America Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2007-2
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Banc of America Commercial Mortgage Trust 2007-3
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Banc of America Commercial Mortgage Trust 2007-5
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2000-WF2
                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)

Brascan Structured Notes 2005-2, Ltd.
Collateralized debt obligations series 2005-2
                                 Rating
Class                    To                  From
B                        NR                  BBB+ (sf)

CD 2007-CD5 Mortgage Trust
Commercial mortgage pass-through certificates series 2007-CD5
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2000-3
                                 Rating
Class                    To                  From
F                        NR                  BBB+ (sf)

COMM 2004-LNB2
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
X-2                      NR                  AAA (sf)

COMM 2006-FL12
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
CM1                      NR                  BB- (sf)
CM2                      NR                  CCC- (sf)

Commercial Mortgage Acceptance Corp.
Comm mtg pass-thru certs ser 1998-C-2
                                 Rating
Class                    To                  From
E                        NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CF2
                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-CKS4
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates, series 2004-C1
                                 Rating
Class                    To                  From
A-SP                     NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2006-TFL2
                                 Rating
Class                    To                  From
ARG-A                    NR                  CCC- (sf)
ARG-B                    NR                  CCC- (sf)

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 1999-C4
                                 Rating
Class                    To                  From
E                        NR                  AAA (sf)
F                        NR                  AA (sf)

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2001-C2
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)
E                        NR                  AAA (sf)
F                        NR                  AAA (sf)
G                        NR                  AA+ (sf)

GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates, series 2001-3
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

GE Commercial Mortgage Corporation, Series 2006-C1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

GMAC Commercial Mortgage Securities, Inc.
Mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)

GS Mortgage Securities Corp. II
Commercial mortgage pass-through certificates, series 2006-GSFL
VIII
                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates, series 2006-FL1
                                 Rating
Class                    To                  From
HM-1                     NR                  BB+ (sf)

LB-UBS Commercial Mortgage Trust 2004-C2
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
X-CP                     NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2004-C8
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)
A-3                      NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2006-C4
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2004-HQ4
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-4                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2006-HQ8
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2007-IQ14
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Morgan Stanley Dean Witter Capital I Trust 2000-LIFE1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
E                        NR                  BBB- (sf)

Morgan Stanley Dean Witter Capital I Trust 2001-PPM
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
B                        NR                  AA+ (sf)

Multi Security Asset Trust LP
Commercial mortgage-backed securities pass-through certificates
series
2005-RR4
                                 Rating
Class                    To                  From
X-2                      NR                  AAA (sf)

Prudential Commercial Mortgage Trust 2003-PWR1
Commercial mortgage pass-through certificates series
                                 Rating
Class                    To                  From
X-2                      NR                  AAA (sf)

Salomon Brothers Commercial Mortgage Trust 2001-C1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

Solar Trust
Commercial mortgage pass-through certificates series 2001-1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

STRIPs III LTD
CDO Ltd series 2003-1
                                 Rating
Class                    To                  From
J                        NR                  BBB (sf)

TrizecHahn Office Properties Trust
Commercial mortgage pass-through certificates series 2001-TZH
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C24
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2007-C30
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust 2007-C31
Commercial mortgage pass-through certificates series
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2007-C32
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

RATINGS WITHDRAWN FOLLOWING APPLICATION OF CRITERIA FOR IO
SECURITIES

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 1999-C4
                                 Rating
Class                    To                  From
IO                       NR                  AAA (sf)



GALAXY VI: S&P D            BBB (sf)   BB+ (sf)

                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers"
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR.  Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors" Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Howard C. Tolentino, Joseph Medel C. Martirez, Denise
Marie Varquez, Philline Reluya, Ronald C. Sy, Joel Anthony G.
Lopez, Cecil R. Villacampa, Sheryl Joy P. Olano, Carlo Fernandez,
Christopher G. Patalinghug, and Peter A. Chapman, Editors.

Copyright 2011.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $775 for 6 months delivered via e-
mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Christopher
Beard at 240/629-3300.


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