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         T R O U B L E D   C O M P A N Y   R E P O R T E R

            Sunday, September 4, 2011, Vol. 15, No. 245

                            Headlines

ACAS BUSINESS: Fitch Ups Rating on $90MM Cl. D Notes to 'Bsf'
ACAS BUSINESS: Fitch Affirms Junk Rating on $50 Mil. Class D Notes
ACAS BUSINESS: Fitch Affirms Rating on Four Note Classes
ACAS BUSINESS: Good Notes Performance Cues Fitch to Hold Ratings
ACAS BUSINES: Stable Performance Cues Fitch to Affirm Ratings

ACAS CLO: Fitch Affirms 'Bsf' Rating on $15.5 Mil. Class D Notes
ALTIUS III: S&P Lowers Rating on Class A-1b-1F Notes to 'CC'
AMMC VIII: Moody's Upgrades Ratings of Six Classes of CLO Notes
APIDOS CDO: Moody's Upgrades Ratings of Five Classes of CLO Notes
ARES VII: Fitch Lowers Rating on $26 Mil. Class C Notes to 'D'

BANC OF AMERICA: Fitch Affirms Junk Rating on Two Class Certs.
BANC OF AMERICA: S&P Lowers Rating on Class K Certificates to 'D'
BEAR STEARNS: Fitch Affirms Junk Rating on Five Cert. Classes
BEAR STEARNS: Increased Paydown Cues Fitch to Upgrade Ratings
BEAR STEARNS: Losses Across the Pool Cues Fitch to Lower Ratings

BECKMAN COULTER: Fitch Holds 'BB-' Rating on $97 Mil. Class Notes
BLACKROCK SENIOR: Moody's Raises Rating of Class D-1 Notes to Ba2
BUSINESS LOAN: Fitch Junks Rating on Two Class Certificates
CALLIDUS DEBT: Moody's Raises Ratings of Six Classes of Notes
CAPELLA FUNDING: S&P Removes Class 1 Notes 'BB' Rating From Watch

CAPITALSOURCE REAL: Fitch Affirms Junk Rating on 7 Note Classes
CD 2006-CD3: Moody's Affirms Ratings of 20 CMBS Classes
CITIGROUP COMM: Fitch Affirm 'CCCsf' Rating on 5 Note Classes
CLASS V FUNDING: Moody's upgrades Ratings of One Class of Notes
COMM 2001-J2: Moody's Reviews Ratings of Four CMBS Classes

COMM 2007-FL14: Moody's Downgrades Ratings of 10 CMBS Classes
COMMERCIAL MORTGAGE: S&P Lowers Rating on Class H Certs. to 'D'
CONCORD REAL: Fitch Affirms Junk Rating on Three Classes of Notes
CONNECTICUT VALLEY: Moody's Upgrades Ratings of 5 Classes of Notes
CREDIT SUISSE: Fitch Affirms Rating on Five Certificate Classes

CREDIT SUISSE: Fitch Holds 'Dsf' Rating on $15 Mil. Class J Cert.
CRIIMI MAE: Fitch Affirms Rating on $4 Million Notes at 'Dsf'
CSFB 2001-CP4: Modeled Losses Cue Fitch to Downgrade Ratings
CWMBS REPERFORMING: Moody's Lowers Ratings of $728.1-Mil. RMBS
DEUSTCHE BANK: Fitch Expects to Rate 20 Class Notes

FAIRWAY LOAN: Moody's Upgrades Ratings of Six Classes of CLO Notes
FANNIE MAE: Moody's Lowers Rating of $70-Mil. Non-guaranteed RMBS
FICT UNION: Expected Losses Prompts Fitch to Downgrade Ratings
FMC REAL: S&P Lowers Rating on Class F From 'B-' to 'CCC+'
FTA SANTANDER: DBRS Assigns Series C Bond Rating at 'C'

GCO ELF: Fitch Lowers Rating on Four Class Notes to 'Bsf'
GE CAPITAL: Expected Losses Cue Fitch to Downgrade Ratings
GE COMMERCIAL: Stable Performance Cues Fitch to Affirm Ratings
GENERAL ELECTRIC: Fitch Affirm Rating on $1.8 Mil. Notes at 'Dsf'
GMAC 2004-C1: Fitch Affirm Junk Ratings on Four Note Classes

GMAC COMMERCIAL: Fitch Affirms Rating on $3.3 Mil. Notes at 'D'
GOLDEN TREE: Moody's Upgrades Ratings of 5 Classes of CLO Notes
GREENWICH CAPITAL: Fitch Affirms Junk Rating on Three Note Classes
GREENWHICH CAPITAL: Fitch Holds Junk Rating on 5 Classes of Notes
GS MORTGAGE: DBRS Confirms Class E Rating at 'BB'

GS MORTGAGE: Fitch Affirms Rating on $4 Mil. Notes at 'CCCsf/RR1'
GSMSC II: Fitch Junks Rating on Four Note Classes
GUGGENHEIM 2006-3: Fitch Affirms Junk Rating on 3 Class Notes
GUGGENHEIM 2006-4: Fitch Affirms Junk Rating on Six Class Notes
HELLER SBA: Growing Credit Prompts Fitch to Affirm Low-B Ratings

HEWETT'S ISLAND: Moody's Raises Ratings of 6 Classes of CLO Notes
JP MORGAN: Fitch Affirms Junk Rating on Eight Note Classes
JP MORGAN: Fitch Affirms Junk Rating at Six Certificate Classes
JP MORGAN: Fitch Affirms Low-B Ratings on Three Class Certificates
JP MORGAN: Fitch Junks Rating on Two Class Certificates

JP MORGAN: Moody's Affirms Ratings of 12 CMBS Classes
JP MORGAN: Losses Across the Pool Cues Fitch to Lower Ratings
JP MORGAN: Stable Performance Prompts Fitch to Affirm Ratings
KATONAH IX: Moody's Upgrades Ratings of Notes Due 2019
KINGSLAND III: Moody's Upgrades Ratings of 7 Classes of CLO Notes

LATITUDE CLO: Moody's Upgrades Ratings of Four Classes Of Notes
LATITUDE CLO: Moody's Upgrades Ratings of Siz Classes of Notes
LB-UBS COMMERCIAL: Expected Losses Cue Fitch to Downgrade Ratings
LBUBS COMMERCIAL: Expected Losses Prompt Fitch to Lower Ratings
LCM V: Moody's Upgrades Ratings of Four Classes of CLO Notes

LEHMAN BROTHERS: Stable Loss Expectations Cue Fitch to Hold Rating
LNR CDO: Fitch Withdraws 'Dsf' Rating on 10 Note Classes
MARATHON REAL: Fitch Affirms Junk Rating on Four Note Classes
MASTR REPERFORMING: Moody's Lowers Rating of $415-Mil. RMBS
MAXIM HIGH: Fitch Withdraws 'Dsf' Rating on 10 Note Classes

MERRILL LYNCH: Fitch Affirms 'Dsf' Rating on $45.2MM Certificates
MONTANA HIGHER: Fitch Affirms 'B' Rating on Seven Note Classes
MORGAN STANLEY: Fitch Affirms Rating on Two Notes at 'Dsf'
MORGAN STANLEY: Fitch Revises Rating on 16 Notes to 'Dsf'
MORGAN STANLEY: Moody's Affirms Ratings of 19 CMBS Classes

MORGAN STANLEY: Pay Downs Cues Fitch to Hold Ratings at 'Csf'
MOUNTAIN CAPITAL: Moody's Raises Ratings of 6 Classes of CLO Notes
N-STAR REL: Fitch Affirms Junk Rating on Nine Note Classes
N-STAR REL: Fitch Affirms Junk Rating on Six Note Classes
NAAC REPERFORMING: Moody's Lowers Rating of $93.8-Mil. RMBS

NATIONAL COLLEGIATE: S&P Cuts Ratings on 2 Classes of Notes to 'D'
NORTHWESTERN INVESTMENTS: Fitch Hold Junk Rating on Notes Classes
PETRA CRE: Fitch Affirms Junk Rating on Seven Note Classes
RAIT CRE: Fitch Affirms Junk Rating on Eight Note Classes
RAMPART CLO: Moody's Upgrades Ratings of Four Classes of Notes

RESOURCE REAL: Fitch Affirms Junk Rating on Nine Note Classes
RESOURCE REAL: Fitch Affirms Junk Rating on Six Note Classes
RFC CDO: Fitch Affirms Junk Rating on All Notes Classes
SALOMON BROTHER: Fitch Holds Rating on $21.5MM Cl. H Notes at Csf
SIERRA TIMESHARE: Fitch To Rate $23.8 Million Notes at 'BBsf'

SILVER MARLIN: Fitch Withdraws 'D' Rating on Nine Note Classes
SILVERADO CLO: Moody's Upgrades Ratings of CLO Notes
SIMSBURY CLO: Fitch Lifts Junk Rating on $1 Mil. Notes to 'BBsf'
SLM STUDENT: Fitch Affirms 'BBsf' Rating on Class B Note
SOLSTICE ABS: Fitch Affirms Junk Rating on Four Note Classes

TRADEWINDS II: S&P Lowers Rating on Class A Notes to 'D'
US CMBS: Fitch Lowers Ratings on 21 Bonds to 'D'
US RMBS: Fitch Downgrades 856 Bonds in 53 Transactions to 'Dsf'
WACHOVIA 2003-C3: Stable Performance Cues Fitch to Affirm Ratings
WACHOVIA BANK: Moody's Affirms Ratings of 23 CMBS Classes

WACHOVIA BANK: Moody's Affirms Ratings of 27 CMBS Classes of Notes
WAMU MORTGAGE: Moody's Lowers Rating of $129.5-Mil. of FHA-VA RMBS
WASHINGTON MUTUAL: Modeled Losses Cue Fitch to Downgrade Ratings
WB 2005-WHALE: Fitch Affirms Junk Rating on $10.8MM Class L Cert.
WESTWOOD CDO: Moody's Upgrades Ratings of 6 Classes of CLO Notes

WFDB COMMERCIAL: Fitch Puts Low-B Rating on Four Note Classes
WFRBS COMMERCIAL: Fitch Puts Low-B Rating on Two Class Certs.

* S&P Lowers Ratings on 117 Classes from 26 RMBS Transactions
* S&P Puts Ratings on 59 Classes from 37 RMBS Deals on Watch Neg



                            *********



ACAS BUSINESS: Fitch Ups Rating on $90MM Cl. D Notes to 'Bsf'
-------------------------------------------------------------
Fitch Ratings has upgraded two classes and affirmed three classes
of notes issued by ACAS Business Loan Trust 2005-1 (ACAS BLT 2005-
1):

   -- $63,285,411 class A-1 notes affirmed at 'AAAsf'; Outlook
      revised to Stable from Negative;

   -- $29,096,741 class A-2B notes affirmed at 'AAAsf'; Outlook
      revised to Stable from Negative;

   -- $50,000,000 class B notes upgraded to 'AAsf' from 'Asf';
      Outlook revised to Stable from Negative;

   -- $145,000,000 class C notes affirmed at 'BBsf'; Outlook
      revised to Stable from Negative;

   -- $90,000,000 class D notes upgraded to 'Bsf' from
      'CCCsf/RR4'; Outlook Stable.

The upgrades of the class B and class D notes are the result of
the increased credit enhancement levels and the improved
performance of the notes since Fitch's last review in August 2010.

As of the July 2011 payment date, the class A-2A notes were paid
in full and approximately 85.5% and 41.8% of the class A-1 and
class A-2B notes, respectfully, were paid down.  The amortization
of the class A notes was largely driven by loan prepayments and
excess spread used to pay the Additional Principal Amount (APA).

Excess spread plays a significant role in the transaction, as the
class B and class D notes are likely to perform under higher
rating stresses.  However, the underlying loan portfolio has
become more concentrated in low-rated second lien and subordinated
loans.  The current portfolio contains 28 performing obligors,
represented by 74.6% of second lien or subordinated loans, which
have low recovery prospects upon default.  The rating actions
reflect these concentration risks, which are expected to increase
over the longer term, and may limit the benefit of excess spread,
and subsequently, introduce more volatility to the notes'
performance.  The revised Outlooks indicate the notes' stable
performance under their current rating stresses and Fitch's
expectation that the ratings of the notes will remain stable for
the near term.  The Recovery Rating was also removed and a Stable
Outlook was assigned to the class D notes, as a result of the
upgrade.

Similarly, the affirmation and revised Outlook of the class C
notes is based on the improving performance of the notes, amid the
growing concentration risks of the portfolio.  As with the other
notes, the class C notes are likely to perform under modeled
stresses above their current rating category.  However, the
concentration risks and portfolio quality supporting these notes
is in line with a 'BBsf' rating.  Therefore, Fitch has affirmed
the class C notes at its current rating and revised the Outlook to
Stable.

The notes of ACAS BLT 2005-1 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the additional principal amount
(APA).  Upon the occurrence of a default, the APA feature directs
part or all of the excess interest otherwise available to the
equity to pay down the senior-most notes in an amount equal to
the aggregate balance of defaulted assets in the portfolio.
Since Fitch's last rating action the servicer has considered
an additional $51.5 million of loans as defaulted, while
approximately $138.8 million of excess spread has been used to
pay principal to the class A notes.  The APA stands at
approximately $23.3 million after the July 2011 payment, compared
to $110.6 million in July 2010.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs.  As mentioned above, all classes of notes, with the
exception of the class A notes, passed in various stress scenarios
in rating categories above their current ratings.  However,
Fitch's rating actions deviated from these modeling results due to
the concentration risks stated above.

ACAS BLT 2005-1 is a collateralized debt obligation (CDO) that
closed on Oct. 4, 2005 and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in January 2009.  ACAS BLT 2005-1 is secured by a
portfolio of middle-market loans. The majority of these loans are
not publicly rated; instead, Fitch establishes model-based credit
opinions for the performing loans.  Information for the credit
opinions was gathered from financial statements provided to Fitch
by ACAS.  The performing loan portfolio consists of $456.2 million
from 28 unique obligors, with the three largest obligors
comprising approximately 22.4% of the total portfolio.  Fitch
considers approximately 37.9% of the portfolio to be rated 'CCC',
compared to 12.7% in the last review, while 4.0% is rated 'BB-'
and the remaining obligors are rated in the 'B' category.


ACAS BUSINESS: Fitch Affirms Junk Rating on $50 Mil. Class D Notes
------------------------------------------------------------------
Fitch Ratings has upgraded one class and affirmed one class of
notes issued by ACAS Business Loan Trust 2004-1 (ACAS BLT 2004-1)
as follows:

  -- $30,943,219 class C notes upgraded to 'BBBsf'from 'BBsf';
     Outlook revised to Stable from Negative;

  -- $50,000,000 class D notes affirmed at 'CCCsf'; Recovery
     Rating revised to 'RR2' from 'RR4'.

The upgrade of the class C notes reflects the significant increase
of credit enhancement since the last rating action in August 2010.
The class C notes began to receive principal payments on the April
2011 payment date, driven by loan prepayments and excess spread
used to pay down the Additional Principal Amount (APA).  As of the
July 2011 payment date, 58% of the class C notes have paid down.
The notes are likely to perform under rating modeled stresses
above the 'BBBsf' category; however, a rating above 'BBBsf' would
not appropriately reflect the concentration of the portfolio's
exposure to 12 performing obligors.  Fitch expects the rating of
the class C notes to remain stable in the near term and has
revised the Outlook to Stable.

The affirmation on the class D notes are based on the improved
credit enhancement levels for the notes, tempered by the increased
concentration of the portfolio.  The improved credit enhancement
levels increased the recovery estimates on the class D notes, but
the notes continue to be exposed to default risk with only 12
performing obligors remaining.  The largest obligor is
approximately $14.9 million, or 13.7%, of the portfolio, and
second lien and subordinate loans, which have low recovery
prospects upon default, represent approximately 82.5% of the
performing portfolio.  The notes are likely to perform under
modeled stresses in the 'Bsf' category, but the ability of the
notes to be fully repaid relies upon the performance of a limited
number of companies with distressed ratings.

The notes of ACAS BLT 2004-1 have credit enhancement in the form
of collateral coverage, note subordination, and the application of
excess spread via the APA.  Upon the occurrence of a default in
the portfolio, the APA feature directs part or all of the excess
interest otherwise available to the equity to pay down the senior-
most notes in an amount equal to the aggregate balance of
defaulted assets in the portfolio.  Since Fitch's last rating
action the servicer has considered an additional $2.7 million of
loans as defaulted, while approximately $20.8 million of excess
spread has been used to pay principal to the senior notes.  The
APA was approximately $13.7 million on the July 2011 payment date,
compared to $31.7 million in July 2010.

The Recovery Rating (RR) on the class D notes was revised to 'RR2'
from 'RR4', as discounted cash flows yield a recovery projection
in a range between 70 - 90% in a base-case default scenario.
Recovery Ratings are designed to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities rated 'CCCsf' or below.  For further
details on Recovery Ratings, please see Fitch's reports 'Global
Rating Criteria for Corporate CDOs' and 'Criteria for Structured
Finance Recovery Ratings'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs' using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  As previously mentioned, both classes of notes passed
in modeled scenarios at rating levels above their current ratings.
However, Fitch's rating actions deviated from the modeling results
due to the concentration risks stated above.

ACAS BLT 2004-1 is a collateralized debt obligation (CDO) that
closed on Dec. 2, 2004, and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in Jan. 2007, and it is scheduled to mature in Oct.
2017.  ACAS BLT 2004-1 is secured by a portfolio of middle-market
loans.  The majority of these loans are not publicly rated, but
Fitch establishes model-based credit opinions for the performing
loans.  Information for the credit opinions was gathered from
financial statements provided to Fitch by ACAS.  The performing
loan portfolio consists of $108.6 million from 12 unique obligors,
with three of the largest obligors comprising approximately 40.2%
of the total portfolio.  Fitch considers approximately 57.7% of
the portfolio to be rated 'CCC', compared to 18.5% in the last
review, while none of the remaining obligors are rated above 'B+'.


ACAS BUSINESS: Fitch Affirms Rating on Four Note Classes
--------------------------------------------------------
Fitch Ratings has affirmed these four classes of notes issued by
ACAS Business Loan Trust 2007-1 (ACAS BLT 2007-1):

  -- $72,197,050 class A notes at 'AAsf'; Outlook Stable;

  -- $36,095,289 class B notes at 'Asf'; Outlook revised to Stable
     from Negative;

  -- $64,971,520 class C notes at 'BBsf'; Outlook Negative;

  -- $36,095,289 class D notes at 'Bsf'; Outlook Negative.

The affirmation of the notes is based on the generally stable
performance of the transaction since Fitch's last rating action in
August 2010.  Since that time, each class of notes has benefited
from increased credit enhancement levels due to the significant
principal repayment of the class A notes.  However, the underlying
loan portfolio is becoming increasingly concentrated in low-rated
second lien and subordinated loans.

Through a combination of loan repayments and the diversion of
excess spread to pay principal on the notes, the class A notes
have received over $85 million of principal payments since Fitch's
last rating action.  Both the class A and B notes have a Stable
Rating Outlook reflecting the fact that they are well-positioned
to withstand future credit deterioration in the portfolio due to
their senior priorities and the degree of overcollateralization
available to these notes.  As of the May 15, 2011 servicer report
Fitch considers the performing portfolio balance to consist of
over $257 million of loans.

Fitch maintains Negative Rating Outlooks on the class C and D
notes due to the high degree of obligor concentration and the
increasingly risky characteristics of the underlying loans.  The
performing loan portfolio consists of 20 unique obligors, with
eight obligors each accounting for almost 7% of the total
portfolio. Fitch considers approximately 35% of the performing
portfolio to be rated 'CCC', compared to 17% at Fitch's last
rating action, while none of the remaining obligors are rated
above 'B+'.  Finally, over 90% of the performing portfolio
represents junior secured or unsecured loans, which indicates low
recovery prospects upon default.

The notes of ACAS BLT 2007-1 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the additional principal amount
(APA).  Upon the occurrence of a default in the portfolio, the APA
feature directs part or all of the excess interest otherwise
available to the equity to pay down the senior-most notes in an
amount equal to the aggregate balance of defaulted assets in the
portfolio.  Since Fitch's last rating action the servicer has
considered an additional $14.7 million of loans as defaulted,
while over $24.5 million of excess spread has been used to pay
principal to the class A notes. The APA stands at approximately
$36.3 million after the May 15, 2011 payment, compared to
$46.1 million in May 2010.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs' using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  Each class of notes passed the various stress scenarios
at rating levels in line with their current ratings.

ACAS BLT 2007-1 is a collateralized debt obligation (CDO) that
closed on April 24, 2007 and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in November 2007.  ACAS BLT 2007-1 is secured by a
portfolio of middle-market loans.  The majority of these loans are
not publicly rated; instead, Fitch establishes model-based credit
opinions for the performing loans.  Information for the credit
opinions was gathered from financial statements provided to Fitch
by ACAS.


ACAS BUSINESS: Good Notes Performance Cues Fitch to Hold Ratings
----------------------------------------------------------------
Fitch Ratings has affirmed these notes issued by ACAS Business
Loan Trust 2006-1 (ACAS BLT 2006-1):

  -- $94,239,641 class A notes at 'Asf'; Outlook revised to Stable
     from Negative;

  -- $37,000,000 class B notes at 'BBBsf'; Outlook revised to
     Stable from Negative;

  -- $72,500,000 class C notes at 'Bsf'; Outlook revised to Stable
     from Negative;

  -- $35,500,000 class D notes at 'CCCsf'; Recovery Rating revised
     to 'RR3' from 'RR5'.

The affirmations and revised Outlooks are based on the overall
improvement of the notes' performance, countered by the growing
concentration risks of the portfolio.  As of the May 2011 payment
date, approximately 67.6% of the class A notes have paid down,
driven by loan prepayments and the excess spread used to pay down
the Additional Payment Amount (APA).  However, the current
performing portfolio is concentrated in 23 obligors, and
approximately 85.4% of the performing portfolio is composed of
low-rated second lien loans or subordinated loans, which indicates
low recovery prospects upon default.  The rating actions reflect
these concentration risks, which are expected to increase over the
longer term, and subsequently introduce more volatility to the
notes' performance.  The revised Outlooks indicate the notes'
stable performance under their current rating stresses and Fitch's
expectation that the ratings of the notes will remain stable for
the near term.

The notes of ACAS BLT 2006-1 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the APA.  Upon the occurrence of
a default in the portfolio, the APA feature directs part or all of
the excess interest otherwise available to the equity to pay down
the senior-most notes in an amount equal to the aggregate balance
of defaulted assets in the portfolio.  Since Fitch's last rating
action the servicer has considered an additional $36.7 million of
loans as defaulted, while approximately $38.7 million of excess
spread has been used to pay principal to the class A notes.  The
APA stands at approximately $55.4 million after the May 2011
payment date, compared to $57.5 million in May 2010.

The Recovery Rating (RR) on the class D notes was revised to 'RR3'
from 'RR5', as discounted cash flows yield a recovery projection
in a range between 50 - 70% in a base-case default scenario.
Recovery Ratings are designed to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities rated 'CCCsf' or below. For further
details on Recovery Ratings.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  The class A and class B notes passed modeled scenarios
at rating levels above their current ratings.  However, the rating
actions deviated from the modeling results due to the
concentration risks stated above.  The class C and class D notes
passed stress scenarios at rating levels in line with their
current ratings categories.

ACAS BLT 2006-1 is a collateralized debt obligation (CDO) that
closed on July 28, 2006 and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in August 2009.  ACAS BLT 2006-1 is secured by a
portfolio of middle-market loans.  The majority of these loans are
not publicly rated, but Fitch establishes model-based credit
opinions for the performing loans.  Information for the credit
opinions was gathered from financial statements provided to Fitch
by ACAS.  The performing loan portfolio consists of $276.0 million
from 23 unique obligors, with the three largest obligors
comprising approximately 18.1% of the total portfolio.  Fitch
considers approximately 48.8% of the portfolio to be rated 'CCC',
compared to 30.8% in the last review, while none of the remaining
obligors are rated above 'B+'.


ACAS BUSINES: Stable Performance Cues Fitch to Affirm Ratings
-------------------------------------------------------------
Fitch Ratings has affirmed these five classes of notes issued by
ACAS Business Loan Trust 2007-2 (ACAS BLT 2007-2):

  -- $78,203,494 class A notes at 'AAsf'; Outlook Stable;
  -- $34,874,179 class B notes at 'Asf'; Outlook revised to Stable
     from Negative;
  -- $58,588,620 class C notes at 'BBsf'; Outlook Negative;
  -- $29,294,310 class D notes at 'Bsf'; Outlook Negative;
  -- $39,524,069 class E notes at 'CCCsf/RR6'.

The affirmation of the notes is based on the generally stable
performance of the transaction since Fitch's last rating action in
August 2010.  Since that time, each class of notes has benefited
from increased credit enhancement levels due to the significant
principal repayment of the class A notes.  However, the underlying
loan portfolio is becoming increasingly concentrated in low-rated
second lien and subordinated loans.

Through a combination of loan repayments and the diversion of
excess spread to pay principal on the notes, the class A notes
have received approximately $101.6 million of principal payments
since Fitch's last rating action.  Both the class A and B notes
have a Stable Rating Outlook reflecting the fact that they are
well-positioned to withstand future credit deterioration in the
portfolio due to their senior priorities and the degree of
overcollateralization available to these notes.  As of the May 15,
2011 servicer report Fitch considers the performing portfolio
balance to consist of approximately $227.2 million of loans.
Fitch maintains Negative Rating Outlooks on the class C and D
notes due to the high degree of obligor concentration and the
increasingly risky characteristics of the underlying loans.  The
performing loan portfolio consists of 20 unique obligors, with
each of the nine largest obligors accounting for 6.7% to 7.2% of
the total portfolio.  Fitch considers approximately 43.8% of the
performing portfolio to be rated 'CCC', compared to 19% at Fitch's
last rating action, while none of the remaining obligors are rated
above 'B+'.  Approximately 69.1% of the performing portfolio
represents junior secured or unsecured loans, which indicates low
recovery prospects upon default.  The remaining 30.9% of the
portfolio consists of senior secured loans.

The notes of ACAS BLT 2007-2 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the additional principal amount
(APA).  Upon the occurrence of a default in the portfolio, the APA
feature directs part or all of the excess interest otherwise
available to the equity to pay down the senior-most notes in an
amount equal to the aggregate balance of defaulted assets in the
portfolio.  Since Fitch's last rating action the servicer has
considered an additional $33.1 million of loans as defaulted,
while over $25.6 million of excess spread has been used to pay
principal to the class A notes.  The APA stands at approximately
$62.4 million after the May 15, 2011 payment, compared to
$54.9 million in May 2010.

The class E notes maintain their Recovery Rating (RR) of 'RR6', as
these notes are not projected to recover any proceeds in a base-
case default scenario.  Recovery Ratings are designed to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities rated 'CCCsf' or below.
For further details on Recovery Ratings, please see Fitch's
reports 'Global Rating Criteria for Corporate CDOs' and 'Criteria
for Structured Finance Recovery Ratings'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs' using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  The class A and B notes passed the various stress
scenarios at rating levels in line with their current ratings.
The class C and D notes passed the majority of the stress
scenarios at their current ratings and had minimal model failures
in the remaining scenarios.  The class E notes have a minimal
degree of credit enhancement and are highly sensitive to the
future performance of each of the underlying loans, and their
rating is reflective of this substantial credit risk.

ACAS BLT 2007-2 is a collateralized debt obligation (CDO) that
closed on Aug. 7, 2007 and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in February 2008.  ACAS BLT 2007-2 is secured by a
portfolio of middle-market loans.  The majority of these loans are
not publicly rated; instead, Fitch establishes model-based credit
opinions for the performing loans. Information for the credit
opinions was gathered from financial statements provided to Fitch
by ACAS.


ACAS CLO: Fitch Affirms 'Bsf' Rating on $15.5 Mil. Class D Notes
----------------------------------------------------------------
Fitch Ratings has affirmed seven classes of notes issued by ACAS
CLO 2007-1 Ltd./Corp.(ACAS CLO 2007-1) and revised Rating
Outlooks:

  -- $110,750,000 class A-1 notes at 'AAAsf'; Outlook Stable;
  -- $135,000,000 class A-1-S notes at 'AAAsf'; Outlook Stable;
  -- $33,750,000 class A-1-J notes at 'AAAsf'; Outlook Stable;
  -- $25,000,000 class A-2 notes at 'AAsf'; Outlook Stable;
  -- $22,000,000 class B notes at 'Asf'; Outlook Stable;
  -- $21,000,000 class C notes at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $15,500,000 class D notes at 'Bsf'; Outlook to Stable from
     Negative.

The affirmation of the notes is based on the steady credit
enhancement levels for all classes, as well as the stable
performance of the underlying portfolio since Fitch's last rating
action in August 2010.  Fitch expects the ratings on the notes to
remain stable in the near term and has maintained the Stable
Outlook on the class A-1, A-1-S, A-1-J, A-2 and B notes.  This is
also reflected in Fitch's outlook revision to Stable from Negative
for the class C and D notes.

The current portfolio continues to generate a considerable amount
of excess spread, and all classes of notes are likely to perform
at or above their current ratings under modeled stresses.
However, upgrades are not warranted at this time since the
transaction remains in its reinvestment period until April 2014
and may be managed to covenanted levels which may negatively
affect the portfolio and future cash flows.  In its analysis,
Fitch applied stress scenarios at covenanted levels including
weighted-average rating factor, weighted-average life and
weighted-average spread.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs' using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  Fitch's modeling results for the class A-2, B, and D
notes indicated a higher passing rating when analyzing with the
current portfolio's characteristics; however, analysis with the
portfolio stressed to covenanted levels indicated that an upgrade
was not warranted for these notes.

ACAS CLO 2007-1 is a cash flow CLO that closed April 26, 2007,
and is managed by American Capital Asset Management, LLC.  The
portfolio is currently composed of 92.1% senior secured loans,
3.1% senior secured debt, 2.4% junior secured/mezzanine debt and
2.4% structured finance assets.  Approximately 14.6% of the
$374 million collateral is not publicly rated, however, Fitch has
credit opinions for these performing loans. Information for the
credit opinions was gathered from financial statements provided to
Fitch by the manager or the public domain.  ACAS CLO 2007-1 is
currently in its reinvestment period through April 20, 2014.
During the reinvestment period, failure of the reinvestment
overcollateralization test (OC) test will divert up to 50% of
excess interest to invest in additional collateral to build credit
enhancement for the notes.


ALTIUS III: S&P Lowers Rating on Class A-1b-1F Notes to 'CC'
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A-1b-1F and S notes from Altius III Funding Ltd., a U.S.
cash flow collateralized debt obligation (CDO) transaction
originally backed by high-grade structured finance assets, and
managed by Aladdin Capital Management LLC. "In addition, we
affirmed our ratings on the class A-1a, A-1b-1B, A-1b-2, A-1b-3,
A-1b-V, A-2, B, C, D, and E notes, and removed the ratings on the
class A-1b-1F and S notes from CreditWatch, we placed them with
negative implications on May 25, 2011," S&P related.

"The downgrades of the class A-1b-1F and S notes reflects credit
deterioration we have observed in the deal's underlying portfolio
since we last downgraded the notes on June 8, 2010," S&P said.

"Since that time, based on numbers obtained from the trustee
reports, defaulted obligations and obligations in the 'CCC' rating
category increased. Defaulted obligations increased to $594.45
million as of July 26, 2011, from $524.27 million in the March 26,
2010, trustee report, which we used for the June 2010 rating
action. 'CCC' rated securities increased to $363.11 million from
$353.89 million over the same time period," S&P related.

In addition, the overcollateralization available to support the
rated notes decreased. The trustee reported that the class A/B
overcollateralization test decreased to 26.10%, from 44.54% over
the same time period.

"The affirmations of the ratings on the remaining 10 notes reflect
our belief that the credit support available is commensurate with
the current rating levels," S&P stated.

Rating and CreditWatch Actions

Altius III Funding Ltd.
                        Rating
Class              To           From
A-1b-1F            CC (sf)      CCC- (sf)/Watch Neg
S                  CCC- (sf)    B+ (sf)/Watch Neg

Ratings Affirmed

Altius III Funding Ltd.

Class              Rating
A-1a               CC (sf)
A-1b-1B            CC (sf)
A-1b-2             CC (sf)
A-1b-3             CC (sf)
A-1b-V             CC (sf)
A-2                CC (sf)
B                  CC (sf)
C                  CC (sf)
D                  CC (sf)
E                  CC (sf)


AMMC VIII: Moody's Upgrades Ratings of Six Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by AMMC VIII, Limited:

US$337,500,000 Class A-1 Floating Rate Notes Due November 25, 2022
(current outstanding balance of $335,367,530), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$37,500,000 Class A-2 Floating Rate Notes Due November 25, 2022,
Upgraded to Aa1 (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

US$25,000,000 Class B Floating Rate Notes Due November 25, 2022,
Upgraded to A1 (sf); previously on June 22, 2011 Baa1 (sf) Placed
Under Review for Possible Upgrade;

US$20,000,000 Class C Deferrable Floating Rate Notes Due
November 25, 2022, Upgraded to Baa2 (sf); previously on June 22,
2011 Ba1 (sf) Placed Under Review for Possible Upgrade;

US$20,000,000 Class D Deferrable Floating Rate Notes Due
November 25, 2022, Upgraded to Ba2 (sf); previously on June 22,
2011 B1 (sf) Placed Under Review for Possible Upgrade;

US$20,000,000 Class E Deferrable Floating Rate Notes Due
November 25, 2022 (current outstanding balance of $15,359,090),
Upgraded to Ba3 (sf); previously on June 22, 2011 Caa3 (sf) Placed
Under Review for Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of improvement in the
credit quality of the underlying portfolio since the rating action
in November 2010. Based on the July 2011 trustee report, the
weighted average rating factor is currently 2588 compared to 2786
in October 2010.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $484.1 million,
defaulted par of $6.1 million, a weighted average default
probability of 21.78% (implying a WARF of 2766), a weighted
average recovery rate upon default of 49.79%, and a diversity
score of 65. The 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.

AMMC VIII, Limited, issued in October 2007, 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
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average coupon and diversity score.
   However, as part of the base case, Moody's considered a spread
   level higher than the covenant level due to the large
   difference between the reported and covenant level.


APIDOS CDO: Moody's Upgrades Ratings of Five Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Apidos CDO III:

US$212,000,000 Class A-1 Senior Notes Due 2020, Upgraded to Aaa
(sf), previously on June 22, 2011 Aa1 (sf) placed under review for
possible upgrade;

US$19,000,000 Class A-2 Senior Notes Due 2020, Upgraded to Aa3
(sf), previously on June 22, 2011 A2 (sf) placed under review for
possible upgrade;

US$15,000,000 Class B Mezzanine Notes Due 2020, Upgraded to Baa1
(sf), previously on June 22, 2011 Baa3 (sf) placed under review
for possible upgrade;

US$10,500,000 Class C Mezzanine Notes Due 2020, Upgraded to Ba2
(sf), previously on June 22, 2011 Ba3 (sf) placed under review for
possible upgrade;

US$6,000,000 Class D Mezzanine Notes Due 2020, Upgraded to B1
(sf), previously on June 22, 2011 Caa2 (sf) placed under review
for possible upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an increase in the
overcollateralization ratios since the last rating action in
September 2009. In the July 2011 trustee report, the Class A, B, C
and D Overcollateralization Tests are reported at 119.8%, 112.5 %,
107.9% and 105.4%, respectively, versus reported August 2009
levels of 116.0%, 109.0%, 104.5% and 102.1%, respectively. All
related overcollateralization tests are currently in compliance.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $277 million, no
defaulted par amount, a weighted average default probability of
19% (implying a WARF of 2653), a weighted average recovery rate
upon default of 50% and a diversity score of 75. The 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.

Apidos CDO III, issued in May 2006, 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
June 2011.

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 June 2011.

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 2013 and
2015 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.

A source of additional performance uncertainties is 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 the worse of reported and covenanted values
for weighted average rating factor 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.


ARES VII: Fitch Lowers Rating on $26 Mil. Class C Notes to 'D'
--------------------------------------------------------------
Fitch Ratings has downgraded one class of notes issued by Ares
VII, Ltd/Corp. (Ares VII CLO) and withdrawn the rating:

  -- $26,718,773 class C notes downgraded to 'D' from 'C/RR5', and
     withdrawn.

The rating actions are the result of the transaction's inability
to pay the full amount of principal due on the redemption date of
Aug. 8, 2011.  At the direction of the class C noteholders, an
optional redemption was declared and the portfolio collateral was
liquidated and proceeds were distributed according to the
transaction documents.  All senior notes were paid in full while
the class C notes received only partial payment consisting of
$24,281,227 of principal and $260,186 of interest; leaving a
remaining principal balance of the class C notes is $26,718,773.

Ares VII CLO is a collateralized debt obligation (CDO) that closed
on May 7, 2003, and is managed by Ares Management, LLC.


BANC OF AMERICA: Fitch Affirms Junk Rating on Two Class Certs.
--------------------------------------------------------------
Fitch Ratings has affirmed the pooled classes of Banc of America
Large Loan 2005-MIB1 commercial mortgage pass-through
certificates.  The affirmations reflect overall stable loss
expectations for the pooled classes as well as pay down since
Fitch's last review.  Fitch's performance expectation incorporates
prospective views regarding the outlook of the commercial real
estate market.

Fitch affirms the following classes and revises Rating Outlooks as
indicated:

  -- $10.2 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $43 million class B at 'AAAsf'; Outlook Stable;
  -- $51.2 million class C at 'AAAsf'; Outlook Stable;
  -- $30.3 million class D at 'AA+sf'; Outlook Stable;
  -- $30.3 million class E at 'AAsf'; Outlook Stable;
  -- $30.3 million class F at 'AA-sf'; Outlook to Stable from
     Negative;
  -- $30.3 million class G at 'A-sf'; Outlook to Stable from
     Negative;
  -- $25.3 million class H at 'BBB+sf'; Outlook to Stable from
     Negative;
  -- $28.8 million class J at 'BBsf'; Outlook Negative;
  -- $30 million class L at 'CCsf/RR6'.

Fitch has also affirmed the following class and revised the
Recovery Rating (RR) as indicated:

  -- $30.8 million class K to 'CCCsf/RR2' from 'CCC/RR1'.
     Class A-1 and interest-only classes X-1A and X-4 have paid in
     full.

All of the remaining loans have passed their final maturity or are
maturing over the next 12 months.  At issuance, the majority of
the loans had an average loan term of five years.  There is
uncertainty as to whether or not the loans will have issues
securing financing at final maturity or ultimate disposition.

Under Fitch's methodology, approximately 30% of the pooled balance
is modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled average cash flow
decline is 6.1% and pooled expected losses are 9.3%. To determine
a sustainable Fitch cash flow and stressed value, Fitch analyzed
servicer-reported operating statements and STR reports, updated
property valuations, and recent sales comparisons.  Fitch
estimates that average recoveries will be approximately 68.9% in
the base case.

The transaction is collateralized by six loans, two of which are
secured by hotels (75.4%), two by retail (12.1%), one industrial
(9.6%) and one by multifamily (2.9%). Five of the six loans
(31.9%) are in special servicing.  The three largest pooled
contributors to losses (by unpaid principal balance) in the 'B'
stress scenario are: Radisson Resort Parkway (7.3%), The Shops at
Grand Avenue (6.8%) and The Pointe Apartments (2.9%).

The Radisson Resort Parkway is a 718 key full-service hotel
located in Kissimmee, FL. The property is adjacent to Walt
Disney's Celebration and is located 1.5 miles from Walt Disney
World.  The loan transferred to special servicing in July 2009.

Property performance has deteriorated with the property reporting
a negative year-end (YE) 2010 net cash flow.  As of May 2011, the
trailing 12 month (TTM) reported occupancy, average daily rate
(ADR) and revenue per available room (RevPAR) of 48.8%, $62 and
$30, respectively, compared to 78.5%, $76 and $60 at issuance.
The Shops at Grand Avenue is a 291,033 sf regional mall located in
Milwaukee, WI.  The collateral consists of 168,364 sf of in-line
space. The property is anchored by The Boston Store (not part of
the collateral) and includes major tenants such as TJ Maxx (lease
expiration in March 2014) and Office Max (lease expiration in
March 2016).  As of YE 2010, the servicer-reported NOI DSCR
declined 68.5% in the previous two years due to declining
occupancy at the property.  The loan transferred to special
servicing in September 2009.  One of the major tenants at
issuance, Linens N' Things, opened their store in 2005 and
subsequently vacated following a corporate bankruptcy filing.  As
of March 2011, the property reported an overall occupancy of 41%
and in-line occupancy of approximately 40%.  At issuance, the
property had an overall occupancy of 78.6% and in-line occupancy
of 62.7%.

The Pointe Apartments is a 360-unit multifamily property located
in Stone Mountain, GA, 16 miles northeast of Atlanta.  The loan
transferred to special servicing in August 2008 and is now real-
estate owned (REO).  At issuance, the property was 91.9% occupied.
As of a March 2011, the property was approximately 79% occupied,
an increase from 66% reported in 2009 when occupancy was affected
by tenant evictions.

Fitch previously withdrew the ratings of interest-only classes X-
1B, X-2, X-3 and X-5.


BANC OF AMERICA: S&P Lowers Rating on Class K Certificates to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 26
classes of commercial mortgage pass-through certificates from four
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 14 of these classes to 'D (sf)' because
we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. The 14 classes that we
downgraded to 'D (sf)' had accumulated interest shortfalls
outstanding between one and 12 months," S&P related. The recurring
interest shortfalls for the certificates are primarily due to one
or more of these factors:

    Appraisal subordinate entitlement reduction (ASER) amounts in
    effect for specially serviced assets;

    The lack of servicer advancing for assets 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,
special servicing fees, and interest rate reductions and deferrals
resulting from loan modifications that are likely, in our view, to
cause recurring interest shortfalls," S&P related.

The servicer implements ARAs and resulting ASER amounts in
accordance with each transaction's terms. Typically, these terms
call for the automatic implementation of an ARA equal to 25% of
the stated principal balance of a loan when it 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)'. This is
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.

"We detail the 26 downgraded classes from the four U.S. CMBS
transactions," S&P said.

    Banc of America Commercial Mortgage Loan Trust 2008-LS1

"We lowered our ratings on the class E, F, G, H, J, and K
certificates from Banc of America Commercial Mortgage Loan Trust
2008-LS1. We lowered our rating on the class K certificate to 'D
(sf)' to reflect accumulated interest shortfalls outstanding for
12 months due primarily to ASER amounts related to 23 ($288.6
million, 13.1%) of the 27 ($327.3 million, 14.9%) assets that are
currently with the special servicer, LNR Partners LLC, as well as
shortfalls due to rate modification, recoup of prior advances by
the master servicer, special servicing fees, and workout fees.
ASER recoveries of $1.2 million offset the total interest
shortfalls during this period. We downgraded the class E, F, G, H,
and J certificates due to reduced liquidity support available to
these classes and the potential for these classes to experience
interest shortfalls in the future relating to the specially
serviced assets. As of the Aug. 10, 2011, trustee remittance
report, ARAs totaling $134.1 million were in effect for 23 assets,
and the total reported monthly ASER amount on these assets was
$695,931. The reported monthly interest shortfalls excluding the
aforementioned ASER recoveries this month were $898,331," S&P
stated.

   Bear Stearns Commercial Mortgage Securities Trust 2002-TOP6

"We lowered our ratings on the class G, H, J, K, and L
certificates from Bear Stearns Commercial Mortgage Securities
Trust 2002-TOP6. We lowered our ratings on the class K and L
certificates to 'D (sf)' to reflect accumulated interest
shortfalls outstanding between two and 12 months due primarily to
nonrecoverable advance amounts related to two assets ($4.7
million, 0.8%) of the six ($14.4 million, 2.3%) assets that are
currently with the special servicer, Berkadia Commercial Mortgage
LLC, as well as special servicing fees. We downgraded the class G,
H, and J certificates due to reduced liquidity support available
to these classes following continued interest shortfalls," S&P
related.

As of the Aug. 15, 2011, trustee remittance report, the master
servicer, Wells Fargo Bank N.A., made a nonrecoverability
determination on the two assets that had reported ARAs totaling
$3.8 million. The reported monthly interest shortfalls totaled
$40,938 and have affected all of the classes subordinate to
and including class K.

  Bear Stearns Commercial Mortgage Securities Trust 2006-PWR13

"We lowered our ratings on the class F, G, H, J, K, L, M, N, and O
certificates from Bear Stearns Commercial Mortgage Securities
Trust 2006-PWR13. We lowered our ratings on the class H, J, K, L,
M, N, and O certificates to 'D (sf)' to reflect accumulated
interest shortfalls outstanding between three and 12 months due
primarily to ASER amounts related to 15 ($119.2 million, 4.4%) of
the 22 ($307.0 million, 11.3%) assets that are currently with the
special servicer, Helios AMC LLC, as well as special servicing and
workout fees. An ASER recovery of $140,592 from a liquidated asset
partially offset the total interest shortfalls during this period.
We downgraded the class F and G certificates due to reduced
liquidity support available to these classes following continued
interest shortfalls and the potential for these classes to
experience interest shortfalls in the future relating to the
specially serviced assets. As of the Aug. 11, 2011, trustee
remittance report, ARAs totaling $65.8 million were in effect for
15 assets, and the total reported monthly ASER amount on these
assets was $333,722. The reported monthly interest shortfalls
totaled $353,127 (excluding the aforementioned ASER recovery) and
have affected all of the classes subordinate to and including
class J," S&P related.

      Morgan Stanley Dean Witter Capital I Trust 2002-IQ3

"We lowered our ratings on the class E, F, G, H, J, and K
certificates from Morgan Stanley Dean Witter Capital I Trust 2002-
IQ3. We lowered our ratings on the class G, H, J, and K
certificates to 'D (sf)' because these classes have had
accumulated interest shortfalls outstanding between one and 12
months, primarily due to ASER amounts related to the two loans
($29.2 million, 5.1%) that are currently with the special
servicer, CWCapital Asset Management LLC, as well as special
servicing and workout fees. We lowered our ratings on the
class E and F certificates due to reduced liquidity support
available to these classes following continued interest
shortfalls. As of the Aug. 15, 2011, trustee remittance report,
ARAs totaling $19.2 million were in effect for the two specially
serviced loans, and the total reported monthly ASER amount on
these loans was $128,171. The reported monthly interest shortfalls
totaled $136,212 and have affected all of the classes subordinate
to and including class G," S&P stated.

Ratings Lowered

Banc of America Commercial Mortgage Loan Trust 2008-LS1
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement    interest shortfalls ($)
Class  To        From          (%)     Current  Accumulated
E      CCC+ (sf) B+ (sf)      8.71           0            0
F      CCC- (sf) B+ (sf)      7.51     -46,378            0
G      CCC- (sf) B+ (sf)      6.44    -117,522            0
H      CCC- (sf) CCC+ (sf)    5.11    -146,900            0
J      CCC- (sf) CCC (sf)     3.78    -146,900            0
K      D (sf)    CCC- (sf)    2.45    -167,110      745,005

Bear Stearns Commercial Mortgage Securities Trust 2002-TOP6
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement    interest shortfalls ($)
Class  To        From          (%)     Current  Accumulated
G      B+ (sf)   BB+ (sf)     4.89           0            0
H      CCC+ (sf) BB (sf)      3.31           0            0
J      CCC- (sf) BB- (sf)     1.95      -8,926            0
K      D (sf)    CCC (sf)     1.05      17,379       45,459
L      D (sf)    CCC- (sf)    0.15      27,940      217,028


Bear Stearns Commercial Mortgage Securities Trust 2006-PWR13
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement    interest shortfalls ($)
Class  To        From          (%)     Current  Accumulated
F      CCC+ (sf) B+ (sf)      5.14           0            0
G      CCC- (sf) B (sf)       3.94     -88,255            0
H      D (sf)    B- (sf)      2.87      -5,167      291,696
J      D (sf)    CCC+ (sf)    2.21      79,556      859,092
K      D (sf)    CCC (sf)     2.07      15,910      175,005
L      D (sf)    CCC (sf)     1.67      47,733      552,180
M      D (sf)    CCC- (sf)    1.41      31,823      381,881
N      D (sf)    CCC- (sf)    1.14      31,823      381,881
O      D (sf)    CCC- (sf)    0.87      31,823      381,881


Morgan Stanley Dean Witter Capital I Trust 2002-IQ3
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement    interest shortfalls ($)
Class  To        From          (%)     Current  Accumulated
E      B+ (sf)   BB+ (sf)     7.54           0            0
F      CCC (sf)  B+ (sf)      5.76           0            0
G      D (sf)    CCC+ (sf)    4.58       4,027        4,027
H      D (sf)    CCC- (sf)    2.81      51,165      181,850
J      D (sf)    CCC- (sf)    1.23      45,485      561,083
K      D (sf)    CCC- (sf)    0.44      22,740      280,511


BEAR STEARNS: Fitch Affirms Junk Rating on Five Cert. Classes
-------------------------------------------------------------
Fitch Ratings has downgraded eight classes of Bear Stearns
Commercial Mortgage Securities Trust, 2005-TOP20 commercial
mortgage pass-through certificates.

The downgrades reflect an increase in Fitch expected losses across
the pool.  Fitch modeled losses of 4.5% of the remaining pool.
Fitch has designated 31 loans (23.24% of the pool balance) as
Fitch Loans of Concern, which includes six specially serviced
loans (9.7%).  Fitch expects classes L through Q may be fully
depleted from losses associated with the specially serviced
assets.

As of the August 2011 distribution date, the pool's aggregate
principal balance has been paid down by approximately 9.1% to $1.9
billion from $2.1 billion at issuance.  Three loans (1.8%) are
currently defeased. Interest shortfalls are affecting classes K
through Q.

The largest specially serviced loan is the Lakeforest Mall A-note
(6.3%), and is also the largest loan in the pool.  The loan is
secured by 402,625 square feet (sf) of inline space in a 1.1
million sf regional mall in Gaithersburg, MD.  The loan originally
transferred to special servicing in July 2010 for maturity default
after the sponsor (Simon Property Group) was unable to refinance
the existing debt.  The loan was modified with a maturity date
extension to July 2011 with a one year extension option.  The
extension option was not exercised, and the loan is currently in
maturity default.  The servicer is in negotiations with the
borrower to cure the default.  The property is also encumbered by
a $20 million B-note held outside the trust, which correlates to
the LF rake class of the transaction. The B-note is also in
special servicing.

The largest contributor to loss (1.7% of pool balance) is secured
by the former headquarters of Circuit City, a 368,255 sf office
building located in Richmond, VA.  Circuit City (previously 100%
of the net rentable area [NRA]) had filed for bankruptcy in 2009
and subsequently vacated the entire property in 2010.  The
property remains 100% vacant.  The loan transferred to special
servicing in July 2010 for payment default. The property had
converted to real estate owned (REO) in December 2010. The
servicer has hired CBRE to manage, lease and list the property for
sale.

The next largest contributor to losses (0.9%) is secured by four
mobile home parks located in IL (2) and MI (2), totaling 1,092
pads.  The loan had transferred to special servicing in September
2010 for monetary default.  The servicer has since been negotiated
a Deed in Lieu of foreclosure and the servicer is currently
marketing the loan for a note sale.  As of year end (YE) December
2010 occupancy reported at 69%, and the debt service coverage
ratio (DSCR) reported at 1.21 times (x).


Fitch downgrades the following classes and revises the Outlooks
and Recovery Ratings (RRs) as indicated:

  -- $15.5 million class B to 'Asf' from 'AAsf'; Outlook Stable;
  -- $15.5 million class D to 'BBBsf' from 'Asf'; Outlook Stable;
  -- $28.5 million class E to 'BBsf' from 'BBBsf'; Outlook Stable;
  -- $18.1 million class F to 'BBsf' from 'BBB-sf'; Outlook
     Stable;
  -- $18.1 million class G to 'Bsf' from 'BBsf'; Outlook to
     Negative from Stable;
  -- $23.3 million class H to 'B-sf' from 'Bsf'; Outlook Negative;
  -- $18.1 million class J to 'CCCsf/RR1' from 'B-sf';
  -- $5.2 million class K to 'CCsf/RR6' from 'CCCsf/RR1'.

Fitch also affirms the following classes and revises the RR
ratings as indicated:

  -- $156.1 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $176 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $114.3 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $955 million class A-4A at 'AAAsf'; Outlook Stable;
  -- $130.8 million class A-4B at 'AAAsf'; Outlook Stable;
  -- $147.7 million class A-J at 'AAsf'; Outlook Stable;
  -- $20.7 million class C at 'Asf'; Outlook Stable;
  -- $7.8 million class L at 'Csf'; RR to 'RR6' from 'RR1';
  -- $7.8 million class M at 'Csf/RR6';
  -- $2.6 million class N at 'Csf/RR6';
  -- $2.6 million class O at 'Csf/RR6';
  -- $5.2 million class P at 'Csf/RR6'.

The rake class LF will remain at 'Dsf/RR1' due to realized losses.

Fitch does not rate the $14.2 million class Q. Class A-1 has paid
in full.

On Oct. 21, 2010 Fitch had withdrawn the rating on the interest-
only class X.


BEAR STEARNS: Increased Paydown Cues Fitch to Upgrade Ratings
-------------------------------------------------------------
Fitch Ratings has upgraded one class and affirmed 10 classes of
Bear Stearns Commercial Mortgage Securities Inc., series 2001-
Top2.

The upgrade is a result of increased principal paydown to the
transaction resulting in increased credit enhancement to the
class.  As of the July 2011 distribution date, the pool's
aggregate principal balance has been paid down by approximately
89% to $111.2 million from $1 billion at issuance.

Although the transaction has experienced significant paydowns, the
remaining pool is highly concentrated with only 22 of the original
141 loans remaining, one of which (0.7% of the pool balance) is
fully defeased.  Current risk exposure of the remaining pool
includes vacant buildings, single tenant properties, as well as
properties located in secondary markets.  Fitch modeled losses of
22.6% of the remaining pool, most of which involved increased
losses on the specially serviced loans.  Fitch has designated 15
loans (78.5%) as Fitch Loans of Concern, which include 11
specially serviced loans (61.4%).  Fitch expects class F to be
significantly impacted and class G to be fully depleted from
losses associated with the specially serviced assets.  Interest
shortfalls are affecting classes K through NR.

The largest contributors to loss (29.1% of pool balance) are six
cross defaulted, cross collateralized loans secured by six
industrial properties totaling 1,206,755 square feet (sf) in the
Grand Rapids, MI market.  All six loans transferred to special
servicing in March 2009 when the largest of the six loans had
transferred for payment default due to cash flow issues from
occupancy declines.  The loan terms were modified in order to
allow the borrower an attempt to stabilize the property, which was
unsuccessful.  The loans matured in January 2011. The servicer is
working with the borrower to settle the defaults.

The next largest contributor to losses (8.4%) is secured by six
mobile home parks containing a total of 706 pads in the Grand
Rapids, MI market.  The asset transferred to special servicing in
February 2009 for payment default.  The properties had converted
to real estate owned (REO) via foreclosure in January 2011.  The
servicer is working to stabilize and market the properties for
sale.

The third largest contributor to losses (7.4%) is secured by a
53,404 sf office and research & development building in Sunnyvale,
CA.  The property was 100% leased to a single tenant until its
lease expiration in April 2011; the building is now 100% vacant.
The loan was recently transferred to special servicing in June
2011 for imminent payment default.  The servicer has contacted the
borrower and is reviewing the loan in order to determine an
appropriate resolution strategy.

Fitch stressed the cash flow of the non-specially serviced and
non-defeased loans by applying a minimum 5% reduction to most
recently available fiscal year end net operating income, and
applying an adjusted market cap rate between 8% and 11% to
determine value.

Fitch upgrades the following class and revises the Ratings Outlook
as indicated:

  -- $30.2 million class C to 'BB' from 'B-'; Outlook to Stable
     from Negative.

Fitch affirms the following classes and revises the Ratings
Outlooks as indicated:

  -- $22.4 million class B at 'BBB-'; Outlook to Stable from
     Negative;
  -- $10.1 million class D at 'B-'; Outlook Negative;
  -- $23.9 million class E at 'C/RR3';
  -- $8.8 million class F at 'C/RR6'.

Classes G through M remain at 'D/RR6' due to realized losses.

Fitch does not rate class N. Classes A-1, A-2, and X-2 have paid
in full.  On July 2, 2010, Fitch had withdrawn the rating on the
interest-only classes X-1.


BEAR STEARNS: Losses Across the Pool Cues Fitch to Lower Ratings
----------------------------------------------------------------
Fitch Ratings has downgraded two classes and upgraded one class of
Bear Stearns Commercial Mortgage Securities Inc.'s commercial
mortgage pass-through certificates, series 2002-PBW1.

Fitch downgrades these classes:

  -- $16.1 million class H to 'CCCsf/RR1' from 'B-sf'.
  -- $10.4 million class J to 'Csf/RR2' from 'CCCsf/RR2'.

Fitch upgrades this class:

  -- $13.8 million class F to 'BBBsf' from 'BBB-sf'; Outlook to
     Stable from Negative

In addition, Fitch affirms these classes and revises the Outlooks
as indicated:

  -- $384 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $26.5 million class B at 'AAAsf'; Outlook Stable;
  -- $31.1 million class C at 'AAAsf'; Outlook Stable;
  -- $8.1 million class D at 'AAAsf'; Outlook Stable;
  -- $9.2 million class E at 'AAsf'; Outlook to Stable from
     Negative;
  -- $13.8 million class G at 'Bsf'; Outlook to Stable from
     Negative;
  -- $2.8 million class K at 'Dsf/RR6'
  -- Classes L through N at 'Dsf/RR6'

The downgrade reflects Fitch expected losses across the pool.
Fitch modeled losses of 3.55% of the remaining pool.  There are
currently five specially-serviced loans (2.72%) in the pool.

The upgrade reflects reductions to the pool's principal balance
resulting in increased credit enhancement to the senior classes.
As of the July 2011 distribution date, the pool's aggregate
principal balance has been reduced by 44% (including 3.4% of
realized losses) to $515.9 million from $921 million at issuance.
Twenty loans in the pool (34.42%) are currently defeased. Interest
shortfalls are affecting classes J through P.

The largest contributor to Fitch-modeled losses (0.99%) is secured
by secured by a 58,145 square foot (sf) vacant free-standing
retail building located in Toledo, OH.  The loan was transferred
to special servicing in September 2010 due to monetary default.
The special servicer is pursuing foreclosure.

The second largest contributor to Fitch-modeled losses (0.93%) is
secured by a manufactured housing community located in Belle
Vernon, PA.  Utility expenses have increased largely due to the
property switching to the city sewer plan. The 2010 DSCR was 0.44
times (x).

Class A-1 has repaid in full. Classes L through P has been reduced
to zero due to realized losses. Fitch does not rate class P.


BECKMAN COULTER: Fitch Holds 'BB-' Rating on $97 Mil. Class Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed and revised the Outlook on this class
of Beckman Coulter, Inc., series BC 2000-A:

  -- $97.3 million class A at 'BB-'; Outlook to Positive from
     Stable.

The affirmation is the result of stable performance at the two
collateral properties and continued creditworthiness of the
tenant.  The single tenant at both properties -- Beckman Coulter,
Inc. -- was recently acquired by Danaher Corporation, an
investment grade-rated tenant.  The effects of the acquisition
from an operational perspective are unknown to Fitch at this time.
The Positive Outlook reflects the potential for a future upgrade
if the tenant continues to operate at both of the subject
properties and if the loan continues to amortize as expected
through the maturity date.

The loans are secured by two single-tenant office/research and
development facilities, located in Brea, CA and Miami, FL and
comprising a total of approximately 1.1 million square feet.  Each
property is subject to a triple-net lease in which the tenant is
obligated to remit rental payments at a rate reflecting an amount
equal to the loan's principal and interest payments.  The leases
expire within one month of the loans' maturity dates of June 30,
2018.  Assuming no defaults or prepayments, the combined balance
of the loans at maturity is expected to be approximately
$53.1 million ($46 per square foot).  According to the servicer's
2010 inspection report, the Brea property recently underwent
extensive interior renovations at a cost of approximately $80
million.

The loan remains current on its principal and interest payments.
As part of its analysis, Fitch took the current in-place rents
and deducted market vacancy factors, market management fees, and
assumed capital expenditures and leasing costs in order to derive
a normalized operating cash flow for the properties.  The
resulting stressed debt service coverage ratio, which gives credit
for amortization and is based upon Fitch's stressed cash flow and
a debt service constant of 9.66%, is 1.39 times (x).


BLACKROCK SENIOR: Moody's Raises Rating of Class D-1 Notes to Ba2
-----------------------------------------------------------------
Moody's Investors Service has taken rating actions on these notes
issued by BlackRock Senior Income Series II:

US$278,500,000 Class A-1 Senior Secured Floating Rate Notes Due
2017-1 Notes, Upgraded to Aaa (sf); previously on Jun 22, 2011 Aa2
(sf) Placed Under Review for Possible Upgrade;

US$150,000,000 Class A-2 Delayed Draw Senior Secured Floating Rate
Notes Due 2017 Notes, Upgraded to Aaa (sf); previously on Jun 22,
2011 Aa2 (sf) Placed Under Review for Possible Upgrade;

US$16,600,000 Class B Second Priority Secured Floating Rate Notes
Due 2017 Notes, Upgraded to Aa2 (sf); previously on Jun 22, 2011
A2 (sf) Placed Under Review for Possible Upgrade;

US$38,900,000 Class C Third Priority Secured Floating Rate
Deferrable Notes Due 2017 Notes, Upgraded to Baa2 (sf); previously
on Jun 22, 2011 Baa3 (sf) Placed Under Review for Possible
Upgrade;

US$23,900,000 Class D-1 Fourth Priority Secured Floating Rate
Deferrable Notes Due 2017 Notes, Upgraded to Ba2 (sf); previously
on Jun 22, 2011 B2 (sf) Placed Under Review for Possible Upgrade;

US$4,000,000 Class D-2 Fourth Priority Secured Fixed Rate
Deferrable Notes Due 2017 Notes, Upgraded to Ba2 (sf); previously
on Jun 22, 2011 B2 (sf) Placed Under Review for Possible Upgrade;

US$5,000,000 Class 1 Composite Securities Due 2017 Notes, Upgraded
to A2 (sf); previously on Jun 22, 2011 Baa2 (sf) Placed Under
Review for Possible Upgrade;

US$9,200,000 Class 2 Composite Securities Due 2017 Notes, Upgraded
to A3 (sf); previously on Jun 22, 2011 Ba3 (sf) Placed Under
Review for Possible Upgrade;

US$8,000,000 Class 3 Composite Securities Due 2017 Notes, Upgraded
to A1 (sf); previously on Jun 22, 2011 B1 (sf) Placed Under Review
for Possible Upgrade;

US$1,500,000 Class 4 Composite Securities Due 2017 Notes, Upgraded
to A2 (sf); previously on Jun 22, 2011 B3 (sf) Placed Under Review
for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio since the rating action in October 2009.
Based on the latest trustee report dated June 2011, the Class A/B,
Class C and Class D overcollateralization ratios are in
compliance, reported at 121.0%, 111.0% and 1104.8%, respectively,
versus August 2009 levels of 117.2%, 107.6% and 101.7%,
respectively.

Moody's also notes that the deal has benefited from improvement in
the credit quality of the underlying portfolio since the rating
action. Based on the June 2011 trustee report, the weighted
average rating factor is currently 2315 compared to 2625 in August
2009.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes. Based on the June 2011 trustee report,
reference securities that mature after the maturity date of the
notes currently make up approximately 3.0% of the underlying
reference portfolio. These investments potentially expose the
notes to market risk in the event of liquidation at the time of
the notes' maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $523.7 million,
defaulted par of $2.7 million, a weighted average default
probability of 15.54% (implying a WARF of 2362), a weighted
average recovery rate upon default of 50.53%, and a diversity
score of 65. The 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.

BlackRock Senior Income Series II, issued in June 2005, 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
June 2011.

A secondary methodology used was "Using the Structured Note
Methodology to Rate CDO Combo-Notes" published in February 2004.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CLO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Delevering: The main source of uncertainty in this transaction
   is whether delevering from unscheduled principal proceeds will
   continue and at what pace. Delevering may accelerate due to
   high prepayment levels in the bond or loan market and/or
   collateral sales by the manager, which may have significant
   impact on the notes' ratings.

2) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

3) Long-dated assets: The presence of assets that mature beyond
   the CLO's legal maturity date exposes the deal to liquidation
   risk on those assets. Moody's assumes an asset's terminal value
   upon liquidation at maturity to be equal to the lower of an
   assumed liquidation value (depending on the extent to which the
   asset's maturity lags that of the liabilities) and the asset's
   current market value.


BUSINESS LOAN: Fitch Junks Rating on Two Class Certificates
-----------------------------------------------------------
Fitch Ratings takes these rating actions on four Business Loan
Express (BLX) transactions:

Business Loan Center SBA Loan-Backed Certificates 1998-1

  -- Class A affirmed at 'BB+sf'/Outlook Negative and withdrawn.

Business Loan Express Business Loan Trust 2002-A

  -- Class A downgraded to 'CCsf/RR2' from 'Asf' and withdrawn;
  -- Class B downgraded to 'CCsf/RR6' from 'BB+sf' and withdrawn.

Business Loan Express SBA loan-backed adjustable-rate notes,
series 2001-2

  -- Class A downgraded to 'CCsf/RR2' from 'BBBsf';
  -- Class M downgraded to 'CCsf/RR6' from Bsf.

Business Loan Express SBA loan-backed adjustable-rate notes,
series 2002-1

  -- Class A downgraded to 'BBBsf' from 'Asf'; Outlook Negative;
  -- Class M downgraded to 'BBsf' from 'BB+sf'; Outlook Negative.

The negative rating actions reflect continued deterioration within
the transactions.  Specifically, losses have increased as late-
stage delinquencies have continued to be charged off.
Furthermore, delinquencies have continued to roll through to
later-stage buckets.  Due to the higher delinquency performance
and the resulting loss expectation on the delinquent loans, the
transactions have experienced significant multiple compression
under Fitch's cashflow modeling analysis, detailed below.  As of
July 2011 reporting, total delinquencies for 2001-2, 2002-1, and
2002-A represent 23.05%, 24.08%, and 39.40%, respectively.

The Negative Outlook designation on the 2001-2 and 2002-1
transactions reflects Fitch's continued concern for near-term
potential asset deterioration which may ultimately impact the
ratings on the outstanding notes.  In particular, continued high
delinquency roll rates within the transactions may result in an
increase in net losses leading to a potential reduction in credit
support available to the notes.

The withdrawal of the ratings for the 1998-1 and 2002-A series is
the result of the fact that only a small number of loans (13)
remain in each transaction.  This creates obligor concentrations
and tail risk that are no longer consistent with Fitch's rating
methodology.  Fitch does not believe it can continue to maintain
ratings on bonds backed by pools with obligor counts that fall
below an acceptable number.

Fitch will continue to monitor the series 2001-2 and 2002-1 as the
transactions continue to amortize.  As obligor counts for the
pools continue to decline and tail risk increases, Fitch will
review the transactions for potential ratings action or
withdrawals.

In reviewing the transactions, Fitch took into account analytical
considerations outlined in Fitch's 'Global Structured Finance
Rating Criteria', dated Aug. 16, 2010, including asset quality,
credit enhancement, financial structure, legal structure, and
originator and servicer quality.

Fitch's analysis incorporated a review of collateral
characteristics, in particular, focusing on delinquent and
defaulted loans within the pool.  All loans over 60 days
delinquent were deemed defaulted loans.  The defaulted loans were
applied loss and recovery expectations based on collateral type
and historical recovery performance to establish an expected net
loss assumption for the transaction. Fitch stressed the cashflows
generated by the underlying assets by applying its expected net
loss assumption.  Furthermore, Fitch applied a loss multiplier to
evaluate break-even cash flow runs to determine the level of
expected cumulative losses the structure can withstand at a given
rating level.  The loss multiplier scale utilized is consistent
with that of other commercial ABS transactions.

Additionally, to review possible concentration risks within the
pool, Fitch evaluated the impact of the default of the largest
performing obligors.  Similar to the analysis detailed above,
Fitch applied loss and recovery expectations to the performing
obligors based on collateral type and historical recovery
performance.  The expected loss assumption was then compared to
the credit support available to the outstanding notes given
Fitch's expected losses on the currently defaulted loans.
Consistent with the obligor approach detailed in 'Rating US
Equipment Lease and Loan Securitizations', dated June 16, 2008,
Fitch applied losses from the largest performing obligors
commensurate with the individual rating category.  The number of
obligors ranges from 20 at 'AAA' to five at 'B'.

Fitch will continue to closely monitor these transactions and may
take additional rating action in the event of changes in
performance and credit enhancement measures.


CALLIDUS DEBT: Moody's Raises Ratings of Six Classes of Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Callidus Debt Partners CLO Fund IV, Ltd.:

US$50,000,000 Class A-1A Revolving Senior Secured Floating Rate
Notes Due 2020 (current outstanding balance of $49,480,041),
Upgraded to Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed
Under Review for Possible Upgrade;

US$327,000,000 Class A-1B Senior Secured Floating Rate Notes Due
2020 (current outstanding balance of $325,561,466), Upgraded to
Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review
for Possible Upgrade;

US$25,000,000 Class A-2 Senior Secured Floating Rate Notes Due
2020, Upgraded to Aa2 (sf); previously on June 22, 2011 A1 (sf)
Placed Under Review for Possible Upgrade;

US$26,500,000 Class B Senior Secured Deferrable Floating Rate
Notes Due 2020, Upgraded to A3 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$25,000,000 Class C Senior Secured Deferrable Floating Rate
Notes Due 2020, Upgraded to Ba1 (sf); previously on June 22, 2011
B1 (sf) Placed Under Review for Possible Upgrade;

US$16,000,000 Class D Senior Secured Deferrable Floating Rate
Notes Due 2020, Upgraded to Ba3 (sf); previously on June 22, 2011
Caa2 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in July 2009.
In particular, as of the trustee report dated August 2011, the
weighted average rating factor is currently 2401 compared to 2740
in the June 2009 report. The Class A, Class B, Class C, and Class
D overcollateralization ratios are reported at 123.50%, 115.80%,
109.40%, and 105.70%, respectively, versus June 2009 levels of
119.70%, 112.30%, 106.10%, and 102.50%, respectively, and all
related overcollateralization tests are currently in compliance.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par balance, including principal proceeds, of $494
million, defaulted par of $1.2 million, a weighted average default
probability of 20.2% (implying a WARF of 2730), a weighted average
recovery rate upon default of 49.4%, and a diversity score of 70.

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.

Callidus Debt Partners CLO Fund IV, Ltd., issued in April 2006, 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
June 2011.

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 June 2011.

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 2013 and
2016 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the managers'
investment strategies and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

A source of additional performance uncertainties is collateral
quality metrics: The deal is allowed to reinvest and the manager
has the ability to deteriorate the collateral quality metrics'
existing cushions against the covenant levels. Moody's analyzed
the impact of assuming worse of reported and covenanted values for
weighted average rating factor and diversity score. As part of the
base case, Moody's considered weighted average coupon and weighted
average spread levels higher than the covenant levels due to the
large difference between the reported and covenant levels.


CAPELLA FUNDING: S&P Removes Class 1 Notes 'BB' Rating From Watch
-----------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its rating on the
class 1 notes from Capella Funding Ltd., a U.S. hybrid
collateralized debt obligation (CDO) transaction of high-grade
residential mortgage-backed securities (RMBS), managed by AXA
Investment Managers S.A. "Concurrently, we removed our rating on
the class 1 notes from CreditWatch, where we placed it with
negative implications on May 25, 2011," S&P related.

The affirmation reflects the credit quality supporting the notes
at the current rating level and only addresses the ultimate
repayment of principal. "We placed the rating on the class 1 note
on CreditWatch following the CreditWatch negative placements taken
on the underlying RMBS collateralizing the CDO notes (see '25
Ratings On 14 CDOs Of Structured Finance Transactions Placed On
Watch Negative,' published May 25, 2011). At that time, the
transaction had approximately 67% of its collateral on CreditWatch
negative. Since that time, we have affirmed the majority of the
underlying ratings and removed them from CreditWatch. Capella
Funding Ltd. currently has approximately 10% of its underlying
RMBS on CreditWatch with negative implications," S&P stated.

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

Rating and CreditWatch Actions

Capella Funding Ltd.
                Rating
Class       To           From
1           BB (sf)      BB (sf)/Watch Neg

Transaction Information

Issuer:             Capella Funding Ltd.
Coissuer:           Capella Funding Corp.
Collateral manager: AXA Investment Managers S.A.
Underwriter:        Wachovia Securities Inc.
Trustee:            Bank of New York Mellon (The)
Transaction type:   Hybrid CDO


CAPITALSOURCE REAL: Fitch Affirms Junk Rating on 7 Note Classes
---------------------------------------------------------------
Fitch Ratings has affirmed all classes of CapitalSource Real
Estate Loan Trust 2006-A (CapitalSource 2006-A) reflecting Fitch's
base case loss expectation of 27.3%.  Fitch's performance
expectation incorporates prospective views regarding commercial
real estate market value and cash flow declines.

Since last review, classes A-1A and A-2A have been paid down by
$131 million (10% of the original transaction balance).  While
proceeds have also been directed to pay down the A-1R notes, these
payments only serve to increase the amount of available undrawn
capacity.  The revolver class continues to maintain its total
capacity of $200 million. Since last review, the disposal of
multiple assets from the collateralized debt obligation (CDO)
resulted in realized losses to par of greater than $90 million.
However, these losses were offset by par building of approximately
$108 million from the purchase of new assets, predominately whole
loan/A-note positions and commercial mortgage-backed securities
(CMBS).

CapitalSource 2006-A is primarily collateralized by senior
commercial real estate (CRE) debt with 73.6% of the total
collateral consisting of whole loans/A-notes.  As of the July 2011
trustee report and per Fitch categorization, the remaining
collateral consisted of principal cash (10.7%), CMBS (7.2%),
rediscount facilities (3.4%), B-notes (3.2%), and term loan
financing (1.9%).  Additionally, Fitch is generally concerned with
the high percentage of the total collateral secured by non-
traditional property types, including resort/timeshare (15.4%),
hotel (13.3%), land (9.4%), healthcare (7.6%), and casino (4.8%).

Defaulted assets comprise 3.2% of the total collateral and include
five whole loans, three of which are secured by land (1.7%), one
of which is secured by multifamily (1.4%), and one of which is
secured by healthcare (0.1%).  An additional 18 loans (26.8%) were
identified as Loans of Concern.  These Loans of Concern include 16
whole loan/A-notes (25.3%) and two B-notes (1.5%).  Fitch modeled
significant losses on the defaulted assets and Loans of Concern.

CapitalSource 2006-A was initially issued as a $1.3 billion
revolving CRE CDO with a five-year reinvestment period ending in
January 2012.  All overcollateralization and interest coverage
ratios have remained above their covenants as of the July 2011
trustee report.

Under Fitch's surveillance methodology, approximately 80% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 9.8%.  Fitch estimates that average
recoveries will be at 65.9%.

The largest component of Fitch's base case loss expectation is an
A-note (6.6%) which was initially secured by the construction of a
hotel property located in Atlantic City, NJ.  Construction has
since been completed and the property is fully operational.  Year-
end 2010 property cash flow is insufficient to support debt
service.  Fitch modeled a term default with a significant loss
under its base case scenario.

The second largest component of Fitch's base case loss expectation
is an A-note (2.9%) secured by over 2,000 acres of land located in
the Pocono Mountains of Pennsylvania.  The initial business plan
was to develop the site in multiple phases, but due to economic
downturn, the plan was not realized.  Fitch modeled a term default
with a significant loss under its base case scenario.

The third largest component of Fitch's base case loss expectation
is a whole loan (2.1%) secured by a 64-key beachfront hotel
property located in Cape May, NJ.  The borrower's original
business plan was to demolish the existing structure and construct
luxury condominium units.  However, due to economic downturn, the
borrower has been operating the hotel on a seasonal basis.  Fitch
modeled a term default with a significant loss under its base case
scenario.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Based on this analysis, the breakeven rates for classes A-1A, A-
1R, A-2A, A-2B, and B are generally consistent with the ratings
assigned below.

The ratings for classes C through J are based on a deterministic
analysis that considers Fitch's base case loss expectation for the
pool and the current percentage of defaulted assets and Fitch
Loans of Concern factoring in anticipated recoveries relative to
each class' credit enhancement.  These classes were assigned
Recovery Ratings (RRs) in order to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities.

The Rating Outlook on class A-2A was revised to Stable based upon
its senior position in the capital structure.  Classes A-1A, A-1R,
A-2B, and B maintain a Negative Outlook reflecting Fitch's
expectation for further potential negative credit migration of the
underlying collateral.

At issuance, the CDO was managed by CapitalSource Finance, LLC
(CapitalSource), a subsidiary of CapitalSource, Inc. In the fourth
quarter of 2010, NS Advisors II, LLC (NS Advisors II) became the
delegated collateral manager for the CDO under the delegation
provisions of the Indenture.  All collateral manager
responsibilities and fees have been delegated to NS Advisors II.
In addition, an amendment to the servicing agreement replaced the
special servicer of the CDO to NS Servicing, LLC (NS Servicing).
NS Servicing assumed all rights, interests, duties, and
obligations as special servicer under the servicing agreement,
previously held by CapitalSource.

In June 2009, Fitch was notified by the trustee that a tax event
had occurred under the terms of the indenture.  CapitalSource Inc.
revoked its REIT election as of Jan. 1, 2009, causing the issuer
to lose its status as a Qualified REIT Subsidiary for U.S. income
tax purposes.  Consequently, the issuer was treated as a
corporation subject to income taxes for the remaining life of the
deal.  According to discussions with NS Advisors II, it is
expected that the CDO will resume as a non-taxable entity. The CDO
currently has a tax reserve account in place which has a balance
of $24.5 million as of the July 2011 trustee report.

Fitch has affirmed and revised Recovery Ratings (RRs) on these
classes:

  -- $49.6 million class A-1A at 'BB'; Outlook Negative;
  -- $200 million class A-1R at 'BB'; Outlook Negative;
  -- $315.6 million class A-2A at 'BB'; Outlook to Stable from
     Negative;
  -- $125 million class A-2B at 'BB'; Outlook Negative;
  -- $82.9 million class B at 'B'; Outlook Negative;
  -- $62.4 million class C at 'CCC/RR4';
  -- $30.2 million class D at 'CCC/RR6';
  -- $30.2 million class E at 'CCC/RR6';
  -- $26.7 million class F at 'CC/RR6';
  -- $33.2 million class G at 'CC/RR6';
  -- $31.2 million class H at 'C/RR6';
  -- $47.5 million class J at 'C/RR6'.


CD 2006-CD3: Moody's Affirms Ratings of 20 CMBS Classes
-------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 20
classes and downgraded one class of CD 2006-CD3 Commercial
Mortgage Trust Commercial Mortgage Pass Through Certificates,
Series 2006-CD3:

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

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

Cl. A-AB, Affirmed at Aaa (sf); previously on Nov 14, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Oct 7, 2010 Confirmed
at Aaa (sf)

Cl. A-5, Affirmed at Aaa (sf); previously on Oct 7, 2010 Confirmed
at Aaa (sf)

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

Cl. A-M, Affirmed at A1 (sf); previously on Oct 7, 2010 Downgraded
to A1 (sf)

Cl. A-J, Downgraded to Ba3 (sf); previously on Oct 7, 2010
Downgraded to Baa3 (sf)

Cl. A-1A, Affirmed at Ba3 (sf); previously on Oct 7, 2010
Downgraded to Ba3 (sf)

Cl. B, Affirmed at B1 (sf); previously on Oct 7, 2010 Downgraded
to B1 (sf)

Cl. C, Affirmed at B2 (sf); previously on Oct 7, 2010 Downgraded
to B2 (sf)

Cl. D, Affirmed at B3 (sf); previously on Oct 7, 2010 Downgraded
to B3 (sf)

Cl. E, Affirmed at Caa1 (sf); previously on Oct 7, 2010 Downgraded
to Caa1 (sf)

Cl. F, Affirmed at Caa2 (sf); previously on Oct 7, 2010 Downgraded
to Caa2 (sf)

Cl. G, Affirmed at Caa3 (sf); previously on Oct 7, 2010 Downgraded
to Caa3 (sf)

Cl. H, Affirmed at Ca (sf); previously on Oct 7, 2010 Downgraded
to Ca (sf)

Cl. J, Affirmed at C (sf); previously on Oct 7, 2010 Downgraded to
C (sf)

Cl. K, Affirmed at C (sf); previously on Oct 7, 2010 Downgraded to
C (sf)

Cl. L, Affirmed at C (sf); previously on Oct 7, 2010 Downgraded to
C (sf)

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

Cl. XS, Affirmed at Aaa (sf); previously on Nov 14, 2006
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. The downgrade is the
result of a correction in Moody's previous analysis of the cash
flow waterfall. When Class A-J was downgraded on October 7, 2010,
Moody's misinterpreted how the realized losses would be applied.
The rating action reflects the corrected cash flow waterfall.

Moody's rating action reflects a cumulative base expected loss of
9.2% of the current balance compared to 12.2% at last review.
Moody's stressed scenario loss is 19.8% 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. Due to the high level of credit subordination
and defeasance, it is unlikely that investment grade classes would
be downgraded even if losses are higher than Moody's expected
base.

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 ratings was "Moody's
Approach to Rating Fusion U.S. CMBS 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 and the CMBS Large Loan Model v 8.0. Conduit model
results at the Aa2 (sf) 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 (sf)
level are driven by a pay down 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 (sf) and B2 (sf), the remaining conduit classes are either
interpolated between these two data points or determined based on
a multiple or ratio of either of these two data points. For fusion
deals, the credit enhancement for loans with investment-grade
underlying ratings is melded with the conduit model credit
enhancement into an overall model result. Fusion loan credit
enhancement is based on the credit estimate of the loan which
corresponds to a range of credit enhancement levels. Actual fusion
credit enhancement levels are selected based on loan level
diversity, pool leverage and other concentrations and correlations
within the pool. Negative pooling, or adding credit enhancement at
the underlying rating level, is incorporated for loans with
similar credit estimates in the same transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 41 compared to 37 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 October 7, 2010. Please see
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

DEAL PERFORMANCE

As of the August 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 7% to $3.328
billion from $3.571 billion at securitization. The Certificates
are collateralized by 189 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten conduit loans
representing 35% of the pool. The pool does not contain any
defeased loans and there is currently one loan, representing 8% of
the pool, with an investment grade credit estimate.

Moody's was provided with full year 2009 and partial year 2010
operating results for 100% and 78% of the performing pool,
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 106% compared to 107% at last
review. Moody's net cash flow reflects a weighted average haircut
of 10% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.4%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.30X and 1.01X, respectively, compared to
1.26X and 0.98X 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.

Thirty three loans, representing 17% of the pool, are currently in
special servicing. The largest specially serviced loan is the High
Point Furniture Mart Loan ($111.6 million -- 3.4% of the pool),
which is secured by a 2.0 million square foot (SF) office and home
furnishing exhibit complex located in High Point, North Carolina.
The loan was transferred to special servicing in March 2010 as a
result of payment default. The loan was sold to Related Properties
& Bain Company in March 2011 for $139.5 million. Subsequently, the
loan was paid down by $27.9 million in cash and the existing debt
was assumed at a price of $111.6 million. As a result, the trust
endured a $51 million loss. The loan is current and Moody's does
not estimate any additional losses from this loan at this time.

The remaining 32 specially serviced loans are secured by a mix of
property types. The master servicer has recognized an aggregate
$156.3 million appraisal reduction for 30 of these loans. Moody's
has estimated an aggregate $159.2 million loss (42% expected loss
on average) for 27 of these loans.

Forty-eight loans, representing 22% of the pool, are currently 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. Moody's has estimated an aggregate
$70.8 million loss (20% expected loss based on a 50% probability
of default) from these troubled loans.

Based on the most recent remittance statement, Classes F through S
have experienced cumulative interest shortfalls totaling $14.4
million. At last review, interest shortfalls totaled $3.9 million
and affected Class K through S. Moody's anticipates that the pool
will continue to experience interest shortfalls because of the
high exposure to specially serviced loans. Interest shortfalls are
caused by special servicing fees, including workout and
liquidation fees, appraisal entitlement reductions (ASERs),
modifications and extraordinary trust expenses.

Four loans have been liquidated from the pool since
securitization, resulting in an aggregate $19.7 million loss (66%
loss severity on average). The pool has also realized an
additional $66 million in losses from eleven modified loans.

The loan with a credit estimate is the GGP sponsored Ala Moana
Portfolio Loan ($261.2 million -- 7.8% of the pool), which
represents a pari-passu interest in a first mortgage loan secured
by a 2.0 million square foot SF mixed-use portfolio located on the
island of Hawaii. The largest property is the Ala Moana Mall,
which is considered the world's largest open-air shopping center.
As of March 2011, the portfolio was 95% leased, essentially the
same as last review. The loan was transferred to special servicing
in April 2009 when GGP filed for bankruptcy. Since exiting
bankruptcy, GGP paid down the current portfolio loan balance by
$150 million. Additionally, the loan's maturity date was extended
to 2018 and the loan was restructured with a 25-year amortization
schedule. Moody's credit estimate and stressed DSCR are A3 and
0.89X, respectively, compared to A3 and 0.90X at Moody's last
review.

The top three conduit loans represent 17% of the pool balance. The
largest loan is the ShopKo Portfolio Loan ($243.1 million -- 7.3%
of the pool) which represents a pari-passu interest in a first
mortgage loan secured by 112 cross-collateralized and cross-
defaulted ShopKo retail stores. The stores are located in 12
states, with a total of 10,974,960 SF. The stores are all operated
under 15-year triple net leases. One of the properties, which is
located in Green Bay, Wisconsin, serves and Shop Ko's
headquarters. Moody's LTV and stressed DSCR are 80% and 1.23X,
respectively, compared to 87% and 1.13X at last review.

The second largest loan is the Intercontinental Boston Hotel Loan
($175.0 million -- 5.3% of the pool), which is secured by a 424-
room, luxury hotel located in Boston's Financial District. The
hotel was constructed in 2006 and is affiliated with the
Intercontinental Hotel Group, which signed a 99-year triple net
lease. The loan is interest-only throughout its 15-year term.
There is additional mezzanine debt of $45 million. Moody's LTV and
stressed DSCR are 147% and 0.75X, respectively, the same as at
Moody's last review.

The third largest loan is the Fair Lakes Office Portfolio Loan
($142.5 million -- 4.3% of the pool), which represents a pari
passu interest in a first mortgage loan secured by a 1.25 million
SF office park located in Fairfax, Virginia. The complex consists
of nine buildings ranging in size from 75,000 SF to 275,000 SF. As
of December 2010, the complex was 89% leased compared to 87% at
last review. Over 60% of the net rentable area is due to expire
prior to loan maturity. The loan sponsor is the Shorenstein
Company. Moody's LTV and stressed DSCR are 118% and 0.84X compared
to 111% and 0.90X, respectively, at last review.


CITIGROUP COMM: Fitch Affirm 'CCCsf' Rating on 5 Note Classes
-------------------------------------------------------------
Fitch Ratings has removed five classes of Citigroup Commercial
Mortgage Trust (CGCMT) commercial mortgage pass-through
certificates, series 2006-FL2 from Rating Watch Negative and
affirmed all classes.  The resolution of the Rating Watch and the
affirmations reflect Fitch's updated base case loss expectation of
18.7%.  Fitch's performance expectation incorporates prospective
views regarding commercial real estate market value and cash flow
declines.

The Rating Watch Negative removals reflect the special servicer's
receipt of an updated appraisal for the Radisson Ambassador Plaza
Hotel & Casino, the largest loan in the pool (33%).  In addition,
since Fitch's July 2011 rating action, the CarrAmerica National
Pool Portfolio has paid down by approximately 18% and the
CarrAmerica CARP Pool Portfolio paid off in full.

Under Fitch's methodology, 100% of the remaining pool is modeled
to default in the base case stress scenario, defined as the 'B'
stress.  In this scenario, the modeled average cash flow decline
is 10% from generally 2010. To determine a sustainable Fitch cash
flow and stressed value, Fitch analyzed servicer-reported
operating statements and rent rolls, updated property valuations,
and recent sales comparisons.  Fitch estimates the average
recoveries on the pooled loans will be approximately 81% in the
base case.

The transaction is collateralized by six loans, which includes
three secured by hotels (56.8% of the total trust balance), two by
offices (31.6%), and one by a mixed-use (hotel/office) property
(11.6%).  All six remaining loans are in special servicing, having
transferred for imminent or actual maturity default.

With respect to the pooled classes, two loans were modeled to take
a loss in the base case: Radisson Ambassador Plaza Hotel & Casino
(32.7%) and Doubletree Hospitality & Centre Plaza Office (10.6%).
Of the six remaining junior non-pooled classes rated by Fitch, the
two classes associated with the Radisson Ambassador Plaza Hotel &
Casino were modeled with losses.

The largest contributor to loss under the 'B' stress remains
the specially-serviced Radisson Ambassador Plaza Hotel & Casino
loan, which is secured by a 233-room, full-service hotel and
approximately 15,000 square foot (sf) casino located in San Juan,
Puerto Rico.  The loan transferred to special servicing in June
2011 for imminent maturity default.  The loan was structured with
an initial maturity of July 9, 2008, with three one-year extension
options.  The borrower exercised its third and final extension
option, which expired on July 9, 2011.  According to the servicer,
the loan had not been extended beyond its final maturity and
discussions are ongoing with the borrower regarding potential
resolutions.  As of the Aug. 17, 2011 remittance, the special
servicer received an updated appraisal.  As is common with hotel
properties, the appraised value is higher than that derived by
capitalizing current property operating income.  Fitch continues
to model significant losses to the senior pooled component based
on a Fitch adjustment to the updated valuation.  The non-pooled
RAM-1 and RAM-2 classes associated with the loan continue to be
modeled with no recoveries in the base case.

The other contributor to loss under the 'B' stress is the
specially-serviced Doubletree Hospitality & Centre Plaza Office
loan, which is secured by a mixed-use property containing 258
hotel rooms, 59,287 sf of office space, and 2,757 sf of retail
space located in Modesto, CA.  The loan transferred to special
servicing in May 2011 for imminent maturity default and was
structured with an initial maturity of July 9, 2008, with three
one-year extension options.  The borrower exercised its third and
final extension option, which expired on July 9, 2011.  According
to the special servicer, a 60-day extension was granted as it
works with the borrower to determine a longer term resolution.

Fitch has affirmed and removed from Rating Watch Negative the
following classes:

  -- $22.4 million class J 'BBB+sf', Outlook Stable;
  -- $22.4 million class K 'CCCsf/RR5';
  -- $23.9 million class L 'CCsf/RR6';
  -- $2 million class RAM-1 'CCsf/RR6';
  -- $2.4 million class RAM-2 'CCsf/RR6'.

Fitch has affirmed the following classes:

  -- $12.5 million class E at 'AAAsf', Outlook Stable;
  -- $26.9 million class F at 'AAAsf', Outlook Stable;
  -- $23.9 million class G at 'AAsf', Outlook Stable;
  -- $20.9 million class H at 'A-sf', Outlook Stable;
  -- $581,390 class CAN-1 at 'BBB+sf', Outlook Stable;
  -- $861,996 class CAN-2 at 'BBBsf', Outlook Stable;
  -- $1.7 million class CAN-3 at 'BBB-sf', Outlook Stable;
  -- $948,936 class DSG-1 at 'BBB-sf', Outlook Stable.

The following classes originally rated by Fitch have paid in full:
A-1, A-2, X-1, B, C, D, CAC-1, CAC-2, CAC-3, CNP-1, CNP-2, CNP-3,
HFL, HGI-1, HGI-2, HMP-1, HMP-2, HMP-3, MVP, WBD-1, and WBD-2.  In
addition, Fitch previously withdrew the ratings on the interest-
only classes X-2 and X-3.

Fitch does not rate the non-pooled classes DHC-1, DHC-2, DHC-3,
DSG-2, PHH-1, PHH-2, SRL, and WPP.


CLASS V FUNDING: Moody's upgrades Ratings of One Class of Notes
---------------------------------------------------------------
Moody's Investors Service  has upgraded the ratings of one class
of notes issued by Class V Funding II, Limited. The class of notes
affected by the rating actions are:

US$68,000,000 Class A-1 Second Priority Senior Secured Floating
Rate Notes Due 2046 (current balance: 60,282,753), Upgraded to
Caa2 (sf), Remaining on review for Possible Upgrade, previously on
June 24, 2011 Ca (sf), Placed on Review for Possible Upgrade

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes result
primarily from the improvement of the credit quality of the
portfolio. As of the latest trustee report dated August 18, 2011,
the WARF is reported at 978 versus July 2010 reported WARF of
3393.

An Event of Default under Section 5.1(i) of the Indenture was
declared by the Trustee on January 22, 2008 because the Class
A/B/C Overcollateralization Percentage was less than 100%. On
June 15, 2011 the Trustee received direction to accelerate the
Notes. Under an acceleration the Class A-1 notes will receive all
interest and principal payments before any further payments are
made on account of the other classes of Notes. As provided in
Article V of the Indenture during the occurrence and continuance
of an Event of Default, certain parties to the transaction may be
entitled to direct the Trustee to take particular actions with
respect to the Collateral and the Notes, including the sale and
liquidation of the assets. The severity of losses of certain
tranches may be different depending on the timing and outcome of a
liquidation.

Following an announcement by Moody's on June 22nd that nearly all
CLO tranches currently rated Aa1 and below were placed on review
for possible upgrade ("Moody's places 4,220 tranches from 611 U.S.
and 171 European CLO transactions on review for upgrade"), 98
tranches of U.S. and European Structured Finance (SF) CDOs with
material exposure to CLOs were also placed on review for possible
upgrade ("Moody's places 98 tranches from 19 U.S. and 3 European
SF CDO transactions with exposure to CLOs on review for upgrade").
The rating action on the notes reflects CLO tranche upgrades that
have taken place thus far, as well as a two notch adjustment for
CLO tranches which remain on review for possible upgrade.
According to Moody's, $22 million of the collateral has been
upgraded since June 22, and $41 million remains on review.

Class V Funding II, Ltd. is a collateralized debt obligation
backed primarily by a portfolio of CLOs, and SF CDOs.

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
CDOROMv2.8 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
pool. 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 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.


COMM 2001-J2: Moody's Reviews Ratings of Four CMBS Classes
----------------------------------------------------------
Moody's Investors Service (Moody's) placed four classes of COMM
2001-J2 Commercial Pass-Through Certificates, Series 2001-J2 on
review for possible downgrade:

Cl. B, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Aug 2, 2011 Confirmed at Aaa (sf)

Cl. C, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Aug 2, 2011 Confirmed at Aaa (sf)

Cl. D, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Aug 2, 2011 Confirmed at Aaa (sf)

Cl. H, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 27, 2007 Downgraded to Caa1 (sf)

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from anticipated
increases in interest shortfalls.

On July 15, 2011 Moody's placed five classes on review for
possible downgrade due to an increase in interest shortfalls as a
result of a $986,000 workout fee related to a General Growth
Property (GGP) mall which was modified pursuant to GGP's
bankruptcy and reorganization plan. The loan paid off on June 1,
2011. Consequently, classes E, E-CS, E-IO, F and G of this
transaction are already on review for possible downgrade.
Cumulative interest shortfalls total almost $1.8 million as of the
August 16, 2011 remittance report and affect Classes E through H.
Additional workout fees will be payable to the special servicer
when the two remaining loans in the trust, the Willowbrook Mall
Loan and the AT&T Building Loan, pay off. The workout fees will be
1% of the loan balances at the time of pay off. The two loans have
a current combined outstanding loan balance of $348.4 million.

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 December 2, 2010.

The principal methodology used in this rating was "Moody's
Approach to Rating CMBS Large Loan/Single Borrower Transactions,"
published July 2000.

DEAL AND PERFORMANCE SUMMARY

As of the August 16, 2011 distribution date, the deal's aggregate
certificate balance has decreased by 77% to $348.4 million from
$1.5 billion at securitization. The Certificates are
collateralized by two mortgage loans. The largest loan in the
pool, AT&T Building Loan ($197 million -- 56% of the pool) is
fully defeased and is secured by US Government securities.

The second loan is the Willowbrook Mall Loan ($152 million -- 44%
of the pool), which is secured by approximately 500,000 square
feet of mall shop space in a 1.5 million square foot super-
regional mall located in Wayne, New Jersey. Willowbrook Mall,
considered one of the top malls in the region, is anchored by
Macy's, Bloomingdales, Lord & Taylor and Sears. As of December
2010 the in-line space was approximately 95% leased. Comparable
in-line sales for calendar year 2010 were $630 per square foot
with an occupancy cost of approximately 14%. The loan sponsor is
an affiliate of GGP. GGP emerged from bankruptcy protection in
November 2010. As part of GGP's bankruptcy plan, the loan's
maturity date was extended from July 1, 2011 to June 30, 2016

Neither of the two loans in the trust are on the servicer's
watchlist. The watchlist includes loans which meet certain
portfolio review guidelines established as part of the CRE Finance
Council (CREFC; formerly the Commercial Mortgage Securities
Association) monthly reporting package. As part of Moody's ongoing
monitoring of a transaction, Moody's reviews the watchlist to
assess which loans have material issues that could impact
performance. Neither loan is in special servicing.

Moody's review will focus on the impact that the current and
expected interest shortfalls will have on the trust certificates.


COMM 2007-FL14: Moody's Downgrades Ratings of 10 CMBS Classes
-------------------------------------------------------------
Moody's Investors Service (Moody's) downgraded the ratings of ten
pooled classes, upgraded the rating of one non-pooled, or rake,
class and affirmed the ratings of sixteen classes, including six
pooled classes and ten rake classes of COMM 2007-FL14 Commercial
Pass-Through Certificates, Series 2007-FL14:

Cl. A-1, Affirmed at Aaa (sf); previously on May 24, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on May 24, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-3-DB, Affirmed at Aaa (sf); previously on May 24, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-3-SG, Affirmed at Aaa (sf); previously on May 24, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-5-DB, Affirmed at Aaa (sf); previously on May 24, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-5-SG, Affirmed at Aaa (sf); previously on May 24, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-J, Downgraded to A1 (sf); previously on Dec 9, 2010
Downgraded to Aa3 (sf)

Cl. B, Downgraded to A3 (sf); previously on Dec 9, 2010 Downgraded
to A2 (sf)

Cl. C, Downgraded to Baa2 (sf); previously on Dec 9, 2010
Downgraded to Baa1 (sf)

Cl. D, Downgraded to Ba1 (sf); previously on Dec 9, 2010
Downgraded to Baa3 (sf)

Cl. E, Downgraded to Ba3 (sf); previously on Dec 9, 2010
Downgraded to Ba2 (sf)

Cl. F, Downgraded to B2 (sf); previously on Dec 9, 2010 Downgraded
to B1 (sf)

Cl. G, Downgraded to B3 (sf); previously on Dec 9, 2010 Downgraded
to B2 (sf)

Cl. H, Downgraded to Caa1 (sf); previously on Dec 9, 2010
Downgraded to B3 (sf)

Cl. J, Downgraded to Caa2 (sf); previously on Dec 9, 2010
Downgraded to Caa1 (sf)

Cl. K, Downgraded to Caa3 (sf); previously on Dec 9, 2010
Downgraded to Caa2 (sf)

Cl. GLB1, Affirmed at B1 (sf); previously on Dec 9, 2010
Downgraded to B1 (sf)

Cl. GLB2, Affirmed at B2 (sf); previously on Dec 9, 2010
Downgraded to B2 (sf)

Cl. GLB4, Affirmed at Caa1 (sf); previously on Dec 9, 2010
Downgraded to Caa1 (sf)

Cl. PG1, Affirmed at Ba1 (sf); previously on Feb 24, 2009
Downgraded to Ba1 (sf)

Cl. PG2, Affirmed at Ba2 (sf); previously on Feb 24, 2009
Downgraded to Ba2 (sf)

Cl. PG3, Affirmed at Ba3 (sf); previously on Feb 24, 2009
Downgraded to Ba3 (sf)

Cl. PG4, Affirmed at B1 (sf); previously on Feb 24, 2009
Downgraded to B1 (sf)

Cl. PH1, Affirmed at B1 (sf); previously on Dec 9, 2010 Downgraded
to B1 (sf)

Cl. PH2, Affirmed at B2 (sf); previously on Dec 9, 2010 Downgraded
to B2 (sf)

Cl. PH3, Affirmed at B3 (sf); previously on Dec 9, 2010 Downgraded
to B3 (sf)

Cl. SA1, Upgraded to Ba1 (sf); previously on Feb 24, 2009
Downgraded to Ba3 (sf)

RATINGS RATIONALE

The downgrades were due to the decrease in pool diversity that
resulted from the payoff on August 9, 2011 of the
Trizec/Blackstone Portfolio Loan that accounted for 11% of the
total pooled balance and the deterioration in the performance of
the Rose Orchard Technology Park Loan where occupancy has
decreased to 36% from 80% in December 2010 due to one tenant's
lease expiration. The upgrade of rake Class SA1 was due to the
improved performance of the Sheraton Austin Loan. The affirmations
were due to key parameters, including Moody's loan to value (LTV)
ratio remaining within an acceptable range.

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

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 performance
in the commercial real estate property markets. While commercial
real estate property markets are gaining momentum, a consistent
upward trend will not be evident until the volume of transactions
increases, distressed properties are cleared from the pipeline and
job creation rebounds. The hotel and multifamily sectors are
continuing to show signs of recovery through the first half of
2011, while recovery in the non-core office and retail sectors are
tied to pace of recovery of the broader economy. Core office
markets are showing signs of recovery through lending and leasing
activity. 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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

The principal methodology used in this rating was "Moody's
Approach to Rating CMBS Large Loan/Single Borrower Transactions"
published in July 2000. Please see the Credit Policy page on
www.moodys.com for a copy of this methodology.

Moody's review incorporated the use of the excel-based Large Loan
Model v 8.1. 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 review is
summarized in a press release dated December 9, 2010.

DEAL PERFORMANCE

As of the August 15, 2011 Distribution Date, the transaction's
aggregate certificate balance has decreased by approximately 68%
to $793.2 million from $2.5 billion at securitization due to the
pay off of five loans originally in the pool. The certificates are
collateralized by seven mortgage loans ranging in size from 4% to
51% with the largest three loans representing 78% of the pool. All
the loans in the pool have final maturity dates within the next
six months.

Moody's weighted average pooled loan to value (LTV) ratio is 84%,
the same as last review. Moody's stressed debt service coverage
(DSCR) is 1.24, compared to 1.21X at last review.

The trust has incurred $31,273 in cumulative losses affecting
Class K, and $4,381 in interest shortfalls also affecting Class K.
There is currently one loan in special servicing, the New Jersey
Office Portfolio Loan that was transferred to special servicing in
January 2011 due to a maturity default.

The MSREF/Glenborough Portfolio Loan ($343.7 million -- 51% of the
pooled balance) is secured by 16 class A and B office properties
with a total of 2.0 million square feet, located in five states,
California, Virginia, Colorado, Nevada and Florida. The properties
range in size from 79,393 square feet to 303,802 square feet with
an average size of 17,698 square feet. Since securitization four
properties totaling 432,388 square feet were released from the
loan collateral. The $526.5 million whole loan includes non-pooled
trust debt of $71.8 million, certificate Classes GLB1, GLB2, GLB3
and GLB4, and a $111.0 million non-trust junior component. The
trust debt has paid down by 4% since securitization due to
premiums paid for collateral releases. There is also approximately
$311 million in mezzanine debt. As of March 2011 the portfolio was
87% leased compared to 88% at last review. Moody's LTV for the
pooled debt is 88%, the same as last review. Moody's credit
estimate is Ba3, the same as last review.

The Poughkeepsie Galleria Loan ($142.5 million -- 18% of the
pooled balance) is secured by a portion of a 1.2 million square
foot dominant regional mall located in Poughkeepsie, New York. The
mall is anchored by J.C. Penney, Macy's, Sears, Target and a 16-
screen Regal Cinema. The Macy's, Sears and Target stores are
anchor-owned and not part of the loan collateral. The $176.0
million whole loan includes non-pooled trust debt of $21.4
million, certificate Classes PG1, PG2, PG3 and PG4, and a $33.5
million non-trust junior component. Comparable tenant sales for
calendar year 2010 were $375 per square foot. In-line occupancy
cost, both in 2010 and at securitization, of approximately 17% is
higher than typical for malls with tenant sales at this level.
Moody's took this into account in its analysis. As of March 2011
in-line vacancy was 24%, compared to 22% at last review. Moody's
LTV for the pooled debt is 75%, the same as last review. Moody's
credit estimate is Ba1, the same as last review.

San Francisco Parc 55 ($67.6 million -- 10% of the pooled balance)
is secured by a 1,009-unit Wyndham hotel located in downtown San
Francisco, California. The hotel recently completed a $30 million
renovation and was re-branded under the Wyndham flag in the 2nd
Quarter of 2010. Revenue per available room (RevPAR) for the
trailing-12 month period ending March 2011 was $130. For the first
six months of 2011 RevPAR increased 16% from the same period in
2010. Although revenue has improved operating expenses have
increased significantly since securitization. The $123.1 million
whole loan includes $14.4 million in non-pooled trust debt,
certificate Classes PH1, PH2 and PH3, and a $42.1 million non-
trust junior component. There is also $88.4 million in mezzanine
debt. Moody's LTV is 74%, the same as last review. Moody's credit
estimate is Ba3, the same as last review.

The New Jersey Office Portfolio Loan ($63.9 million -- 9% of
the pooled balance) was transferred to special servicing in
January 2011 due to a maturity default. The loan is secured by
six office buildings located in Franklin Township, New Jersey
with a total of 1.1 million square feet. As of July 2011 the
portfolio was 61% leased. An April 2011 appraisal valued the loan
collateral at $77.1 million resulting in an appraisal reduction of
$12.3 million. The $82.0 whole loan includes a $19.1 million non-
trust junior component. The special servicer is assessing the
situation to determine the optimal resolution strategy. Moody's
LTV is over 100%. Moody's credit estimate is Caa2, the same as
last review.

Rose Orchard Technology Park Portfolio Loan ($29.1 million
-4% of the pooled balance) is secured by a 310,233 square
foot five-building office/R&D property located in San Jose,
California. In December 2010, Harris, Stratex Networks
vacated 133,173 square feet when its lease expired . The move-out
reduced occupancy to 36% from 80%. The $49.8 million whole loan
includes a $20.7 million non-trust junior component. Moody's LTV
is over 100%. Moody's credit estimate is Caa3 compared to B2 at
last review.

The Sheraton Austin Loan ($28.7 million -- 4% of the pooled
balance) is secured by a 365-room full-service hotel located in
downtown Austin, Texas. The hotel's performance has improved since
Moody's last review. Revenue per available room (RevPAR) for
calendar year 2010 was $98, a 5% increase from RevPAR of $93 in
2009. For the first six months of 2011 RevPAR increased 15% to
$115 from $100 during the same period in 2010. The $62.5 million
whole loan includes $7.9 million in non-pooled trust debt,
certificate Class SA1, and a $26.1 million non-trust junior
component. Moody's LTV is 54% compared to 60% at last review.
Moody's credit estimate is Baa1 compared to Baa3 at last review.


COMMERCIAL MORTGAGE: S&P Lowers Rating on Class H Certs. to 'D'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 10
classes of commercial mortgage pass-through certificates from four
U.S. commercial mortgage-backed securities (CMBS) transactions due
to interest shortfalls. "We also removed our rating on one class
from CreditWatch with negative implications," S&P related.

The downgrades reflect current and potential interest shortfalls.
"We lowered our ratings on five of these classes to 'D (sf)'
because we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. All of the classes that we
downgraded to 'D (sf)' have had accumulated interest shortfalls
outstanding between four and 11 months," S&P said. The recurring
interest shortfalls for the respective certificates are primarily
due to one or more of these factors:

    Appraisal subordinate entitlement reduction (ASER) amounts in
    effect for specially serviced loans;

    Interest rate reductions or deferrals resulting from rate
    modifications;

    Special servicing fees; and

    Workout fees.

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 interest rate deferrals or reductions associated
with modified loans, 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 in
accordance with each transaction's terms. Typically, these terms
call for the automatic implementation of an ARA equal to 25% of
the stated principal balance of a loan when it 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)'. This is
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.

"We detail the 10 downgraded classes from the four U.S. CMBS
transactions," S&P said.

        Commercial Mortgage Asset Trust's series 1999-C1

"We lowered our ratings on the class G and H certificates from
Commercial Mortgage Asset Trust's series 1999-C1. We lowered our
rating on the class H certificate to 'D (sf)' to reflect
accumulated interest shortfalls outstanding for seven months,
primarily resulting from ASER amounts related to two ($51.1
million, 4.9%) of the five loans ($197.7 million, 18.9%) that are
currently with the special servicer, LNR Partners LLC (LNR), as
well as special servicing and workout fees. We downgraded class G
due to reduced liquidity support available to this class and the
potential for this class to experience interest shortfalls in the
future relating to the specially serviced loans," S&P related.

As of the Aug. 17, 2011, trustee remittance report, ARAs totaling
$31.6 million were in effect for two loans, and the total reported
monthly ASER amount was $278,208. The reported monthly interest
shortfalls totaled $323,790 and have affected all classes
subordinate to and including class H.

      Commercial Mortgage Asset Trust's series 1999-C2

"We lowered our ratings on the class E and F certificates from
Commercial Mortgage Asset Trust's series 1999-C2 and removed our
rating on the class E certificate from CreditWatch with negative
implications. We lowered our rating on the class F certificate to
reflect accumulated interest shortfalls outstanding for eight
months, primarily resulting from an ASER amount related to the
sole loan ($29.1 million, 12.1%) currently with the special
servicer, LNR, as well as special servicing and workout fees. We
also downgraded class F due its heightened susceptibility to
continue experiencing interest shortfalls. We also lowered the
rating on class E and removed it from CreditWatch with negative
implications due to reduced liquidity support available to this
class. As of the Aug. 17, 2011, trustee remittance report, a
$25.0 million ARA was in effect for the sole specially serviced
loan, and the total reported monthly ASER amount was $213,196. The
reported monthly interest shortfalls totaled $238,956 and have
affected all classes subordinate to and including class F," S&P
related.

                JPMorgan Chase Commercial Mortgage
               Securities Corp.'s series 2001-CIBC2

"We lowered our ratings on the class E, F, G, H, and J
certificates from JPMorgan Chase Commercial Mortgage Securities
Corp.'s series 2001-CIBC2. We lowered our ratings on the class G,
H, and J certificates to 'D (sf)' to reflect accumulated interest
shortfalls outstanding between four and seven months, resulting
primarily from ASER amounts related to four ($36.9 million, 21.7%)
of the nine assets ($61.8 million, 36.3%) that are currently with
the special servicer, C-III Asset Management LLC, as well as
interest rate reduction ($5,899) from a loan modification, special
servicing fees, and workout fees.  We downgraded classes E and F
due to reduced liquidity support available to these classes. As of
the Aug. 15, 2011, trustee remittance report, ARAs totaling $16.9
million were in effect for four assets, and the total reported
monthly ASER amount was $111,749. The reported monthly interest
shortfalls totaled $172,036 and have affected all classes
subordinate to and including class G," S&P related.

   Wachovia Bank Commercial Mortgage Trust's series 2004-C10

"We lowered our rating on the class O certificate from Wachovia
Bank Commercial Mortgage Trust's series 2004-C10 to 'D (sf)' to
reflect accumulated interest shortfalls outstanding for 11 months,
primarily resulting from workout fees and special servicing fees
from the three loans ($12.6 million, 1.5%) that are currently with
the special servicer, LNR. As of the Aug. 17, 2011, trustee
remittance report, the reported monthly interest shortfalls
totaled $4,342 and have affected classes O and P (not rated by
Standard & Poor's)," S&P related.

Ratings Lowered

Commercial Mortgage Asset Trust
Commercial mortgage pass-through certificates series 1999-C1

                            Credit        Reported
          Rating       enhancement  interest shortfalls ($)
Class  To         From         (%)     Current  Accumulated
G      CCC+ (sf)  BB- (sf)    7.08           0            0
H      D (sf)     CCC- (sf)   4.81      62,327      219,054

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

                            Credit           Reported
          Rating       enhancement     interest shortfalls ($)
Class  To         From         (%)        Current  Accumulated
F      CCC+ (sf)  B+ (sf)    19.64          2,933      220,418

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CIBC2

                            Credit        Reported
          Rating       enhancement  interest shortfalls ($)
Class  To         From         (%)     Current  Accumulated
E      BBB+ (sf)  A+ (sf)    33.31           0            0
F      B- (sf)    BB+ (sf)   26.25           0            0
G      D (sf)     CCC+ (sf)  11.42      70,714      230,395
H      D (sf)     CCC (sf)    7.19      37,568      160,949
J      D (sf)     CCC- (sf)   2.95      37,563      267,082

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2004-C10

                              Credit         Reported
          Rating         enhancement   interest shortfalls ($)
Class  To         From           (%)    Current    Accumulated
O      D (sf)     CCC- (sf)    0.04      2,767          21,274

Rating Lowered and Removed From CreditWatch Negative

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

                                              Reported
                                 Credit       interest
         Rating             enhancement       shortfalls ($)
Class  To       From                (%)  Current  Accumulated
E      BBB (sf) A (sf)/Watch Neg  26.09        0            0


CONCORD REAL: Fitch Affirms Junk Rating on Three Classes of Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed seven classes and withdrawn the ratings
on two classes of Concord Real Estate CDO 2006-1, Ltd./LLC
reflecting Fitch's base case loss expectation of 30.9%.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market values and cash flow declines.

In January 2010, $66.3 million of notes of Concord 2006-1 were
submitted to the trustee for cancellation.  Additional notes were
subsequently submitted for cancellation in November 2010 and
February 2011.  Initially, the trustee rejected the cancellation
and continued to treat the notes as outstanding for purposes of
calculating the interest coverage and par value tests.  The co-
issuers brought an action against the trustee and certain funds
were held in escrow while the litigation was ongoing.  In May
2011, the trustee provided notice that the action was decided in
the co-issuers' favor and is now in the process of restating its
note valuation reports and distributing funds.  The trustee
confirmed that approximately $54 million in principal remains in
escrow. The collateral manager indicated that of this amount,
roughly $20 million will be used to pay down the class A-1 notes
with the balance to remain as principal cash of the CDO.  The
original $66.3 million of note cancellations have been reflected,
but the subsequent note cancellations ($29 million) have not yet
been reflected as of the July trustee report.  As such, classes C
through F have been partially cancelled and classes G and H have
been fully cancelled.  Fitch's review is based on balances
presented in the trustee's most recent note valuation report,
dated July 19, 2011.  Fitch anticipates another review after all
reports have been restated and after the transaction becomes
static in December 2011.

Since last review and as of the July 2011 trustee report, the
disposal of seven credit impaired assets has resulted in realized
losses to the CDO of $38.7 million.  Per the current trustee
reporting, the transaction fails all five of its par value tests.
As a result, interest payments after class C and future principal
proceeds would be used to delever class A-1.  According to the
collateral manager, after the completion of the restatement of the
trustee reports (reflecting the full $95.3 million in notes
submitted for cancellation), all par value tests will be passing.

Commercial real estate loans (CREL) comprise approximately 68.2%
of the collateral of the CDO.  Approximately 80% of the CREL are
B-notes or mezzanine loans with the remainder whole loans or A-
notes.  Defaulted CREL assets have increased to 8% from 1.1%,
while loans of concern decreased to 4.3% from 8.2% at last review.
CMBS/CDO collateral represents 19.3% of the total collateral.
Since last review, the average Fitch derived rating for the
underlying CMBS collateral improved slightly to 'B-/CCC+' compared
with 'CCC+' at last review.

Under Fitch's updated methodology, approximately 42.5% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  Fitch estimates that average
recoveries will be low at 27.3% due to the high concentration of
subordinate CMBS collateral and B-notes/mezzanine debt.

While the largest component of Fitch's base case loss expectation
is the modeled losses on the CMBS/CDO bond collateral, the second
largest component is a defaulted B-note (8%) secured by a 575-room
full service resort located in Tucson, AZ.  In March 2010, the
loan transferred to special servicing after the borrower failed to
make a required debt seasonality reserve payment. Since August
2010, the loan has been in maturity default.  A third party asset
manager is performing a review of the property's performance and
projections, with a final report due soon.  Given the note's
subordinate position, Fitch modeled a term default with a full
loss in its base case scenario.

The next largest component of Fitch's base case loss expectation
is mezzanine debt (6.1%) associated with an 805-room full service
boutique hotel in Manhattan.  The loan was previously extended
through October 2011 and remains current on payments.  Given the
mezzanine debt's subordinate position, Fitch modeled a maturity
default with a modest loss in its base case scenario.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to classes A-1 through C was then compared
to the modeled expected losses.  Given the concentration of the
pool, the credit enhancement was determined to be consistent with
the ratings assigned below.  Based on prior modeling results, no
material impact was anticipated from cash flow modeling the
transaction.

The 'CCC' and below ratings for classes D through F are based on
a deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Classes B and C maintain Negative Rating Outlooks reflecting
Fitch's expectation of further potential negative credit migration
of the underlying collateral and the recent transfer of an office
portfolio into special servicing due to occupancy issues.

WRP Management, LLC is the collateral asset manager for the
transaction.  The CDO's reinvestment period ends in December 2011.

Fitch has affirmed the ratings and revised the Rating Outlooks for
these classes:

  -- $202,275,000 class A-1 'BBBsf'; Outlook to Stable from
     Negative;
  -- $23,250,000 class A-2 'BBsf'; Outlook to Stable from
     Negative.

Fitch has affirmed these classes:

  -- $46,500,000 class B at 'BBsf'; Outlook Negative;
  -- $10,000,000 class C at 'Bsf'; Outlook Negative;
  -- $26,000,000 class D at 'CCCsf/RR5';
  -- $17,087,000 class E at 'CCCsf/RR6';
  -- $22,413,000 class F at 'CCCsf/RR6'.

Fitch has withdrawn the ratings of classes G and H following the
full surrender of those certificates.  Fitch does not rate the
$51,150,000 preferred shares.


CONNECTICUT VALLEY: Moody's Upgrades Ratings of 5 Classes of Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 5 classes of
notes issued by Connecticut Valley Structured Credit CDO II, Ltd.
The classes of notes affected by the rating actions are:

US$25,000,000 Class A-2 Floating Rate Notes (current balance of
$189,615,371), Upgraded to Baa1(sf) and Remains On Review for
Possible Upgrade; previously on June 24, 2011 Ba3(sf) Placed Under
Review for Possible Upgrade;

US$6,000,000 Class B-1 Deferrable Floating Rate Notes, Upgraded to
B1(sf) and Remains On Review for Possible Upgrade; previously on
June 24, 2011 C(sf) Placed Under Review for Possible Upgrade;

US$15,000,000 Class B-2 Deferrable Fixed Rate Notes, Upgraded to
B1(sf) and Remains On Review for Possible Upgrade; previously on
June 24, 2011 C(sf) Placed Under Review for Possible Upgrade;

US$18,250,000 Class C-1 Deferrable Floating Rate Notes, Upgraded
to Caa3(sf) and Remains On Review for Possible Upgrade; previously
on June 24, 2011 C(sf) Placed Under Review for Possible Upgrade;

US$13,250,000 Class C-2 Deferrable Fixed Rate Notes, Upgraded to
Caa3(sf) and Remains On Review for Possible Upgrade; previously on
June 24, 2011 C(sf) Placed Under Review for Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes result
primarily from improvement in the credit quality of the portfolio.

Since the last rating action in December 2009, the weighted
average rating factor has improved to 2346 from 3988 as of the
December 2009 report. Also as of the latest trustee report dated
August 5, 2011, the Class A/B and Class C Par Coverage ratios have
improved significantly and are reported at 103.88% and 88.98%
compared to December 2009 levels of 88.58% and 79.5%,
respectively.

Following an announcement by Moody's on June 22, 2011 that nearly
all CLO tranches currently rated Aa1 (sf) and below were placed on
review for possible upgrade ("Moody's places 4,220 tranches from
611 U.S. and 171 European CLO transactions on review for
upgrade"), 98 tranches of U.S. and European Structured Finance
(SF) CDOs with material exposure to CLOs were also placed on
review for possible upgrade ("Moody's places 98 tranches from 19
U.S. and 3 European SF CDO transactions with exposure to CLOs on
review for upgrade"). The rating action on the notes reflects CLO
tranche upgrades that have taken place thus far, as well as a pro
forma assumption that CLO tranches which remain on review for
possible upgrade will be upgraded by two notches. According to
Moody's, 62% of the collateral has been upgraded since June 22nd,
and 18.5% remains on review.

Connecticut Valley Structured Credit CDO II, Ltd. is a
collateralized debt obligation backed primarily by a portfolio of
CLOs which originated between 2003 and 2006.

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 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:

CLO bucket on review for potential upgrade notched up by 1 rating
category (instead of Moody's standard assumption of 2 notches):

Class A-2: -1
Class B-1: -1
Class B-2: -1
Class C-1: 0
Class C-2: 0

CLO bucket on review for potential upgrade notched up by 3 rating
categories (instead of Moody's standard assumption of 2 notches):

Class A-2: 0
Class B-1: +1
Class B-2: +1
Class C-1: +1
Class C-2: +1


CREDIT SUISSE: Fitch Affirms Rating on Five Certificate Classes
---------------------------------------------------------------
Fitch Ratings affirms five classes of Credit Suisse First Boston
Mortgage Securities Corp. commercial mortgage pass through
certificates, series 1999-C1.

The affirmations are due to sufficient credit enhancement of the
remaining Fitch rated classes to offset Fitch expected losses from
the specially serviced loan and losses from Fitch's refinance
test.  As of the July 2011 distribution date, the pool's
certificate balance has paid down 92.2% to $91.3 million from
$1.2 billion at issuance.

There are eight remaining loans from the original 153 loans at
issuance.

Fitch expects losses of 64.2% which will be absorbed by the Fitch
rated classes H, J, K and the un-rated class L.

The Tallahassee Mall asset is currently the only asset in special
servicing and is also the largest contributor to losses.  The
973,973 sf mall is located in Tallahassee, FL and is suffering
from the vacancy of several large tenant spaces including
Dillard's and Goody's.  The property was foreclosed upon in
January 2011 and the special servicer is working to stabilize and
liquidate the asset.

Fitch affirms the following classes and revises Rating Outlooks
and Recovery Ratings (RRs) as indicated:

  -- $7.9 million class F at 'Asf'; Outlook to Stable from
     Negative;
  -- $32.2 million class G at 'CCCsf'; RR to 'RR1' from 'RR3';
  -- $23.4 million class H at 'Csf'; RR to 'RR4' from 'RR6';
  -- $11.7 million class J at 'Csf/RR6';
  -- $11.7 million class K at 'Csf/RR6'.

Fitch does not rate classes L and O. Classes A-1, A-2, B, C, D, E
and M have paid in full.

Fitch has withdrawn the rating of class N and has also withdrawn
the rating of the interest only class A-X.


CREDIT SUISSE: Fitch Holds 'Dsf' Rating on $15 Mil. Class J Cert.
-----------------------------------------------------------------
Fitch Ratings has upgraded one class of Credit Suisse First Boston
Mortgage Securities Corp.'s commercial mortgage pass-through
certificates, series 2001-CK3.

The upgrade is a result of increased credit enhancement due to
paydown which is sufficient to offset Fitch expected losses.
Fitch modeled losses of 6.7% of the remaining pool.  Fitch
designated 15 loans (78.5%) as Fitch Loans of Concern, which
include 11 specially serviced loans (61.4%).  Fitch expects losses
associated with the specially serviced assets to effect class J.

As of the July 2011 distribution date, the pool's aggregate
principal balance has been reduced by approximately 92% to $87.3
million from $1.1 billion at issuance.  One loan (0.3% of the pool
balance) is fully defeased. Interest shortfalls are affecting
classes J through O.

The largest loan in the pool (48.7% of pool balance) is
collateralized by a 214,755 square foot retail center in Chestnut
Hill, MA.  The loan is sponsored by Simon Property Group (Simon)
and is directly across from the Chestnut Hill Mall (also a Simon
property).  The subject property's largest tenants include The Gap
(12.6% of the net rentable Area [NRA]), Pottery Barn/Pottery Barn
Kids (10.3% NRA), Anthropologie (6.7% NRA) and J. Crew (6.5% NRA).
The June 2011 rent roll reported occupancy at 63%, a decline from
December 2010 at 77% due to the recent closing and bankruptcy of
Borders Books (previously 12.6% NRA).  The year to date servicer-
reported March 2011 debt service coverage ratio (DSCR) reported at
1.39 times (x), compared to the year end (YE) December 2010 DSCR
at 1.51x.

The largest contributor to losses (6.3%) is a 208,000 square foot
(sf) single tenant industrial property located in Waterbury, CT.
The loan transferred to special servicing in March 2010 due to
monetary default after the tenant filed for bankruptcy and
subsequently vacated the building in September 2009, 18 months
prior to its lease expiration. The property remains vacant and the
special servicer is in the process of selling the note.

The next largest contributor to losses (2.3%) is secured by a 44
unit multifamily property located in Reno, NV.  The property has
experienced cash flow issues due to significant increases in
expenses and declining rents.  The most recent occupancy reported
is 88% as of December 2010 and DSCR of 0.52 times (x).  The loan
remains current as of the July 2011 payment date.

Fitch stressed the cash flow of the non-specially serviced and
non-defeased loans by applying a minimum 5% reduction to most
recently available fiscal year end net operating income, and
applying an adjusted market cap rate between 8% and 11% to
determine value.

Fitch upgrades this class as indicated:

  -- $25.4 million class F to 'AAAsf' from 'AA+sf'; Outlook
     Stable.

Fitch affirms these classes and revises the Rating Outlooks and
Recovery Ratings (RR) as indicated:

  -- $7.8 million class E at 'AAAsf'; Outlook Stable;
  -- $8 million class G-1 at 'Asf'; Outlook to Stable from
     Negative;
  -- $11.7 million class G-2 at 'Asf'; Outlook to Stable from
     Negative;
  -- $14.1 million class H at 'BBsf'; Outlook Negative;
  -- $15 million class J at 'Dsf'; Recovery Rating to 'RR4' from
     'RR2'.

Classes K, L and M remain at 'Dsf/RR6' due to realized losses.

Fitch does not rate classes N or O. Classes A-1, A-2, A-3, A-4, B,
C and D have paid in full.  On July 16, 2010 Fitch had withdrawn
the rating on the interest-only classes A-X.


CRIIMI MAE: Fitch Affirms Rating on $4 Million Notes at 'Dsf'
-------------------------------------------------------------
Fitch Ratings has affirmed two classes of notes issued by CRIIMI
MAE Trust, series 1996-C1.  The affirmations reflect the
distressed nature of the underlying collateral of which
approximately 46.9% are non-rated or defaulted first loss
commercial mortgage-backed securities (CMBS) bonds.

Since the last review in September 2010, cumulative losses on
the underlying collateral have increased to $7.8 million from
$6.8 million at the last review.  The class E notes have 12.4%
credit enhancement as of the Aug. 1, 2011 trustee report.

Given the high concentration of the pool, Fitch conducted an asset
by asset analysis of the underlying collateral to estimate
recoveries.  For each underlying transaction, Fitch used a
combination of Fitch's last CMBS review loss estimate, if rated by
Fitch, and the average loan loss severity estimate from Fitch's
most recent U.S. CMBS Loss Study, if not rated by Fitch, and
accounted for defeasance.  Based on this analysis, default appears
inevitable for class E.  However, Fitch estimates recovery on the
class to be approximately 50% to 70% of the current outstanding
balance.

The class F notes have already experienced losses of approximately
$7.8 million and further losses are anticipated as losses on the
underlying collateral will directly impact them.

This review was conducted under the framework described in the
reports 'Global Structured Finance Rating Criteria' and 'Global
Rating Criteria for Structured Finance CDOs'.  However, given the
portfolio's distressed nature, Fitch believes that the probability
of default for all classes of notes can be evaluated without using
the Structured Finance Portfolio Credit Model (SF PCM) to estimate
potential further losses from the non-defaulted portion of the
portfolio.

CRIIMI MAE 1996-C1 is collateralized by all or a portion of five
classes of fixed-rate CMBS in four separate underlying
transactions from the 1995 and 1996 vintages.  The entire
portfolio has a Fitch derived rating below 'CCC' or not rated, and
therefore, is more susceptible to default in the near term.

Fitch has affirmed the following classes:

  -- $29,590,196 class E notes at 'Csf';
  -- $4,200,358 class F notes at 'Dsf'.

Classes A-1, A-2, B, C, and D have been paid in full.


CSFB 2001-CP4: Modeled Losses Cue Fitch to Downgrade Ratings
------------------------------------------------------------
Fitch Ratings has downgraded two classes of Credit Suisse First
Boston Mortgage Securities Corp., series 2001-CP4 (CSFB 2001-CP4).

The downgrades reflect Fitch modeled losses of 18.75% of the
remaining pool.  Fitch has designated 26 loans (85.4%) as Fitch
Loans of Concern, which includes 19 specially-serviced loans
(66.7%).  Fitch expects classes J through O to be fully depleted
and class H to be impacted significantly from losses associated
with the specially serviced assets.

As of the July 2011 distribution date, the pool's aggregate
principal balance has reduced by 86.7% to $157.4 million from
$1.18 billion at issuance.  In addition, one loan (.4%) has been
fully defeased.  Interest shortfalls totaling $7,808,151 are
currently affecting classes H through O.

The largest contributor to modeled losses is a specially serviced
loan (10%) secured by a 156,776 square feet (SF) of office space
located in Shelton, CT.  The loan transferred to special servicing
in June 2008 due to monetary default.  The borrower has been under
bankruptcy protection since August 2009 and the judge ordered
conversion to Chapter 7 Bankruptcy in August 2010.

The second largest contributor to modeled losses is a specially
serviced (7.6%) real estate owned (REO) 121,409 square foot office
building located in Rockville, MD.  The loan transferred to
special servicing in October 2009 due to monetary default and the
property was foreclosed on in May 2010.  Lincoln Property Company
has been appointed as the property manager and leasing agent while
Cassidy Turley is marketing the property for sale.

The third largest contributor to modeled losses is a specially
serviced loan (8.7%) secured by a 166,594 sf of office space
located in Raleigh, NC.  The loan transferred to special servicing
in December 2009 due to monetary default.  A foreclosure sale was
originally scheduled for November 2010 until the borrower filed
for bankruptcy which stayed the foreclosure sale.  The court has
postponed a confirmation of the borrower proposed reorganization
plan until the value of the property is determined.


Fitch has downgraded, assigned Recovery Ratings (RRs), and revised
Outlooks on these classes as indicated:

  -- $11.8 million class G to 'B-sf' from 'Bsf'; Outlook to Stable
     from Negative;
  -- $22.1 million class H to 'CCsf/RR5' from 'B-'.

Fitch has also affirmed the following classes:

  -- $10.1 million class B at 'AAAsf'; Outlook Stable;
  -- $45.7 million class C at 'AAAsf'; Outlook Stable;
  -- $22.1 million class D at 'AAAsf'; Outlook Stable;
  -- $16.2 million class E at 'Asf'; Outlook Stable;
  -- $16.2 million class F at 'BBsf'; Outlook Stable;
  -- $13.2 million class J to 'Dsf/RR6' from 'Dsf/RR3'.

Class K, L, M, and N remain at 'Dsf/RR6'. Class O, which is not
rated by Fitch has been reduced to zero from 20.6 million at
issuance due to realized losses.

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


CWMBS REPERFORMING: Moody's Lowers Ratings of $728.1-Mil. RMBS
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 43
tranches from eight deals issued by CWMBS Re-Performing Loan REMIC
Trust. The collateral consists of fixed and adjustable rate
mortgage loans insured by the Federal Housing Administration (FHA)
an agency of the U.S. Department of Urban Development (HUD) or
guaranteed by the Veterans Administration (VA).

Complete rating actions are:

Issuer: CWMBS Re-Performing Loan REMIC Trust Certificates, Series
2002-1

Cl. M, Downgraded to Baa1 (sf); previously on Jul 27, 2011 Aa2
(sf) Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to Ba2 (sf); previously on Jul 27, 2011 A2
(sf) Placed Under Review for Possible Downgrade

Cl. B-2, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba1
(sf) Placed Under Review for Possible Downgrade

Cl. B-3, Downgraded to Ca (sf); previously on Jul 27, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

Issuer: CWMBS Reperforming Loan REMIC Trust Certificates, Series
2004-R1

Cl. 1A-F, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa1
(sf) Placed Under Review for Possible Downgrade

Cl. 1A-S, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa1
(sf) Placed Under Review for Possible Downgrade

Cl. 1M, Downgraded to Caa2 (sf); previously on Jul 27, 2011 Ba2
(sf) Placed Under Review for Possible Downgrade

Cl. 1B-1, Downgraded to Ca (sf); previously on Jul 27, 2011 B2
(sf) Placed Under Review for Possible Downgrade

Cl. 2A, Downgraded to B1 (sf); previously on Jul 27, 2011 Baa1
(sf) Placed Under Review for Possible Downgrade

Cl. 2M, Downgraded to Ca (sf); previously on Jul 27, 2011 Ba2 (sf)
Placed Under Review for Possible Downgrade

Cl. 2B-1, Downgraded to Ca (sf); previously on Jul 27, 2011 Caa1
(sf) Placed Under Review for Possible Downgrade

Cl. 3A, Downgraded to B1 (sf); previously on Jul 27, 2011 Baa1
(sf) Placed Under Review for Possible Downgrade

Cl. PT, Downgraded to B1 (sf); previously on Jul 27, 2011 Baa1
(sf) Placed Under Review for Possible Downgrade

Issuer: CWMBS Reperforming Loan REMIC Trust Certificates, Series
2004-R2

Cl. 1A-F1, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba1
(sf) Placed Under Review for Possible Downgrade

Cl. 1A-F2, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba1
(sf) Placed Under Review for Possible Downgrade

Cl. 1A-S, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba1
(sf) Placed Under Review for Possible Downgrade

Cl. M, Downgraded to Ca (sf); previously on Jul 27, 2011 B2 (sf)
Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Cl. B-2, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Issuer: CWMBS Reperforming Loan REMIC Trust Certificates, Series
2005-R2

Cl. 1A-F1, Downgraded to Ba1 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A-F2, Downgraded to Caa2 (sf); previously on Jul 27, 2011 B1
(sf) Placed Under Review for Possible Downgrade

Cl. 1A-S, Downgraded to Caa1 (sf); previously on Jul 24, 2009
Downgraded to B1 (sf)

Cl. 2A-1, Downgraded to Caa1 (sf); previously on Jul 27, 2011 B1
(sf) Placed Under Review for Possible Downgrade

Cl. 2A-2, Downgraded to Caa1 (sf); previously on Jul 27, 2011 B1
(sf) Placed Under Review for Possible Downgrade

Cl. 2A-3, Downgraded to Caa1 (sf); previously on Jul 27, 2011 B1
(sf) Placed Under Review for Possible Downgrade

Cl. 2A-4, Downgraded to Caa1 (sf); previously on Jul 27, 2011 B1
(sf) Placed Under Review for Possible Downgrade

Cl. 2A-IO, Downgraded to Caa1 (sf); previously on Jul 27, 2011 B1
(sf) Placed Under Review for Possible Downgrade

Issuer: CWMBS Reperforming Loan REMIC Trust Certificates, Series
2005-R3

Cl. A-F, Downgraded to B1 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. A-S, Downgraded to B1 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. M, Downgraded to Ca (sf); previously on Jul 27, 2011 B2 (sf)
Placed Under Review for Possible Downgrade

Issuer: CWMBS, Inc. Structured Pass-Through Certificates Series
2003-R3

Cl. M, Downgraded to B1 (sf); previously on Jul 27, 2011 Baa2 (sf)
Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to Ca (sf); previously on Jul 27, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

Issuer: Reperforming Loan REMIC Trust 2003-R2

Cl. M, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba1 (sf)
Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to C (sf); previously on Jul 27, 2011 B2 (sf)
Placed Under Review for Possible Downgrade

Cl. B-2, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Issuer: Reperforming Loan REMIC Trust 2003-R4

Cl. 1A-4, Downgraded to Baa3 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A-PO, Downgraded to Baa3 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A-IO, Downgraded to Baa3 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. 2A, Downgraded to Baa3 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. 2A-IO, Downgraded to Baa3 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. M, Downgraded to B2 (sf); previously on Jul 27, 2011 Baa3 (sf)
Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to Ca (sf); previously on Jul 27, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

Cl. B-2, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

RATINGS RATIONALE

The actions are a result of Moody's updated loss projection for
the RMBS FHA-VA portfolio. The updated projection accounts for
higher potential pool losses due to self-curtailment of claims by
servicers whereby they pass expenses as deemed reasonable to the
trusts instead of submitting them to HUD, and continued weaknesses
in the macro economy and the housing market.

A FHA guarantee covers 100% of a loan's outstanding principal and
a large portion of its outstanding interest and foreclosure-
related expenses in the event that the loan defaults. A VA
guarantee covers only a portion of the principal based on the
lesser of either the sum of the current loan amount, accrued and
unpaid interest, and foreclosure expenses, or the original loan
amount. HUD usually pays claims on defaulted FHA loans when
servicers submit the claims, but can impose significant penalties
on servicers if it finds irregularities in the claim process later
during the servicer audits. This can prompt servicers to push more
expenses to the trust that they deem reasonably incurred than
submit them to HUD and face significant penalty. The rating
actions consider the portion of a defaulted loan normally not
covered by the FHA or VA guarantee and other servicer expenses
they deemed reasonably incurred and passed on to the trust.

FHA/VA borrowers, in Moody's-rated transactions, are typically low
income borrowers with poor credit history who have been affected
by the weak economy and housing market. Moody's expects
delinquencies to remain high for this sector at 40%, 35%, and 30%
for the 2004, 2005, and 2006 vintages, respectively as house
prices continue to decline and unemployment rates remain high.
FHA/VA RMBS transactions have had very low losses to date (less
than 1%) despite high delinquency levels due to the FHA and VA
guarantees. However, Moody's expects this trend to change due to
the higher level of self-curtailments by the servicers.

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, 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. Moody's now
projects house price index to reach a bottom in the first quarter
of 2012, with a 2% remaining decline between the first quarter of
2011 and 2012, and unemployment rate to start declining by fourth
quarter of 2011.

The principal methodology used in these ratings is described in
the Monitoring and Performance Review section in "Moody's Approach
to Rating US Residential Mortgage-Backed Securities" published in
December 2008. Other methodology and factors used in this rating
are described in "FHA VA US RMBS Surveillance Methodology"
published in July 2011.


DEUSTCHE BANK: Fitch Expects to Rate 20 Class Notes
---------------------------------------------------
Fitch Ratings has issued a presale report on Deutsche Bank
Securities DBUBS 2011-LC3 commercial mortgage pass-through
certificates:

Fitch expects to rate the transaction and assign ratings and
Outlooks:

  -- $97,779,000 class A-1 'AAAsf'; Outlook Stable;
  -- $571,771,000 class A-2FX 'AAAsf'; Outlook Stable;
  -- $100,000,000 class A-2FL* 'AAAsf'; Outlook Stable;
  -- $0 class A-2C 'AAAsf'; Outlook Stable;
  -- $97,268,000 class A-3 'AAAsf'; Outlook Stable;
  -- $112,102,000 class A-4 'AAAsf'; Outlook Stable;
  -- $1,106,529,000** class X-A 'AAAsf'; Outlook Stable;
  -- $127,609,000 class A-M 'AAAsf'; Outlook Stable;
  -- $75,167,000 class B 'AAsf'; Outlook Stable;
  -- $54,190,000 class C 'Asf'; Outlook Stable;
  -- $73,419,000 class D'BBB-sf'; Outlook Stable;
  -- $19,229,000 class E 'BBsf'; Outlook Stable;
  -- $19,229,000 class F 'Bsf'; Outlook Stable;
  -- $140,100,000 class PM-1 'AAAsf'; Outlook Stable.
  -- $227,840,366** class PM-X 'AAsf'; Outlook Stable;
  -- $32,900,000 class PM-2 'AAsf'; Outlook Stable;
  -- $28,900,000 class PM-3 'Asf'; Outlook Stable;
  -- $26,500,000 class PM-4 'BBBsf'; Outlook Stable;
  -- $21,700,000 class PM-5 'BBB-sf'; Outlook Stable;
  -- $4,163,092 class PM-6 'BBsf'; Outlook Stable.

  * Floating Rate (The aggregate balance of class A-2FL may be
    adjusted as a result of the exchange of all or a portion of
    the class A-2FL certificates for A-2C certificates, which have
    a balance of $0 at closing.)

** Notional amount and interest only

The expected ratings are based on information provided by the
issuer as of Aug. 8, 2011.  Fitch does not expect to rate the
$291,928,485 interest-only class X-B or the $50,694,485 class G.
The certificates represent the beneficial ownership in the trust,
primary assets of which are 43 loans secured by 64 commercial
properties having an aggregate pooled principal balance of
approximately $1.4 billion as of the cutoff date.  The loans were
sold by German American Capital Corporation., UBS Real Estate
Securities, Ladder Capital Finance LLC, and Starwood Property
Mortgage.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 72.7% of the properties
by balance, cash flow analysis of 84.8% of the pool and asset
summary reviews of 86.5% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.34 times (x), a Fitch stressed loan-to value (LTV) of
91.9%, and a Fitch debt yield of 12.7%.  Fitch's aggregate net
cash flow represents a variance of 6.3% to issuer cash flows.
The Master Servicer and Special Servicer will be Wells Fargo and
Midland Loan Services, Inc., rated 'CMS2' and 'CSS1',
respectively, by Fitch.


FAIRWAY LOAN: Moody's Upgrades Ratings of Six Classes of CLO Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Fairway Loan Funding company:

US$510,000,000 (current balance of $498,399,269.43) Class A-1L
Floating Rate Notes Due October 2018, Upgraded to Aaa (sf),
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$75,000,000 (current balance of $73,294,010.21) Class A-1LV
Floating Rate Revolving Notes Due October 2018, Upgraded to Aaa
(sf), previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$52,000,000 Class A-2L Floating Rate Notes Due October 2018;
Upgraded to A1 (sf), previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$49,000,000 Class A-3L Deferrable Floating Rate Notes Due
October 2018, Upgraded to Baa1 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$32,000,000 Class B-1L Floating Rate Notes Due October 2018;
Upgraded to Ba1 (sf), previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade; and

US$32,000,000 Class B-2L Floating Rate Notes Due October 2018;
Upgraded to B1 (sf); previously on June 22, 2011 Caa2 (sf) Placed
Under Review for Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $762 million,
defaulted par of $5.7 million, a weighted average default
probability of 21.37% (implying a WARF of 2800), a weighted
average recovery rate upon default of 51.09%, and a diversity
score of 58. The 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.

Fairway Loan Funding Company, issued in July 2006, 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
June 2011.

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 June 2011.

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 2013 and
2015 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 the
   worse of reported and covenanted 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 level higher than the covenant levels
   due to the large difference between the reported and covenant
   levels.


FANNIE MAE: Moody's Lowers Rating of $70-Mil. Non-guaranteed RMBS
-----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 25
subordinate tranches from six deals issued by Fannie Mae REMIC
Trust. These bonds are not guaranteed by Fannie Mae. The
collateral backing these transactions consists primarily of first-
lien, fixed and adjustable rate, mortgage loans insured by the
Federal Housing Administration (FHA) an agency of the U.S.
Department of Urban Development (HUD) or guaranteed by the
Veterans Administration (VA).

Complete rating actions are:

Issuer: Fannie Mae REMIC Trust 2001-W3

Cl. M, Downgraded to Baa1 (sf); previously on Jul 27, 2011 Aa2
(sf) Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to Baa2 (sf); previously on Jul 27, 2011 A2
(sf) Placed Under Review for Possible Downgrade

Cl. B-2, Downgraded to B1 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. B-3, Downgraded to Ca (sf); previously on Jul 27, 2011 Ba2
(sf) Placed Under Review for Possible Downgrade

Cl. B-4, Downgraded to C (sf); previously on Oct 8, 2009
Downgraded to Ca (sf)

Issuer: Fannie Mae REMIC Trust 2002-W1

Cl. M, Downgraded to Baa1 (sf); previously on Jul 27, 2011 Aa2
(sf) Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to Ba1 (sf); previously on Jul 27, 2011 A2
(sf) Placed Under Review for Possible Downgrade

Cl. B-2, Downgraded to Caa2 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. B-3, Downgraded to C (sf); previously on Jul 27, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

Issuer: Fannie Mae REMIC Trust 2002-W6

Cl. M, Downgraded to Baa2 (sf); previously on Jul 27, 2011 Aa2
(sf) Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to B2 (sf); previously on Jul 27, 2011 A2 (sf)
Placed Under Review for Possible Downgrade

Cl. B-2, Downgraded to C (sf); previously on Jul 27, 2011 Ba3 (sf)
Placed Under Review for Possible Downgrade

Issuer: Fannie Mae REMIC Trust 2003-W1

Cl. M, Downgraded to Baa2 (sf); previously on Jul 27, 2011 Aa2
(sf) Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to B1 (sf); previously on Jul 27, 2011 A2 (sf)
Placed Under Review for Possible Downgrade

Cl. B-2, Downgraded to Ca (sf); previously on Jul 27, 2011 Ba1
(sf) Placed Under Review for Possible Downgrade

Cl. B-3, Downgraded to C (sf); previously on Oct 8, 2009
Downgraded to Ca (sf)

Issuer: Fannie Mae REMIC Trust 2003-W10

Cl. 1M, Downgraded to Ba1 (sf); previously on Jul 27, 2011 Aa2
(sf) Placed Under Review for Possible Downgrade

Cl. 1B-1, Downgraded to Caa2 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. 1B-2, Downgraded to C (sf); previously on Jul 27, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

Cl. 1B-3, Downgraded to C (sf); previously on Oct 8, 2009
Downgraded to Ca (sf)

Issuer: Fannie Mae REMIC Trust 2003-W4

Cl. IM, Downgraded to Ba1 (sf); previously on Jul 27, 2011 Aa2
(sf) Placed Under Review for Possible Downgrade

Cl. IB-1, Downgraded to B3 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. IB-2, Downgraded to C (sf); previously on Jul 27, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

Cl. IB-3, Downgraded to C (sf); previously on Oct 8, 2009
Downgraded to Ca (sf)

RATINGS RATIONALE

The actions are a result of Moody's updated loss projection for
the RMBS FHA-VA portfolio. The updated projection accounts for
higher potential pool losses due to self-curtailment of claims by
servicers whereby they pass expenses as deemed reasonable to the
trusts instead of submitting them to HUD, and continued weaknesses
in the macro economy and the housing market.

A FHA guarantee covers 100% of a loan's outstanding principal and
a large portion of its outstanding interest and foreclosure-
related expenses in the event that the loan defaults. A VA
guarantee covers only a portion of the principal based on the
lesser of either the sum of the current loan amount, accrued and
unpaid interest, and foreclosure expenses, or the original loan
amount. HUD usually pays claims on defaulted FHA loans when
servicers submit the claims, but can impose significant penalties
on servicers if it finds irregularities in the claim process later
during the servicer audits. This can prompt servicers to push more
expenses to the trust that they deem reasonably incurred than
submit them to HUD and face significant penalty. The rating
actions consider the portion of a defaulted loan normally not
covered by the FHA or VA guarantee and other servicer expenses
they deemed reasonably incurred and passed on to the trust.

FHA/VA borrowers, in Moody's-rated transactions, are typically low
income borrowers with poor credit history who have been affected
by the weak economy and housing market. Moody's expects
delinquencies to remain high for this sector at 40%, 35%, and 30%
for the 2004, 2005, and 2006 vintages, respectively as house
prices continue to decline and unemployment rates remain high.
FHA/VA RMBS transactions have had very low losses to date (less
than 1%) despite high delinquency levels due to the FHA and VA
guarantees. However, Moody's expects this trend to change due to
the higher level of self-curtailments by the servicers.

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, 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. Moody's now
projects house price index to reach a bottom in the first quarter
of 2012, with a 2% remaining decline between the first quarter of
2011 and 2012, and unemployment rate to start declining by fourth
quarter of 2011.

The principal methodology used in these ratings is described in
the Monitoring and Performance Review section in "Moody's Approach
to Rating US Residential Mortgage-Backed Securities" published in
December 2008. Other methodology used in this rating was "FHA VA
US RMBS Surveillance Methodology" published in July 2011.


FICT UNION: Expected Losses Prompts Fitch to Downgrade Ratings
--------------------------------------------------------------
Fitch Ratings has downgraded First Union Bank - Bank of America,
N.A. Commercial Mortgage Trust, series 2001-C1 commercial mortgage
pass-through certificates.

The downgrades are the result of expected losses, primarily
associated with loans currently in special servicing.  The
affirmations of the senior classes are the result of sufficient
credit enhancement to offset Fitch expected losses. Fitch modeled
losses of 27.4% of the remaining pool.

As of the July 2011 distribution date, the pool's certificate
balance has paid down 91.8% to $107.1 million from $1.3 billion.
All of the remaining 16 loans in the pool have been designated
Fitch Loans of Concern, of which 14 (65.6%) are in special
servicing.

The greatest contributor to Fitch expected losses, the pool's
largest loan (34.4%), is collateralized by a 223,720 square foot
(sf) office building located in Emeryville, CA, a suburb of
Oakland.  The loan transferred to special servicing in June 2009
due to monetary default from tenant failures and low occupancy.
In March 2011, the loan was returned to the master servicer
following a modification to an A/B note structure and a maturity
date extension of December 2020.  The B note is subordinate to a
tenant improvement/leasing commission note that was created to
help build out the office space and lease the property.  Master
servicer-reported year-end occupancy was at 93%.

The second largest contributor to Fitch expected losses is a loan
(7.7%) collateralized by a 120 unit healthcare facility in
Swansea, IL, located 20 miles east of St. Louis. The loan
transferred to special servicing in December 2009 due to monetary
default from increased operating costs. The special servicer has
filed for foreclosure.

The third largest contributor to Fitch expected losses is a loan
(10.4%) that is secured by nine warehouse buildings with 836,264
sf of space in Greenville, NC.  The loan transferred to special
servicing in December 2010 due to imminent default.  Currently the
property is 100% leased by two tenants, however, both of the
leases are due to roll-over within the next 12 months.  The
special servicer has reported that the loan is performing and has
been given a 12-month extension.

Fitch downgrades these classes and Recovery Ratings (RR) as
indicated:

  -- $16.3 million class H to 'CCCsf/RR1' from 'Bsf';
  -- $19.6 million class J to 'Csf/RR6' from 'CCCsf/RR1'.

Fitch does not assign Rating Outlooks to classes rated 'CCCsf' or
below.  Prior to the downgrades the Outlook for class H was
Negative.

Fitch affirms these classes and revises Outlooks as indicated:

  -- $3 million class D at 'AAAsf'; Outlook Stable;
  -- $16.3 million class E at 'AAAsf'; Outlook Stable;
  -- $13 million class F at 'AAAsf'; Outlook to Stable from
     Negative;
  -- $26.1 million class G at 'BBB-sf'; Outlook Negative;
  -- $12.5 million class K at 'Dsf/RR6' from 'D/RR3.

Fitch also revises the Recovery Rating on class L to 'Dsf/RR6'
from 'Dsf/RR5'.

Fitch does not rate class Q.

Classes A-1, A-2, A-2F, B and C have paid in full. Due to realized
losses, classes M, N, O and P have been reduced to zero and remain
at 'Dsf/RR6'.

Fitch has previously withdrawn the rating on interest-only (IO)
classes IO-I, IO-II and IO-III.


FMC REAL: S&P Lowers Rating on Class F From 'B-' to 'CCC+'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
classes from FMC Real Estate CDO 2005-1 Ltd. (FMC 2005-1), a
commercial real estate collateralized debt obligation (CRE CDO)
transaction. "At the same time, we affirmed our ratings on seven
classes of notes. We subsequently withdrew our class G and H
ratings," S&P related.

"According to the notice we received from the trustee, U.S. Bank
N.A., certain subordinate notes were cancelled before they were
repaid through the transaction's payment waterfall. The downgrades
primarily reflect our assessment of increased risks and credit
stability considerations regarding subordinate note cancellations
that occurred prior to their repayment through the transaction's
payment waterfall. The affirmations reflect our view that the
classes have adequate credit support at their current rating
levels and will not be affected by these increased risks and
credit stability considerations," S&P said.

The notes that were cancelled without payment are:

Class     Cancelled (US$)
G              35,153,000
H              12,084,000

Note: The class G and H note cancellations affected all of the
outstanding tranche principal balances.

To assess the risks and credit stability considerations regarding
certain subordinate note cancellations, S&P applied these stresses
it deemed appropriate:

    S&P generated a cash flow analysis using two scenarios. The
    first scenario utilized the current balances of the notes,
    including any note cancellations, when modeling the interest
    or principal diversion mechanisms. The second scenario
    recognized only the balances of the senior notes in the
    calculation of any interest or principal diversion mechanisms.

    "Using the two scenarios, we then applied the lower of the
    rating levels as the starting point for our rating analysis
    for each class of notes," S&P said.

    "Finally, we reviewed the level of cushion relative to our
    credit stability criteria and made further adjustments to the
    ratings that we believed were appropriate," S&P related.

"The rating actions also reflect our analysis of the transaction,
including the reported impaired assets ($170.9 million, 48.1%).
According to the July 21, 2011, trustee report, total liabilities
were $332.4 million, while total assets, including principal cash,
were $355.8 million. The transaction passed all of its
overcollateralization and interest coverage ratio tests," S&P
said.

The transaction's current asset pool included:

    Nine first mortgage loans ($147.4 million, 41.4%);

    Thirteen B participation loans ($87.0 million, 24.4%);

    Five C participation loans ($26.2 million, 7.4%);

    Five mezzanine loans ($76.6 million, 21.5%); and

    Cash ($18.6 million, 5.2%).

The trustee report noted 14 impaired loans ($170.9 million, 48.1%)
in the pool. Standard & Poor's estimated asset specific recovery
rates for the impaired loans with a weighted average recovery of
44%. "We based the recovery rates on information from the
collateral manager and third-party data providers," S&P said.
Notable impaired loan assets include:

    CNL Resort Hotel Portfolio - mezzanine loan ($28.0 million,
    7.9%);

    600 Stinson Boulevard - first mortgage ($25.2 million, 7.1%);

    Amara Resort & Spa - first mortgage ($20.5 million, 5.8%); and

    Park Central Refi - B participation ($20 million, 5.6%).

"We subsequently withdrew our ratings on classes G and H following
the redemption of the principal balances in full because of note
cancellations," S&P said.

"Standard & Poor's analyzed the transaction and its underlying
assets in accordance with our current criteria. Our analysis is
consistent with the lowered, affirmed, and withdrawn ratings," S&P
added.

Ratings Lowered

FMC Real Estate CDO 2005-1 Ltd.

               Rating
Class     To              From
B         BBB (sf)        BBB+ (sf)
F         CCC+ (sf)       B- (sf)

Ratings Affirmed

FMC Real Estate CDO 2005-1 Ltd.

Class     Rating
A-1       A+ (sf)
A-2       A- (sf)
C         BB+ (sf)
D         BB- (sf)
E         B+ (sf)

Ratings Affirmed And Withdrawn

FMC Real Estate CDO 2005-1 Ltd.

               Rating
Class     To             From
G         CCC- (sf)      CCC- (sf)
          NR             CCC- (sf)
H         CCC- (sf)      CCC- (sf)
          NR             CCC- (sf)

NR -- Not rated


FTA SANTANDER: DBRS Assigns Series C Bond Rating at 'C'
-------------------------------------------------------
DBRS Ratings Limited ("DBRS") has assigned a rating of C (sf) to
the Series C Bonds and confirmed the ratings of AAA (sf) for the
Series A and BBB (sf) for the Series B Bonds issued by FTA
Santander Financiacion 5 (the "Issuer").  The Bonds are backed by
a portfolio of consumer loans originated by Banco Santander, SA.

The rating of the Series C Bonds is based upon DBRS' review of
these considerations:

  -- The Series C Bonds are in the first loss position.
  -- As such, the Series C Bonds are highly likely to default

The confirmation of the Series A and Series B Bonds is based upon
DBRS' review of these considerations:

  -- The replacement of the Subordinated Loan with the Series C
     Bonds has no impact on the rating of the Series A and Series
     B Bonds.

  -- The transaction closed June 29, 2011 with no adverse
     portfolio performance reported since then.


GCO ELF: Fitch Lowers Rating on Four Class Notes to 'Bsf'
---------------------------------------------------------
Fitch Ratings affirms the senior student loan notes at 'AAAsf' and
downgrades the subordinate and junior subordinate student loan
notes to 'Bsf' from 'BBsf' issued by GCO Education Loan Funding
Master Trust II.  The Rating Outlook remains Stable. Fitch used
its 'Global Structured Finance Rating Criteria', and 'U.S. FFELP
Student Loan ABS Surveillance Criteria', as well as 'Rating U.S.
Federal Family Education Loan Program Student Loan ABS' to review
the ratings.

The ratings on the senior notes are affirmed based on the
sufficient level of credit enhancement (consisting of
subordination and the projected minimum excess spread) to cover
the applicable risk factor stresses.

The ratings on the subordinate and junior subordinate notes are
downgraded to 'Bsf' from 'BBsf' because the trust remains
undercollateralized.  The Fitch calculated total parity, which
includes the junior subordinate notes, is 97.34%.  The reported
subordinate parity, which excludes the junior subordinate notes,
is 99.75%.

Fitch has taken these rating actions:

GCO Education Loan Funding Master Trust II:

  -- 2006-2 A-1AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-1L PIF;
  -- 2006-2 A-1RRN affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-2AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-2L affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-3AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-3L affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-4AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-4L PIF;
  -- 2007-1 A-5AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-5L affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-6AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-6L affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-7AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-7L affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-8AR PIF;
  -- 2006-2 B-1AR downgraded to 'Bsf' from 'BBsf'; Outlook Stable;
  -- 2006-2 B-2AR downgraded to 'Bsf' from 'BBsf'; Outlook Stable;
  -- 2006-2 B-3AR downgraded to 'Bsf' from 'BBsf'; Outlook Stable;
  -- 2007-1 C-1L downgraded to 'Bsf' from 'BBsf'; Outlook Stable.


GE CAPITAL: Expected Losses Cue Fitch to Downgrade Ratings
----------------------------------------------------------
Fitch Ratings has downgraded three classes and upgraded two
classes of GE Capital Commercial Mortgage Corporation's commercial
mortgage pass-through certificates, series 2001-3.

The downgrades of the junior classes reflect Fitch expected losses
largely attributed to loans in special servicing.  The upgrades of
the senior classes are the result of sufficient credit enhancement
to offset Fitch expected losses.  Fitch modeled losses of 6.01% of
the remaining pool.  There are currently eight specially-serviced
loans (9.48%) in the pool.

As of the July 2011 distribution date, the pool's aggregate
principal balance has been reduced by 51.82% (including 3.66% of
realized losses) to $464.4 million from $963.8 million at
issuance.  Sixteen loans in the pool (29.01%) are currently
defeased.  Interest shortfalls are affecting classes J, K, M and
N.

The largest contributor to Fitch-modeled losses (2.68%) is secured
by a 114,421 square foot (SF) office building located in
Arlington, TX.  The loan was transferred to special servicing in
November 2008 and became real-estate owned (REO) in April 2010.
The special servicer is pursuing a lease up strategy before taking
the property to market.

The second largest contributor to Fitch-modeled losses (1.66%) is
a 88,072 square foot (SF) office building located in Fairfield,
NJ. The loan was transferred to special servicing in November 2010
and the special servicer is pursuing foreclosure.

Fitch downgrades these classes:

  -- $27.7 million class H to 'CCCsf/RR1' from 'B-sf';
  -- $8.4 million class I to 'Csf/RR2' from 'CCCsf/RR2';
  -- $7.2 million class J to 'Csf/RR6' from 'CCsf/RR2'.

Fitch upgrades these classes:

  -- $7.2 million class E to 'AAAsf' from 'AAsf'; Outlook Stable;
  -- $12.0 million class G to 'BBBsf' from 'BBB-sf'; Outlook to
     Stable from Negative.

In addition, Fitch affirms these classes and revises the Outlooks
as indicated:

  -- $285.2 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $42.2 million class B at 'AAAsf'; Outlook Stable;
  -- $38.6 million class C at 'AAAsf'; Outlook Stable;
  -- $13.3 million class D at 'AAAsf'; Outlook Stable;
  -- $14.5 million class F at 'Asf'; Outlook to Stable from
     Negative;
  -- $8.1 million class K at 'Dsf/RR6'.
  -- Classes L and M at 'Dsf/RR6'.

Class A-1 has repaid in full. Classes L through N have been
reduced to zero due to realized losses.  Fitch does not rate class
N. Classes X-1 and X-2 have previously been withdrawn


GE COMMERCIAL: Stable Performance Cues Fitch to Affirm Ratings
--------------------------------------------------------------
Fitch Ratings affirms GE Commercial Mortgage Corporation
commercial mortgage pass-through certificates.

Fitch has affirmed these classes and revised Rating Outlooks and
Recovery Ratings (RRs):

  -- $42.4 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $406.1 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $159.7 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $35.5 million class B at 'AAAsf'; Outlook Stable;
  -- $14.8 million class C at 'AAAsf'; Outlook Stable;
  -- $26.6 million class D at 'AAAsf'; Outlook Stable;
  -- $14.8 million class E at 'AAAsf'; Outlook Stable;
  -- $14.8 million class F at 'AAAsf'; Outlook Stable;
  -- $14.8 million class G at 'AAsf'; Outlook Stable;
  -- $14.8 million class H at 'Asf'; Outlook Stable;
  -- $19.2 million class J at 'BBBsf'; Outlook Stable;
  -- $7.4 million class K at 'BB+sf'; Outlook to Stable from
     Negative;
  -- $8.9 million class L at 'Bsf'; Outlook Negative;
  -- $4.4 million class M at 'CCC/RR1';
  -- $7.4 million class N at 'CC/RR1';
  -- $3.0 million class O at 'C'; RR to 'RR2' from 'RR1';
  -- $624,593 class BLVD-1 at 'A'; Outlook Stable;
  -- $2.5 million class BLVD-2 at 'A-'; Outlook Stable;
  -- $4.5 million class BLVD-3 at 'BBB+'; Outlook Stable;
  -- $3.5 million class BLVD-4 at 'BBB'; Outlook Stable;
  -- $8.0 million class BLVD-5 at 'BB+'; Outlook Stable.

The rating affirmations reflect the stable performance and minimal
losses to date. Fitch modeled losses of 3.1% of the remaining
pool.  Fitch has designated 23 loans (17.6%) as Fitch loans of
concern, which includes two specially serviced loans (2.7%).
As of the July 2011 distribution date, the pool's collateral
balance has paid down 31.9% to $824.3 million from $1.2 billion at
issuance.  Twenty-five of the remaining loans have defeased
(29.8%).

The largest contributor to loss (2.0%), also specially serviced,
is secured by an 1,124,432 square foot (sf) industrial/warehouse
distribution center located in Memphis, TN.  The loan was
transferred to special servicing in May 2010 due to imminent
default.  The decline in performance was a result of the largest
tenant vacating at lease expiration in May 2010 and the bankruptcy
of the second largest tenant.  Title was acquired via foreclosure
at a trustee sale in May 2011.  A property manager and leasing
agent have been hired.

The second largest contributor to loss (0.8%) is secured by a
63,602 sf office property located in Tukwila, WA.  The property
has suffered declines in performance since late 2008 due to low
occupancy and soft market.  The property is currently 82% occupied
as of March 2011.  Leasing activity is limited and the borrower is
offering concessions.

The third largest contributor to loss (0.7%) is secured by an
office property located in Golden, CO.  The loan was transferred
to special servicing in May 2010 due to payment default.
Occupancy at the property had declined as a result of two tenants
vacating in 2007 and 2010, respectively.  A receiver has been
appointed and has taken over control of the property.  Leasing
activity at the property is limited and there are no prospective
tenants at this time.  The property was 23% occupied as of
February 2011.  The special servicer is proceeding with
foreclosure.

Classes A-1 and A-2 have paid in full.  Classes BLVD-1 through 5
represent the subordinate note rake classes for the Boulevard
Mall.  Fitch has previously withdrawn the rating of the interest-
only classes X-1, and X-2.


GENERAL ELECTRIC: Fitch Affirm Rating on $1.8 Mil. Notes at 'Dsf'
---------------------------------------------------------------
Fitch Ratings affirms all classes of General Electric Capital
Assurance Company, series GFCM 2001-1 commercial mortgage pass-
through certificates.

The affirmations are the result of stable performance, scheduled
amortization and sufficient credit enhancement to offset Fitch
expected losses.  Fitch modeled losses of 2.6% of the remaining
pool.

As of the July 2011 distribution date, the pool's certificate
balance has paid down 52.3% to $351.3 million from $419.7 million.
Fitch has identified 38 (23.4%) Fitch Loans of Concern (LOC), of
which one (0.5%) is specially serviced.

The only specially serviced loan in the pool is collateralized by
a 24,612 square foot (sf) office building located in Rocklin, CA,
a suburb of Sacramento.  The property has been vacant since the
loss of a single tenant at lease expiration in December 2009.  The
loan was modified in September 2010 to make interest only a
payment however has since become delinquent.

The largest contributor to Fitch expected losses is a loan (0.46%)
collateralized by an 81,900 sf warehouse building located in
Rancho Cordova, CA, a submarket of Sacramento.  Currently there is
one tenant, CA Home Furnishings (29%), on a month-to-month lease.
The remaining 71% of the space has been vacant since 2008 when
Room Source filed for bankruptcy.  Master servicer reports the
borrower is marketing the property.

Fitch affirms these classes and revises Outlooks as indicated:

  -- $270 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $112.7 million class A-5 at 'AAAsf'; Outlook Stable;
  -- $11.3 million class B at 'AA+sf'; Outlook to Positive from
     Stable;
  -- $13.3.1 million class C at 'A+sf'; Outlook to Positive from
     Stable;
  -- $11.3 million class D at 'BBBsf'; Outlook Stable;
  -- $10.2 million class E at 'BBB-sf'; Outlook Stable;
  -- $12.3 million class F at 'B-sf'; Outlook Negative;
  -- $7.1 million class G at 'CCsf/RR3';
  -- $1.8 million class H at 'Dsf/RR6'.

Classes A-1, A-2 and A-3, have paid in full.  The total loss to
class J has reduced it to zero and will remain at 'Dsf/RR6'.

Fitch withdrawals the rating on interest-only (IO) class X.


GMAC 2004-C1: Fitch Affirm Junk Ratings on Four Note Classes
------------------------------------------------------------
Fitch Ratings has downgraded three and affirmed 13 classes of GMAC
Commercial Mortgage Securities, Inc., Series 2004-C1 (GMAC 2004-
C1) commercial mortgage pass-through certificates.

The downgrade of classes J through L are the result of Fitch loss
expectations associated with the loans currently in special
servicing.  The affirmations of the senior class reflect
sufficient credit enhancement to offset Fitch modeled losses.
Fitch modeled losses of 6.8% of the remaining pool.

As of the August 2011 distribution date, the pool's certificate
balance has been reduced by 25.1% (to $540.7 million from $721.4
million at issuance), of which 24.2% were due to paydowns and 0.9%
were due to realized losses. Seven loans, representing 19.7% of
the pool, have been fully defeased.

Fitch has designated 12 loans (21.5%) as Fitch Loans of Concern,
which includes five specially serviced loans (11.13%).
The largest specially serviced asset (8% in total), and largest
contributor to Fitch expected losses, is comprised of two cross
collateralized office properties located in Fort Washington, PA.
The borrower was unable to meet debt service obligations after the
loss of a major tenant.  A foreclosure sale was held earlier this
year and the Trust was the winning bidder.  Fitch expects losses
upon liquidation of the assets based on a recent valuation
obtained by the special servicer that is below the outstanding
loan balance.

The next largest specially serviced asset (1.3%) is a retail
property located in Mount Clemens, MI.  The property went into
monetary default after an anchor tenant stopped paying rent. The
special servicer is pursuing foreclosure and the Borrower filed
for bankruptcy.  Fitch expects losses upon liquidation of the
assets based on a recent valuation obtained by the special
servicer that is below the outstanding loan balance.

The third largest contributor to losses (5.1%) is secured by a
1,141,511 square foot commercial office complex located in
Columbus, OH.  The property was 99% occupied as of the June 2011
rent roll.  The borrower stated loss of income was due to the
shared loss for the razing of a building in the center.

Fitch downgrades the following classes as indicated:

  -- $4.5 million class J to 'CCsf/RR6' from 'CCCsf/RR2';
  -- $4.5 million class K to 'Csf/RR6' from 'CCCsf/RR2';
  -- $4.5 million class L to 'Csf/RR6' from 'CCsf/RR4'.

In addition, Fitch affirms the following classes and revises
Outlooks as indicated:

  -- $43.4 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $343.8 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $41.8 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $20.7 million class B at 'AAAsf'; Outlook Stable;
  -- $8.1 million class C at 'AAAsf'; Outlook to Stable from
     Negative;
  -- $15.3 million class D at 'AAsf'; Outlook to Stable from
     Negative;
  -- $8.1 million class E at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $12.6 million class F at 'BBsf'; Outlook to Stable from
     Negative;
  -- $8.1 million class G at 'B-sf'; Outlook to Stable from
     Negative;
  -- $10.8 million class H at 'CCCsf/RR2';
  -- $2.7 million class M at 'Csf/RR6';
  -- $2.7 million class N at 'Csf/RR6';
  -- $2.7 million class O at 'Csf/RR6'.

Class A-1 and A-2 has been paid in full.  Fitch does not rate
class P.


GMAC COMMERCIAL: Fitch Affirms Rating on $3.3 Mil. Notes at 'D'
---------------------------------------------------------------
Fitch Ratings upgrades three classes of GMAC Commercial Mortgage
Securities, Inc., series 2004-C3, commercial mortgage pass-through
certificates.

The upgrades are the result of increased credit enhancement due to
paydown which is sufficient to offset Fitch expected losses.
Fitch modeled losses of 9% of the remaining pool.

As of the July 2011 distribution date, the pool's collateral
balance has paid down 29% to $889.5 million from $1.25 billion at
issuance.  Four loans (4%) have defeased.  Fitch has identified 26
Loans of Concern (35%), including 10 assets in special servicing
(19%).

The largest contributor to loss (3.7%) is secured by a 302,992
square foot (sf), 11 story office building located in Chicago, IL
(approximately 15 miles NW of the CBD). T he loan was transferred
to special servicing in April 2009 due to a technical default.  A
major tenant vacated at lease expiration in May 2007 which
triggered a monthly rollover reserve escrow payment.  The
triggered payment was not implemented until February 2009.  Loan
modification discussions failed and a receiver was appointed in
August 2010.  The special servicer took title through foreclosure
on Jan. 13, 2011.  The property was 60% occupied as of April 2011
which includes two new leases totaling 23,500 sf signed during the
1st quarter of 2011.  There is an additional lease totaling 54,968
sf under negotiation.  The special servicer's strategy is to hold,
reposition, and stabilize the asset.

The second largest contributor to loss (1.7%) is secured by two
four-story buildings which are part of a three building student
housing property located near Winthrop University in Rock Hill,
SC. The two buildings are comprised of 124 units with a total of
432 beds.  The loan was transferred to special servicing in
September 2009 due to monetary default.  A receiver was appointed
by the court in February 2010 and the property remains in
receivership.  As of June 2011, the property was 75% pre-leased
for the fall 2011 school year.

The third largest contributor to loss (1.8%) is secured by a 268
unit apartment building located in Pensacola, FL.  The loan was
transferred to special servicing in October 2009 for imminent
maturity default prior to the November 2009 maturity.  A receiver
was assigned to the property in November 2010.  The receiver is
currently leasing up the property to market occupancy and the
property is currently 71% occupied.

Fitch upgrades and revises Outlooks on these classes as indicated:

  -- $82.9 million class A-J to 'BBBsf' from 'BBB-'; Outlook
     revised to Stable from Negative;
  -- $31.3 million class B to 'BBsf' from 'B-'; Outlook revised to
     Stable from Negative;
  -- $14.1 million class C to 'Bsf' from 'B-'; Outlook revised to
     Stable from Negative.

Fitch also affirms these classes as indicated:

  -- $263.3 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $226.1 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $47 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $138.6 million class A-5 at 'AAAsf'; Outlook Stable;
  -- $20.3 million class D at 'CCCsf/RR1';
  -- $12.5 million class E at 'CCsf/RR3';
  -- $15.6 million class F at 'Csf/RR6';
  -- $10.9 million class G at 'Csf/RR6'';
  -- $20.3 million class H at 'Csf/RR6';
  -- $3.1 million class J at 'Csf/RR6';
  -- $3.3 million class K at 'Dsf/RR6.

Classes L, M, N, and O remain at 'D/RR6' due to principal losses
incurred. Classes A-1, A-2, and A-3 have been paid in full.  Class
P is not rated by Fitch. Fitch had previously withdrawn the
ratings of the interest only classes X-1 and X-2.


GOLDEN TREE: Moody's Upgrades Ratings of 5 Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by GoldenTree Loan Opportunities V, Limited:

US$506,250,000 Class A Senior Secured Floating Rate Notes due
2021, Upgraded to Aaa (sf); previously on June 22, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade;

US$61,875,000 Class B Senior Secured Floating Rate Notes due 2021,
Upgraded to Aa3 (sf); previously on June 22, 2011 A2 (sf) Placed
Under Review for Possible Upgrade;

US$43,125,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2021, Upgraded to A3 (sf); previously on June 22, 2011
Baa3 (sf) Placed Under Review for Possible Upgrade;

US$30,000,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2021 Notes, Upgraded to Baa3 (sf); previously on June
22, 2011 Ba3 (sf) Placed Under Review for Possible Upgrade;

US$33,750,000 Class E Secured Deferrable Floating Rate Notes due
2021, Upgraded to Ba2 (sf); previously on June 22, 2011 B3 (sf)
Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios since the rating action
in September 2009. Based on the August 2011 trustee report, the
Class A/B, Class C, and Class D overcollateralization ratios are
reported at 131.60%, 122.30%, 116.60% and 110.70%, respectively,
versus August 2009 levels of 127.71%, 118.70%, 113.15% and
107.49%, respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $747.5 million, a
weighted average default probability of 26.93% (implying a WARF of
3215), a weighted average recovery rate upon default of 50.30%,
and a diversity score of 45. The 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.

GoldenTree Loan Opportunities V, Limited, issued in September 28,
2007 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
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CLO 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 the
   worse of reported and covenanted 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 and coupon levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.


GREENWICH CAPITAL: Fitch Affirms Junk Rating on Three Note Classes
------------------------------------------------------------------
Fitch Ratings downgrades two classes of Greenwich Capital
Commercial Funding Corporation Commercial Mortgage Trust series
2002-C1, commercial mortgage pass-through certificates.

The downgrades are the result of an increase in Fitch expected
losses across the pool.  Fitch modeled losses of 3.2% of the
remaining pool mostly attributed to specially serviced loans.
Fitch has designated 12 loans (14.1%) as Fitch Loans of Concern,
which includes five specially serviced loans (5.0%).  Fitch
expects losses associated with the specially serviced assets to
deplete classes P and Q and impair class O.

As of the July 2011 distribution date, the pool's aggregate
principal balance has been reduced by approximately 27.1% to
$858.4 million from $1.18 billion at issuance.  Interest
shortfalls are affecting classes N through Q with cumulative
unpaid interest totaling $1.6 million.  Of the 93 remaining loans
in the pool, 22 are defeased (32.5%) including five of the top 15
loans (20.3%).

The largest contributor to Fitch modeled losses is a 185,000
square foot (SF) class A office property located in Northbrook,
IL, a Chicago suburb.  The loan was transferred to special
servicing in April 2010 for imminent default and the borrower's
requested for a loan modification. The loan has since become
delinquent.  The special servicer has filed for foreclosure and
recent property valuations obtained by the special servicer
indicate losses upon liquidation.  As of April 2011, property was
68.5% occupied.

The second largest contributor to Fitch modeled losses is a 266
room limited service hotel located in Daton, OH.  The loan was
transferred to special servicing in November 2008 due to the
borrower's request for loan modification.  The borrower filed
bankruptcy in June 2010 after the special servicer initiated the
foreclosure process.  The special servicer continues to work
through the bankruptcy court to cure the default.

The third largest contributor to Fitch modeled losses is a 49,416
SF retail property located in Greenwood Village, CO.  The loan has
been on the master servicer watchlist since June 2006 due to
declining occupancy and debt service coverage ratio (DSCR).  The
most recent servicer reported year-end (YE) 2010 DSCR was 0.55x
and occupancy of 64%.  Occupancy at the property declined to 56%
as of May 2011 due to tenants vacating their spaces or downsizing
throughout 2010.  The loan remains current.

Fitch has downgraded these classes:

  -- $20.4 million class L to 'Bsf' from 'BBsf'; Outlook Negative;
  -- $8.7 million class O to 'Csf/RR4' from 'CCsf/RR2'.

Fitch has affirmed ratings and revised Outlooks for these classes:

  -- $6.1 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $14.6 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $608.2 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $46.5 million class B at 'AAAsf'; Outlook Stable;
  -- $11.6 million class C at 'AAAsf'; Outlook Stable;
  -- $14.5 million class D at 'AAAsf'; Outlook Stable;
  -- $20.4 million class E at 'AAAsf'; Outlook Stable;
  -- $16 million class F at 'AAAsf'; Outlook Stable;
  -- $16 million class G at 'AAAsf; Outlook Stable;
  -- $17.4 million class H at 'AA+sf; Outlook Stable;
  -- $14.5 million class J at 'Asf'; Outlook to Stable from
     Negative;
  -- $20.4 million class K at 'BBBsf'; Outlook Negative;
  -- $8.7 million class M at 'CCCsf/RR1';
  -- $5.8 million class N at 'CCsf/RR2';
  -- $4.4 million class P at 'Csf/RR6'.

Fitch does not rate class Q.  Class A-1, interest-only classes XPB
and XP, and non-rated class SWD-B are paid in full.  Fitch has
withdrawn the rating of the interest-only class XC.


GREENWHICH CAPITAL: Fitch Holds Junk Rating on 5 Classes of Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed Greenwich Capital Commercial Funding
Corp. commercial mortgage pass-through certificates, series 2005-
FL3. While performance of the remaining loan has continued to
decline from year end (YE) 2009 to 2010, Fitch expects minimal, if
any, losses to the pooled certificates based on the quality and
location of the underlying asset.  The previous negative rating
actions take into account the decline since issuance, with
Negative Rating Outlooks reflecting the continuing decline.

The remaining loan in the transaction is the $43 million Lowell
Hotel loan ($28.7 million pooled note and $14.3 million non-pooled
rake).  In addition, there is $14.3 million in debt held outside
the trust.  Fitch analyzed servicer reported operating statements,
in addition to other information received from the master servicer
as the loan returned to master servicing in late 2010 after being
modified.

The loan is collateralized by a 17-story full-service luxury hotel
located on 63rd Street between Madison and Park Avenues in New
York City.  There are 70 rooms with a high percentage of suites
and suites with fireplaces.  Amenities include two restaurants,
the Post House located on the ground floor and the Pembroke Room
located on the second floor.

The loan transferred to special servicing in August 2010 due to
imminent default when the borrower indicated that they would be
unable to pay off the loan at the final maturity date in September
2010.  The special servicer has modified the loan to include two
additional one-year extension options and pay down of the loan.
The borrower utilized the first extension option and paid down the
trust debt by $2 million and is expected to utilize the second
extension option with an extended maturity date of September 2012.

Property performance has declined. While revenue per available
room (RevPAR) remains relatively stable compared to issuance
levels, there has been a significant decline in net operating
income (NOI).  As of YE 2010, the servicer-reported NOI has
declined 41% from YE 2009.  The reported YE 2010 occupancy, ADR
and RevPAR were 63.5%, $827, and $525, respectively, compared to
issuance levels (as of trailing 12 months October 2005) of 81.8%,
$625 and $511.

Fitch affirms the ratings, Rating Outlooks and Recovery Ratings to
the pooled and non-pooled certificates:

  -- $707,140 class H at 'AAAsf'; Outlook Stable;
  -- $6.3 million class J at 'AA+sf'; Outlook Stable;
  -- $4.4 million class K at 'A+sf'; Outlook Negative;
  -- $5.1 million class L at 'BBBsf'; Outlook Negative;
  -- $12.2 million class M at 'CCCsf/RR1';
  -- $5.6 million class H-LH at 'CCCsf/RR1';
  -- $3.8 million class K-LH at 'CCCsf/RR1';
  -- $3.8 million class M-LH at 'CCCsf/RR6';
  -- $1.1 million class N-LH at 'CCCsf/RR6'.

Classes A-1 through G, X-1, and various non-pooled classes related
to individual loans have paid in full.


GS MORTGAGE: DBRS Confirms Class E Rating at 'BB'
-------------------------------------------------
DBRS has confirmed these ratings of GS Mortgage Securities Trust,
2010-C1:

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

The collateral consists of 23 fixed-rate loans secured by 48
commercial properties.  As of the August 2011 remittance report,
the pool has a balance of $775,978,349, representing a collateral
reduction of approximately 1.6% since issuance in August 2010.
Overall, the loans in the pool have reported stable performance
since issuance.

The DBRS analysis included an in depth review of the top ten loans
and the shadow rated loans, which represents approximately 85% of
the current pool balance.  These loans, based on the DBRS
underwritten net cash flow, have a weighted average term debt
yield of approximately 13.1%, based on the August 2011 loan
balance, indicating lower leverage financing.  The transaction
also benefits from loans structured with significant amortization
as 19.2% of the pool amortizes down by maturity.

At issuance, DBRS shadow-rated eleven loans, representing 58.2% of
the current pool balance, investment grade.  DBRS confirmed that
the performance of the loans remains consistent with investment-
grade loan characteristics.  The investment-grade shadow-rated
loans are indicative of the long-term stability of the underlying
assets' cash flow and the low leverage of the loans secured by
those assets.

As of the August 2011 remittance report, there are no loans on the
servicer's watchlist and there are no delinquent or specially
serviced loans.

DBRS continues to monitor this transaction in our Monthly CMBS
Surveillance Report, to assess any material changes at the bond
level or the collateral level that may impact our ratings.  The
Monthly CMBS Surveillance Report also highlights any material
updates in the loans on the servicer's watchlist or any specially
serviced loans.


GS MORTGAGE: Fitch Affirms Rating on $4 Mil. Notes at 'CCCsf/RR1'
-----------------------------------------------------------------
Fitch Ratings has upgraded these classes of GS Mortgage Securities
Corporation II's commercial mortgage pass-through certificates,
series 2003-C1:

  -- $12.1 million class F to 'AAAsf' from 'AA+sf'; Outlook
     Stable;
  -- $20.1 million class G to 'AAsf' from 'AA-sf'; Outlook Stable;
  -- $12.1 million class H to 'Asf' from 'A-sf'; Outlook Stable;

Fitch has affirmed the ratings and revised Outlooks for the
following classes:

  -- $85.9 million class A-2B at 'AAAsf'; Outlook Stable;
  -- $676.8 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $54.4 million class B at 'AAAsf'; Outlook Stable;
  -- $16.1 million class C at 'AAAsf'; Outlook Stable;
  -- $12.1 million class D at 'AAAsf'; Outlook Stable;
  -- $18.1 million class E at 'AAAsf'; Outlook Stable;
  -- $12.1 million class J at 'BBB+sf'; Outlook Stable;
  -- $12.1 million class K at 'BBBf'; Outlook Stable;
  -- $8.1 million class L at 'BB+sf'; Outlook Stable;
  -- $6 million class M at 'BBsf'; Outlook Stable.
  -- $6 million class N at 'B+sf'; Outlook revised to Stable from
     Negative;
  -- $2 million class O at 'Bsf'; Outlook revised to Stable from
     Negative.
  -- $4 million class P at 'CCCsf/RR1'.

Additionally, Fitch has withdrawn the rating on the Interest-Only
class X-1.

The $14.1 million class S is not rated by Fitch.  Classes A-1, A-
2A, and X-2 have paid in full.

Fitch expects losses of approximately 1.5% of the remaining pool
balance ($14.1 million).  The Rating Outlooks indicate the likely
direction of any changes to the ratings over the next one to two
years.

As of the July 2011 distribution date, the pool's aggregate
certificate balance has decreased 39.8% to $978.9 million, from
$1.61 billion at issuance.  Eleven loans (30%) have defeased,
including the largest loan (21.7%).  Of the original 76 loans, 45
remain. There are no loans in special servicing as of July 2011.

Fitch has identified five Loans of Concern (5.2%), including two
of the top 10 remaining loans (4.6%).

The largest Fitch Loan of Concern (2.5%) is secured by the
leasehold interest in a 424,378-square foot (sf) office property
located in Newark, NJ.  Occupancy has increased over the past year
to 87% (January 2011) but is still lower than the building's 98.5%
occupancy level at issuance.  Year-end 2010 servicer-reported debt
service coverage ratio (DSCR) improved year-over-year to 1.26x
from 0.91x at the end of 2009.  The loan remains current with the
master servicer.


GSMSC II: Fitch Junks Rating on Four Note Classes
-------------------------------------------------
Fitch Ratings has downgraded five and affirmed 18 classes of GS
Mortgage Securities Corporation II, commercial mortgage pass-
through certificates, series 2005-GG4 (GSMSC II 2005-GG4), due to
further deterioration of performance, most of which involves
increased losses on the specially serviced loans.

The downgrades and assignment of Negative Outlooks reflect an
increase in Fitch-modeled losses across the pool.  Fitch modeled
losses of 8.1% for the remaining pool.  Fitch has designated 47
loans (30%) as Fitch Loans of Concern, which includes 26
specially-serviced loans (20.6%).  Of the loans in special
servicing, three loans (4.3%) are real-estate owned (REO), 16
loans (14%) are in foreclosure, two loans (0.2%) are 90 days or
more delinquent, two loans (1%) are 30 days delinquent, and three
loans (1.1%) remain current.  Fitch expects classes H through P
may be fully depleted from losses associated with the specially-
serviced assets.

As of the August 2011 distribution date, the pool's aggregate
principal balance has been reduced by 13.73% (to $3.45 billion
from $4 billion at issuance), of which 13.18% were due to pay down
and 0.55% were due to realized losses.  Seven loans comprising 7%
of the pool have been defeased.  Cumulative interest shortfalls
totaling $11.7 million are currently affecting classes J through
P.

The largest contributor to modeled losses is a specially-serviced
loan (2.1%) secured by a 73,522 square foot (sf) open-air retail
center located in Waikoloa, HI.  The loan was transferred to
special servicing in January 2010 as the borrower was unable to
pay off the loan at maturity.  According to the special servicer,
a loan modification agreement has been approved.  Terms of the
approved modification include a bifurcation of the loan into an A-
note and a B-note and an extension of the maturity date.  Legal
counsel is in the process of drafting the agreement.

The second largest contributor to modeled losses is a specially-
serviced loan (2.3%) secured by a 707-room hotel property located
in New Orleans, LA. The loan was transferred to special servicing
in May 2009 due to monetary default. The loan became REO in April
2011. Property management is in the process of implementing
upgrades to the rooms and to certain common areas and evaluating
options to enhance the street-level visibility and appeal of the
property.

The third largest contributor to modeled losses is a specially-
serviced loan (1.4%) secured by 267,379 square feet within a
462,454 sf retail power center located in Gilbert, AZ.  The loan
was transferred to special servicing in September 2010 due to
imminent default.  The lender has commenced the foreclosure
process with a foreclosure sale date scheduled for November 2011.

The largest non-specially serviced loan, which is of concern, is
secured by a 40-story, 851,915 sf office building located in
Buffalo, NY.  Fitch continues to monitor the performance of the
property as the leases of the two largest tenants (87% of total
NRA) both expire in 2013.  According to the servicer, these
tenants are considering relocation at or prior to lease
expiration. Renewing these tenant's leases will be critical to
successfully refinancing the loan in February 2015.  If these
tenants vacate and the sponsor is unable to release the space,
further negative ratings migration may be possible.

Fitch has downgraded and revised Recovery Ratings (RR) as
indicated:

  -- $75 million class D to 'Bsf' from 'BBsf'; Outlook Negative;
  -- $40 million class E to 'CCCsf/RR1' from 'Bsf';
  -- $55 million class F to 'CCsf/RR1' from 'CCCsf/RR1';
  -- $45 million class G to 'CCsf/RR6' from 'CCCsf/RR1';
  -- $40 million class H to 'Csf/RR6' from 'CCsf/RR5'.

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

  -- $224,759 class A-DP at 'AAAsf'; Outlook Stable;
  -- $229.5 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $288.7 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $145.7 million class A-ABA at 'AAAsf'; Outlook Stable;
  -- $29.6 million class A-ABB at 'AAAsf'; Outlook Stable;
  -- $500 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $1.17 billion class A-4A at 'AAAsf'; Outlook Stable;
  -- $167.4 million class A-4B at 'AAAsf; Outlook Stable;
  -- $140.8 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $300.1 million class A-J at 'Asf'; Outlook Stable;
  -- $65 million class B at 'BBBsf'; Outlook Stable;
  -- $35 million class C at 'BBB-sf'; Outlook to Negative from
     Stable;
  -- $20 million class J at 'Csf/RR6';
  -- $20 million class K at 'Csf/RR6';
  -- $20 million class L at 'Csf/RR6';
  -- $10 million class M at 'Csf/RR6';
  -- $10 million class N at 'Csf/RR6';
  -- $10 million class O at 'Csf/RR6'.

The $32.9 million class P is not rated by Fitch.

Classes A-1 and A-1P have been paid in full.  The ratings on the
interest-only classes X-P and X-C were previously withdraw.





GUGGENHEIM 2006-3: Fitch Affirms Junk Rating on 3 Class Notes
-------------------------------------------------------------
Fitch Ratings has upgraded three classes of Guggenheim Structured
Real Estate Funding 2006-3 Ltd./LLC reflecting significant paydown
since Fitch's last review.  Fitch's base case loss expectation is
currently 37.1% for the remaining assets.  Fitch's performance
expectation incorporates prospective views regarding commercial
real estate market value and cash flow declines.

Fitch has upgraded, affirmed, and revised or assigned Outlooks on
these classes:

  -- $20,000,000 class S affirmed at 'Asf', Outlook to Stable from
     Negative;

  -- $24,357,606 class B upgraded to 'A' from 'BB'; Outlook to
     Stable from Negative;

  -- $42,053,000 class C upgraded to 'BB' from 'B; Outlook to
     Stable from Negative;

  -- $24,029,000 class D upgrade to 'B' from 'CCC/RR6'; Outlook
     Stable;

  -- $28,827,789 class E affirm at 'CCC/RR6';

  -- $22,054,477 class F affirm at 'CC/RR6';

  - -$22,126,278 class G affirm at 'CC/RR6'.

Class A-1 and A-2 have paid in full.

Since Fitch's last review, the transaction has benefited from
significant repayments of approximately $155.9 million.  The
transaction is now considered concentrated with only 12 obligors.
Guggenheim 2006-3 is primarily collateralized by commercial real
estate (CRE) debt of which approximately 45.8% is subordinate debt
or non-senior tranches from structured finance transactions.
Fitch expects significant losses upon default for the subordinate
positions, since they are generally highly leveraged.  Two loans
(11%) are currently defaulted and one loan (21.7%) is considered a
Fitch loan of concern.  Fitch expects significant losses on the
defaulted assets.

Guggenheim 2006-3 is a CRE collateralized debt obligation (CDO)
managed by GSREA, LLC with approximately $184.7 million of
collateral.  The transaction has a five-year reinvestment period,
which ends in August 2011.

As of the July 2011 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: CRE subordinate
debt (28.1%), A-notes/whole loans (42.6%), CMBS (8.7%), and CRE
CDOs (20.6%).  In general, Fitch treats non-senior, single-
borrower CMBS as CRE B-notes.  The average Fitch derived rating
for the remaining collateral that carries a public rating is
'B/B+'.

All overcollateralization (OC) and interest coverage (IC) tests,
except for the class E OC test, are passing, as of the July 2011
trustee report.  As a result of the class E OC test failure,
interest and principal proceeds (after class E) are being
redirected to redeem class A-1.  The failure, however, is slight
and Fitch anticipates that it will cure in the next payment
period.

Under Fitch's updated methodology, approximately 57.8% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 8.5% from the most recent available cash
flows (generally from year-end 2010).  Fitch estimates that
recoveries will average 35.8%.

The largest component of Fitch's base case loss expectation is the
expected loss assigned to the CRE CDO collateral.

The second largest component of loss expectation is a highly
leveraged whole loan (21.7%) on a full-service hotel located one
block east of Chicago's Magnificent Mile.  The hotel's most
recently reported trailing 12-month net cash flow is again lower
than the prior year.  Although the hotel is still covering its
debt service payments given historically low LIBOR, Fitch modeled
a term default in its base case scenario.

The third largest component of Fitch's base case loss expectation
is an A-note (10.1%) secured by an undeveloped land parcel in
Orlando, FL. Fitch is modeling a term default in its base case
scenario with substantial modeled losses.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio. Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to class B through D was then compared to
the modeled expected losses, and in consideration of the high
concentration of the pool, the credit enhancement was determined
to be consistent with the ratings assigned below.  Based on prior
modeling results, no material impact was anticipated from cash
flow modeling the transaction. The Rating Outlooks for classes B
through D are Stable reflecting the paydown of the senior notes.

The 'CCC' and below ratings for classes E through G are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Class S is an interest-only class with a notional balance of $20
million. The interest amount is paid monthly out of CDO cash flows
and is pari passu in priority to class A-1.  Class S credit
characteristics are consistent with a 'A' rating; there are only
two payments remaining.


GUGGENHEIM 2006-4: Fitch Affirms Junk Rating on Six Class Notes
---------------------------------------------------------------
Fitch Ratings has affirmed all classes of Guggenheim Structured
Real Estate Funding 2006-4 Ltd./LLC reflecting Fitch's base case
loss expectation of 40.7% for the remaining assets.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market value and cash flow declines.

Fitch has affirmed the ratings, and revised Outlooks on these
classes as indicated:

  -- $6,000,000 class S at 'BB'; Outlook to Stable from Negative;
  -- $91,145,375 class A-1 at 'BB'; Outlook to Stable from
     Negative;
  -- $34,833,426 class A-2 at 'B'; Outlook to Stable from
     Negative;
  -- $42,040,342 class B at 'B'; Outlook Negative;
  -- $26,143,106 class C at 'CCC'; 'RR6';
  -- $14,004,731 class D at 'CCC'; 'RR6;
  -- $13,426,314 class E at 'CCC'; 'RR6';
  -- $13,582,609 class F at 'CC'; 'RR6';
  -- $14.895,706 class G at 'C'; 'RR6';
  -- $10,692,678 class H at 'C'; 'RR6'.

Since last review the class A-1 notes have amortized by an
additional $90.8 million due to the removal of four assets
(three of which paid in full), the partial paydown and
amortization of several other loans, and through interest
diversion. The disposal of one asset resulted in the realized
loss to the CDO of $4.1 million.

Guggenheim 2006-4 is concentrated with 14 obligors of commercial
real estate (CRE) debt of which approximately 84.3% is subordinate
debt or subordinate tranches of structured finance transactions.
Fitch expects significant losses upon default for the subordinate
positions since they are generally highly leveraged. Positions
from three obligors (26.2%) are currently defaulted and one loan
(3.3%) is considered a Fitch loan of concern.  Fitch expects
significant losses on the defaulted assets.

Guggenheim 2006-4 is a CRE collateralized debt obligation (CDO)
managed by GSREA, LLC with approximately $302.2 million of
collateral. The transaction has a five-year reinvestment period,
which ends in February 2012.

As of the July 2011 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: CRE subordinate B-
notes/mezzanine loans (57.4%), A-notes/whole loans (15.4%), CMBS
(10.2%), and CRE CDOs (17%).  In general, Fitch treats non-senior,
single-borrower CMBS as CRE B-notes.  The average Fitch derived
rating for the remaining collateral that carries a public rating
is 'CCC+'.

All overcollateralization (OC) tests are failing, as of the July
2011 trustee report.  As a result all interest proceeds remaining
after the payment of the class B interest are redirected to redeem
class A-1.

Under Fitch's updated methodology, approximately 61.7% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 8.2% from the most recent available cash
flows (generally from year-end 2010).  Fitch estimates that
recoveries will average 34.0%.

The largest component of Fitch's base case loss expectation is the
expected loss assigned to the CRE CDO collateral.

The second largest component of Fitch's base case loss expectation
is the expected loss on three B-notes (10.9%) on a portfolio of
three hotel/gaming properties that have experienced significant
declines in performance.  Fitch modeled a term default in its base
case scenario with a full loss on the subordinate positions.

The third largest component of Fitch's base case loss expectation
is an A-note (12.1%) secured by an undeveloped land parcel in
Orlando, FL.  Fitch is modeling a term default in its base case
scenario with substantial modeled losses.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S.  CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to class A-1 through B was then compared to
the modeled expected losses, and in consideration of the high
concentration of the pool, the credit enhancement was determined
to be consistent with the ratings assigned below.  Based on prior
modeling results, no material impact was anticipated from cash
flow modeling the transaction.  The Rating Outlooks for classes A-
1, A-2, and S are revised to Stable from Negative reflecting the
paydown of the senior notes.  Class B maintains a Negative Rating
Outlook reflecting Fitch's expectation of further potential
negative credit migration of the underlying collateral.

The 'CCC' and below ratings for classes C through H are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Class S is an interest-only class with a notional balance of
$6 million. The interest amount is paid monthly out of CDO cash
flows and is pari passu in priority to class A-1.  Class S credit
characteristics are consistent with a 'BBsf' rating.


HELLER SBA: Growing Credit Prompts Fitch to Affirm Low-B Ratings
----------------------------------------------------------------
Fitch Ratings affirms Heller SBA Corp. pass-through adjustable-
rate certificates, series 1998-1:

  -- Class A at 'AAsf'; Outlook Negative;
  -- Class M-1 at 'Asf'; Outlook Negative;
  -- Class M-2 at 'BBBsf'; Outlook Negative;
  -- Class M-3 at 'BBsf'; Outlook Negative;
  -- Class B at 'Bsf'; Outlook Negative.

The affirmations reflect growing credit enhancement and strong
obligor loss coverage, despite higher delinquency performance.  As
of the July 2011 reporting period, 30.62% of the pool is currently
delinquent.  Cumulative net losses to date are 3.45%.  Due to the
higher delinquency performance and the resulting loss expectation
on the delinquent loans, the transaction has experienced multiple
compression under Fitch's cashflow modeling analysis, detailed
below. However, obligor concentration coverage is significantly
strong with coverage exceeding the obligor thresholds for the
current ratings.

The Negative Rating Outlooks are a result of the higher
delinquency roll rate the transaction continues to experience.  As
late-stage delinquencies continue through the liquidation process,
credit enhancement may be materially impacted if ultimate
recoveries are lower than expected.  Furthermore, Fitch will
continue to monitor the series as the transaction amortizes to
assess the impact of increasing obligor concentrations.  As
obligor counts for the pools continue to decline and tail risk
increases, Fitch will review the transaction for potential ratings
action or withdrawals.

In reviewing the transactions, Fitch took into account analytical
considerations outlined in Fitch's 'Global Structured Finance
Rating Criteria', issued Aug. 16, 2010, including asset quality,
credit enhancement, financial structure, legal structure, and
originator and servicer quality.

Fitch's analysis incorporated a review of collateral
characteristics, in particular, focusing on delinquent and
defaulted loans within the pool.  All loans over 60 days
delinquent were deemed defaulted loans.  The defaulted loans were
applied loss and recovery expectations based on collateral type
and historical recovery performance to establish an expected net
loss assumption for the transaction. Fitch stressed the cashflows
generated by the underlying assets by applying its expected net
loss assumption.  Furthermore, Fitch applied a loss multiplier to
evaluate break-even cash flow runs to determine the level of
expected cumulative losses the structure can withstand at a given
rating level.  The loss multiplier scale utilized is consistent
with that of other commercial ABS transactions.

Additionally, to review possible concentration risks within the
pool, Fitch evaluated the impact of the default of the largest
performing obligors.  Similar to the analysis detailed above,
Fitch applied loss and recovery expectations to the performing
obligors based on collateral type and historical recovery
performance.  The expected loss assumption was then compared to
the credit support available to the outstanding notes given
Fitch's expected losses on the currently defaulted loans.
Consistent with the obligor approach detailed in 'Rating US
Equipment Lease and Loan Securitizations', dated June 16, 2008,
Fitch applied losses from the largest performing obligors
commensurate with the individual rating category. The number of
obligors ranges from 20 at 'AAA' to five at 'B'.

Fitch will continue to closely monitor these transactions and may
take additional rating action in the event of changes in
performance and credit enhancement measures.


HEWETT'S ISLAND: Moody's Raises Ratings of 6 Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Hewett's Island CLO VI, Ltd.:

US$255,500,000 Class A-T First Priority Senior Secured Floating
Rate Term Notes Due June 9, 2019 (current outstanding balance of
$231,262,519), Upgraded to Aaa (sf); previously on June 22, 2011
Aa2 (sf) Placed Under Review for Possible Upgrade;

US$50,000,000 Class A-R First Priority Senior Secured Floating
Rate Revolving Notes Due June 9, 2019 (current outstanding balance
of $45,256,853), Upgraded to Aaa (sf); previously on June 22, 2011
Aa2 (sf) Placed Under Review for Possible Upgrade;

US$27,500,000 Class B Second Priority Senior Secured Floating Rate
Notes Due June 9, 2019, Upgraded to Aa3 (sf); previously on June
22, 2011 A3 (sf) Placed Under Review for Possible Upgrade;

US$15,500,000 Class C Third Priority Senior Secured Deferrable
Floating Rate Notes Due June 9, 2019, Upgraded to Baa1 (sf);
previously on June 22, 2011 Baa3 (sf) Placed Under Review for
Possible Upgrade;

US$15,500,000 Class D Fourth Priority Mezzanine Secured Deferrable
Floating Rate Notes Due June 9, 2019, Upgraded to Ba1 (sf);
previously on June 22, 2011 B1 (sf) Placed Under Review for
Possible Upgrade;

US$16,000,000 Class E Fifth Priority Mezzanine Secured Deferrable
Floating Rate Notes Due June 9, 2019, Upgraded to Ba3 (sf);
previously on June 22, 2011 Caa2 (sf) Placed Under Review for
Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $361.2 million,
defaulted par of $4.0 million, a weighted average default
probability of 19.24% (implying a WARF of 2593), a weighted
average recovery rate upon default of 48.44%, and a diversity
score of 67. The 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.

Hewett's Island CLO VI, Ltd., issued in May 2007, 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
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CLO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) 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 the worse of reported
   and covenanted values for weighted average rating factor,
   weighted average spread, and diversity score. However, as part
   of the base case, Moody's considered spread and diversity
   levels higher than the covenant levels due to the large
   difference between the reported and covenant levels.


JP MORGAN: Fitch Affirms Junk Rating on Eight Note Classes
----------------------------------------------------------
Fitch Ratings has affirmed J.P. Morgan Chase Commercial Mortgage
Securities Corp.'s commercial mortgage pass-through certificates,
series 2004-CIBC9.


The affirmations reflect stable portfolio performance and
sufficient credit enhancement to offset Fitch expected losses.
Fitch modeled losses of 9.12% of the remaining pool.  Fitch
designated 21 loans (24%) as Fitch Loans of Concern, which include
seven specially serviced loans (11.95%).

As of the July 2011 distribution date, the pool's aggregate
principal balance has been reduced by 28.85% (including 1.56% of
realized losses) to $784 million from $1.1 billion at issuance.
Interest shortfalls are affecting classes G through NR. Five loans
in the pool (5.99%) are currently defeased.

The largest specially-serviced loan in the pool (5.47%) is secured
by 433,829 square feet (sf) of owned space at a 603,207 sf retail
property located in Sacramento, CA.  The loan transferred to
special servicing in March 2008 due to imminent default. In
January 2009, the anchor tenant (44.8%) filed for bankruptcy and
vacated the property in July 2009.  The special servicer continues
to work with the borrower cure the default while simultaneously
pursuing foreclosure.

The second largest specially-serviced loan in the pool (1.96%) is
secured by two multifamily properties located in Chattanooga, TN
and Red Bank, TN.  The loan was transferred to special servicing
in January 2010 due to monetary default and the special servicer
is pursuing foreclosure.

Fitch affirms these classes and revises the Outlooks and Recovery
Ratings (RR) as indicated:

  -- $46.8 million class A-3 at 'AAAsf'; Outlook to Stable from
     Negative;
  -- $466.4 million class A-4 at 'AAAsf'; Outlook to Stable from
     Negative;
  -- $135.1 million class A1-A at 'AAAsf'; Outlook to Stable from
     Negative;
  -- $27.5 million class B at 'BBB-sf'; Outlook Negative;
  -- $13.8 million class C at 'BBsf'; Outlook Negative;
  -- $20.7 million class D at 'B-sf'; Outlook Negative;
  -- $11 million class E at 'CCCsf'; RR to 'RR2' from 'RR1';
  -- $15.15 million class F at 'CCCsf'; RR to 'RR2' from 'RR1';
  -- $9.6 million class G at 'CCsf'; RR to 'RR6' from 'RR2';
  -- $17.9 million class H at 'Csf'; RR to 'RR6' from 'RR3';
  -- $2.8 million class J at 'Csf'; RR to 'RR6' from 'RR4';
  -- $4.1 million class K at 'Csf/RR6';
  -- $5.5 million class L at 'Csf/RR6';
  -- $5.5 million class M at 'Csf/RR6';
  -- $2.8 million class N at 'Dsf/RR6';
  -- Class P at 'Dsf/RR6'.

Classes A-1 and A-2 have repaid in full. Classes P and NR have
been reduced to zero due to realized losses.  Fitch does not rate
class NR.  The rating on class X was previously withdrawn.


JP MORGAN: Fitch Affirms Junk Rating at Six Certificate Classes
---------------------------------------------------------------
Fitch Ratings has downgraded five classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp.'s commercial mortgage pass-
through certificates, series 2005-LDP5.

The downgrade reflects an increase in Fitch expected losses.
Fitch modeled losses of 6.25% of the remaining pool.  Fitch
designated 29 loans (12.2%) as Fitch Loans of Concern, which
include nine specially serviced loans (3.86%).

As of the August 2011 distribution date, the pool's aggregate
principal balance has been reduced by 11.41% (including 0.08% of
realized losses) to $3.7 billion from $4.2 billion at issuance.
Interest shortfalls are affecting classes M through NR. Nine loans
in the pool (4.2%) are currently defeased.

The largest contributor to Fitch-modeled losses (2.28%) is a
specially-serviced loan secured by 704,800 square foot (sf)
regional shopping center located in Hanover, MA.  The loan
transferred to special servicing in November 2009 for imminent
default.  The borrower and the special servicer were unable to
agree to terms on a modification and the special servicer
ultimately took title to the property in February 2010.  As of
July 1, 2011, the property is 94.9% occupied and the servicer is
in discussions with several existing tenants to expand.

The second largest contributor to Fitch-modeled losses (0.37%) is
a specially-serviced loan secured by three multifamily properties,
totaling 465 units, located in Birmingham, AL.  The loan
transferred to special servicing in December 2008 for imminent
default.  The properties are currently being marketed for sale.

Fitch downgrades the following classes as indicated:

  -- $21 million class E to 'BBBsf' from 'Asf'; Outlook Stable;
  -- $52.5 million class F to 'BBB-sf' from 'BBBsf'; Outlook
     Stable;
  -- $52.5 million class H to 'Bsf' from 'BBsf'; Outlook Negative;
  -- $42 million class J to 'B-sf' from 'BBsf'; Outlook Negative;
  -- $63 million class K to 'CCCsf/RR1' from 'B-sf'.

In addition, Fitch affirms the following classes and Outlooks and
revises the Recovery Ratings (RR) as indicated:

  -- $29.1 million class A-2FL at 'AAAsf'; Outlook Stable;
  -- $297.5 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $171.5 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $1.4 billion class A-4 at 'AAAsf'; Outlook Stable;
  -- $132.1 million class A-SB at 'AAAsf'; Outlook Stable;
  -- $436.5 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $419.7 million class A-M at 'AAAsf'; Outlook Stable;
  -- $299 million class A-J at 'AAsf'; Outlook Stable;
  -- $26.2 million class B at 'AAsf'; Outlook Stable;
  -- $73.5 million class C at 'Asf'; Outlook Stable;
  -- $42 million class D at 'Asf'; Outlook Stable;
  -- $36.7 million class G at 'BBsf'; Outlook Stable;
  -- $26.2 million class L at 'CCCsf', recovery rating to 'RR2'
     from 'RR1';
  -- $15.7 million class M at 'CCsf/RR3';
  -- $15.7 million class N at 'CCsf/RR3';
  -- $5.2 million class O at 'Csf/RR6';
  -- $5.2 million class P at 'Csf/RR6';
  -- $10.5 million class Q at 'Csf/RR6';

Class A-1 has repaid in full.  Fitch does not rate class NR or any
of the rake classes HG-1 through HG-5.  The ratings on classes X-1
and X-2 were previously withdrawn.


JP MORGAN: Fitch Affirms Low-B Ratings on Three Class Certificates
------------------------------------------------------------------
Fitch Ratings affirms 11 classes of JP Morgan Chase Commercial
Mortgage Securities Trust commercial mortgage pass through
certificates, series 2010-C1.

The affirmations are due to stable performance of the collateral
and sufficient credit enhancement to the Fitch rated classes.  As
of the July 2011 distribution date, the pool's certificate balance
has paid down 1.3% to $706.9 million from $716.3 million at
issuance.

There are currently 36 loans collateralized by 96 properties.
Currently there are no loans in special servicing and no loans
that are defeased.

The largest loan (14.1%) in the pool is The Gateway loan which is
collateralized by a 623,972 square foot (sf) retail property in
downtown Salt Lake City, UT. The property is anchored by Dick's
Sporting Goods, Barnes & Noble and Gateway Theaters.  Occupancy as
of March 2011 was 93% with debt service coverage ratio (DSCR) of
1.85 times (x) at year-end (YE) 2010.  Rollover risk remains a
concern as approximately 31% of the net rentable area (NRA) will
expire through 2012.  However, several of these tenants have lease
extension options.  Additionally, the transaction is structured
with an up-front reserve to address rollover.

The second largest loan (6.6%) in the pool is collateralized by a
portfolio of four multi-tenant retail properties totaling 469,000
sf.  The properties are located in Virginia, California, New
Jersey and Texas.  As of December 2010, the servicer reported
occupancy was 92% and the YE 2010 DSCR was 1.58x.

Fitch stressed the cash flow of the loans by applying a 5%
reduction to the most recent year end net operating income and
applying an adjusted market cap rate to determine value. None of
the loans took losses in Fitch's refinance test.

Fitch affirms these classes:

  -- $406.6 million class A-1 at 'AAAsf'; Outlook Stable;
  -- $131.3 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $61.5 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $16.1 million class B at 'AAsf'; Outlook Stable;
  -- $26.9 million class C at 'A-sf'; Outlook Stable;
  -- $14.3 million class D at 'BBBsf'; Outlook Stable;
  -- $9 million class E at 'BBB-sf'; Outlook Stable;
  -- $7.2 million class F at 'BBsf'; Outlook Stable;
  -- $6.3 million class G at 'B+sf'; Outlook Stable;
  -- $11.6 million class H at 'B-sf'; Outlook Stable;
  -- $599.4 million class X-A at 'AAAsf'; Outlook Stable.

Fitch does not rate classes NR and X-B.


JP MORGAN: Fitch Junks Rating on Two Class Certificates
-------------------------------------------------------
Fitch Ratings has downgraded four classes of JP Morgan Chase
Commercial Mortgage Securities Corporation's (JPMC) commercial
mortgage pass-through certificates, series 2002-CIBC5.

The downgrades are the result of Fitch modeled losses associated
with specially serviced loans and loans that are not expected to
refinance at maturity.  Fitch modeled losses of 2.3% of the
remaining pool.  Rating Outlooks reflect the likely direction of
any changes to the ratings over the next one to two years.  Fitch
has designated 13 loans (10.9%) as Fitch Loans of Concern, which
includes two specially-serviced loans (2.6%).

As of the July 2011 distribution date, the pool's certificate
balance has been reduced by 30.6% to $696.8 million from $1
billion.  Thirty loans (31.1%) have been defeased.  Interest
shortfalls are currently affecting the unrated class NR.

The largest contributor to Fitch-modeled losses is a specially-
serviced loan (1.7% of the pool balance) secured by a former A&P
grocery-anchored retail center, which is now vacant, located in
Woodbridge, NJ.  The loan was transferred to special servicing due
to monetary default.  The special servicer has contacted to
borrower and is attempting to cure the default while pursuing
foreclosure to protect the interest of the trust.

The second largest contributor to Fitch-modeled losses is a
specially-serviced asset (1.0%) secured by a retail strip center
located in Gilbert, AZ.  The loan was transferred to special
servicing in December 2009 and the special serviced took title to
the property via foreclosure in January 2011. The special servicer
is currently marketing the property for sale.

The third largest contributor to Fitch-modeled losses is a loan
(1.7%) secured by 190,186 square foot office building located in
Emeryville, CA.  The servicer reported year-end 2010 debt-service
coverage ratio dropped to 0.63 times (x) with an occupancy of
69.3%, as compared to the year-end 2009 debt-service coverage
ratio of 1.11x and occupancy of 82%.  The drop in performance is
primarily due to low occupancy levels and increases in expenses
throughout 2010.  The loan remains current.

Fitch has downgraded and assigned Outlooks and Recovery Ratings
(RR) as indicated:

  -- $5.0 million class K to 'BBsf' from 'BBsf+'; Outlook
     Negative;
  -- $5.0 million class L to 'Bsf' from 'BBsf'; Outlook Negative;
  -- $8.8 million class M to 'CCsf/RR1' from 'B-sf';
  -- $2.5 million class N to 'Csf/RR6' from 'B-sf'.

In addition, Fitch affirms these classes and revises Rating
Outlooks as indicated:

  -- $14.3 million class A-1 at 'AAAsf'; Outlook Stable;
  -- $487.2 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $36.4 million class B at 'AAAsf'; Outlook Stable;
  -- $13.8 million class C at 'AAAsf'; Outlook Stable;
  -- $27.6 million class D at 'AAAsf' ; Outlook Stable;
  -- $13.8 million class E at 'AAAsf'; Outlook Stable;
  -- $28.9 million class F at 'AA+sf' ; Outlook Stable;
  -- $16.3 million class G at 'AA-sf'; Outlook Stable;
  -- $18.8 million class H at 'BBB+sf' ; Outlook Stable;
  -- $12.6 million class J at 'BBB-sf'; Outlook to Negative from
     Stable.

The interest only Class X-2 is paid in full.  Class NR is not
rated by Fitch.

In addition, Fitch withdraws the rating of the interest-only class
X-1.


JP MORGAN: Moody's Affirms Ratings of 12 CMBS Classes
-----------------------------------------------------
Moody's Investors Service (Moody's) affirmed 12 class of J.P.
Morgan Chase Commercial Mortgage Securities Corp. Commercial
Mortgage Pass-Through Certificates, Series 2006-FL2.

Cl. A-1, Affirmed at Aaa; previously on Dec 7, 2006 Definitive
Rating Assigned Aaa

Cl. A-2, Affirmed at Aa2; previously on Sep 22, 2010 Downgraded to
Aa2

Cl. B, Affirmed at A1; previously on Sep 22, 2010 Downgraded to A1

Cl. C, Affirmed at A2; previously on Sep 22, 2010 Downgraded to A2

Cl. D, Affirmed at A3; previously on Sep 22, 2010 Downgraded to A3

Cl. E, Affirmed at Baa1; previously on Sep 22, 2010 Downgraded to
Baa1

Cl. F, Affirmed at Baa3; previously on Sep 22, 2010 Downgraded to
Baa3

Cl. G, Affirmed at Ba1; previously on Sep 22, 2010 Downgraded to
Ba1

Cl. H, Affirmed at Ba2; previously on Sep 22, 2010 Downgraded to
Ba2

Cl. J, Affirmed at B1; previously on Sep 22, 2010 Downgraded to B1

Cl. K, Affirmed at Ca; previously on Sep 22, 2010 Downgraded to Ca

Cl. L, Affirmed at C; previously on Sep 22, 2010 Downgraded to C

RATINGS RATIONALE

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

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 performance in the commercial real
estate property markets. While commercial real estate property
markets are gaining momentum, a consistent upward trend will not
be evident until the volume of transactions increases, distressed
properties are cleared from the pipeline and job creation
rebounds. The hotel and multifamily sectors are continuing to show
signs of recovery through the first half of 2011, while recovery
in the non-core office and retail sectors are tied to pace of
recovery of the broader economy. Core office markets are showing
signs of recovery through lending and leasing activity.

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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

The principal methodology used in this rating was "Moody's
Approach to Rating CMBS Large Loan/Single Borrower Transactions"
published on July 2000.

Moody's review incorporated the use of the excel-based Large Loan
Model v 8.1. 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 September 22, 2010.

As of the August 15, 2011 distribution date, the transaction's
certificate balance decreased by approximately 65% to $528.1
million from $1.5 billion at securitization due to the payoff of
nine loans and principal pay downs associated with five loans. The
Certificates are collateralized by seven floating-rate loans
ranging in size from 3% to 25% of the pooled trust mortgage
balance. The largest three loans account for 63% of the pooled
balance. The pool composition includes office properties (71% of
the pooled balance) and hotel properties (29%).

The deal has a modified pro-rata structure. Interest on the pooled
trust certificates are distributed first to Classes A-1, X-1 and
X-2, pro rata, and then to Classes A-2, B, C, D, E, F, G, H, J, K,
and L, sequentially. Prior to a monetary or material non-monetary
event of default, scheduled and unscheduled principal payments are
allocated to the Pooled Classes and junior participation interests
on a pro rata basis. Initially, 80% of the principal received is
paid to the Class A-1 and A-2 certificates sequentially and 20%
will be allocated pro rata to the other certificates. Principal
distributions are made sequentially from the most senior to the
most junior class after the outstanding principal balance of the
Pooled Trust Assets (exclusive of Trust Assets related to
Specially Service Mortgage Loans) is less than 20% of the initial
principal balance of the Trust Assets. All losses and shortfalls
are allocated first to the relevant junior interest, and then to
Classes L, K, J, H, G, F, E, D, C, B, and A-2 in that order, and
then to Class A-1.

The pool has experienced losses of $161,948 since securitization.
There are currently two loans in special servicing which are the
Menlo Oaks Corporate Center loan ($58 million; 11% of the pooled
balance) and the Hilton Los Cabos Beach and Golf Resort loan
($29.3 million; 7%). Both loans have been modified including
maturity extensions and principal paydowns and are pending return
to the master servicer.

Moody's weighed average pooled loan to value (LTV) ratio is 91.6%,
compared to 90.2% at last review on September 22, 2010 and 66.1%
at securitization. Moody's pooled stressed debt service coverage
(DSCR) is 1.20X, compared to 1.30X at last review and 1.38X at
securitization.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. Large
loan transactions have a Herf of less than 20. The pool has a Herf
of 6 compared to 7 at Moody's prior review.

The largest loan in the pool is the RREEF Silicon Valley Office
Portfolio Loan ($131.9 million -- 25.0%), a 27% portion of a pari
passu split loan structure, is the largest in the pool. The loan
is secured by a 5.2 million square foot portfolio of office/R&D
properties located in Santa Clara, Sunnyvale, Mountain View,
Milpitas and San Jose, California. Occupancy as of March 2011 was
72%, compared to 71% at securitization. At securitization, the
largest tenant was Maxtor, leasing approximately 15% of the NRA on
multiple leases that expire in 2011. Moody's current loan to value
ratio ("LTV") and stressed DSCR for the pooled loan are 93.1% and
1.11X. The collateral is also encumbered by a B Note that is held
outside the trust. Moody's credit estimate for the pooled balance
is Ba3, the same as last review.

The Marina Village loan ($104.0 million, 19.7%) is the second
largest loan in the pool and was modified on June 1, 2011 and
returned to the master servicer on August 18, 2011. The loan is
secured by a 1.2 million square foot suburban office property in
the Alameda submarket of Oakland, California. Occupancy and net
cash flow have fallen significantly since securitization. As of
May 2011, occupancy for the property was 74% compared to 80% at
securitization. At the time of securitization, the property had
recently lost two tenants but had historically performed better. A
return to prior cash flow levels had been anticipated at
securitization, however this has not materialized. The loan
modification included a $9 million principal payment and loan
maturity has been extended through 2013. Moody's current loan to
value ratio ("LTV") is over 100% and Moody's stressed DSCR for the
loan is 0.73X. Moody's credit estimate for the pooled balance is
C, the same as at last review.

The third largest loan is the Roosevelt Hotel loan ($96.6 million,
18.3% of the pooled balance). The loan is secured by a 1,015 room
hotel that sits on an entire city block in mid-town Manhattan,
just west of Grand Central Terminal. RevPAR for 2010 was$165.47 up
almost 7% from RevPAR for 2009 of $155.11. According to Smith
Travel Research, RevPAR for New York increased 12.9% for the same
period. The loan matures in November 2011. Moody's current loan to
value ratio ("LTV") is 68.0% and stressed DSCR is 1.67X. Moody's
credit estimate for the pooled balance is Baa1, the same as last
review.


JP MORGAN: Losses Across the Pool Cues Fitch to Lower Ratings
-------------------------------------------------------------
Fitch Ratings has downgraded three classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp. 2001-CIBC3.

Fitch downgrades these classes and assigns Recovery Ratings (RRs)
as indicated:

  -- $7.6 million class K to 'CCsf/RR3' from 'B-sf';
  -- $4.3 million class L to 'Csf/RR6' from 'B-sf';
  -- $4.3 million class M to 'Csf/RR6' from 'CCCsf/RR4'.

Classes K and L previously carried a Negative Rating Outlook.

Fitch also affirms these classes and revises the Ratings Outlooks:

  -- $184.9 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $36.9 million class B at 'AAAsf'; Outlook Stable;
  -- $36.9 million class C at 'AAAsf'; Outlook Stable;
  -- $9.8 million class D at 'AAAsf'; Outlook Stable;
  -- $27.1 million class E at 'AAAsf'; Outlook Stable;
  -- $10.8 million class F at 'AAsf'; Outlook to Stable from
     Negative;
  -- $17.3 million class G at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $6.5 million class H at 'BBsf'; Outlook to Stable from
     Negative;
  -- $6.5 million class J at 'Bsf'; Outlook Negative.

The downgrades reflect an increase in Fitch expected losses across
the pool.  Fitch modeled losses of 4.7% of the remaining pool.
Fitch has designated 14 loans (22.5%) as Fitch Loans of Concern,
which includes five specially serviced loans (7.8%). Fitch expects
classes L through NR may be fully depleted from losses associated
with the specially serviced assets.

As of the July 2011 distribution date, the pool's aggregate
principal balance has been paid down by approximately 59.2% to
$354.2 million from $867.5 billion at issuance.  Nineteen loans
(25.6%) are defeased. Interest shortfalls are affecting classes K
through NR.

The largest contributor to loss (2.6% of pool balance) is secured
by a 233,709 square foot (sf) retail center in Madison, WI. The
property is anchored by TJ Maxx (14% of net rentable area [NRA]).
The most recent servicer reported occupancy is 48% as of December
2010 and year end (YE) 2010 debt service coverage ratio (DSCR) was
reported at 0.32 times (x).The loan had transferred to special
servicing in March 2009 due to imminent monetary default and is
now greater than 90 days delinquent.  The special servicer has
approved a discounted payoff and executed a settlement agreement
with the borrower. Fitch expects losses upon resolution of the
loan.

The next largest contributor to losses (3%) is secured by a
107,822 sf office property in Newark, DE. At issuance, the
property was 100% occupied by a large single tenant who had
subsequently vacated a portion of the space (42% NRA) in 2009,
with the remaining space (58% NRA) vacated in December 2010.  The
most recent reported occupancy is 41.1% as of February 2011 and
the YE 2010 DSCR was reported at 0.98x.  The loan transferred to
special servicing in February 2011 due to monetary default.  The
special servicer is awaiting a loan modification proposal from the
borrower while simultaneously pursuing foreclosure.

The third largest contributor to losses (1.1%) is secured by three
one-story mixed-use buildings totaling 85,443 sf located in
Waterford, MI near the Oakland County International Airport.  The
property had suffered cash flow issues due to occupancy declines
and transferred to special servicing in April 2009.  The servicer
is currently pursuing foreclosure.  The most recent occupancy is
37.5% as of the June 2011 rent roll and the borrower continues to
make sporadic partial debt service payments.

Fitch does not rate class NR, which has been reduced to
$1.2 million from $16.3 million due to realized losses.  Classes
A-1, A-2 and X-2 have paid in full.

Fitch withdraws the rating on the interest-only classes X-1.


JP MORGAN: Stable Performance Prompts Fitch to Affirm Ratings
-------------------------------------------------------------
Fitch Ratings has affirmed 11 classes and placed five classes of
J.P. Morgan Chase Commercial Mortgage Securities Corp., series
2003-PM1 (JPMCC 2003-PM1) on Rating Watch Positive.

Fitch affirms these classes, places classes on Rating Watch
Positive, and revises Recovery Ratings (RRs):

  -- $299.5 million class A1A at 'AAAsf'; Outlook Stable;
  -- $82.6 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $282 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $33.2 million class B at 'AAAsf'; Outlook Stable;
  -- $13 million class C at 'AAsf'; Rating Watch Positive;
  -- $27.5 million class D at 'BBB-sf'; Rating Watch Positive;
  -- $13 million class E at 'BBsf'; Rating Watch Positive;
  -- $15.9 million class F at 'CCCsf/RR1'; Rating Watch Positive;
  -- $13 million class G at 'CCCsf/RR1'; Rating Watch Positive;
  -- $18.8 million class H at 'Csf/RR2';
  -- $15.9 million class J at 'Csf'; RR to RR4' from 'RR6';
  -- $7.2 million class K at 'Csf/RR6';
  -- $8.7 million class L at 'Csf/RR6';
  -- $7.2 million class M at 'Csf/RR6';
  -- $4.3 million class N at 'Csf/RR6';
  -- $2.9 million class P at 'Csf/RR6'.

The affirmations are due to stable performance of the transaction
since Fitch's most recent formal review.  Classes C through G have
been placed on Rating Watch Positive due to a decrease in losses
from special servicing since Fitch's last formal review.  Fitch
expects to resolve the Watch status upon the resolution of loans
in special servicing which is expected to occur within six months.

As of the July 2011 distribution date, the pool's aggregate
principal balance has reduced by 29.5% to $815.8 million from
$1.16 billion at issuance. In addition, 16 loans (22.5%) have been
fully defeased.

Fitch modeled losses of 7.22% of the remaining pool.  Fitch has
designated 27 loans (22.7%) as Fitch Loans of Concern, which
includes nine specially-serviced loans (10.10%).  Fitch expects
classes K through NR to be fully depleted and class J to be
affected significantly from losses associated with the specially
serviced assets.  Interest shortfalls totaling $6,098,680 are
currently affecting classes G through NR.

The largest contributor to Fitch modeled losses is a specially
serviced loan (6.53%) secured by a 702,427 square foot (sf) mall
located in West Palm Beach FL.  The loan transferred to special
servicing in March 2009 due to imminent default and the property
was foreclosed on in March 2010.  The mall closed in January 2010
and only three tenants with outdoor entrances remain.  Fitch
expects losses upon liquidation of the property based on
valuations obtained by the special servicer.

The second largest contributor to Fitch modeled losses is a
specially loan (1.52%) secured by 127,676 sf of office space
located in Hauppauge, NY.  The loan transferred to special
servicing in September 2009 due to imminent default The servicer-
reported occupancy as of March 2011 is 53% with some tenants on a
month-to-month lease.

The third largest contributor to modeled losses is a loan (2.14%)
secured by a 369 unit apartment complex located in North Las
Vegas.  The loan remains current as of the July remittance report;
however, the property does not generate sufficient cash flow to
meet debt service.  The most recent servicer reported occupancy is
81% as of December 2010 and the debt service coverage ratio has
declined to .80 times for year-end 2010.

Class NR, which is not rated by Fitch has been reduced to
$1.52 million from $20.2 million at issuance due to realized
losses.


KATONAH IX: Moody's Upgrades Ratings of Notes Due 2019
------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Katonah IX CLO Ltd.:

US$221,000,000 Class A-1L Floating Rate Notes Due 2019 (current
outstanding balance of $215,883,475), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa3 (sf) Placed Under Review for
Possible Upgrade;

US$100,000,000 Class A-1LV Revolving Floating Rate Notes Due 2019
(current outstanding balance of $97,684,830), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review for
Possible Upgrade;

US$23,000,000 Class A-2L Floating Rate Notes Due 2019, Upgraded to
A1 (sf); previously on June 22, 2011 Baa2 (sf) Placed Under Review
for Possible Upgrade;

US$26,000,000 Class A-3L Floating Rate Notes Due 2019, Upgraded to
Baa3 (sf); previously on June 22, 2011 Ba3 (sf) Placed Under
Review for Possible Upgrade;

US$15,000,000 Class B-1L Floating Rate Notes Due 2019, Upgraded to
Ba2 (sf); previously on June 22, 2011 Caa2 (sf) Placed Under
Review for Possible Upgrade;

US$15,000,000 Class B-2L Floating Rate Notes Due 2019, Upgraded to
Caa1 (sf); previously on June 22, 2011 Caa3 (sf) Placed Under
Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in CLO tranches that mature after the
maturity date of the notes. Based on the July 2011 trustee report,
reference securities that mature after the maturity date of the
notes currently make up approximately 4.2% of the underlying
reference portfolio. These investments potentially expose the CLO
notes to market risk in the event of liquidation at the time of
the notes' maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $405.3 million,
defaulted par of $8.6 million, a weighted average default
probability of 19.86% (implying a WARF of 2602), a weighted
average recovery rate upon default of 50.80%, and a diversity
score of 65. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Katonah IX CLO Ltd., issued in November 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) Long-dated assets: The presence of assets that mature beyond
   the CLO's legal maturity date exposes the deal to liquidation
   risk on those assets. Moody's assumes an asset's terminal value
   upon liquidation at maturity to be equal to the lower of an
   assumed liquidation value (depending on the extent to which the
   asset's maturity lags that of the liabilities) and the asset's
   current market value.

3) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

4) 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 the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score.


KINGSLAND III: Moody's Upgrades Ratings of 7 Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Kingsland III, Ltd.:

US$75,575,000 Class A-2 Senior Secured Floating Rate Notes due
2021, Upgraded to Aa1 (sf); previously on June 22, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade;

US$12,750,000 Class A-3 Senior Secured Floating Rate Notes due
2021, Upgraded to Aa3 (sf); previously on June 22, 2011 A2 (sf)
Placed Under Review for Possible Upgrade;

US$29,750,000 Class B Senior Secured Deferrable Floating Rate
Notes due 2021, Upgraded to A3 (sf); previously on June 22, 2011
Baa3 (sf) Placed Under Review for Possible Upgrade;

US$11,550,000 Class C-1 Senior Secured Deferrable Floating Rate
Notes due 2021, Upgraded to Ba1 (sf); previously on June 22, 2011
B1 (sf) Placed Under Review for Possible Upgrade;

US$11,800,000 Class C-2 Senior Secured Deferrable Fixed Rate Notes
due 2021, Upgraded to Ba1 (sf); previously on June 22, 2011 B1
(sf) Placed Under Review for Possible Upgrade;

US$5,450,000 Class D-1 Secured Deferrable Floating Rate Notes due
2021, Upgraded to Ba3 (sf); previously on June 22, 2011 Caa3 (sf)
Placed Under Review for Possible Upgrade;

US$2,000,000 Class D-2 Secured Deferrable Fixed Rate Notes due
2021, Upgraded to Ba3 (sf); previously on June 22, 2011 Caa3 (sf)
Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios since the rating action
in September 2009. In the latest trustee report dated July 15,
2011, the Class A, Class B, Class C and Class D
overcollateralization ratios are reported at 126.7%, 116.17%,
109.06% and 106.97%, respectively, versus August 2009 levels of
121.79%, 111.67%, 104.83% and 102.82%, respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $415.7 million,
defaulted par of $2.9 million, a weighted average default
probability of 20.65% (implying a WARF of 2670), a weighted
average recovery rate upon default of 46.91%, and a diversity
score of 56. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Kingsland III, Ltd., issued in August 2006, 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
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted 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 and diversity levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.


LATITUDE CLO: Moody's Upgrades Ratings of Four Classes Of Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Latitude CLO II, Ltd.

US$45,500,000 Class A-2 Senior Secured Floating Rate Notes Due
2018, Upgraded to Aaa (sf); previously on June 22, 2011 A1 (sf)
Placed Under Review for Possible Upgrade;

US$27,000,000 Class B Second Priority Deferrable Floating Rate
Notes Due 2018, Upgraded to Baa2 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$13,300,000 Class C Third Priority Deferrable Floating Rate
Notes Due 2018, Upgraded to Ba2 (sf); previously on June 22, 2011
Caa1 (sf) Placed Under Review for Possible Upgrade;

US$9,500,000 Class D Fourth Priority Deferrable Floating Rate
Notes Due 2018 (current outstanding balance of $8,955,390.48),
Upgraded to B3 (sf); previously on June 22, 2011 Caa3 (sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in the publication "Moody's Approach to Rating
Collateralized Loan Obligations" published in June 2011. The
primary changes to the modeling assumptions include (1) a removal
of the temporary 30% default probability macro stress implemented
in February 2009 as well as (2) increased BET liability stress
factors and increased recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio since the rating action in February 2011.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2596 compared to 2712 in January 2011.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $235.8 million, a
defaulted par of $20.3 million, a weighted average default
probability of 19.7% (implying a WARF of 2785), a weighted average
recovery rate upon default of 48.3%, and a diversity score of 65.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Latitude CLO II, Ltd., issued in August 2006, 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
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1. Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2. Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

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


LATITUDE CLO: Moody's Upgrades Ratings of Siz Classes of Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Latitude CLO III, Ltd.

US$202,500,000 Class A Senior Floating Rate Notes Due 2021
(current outstanding balance of $192,813,044.02), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$22,500,000 Class B Second Senior Floating Rate Notes Due 2021,
Upgraded to Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed
Under Review for Possible Upgrade;

US$16,000,000 Class C Mezzanine Floating Rate Notes Due 2021,
Upgraded to Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$15,000,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2021, Upgraded to A3 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$14,000,000 Class E Deferrable Mezzanine Floating Rate Notes Due
2021, Upgraded to Ba1 (sf); previously on June 22, 2011 Ba3 (sf)
Placed Under Review for Possible Upgrade;

US$8,000,000 Class F Deferrable Mezzanine Floating Rate Notes Due
2021, Upgraded to Ba3 (sf); previously on June 22, 2011 Caa2 (sf)
Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in the publication "Moody's Approach to Rating
Collateralized Loan Obligations" published in June 2011. The
primary changes to the modeling assumptions include (1) a removal
of the temporary 30% default probability macro stress implemented
in February 2009 as well as (2) increased BET liability stress
factors and increased recovery rate assumptions.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios since the rating action
in February 2011. Based on the latest trustee report dated July 1,
2011, the Class A/B, Class C, Class D, Class E and Class F
overcollateralization ratios are reported at 135.2%, 125.8%,
118.2%, 111.8% and 108.5%, respectively, versus January 2011
levels of 134.0%, 124.7%, 117.1%, 110.8%, and 107.5%,
respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $293.4 million, a
defaulted par of $7.9 million, a weighted average default
probability of 22.8% (implying a WARF of 2911), a weighted average
recovery rate upon default of 47.5%, and a diversity score of 70.
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.

Latitude CLO III, Ltd., issued in April 2007, 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
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1. Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2. Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3. Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted 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.


LB-UBS COMMERCIAL: Expected Losses Cue Fitch to Downgrade Ratings
-----------------------------------------------------------------
Fitch Ratings has downgraded three classes and upgraded two
classes of LB-UBS Commercial Mortgage, series 2002-C4, commercial
mortgage pass-through certificates.

Fitch has downgraded these classes:

  -- $7.2 million class N to 'B-sf' from 'B+sf; Outlook Negative;
  -- $3.6 million class Q to 'Csf/RR4' from 'CCCsf/RR1';
  -- $1.8 million class S to 'Csf/RR6' from 'CCsf/RR3'.

Fitch has upgraded these classes:

  -- $12.7 million class J to 'AAsf' from 'AA-sf'; Outlook Stable;
  -- $12.7 million class K to 'Asf' from 'A-sf'; Outlook Stable.

Fitch has affirmed these classes:

  -- $12.7 million class A-3 at 'AAAsf; Outlook Stable;
  -- $21.3 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $850.5 million class A-5 at 'AAAsf; Outlook Stable;
  -- $18.2 million class B at 'AAAsf'; Outlook Stable;
  -- $20 million class C at 'AAAsf; Outlook Stable;
  -- $20 million class D at 'AAAsf; Outlook Stable;
  -- $12.7 million class E at 'AAAsf'; Outlook Stable;
  -- $16.3 million class F at 'AAAsf; Outlook Stable;
  -- $10.9 million class G at 'AAAsf'; Outlook Stable;
  -- $12.7 million class H at 'AAAsf; Outlook Stable;
  -- $20 million class L at 'BBB-sf'; Outlook to Negative from
     Stable.
  -- $7.2 million class M at 'BBsf; Outlook Negative;
  -- $3.6 million class T at 'Csf/RR6'.

The downgrades are the result of Fitch expected losses associated
with specially serviced loans that Fitch expects to be liquidated.
The upgrades of the senior classes are the result of sufficient
credit enhancement to offset Fitch expected losses. Fitch modeled
losses of 2.3% of the remaining pool.

Fitch has designated 18 loans (7.5%) as Fitch Loans of Concern,
which includes seven specially serviced loans (4.0%).  Fitch
expects losses associated with the specially serviced assets to
deplete classes S through U and impair class Q.

As of the July 2011 distribution date, the pool's aggregate
principal balance has been paid down by approximately 25.9% to
$1.08 billion from $1.46 billion at issuance.  Interest shortfalls
are affecting classes N through U with cumulative unpaid interest
totaling $1.8 million.  Of the 82 remaining loans in the pool, 23
are defeased (40.8%) including ten of the top 15 loans (33.1%).

The largest contributor Fitch modeled losses is a 171,103 square
foot (sf) class B office building located in Norwalk, CT.  The
property became a real estate owned asset (REO) in December 2010
and recent property valuations obtained by the special servicer
indicated losses upon liquidation.

The second largest contributor to Fitch modeled losses is a
298,179 sf industrial property located in Kansas City, KS.  Loan
transferred to Special Servicing in March 2011 due to monetary
default.  The property's largest tenant occupying 34% vacated when
its lease expired in June 2010. Special servicer is proceeding
with foreclosure.

The third largest contributor Fitch modeled losses is a 75,195 sf
strip mall in Madeira, OH.  Loan transferred to the Special
Servicer in October 2010 due to imminent default.  The property's
largest tenant vacated in first quarter 2009 resulting in below
1.0 times (x) debt servicer coverage ratio (DSCR).  The property
is currently 38% vacant and the special servicer is pursuing
foreclosure.

Fitch does not rate the $7.3 million class P and the $1.3 million
class U. Classes A-1 and A-2 have paid in full.

Fitch has withdrawn the rating of the interest only classes X-CL,
X-CP and X-VF. (For additional information, see 'Fitch Revises
Practice for Rating IO & Pre-Payment Related Structured Finance
Securities', dated June 23, 2010.)


LBUBS COMMERCIAL: Expected Losses Prompt Fitch to Lower Ratings
---------------------------------------------------------------
Fitch Ratings has downgraded nine classes of LBUBS commercial
mortgage pass-through certificates, series 2004-C6.

The downgrades reflect an increase in Fitch expected losses
attributed largely to specially serviced loans.  Fitch modeled
losses of 8.5% of the remaining pool. Fitch has designated 21
loans (19.4%) as Fitch Loans of Concern, which includes 10
specially serviced loans (11.1%).

As of the July 2011 distribution date, the transaction has paid
down approximately 40.2% to $805.6 million from $1.35 billion at
issuance.  There are 77 of the original 97 loans remaining in the
transaction, of which five are defeased (12.1%).

The largest contributor to Fitch expected losses (4.4%) is a
specially serviced loan secured by a 471,442 sf office property
located in Atlanta, GA.  Property performance declined when the
largest tenant, representing 38% of net rentable area, vacated in
February 2011.  The property is 48.8% occupied as of the July 2011
rent roll.

The next largest contributor to losses (1.8%) is a Fitch Loan of
Concern secured by a 137,000 sf office property in Boca Raton FL.
The most recent reported occupancy is 60% as of Aug. 31, 2010.
The loan, which had been specially serviced, transferred back to
the master servicer in July 2011 following an assumption.

The third largest contributor to losses (2.7%) is a specially
serviced loan secured by a 176,240 sf office property located in
Bakersfield, CA.  The property was 63.1% occupied as of October
2010, and an additional 3.4% of NRA is expected to vacate at
the end of the month.  The borrower is negotiating with two
prospective tenants while working with the special servicer to
cure the default.

Fitch has downgraded these classes and assigned or revised
Recovery Ratings (RRs) as indicated:

  -- $13.5 million class E to 'Asf' from 'A+sf'; Outlook Stable;
  -- $15.1 million class F to 'BBB-sf' from 'Asf'; Outlook
     Negative;
  -- $11.8 million class G to 'Bsf' from 'BBB+sf'; Outlook
     Negative;
  -- $11.8 million class H to 'CCCsf/RR1' from 'BBB-sf';
  -- $8.4 million class J to 'CCCsf/RR1' from 'BBsf';
  -- $16.8 million class K to 'CCsf/RR4' from 'Bsf';
  -- $1.7 million class L to 'CCsf/RR6' from 'Bsf';
  -- $6.7 million class M to 'CCsf/RR6' from 'B-sf';
  -- $5 million class N to 'CCsf/RR6' from 'CCCsf/RR1'.

In addition, Fitch has affirmed these classes:

  -- $38.9 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $54 million class A-5 at 'AAAsf'; Outlook Stable;
  -- $470.1 million class A-6 at 'AAAsf'; Outlook Stable;
  -- $83.6 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $13.5 million class B at 'AA+sf'; Outlook Stable;
  -- $23.6 million class C at 'AAsf'; Outlook Stable;
  -- $15.1 million class D at 'AA-sf'; Outlook Stable.

Classes A-1, A-2 and A-3 have paid in full.  Fitch does not rate
the $3.4 million class P, $1.7 million class Q, $1.7 million class
S or the $9.2 million class T.

Fitch withdraws the rating on the interest-only classes X-CL and
X-CP.


LCM V: Moody's Upgrades Ratings of Four Classes of CLO Notes
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by LCM V Ltd.:

US$63,000,000 Class B Second Priority Floating Rate Notes Due
2019, Upgraded to Aa1 (sf); previously on June 22, 2011Aa2 (sf)
Placed Under Review for Possible Upgrade;

US$41,250,000 Class C Third Priority Deferrable Floating Rate
Notes Due 2019, Upgraded to A3 (sf); previously on June 22,
2011Baa3 (sf) Placed Under Review for Possible Upgrade;

US$18,750,000 Class D Fourth Priority Deferrable Floating Rate
Notes Due 2019, Upgraded to Baa3 (sf); previously on June 22,
2011Ba3 (sf) Placed Under Review for Possible Upgrade;

US$16,500,000 Class E Fifth Priority Deferrable Floating Rate
Notes Due 2019, Upgraded to Ba2 (sf); previously on June 22,
2011B3 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Moody's also notes that Moody's adjusted WARF has declined since
the rating action in September 2009 due to a decrease in the
percentage of securities with ratings on "Review for Possible
Downgrade" or with a "Negative Outlook."

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $583.7 million, a
weighted average default probability of 19.33% (implying a WARF of
2463), a weighted average recovery rate upon default of 51.16%,
and a diversity score of 69. The 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.

LCM V Ltd., issued in March 2007, 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
June 2011.

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 June 2011.

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 2013 and
2015 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 the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread 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.


LEHMAN BROTHERS: Stable Loss Expectations Cue Fitch to Hold Rating
------------------------------------------------------------------
Fitch Ratings has affirmed Lehman Brothers Floating Rate
Commercial Mortgage Trust 2007-LLF C5.  The affirmations reflect
overall stable loss expectations and loan performance since the
last review.  Fitch's performance expectation incorporates
prospective views regarding the outlook of the commercial real
estate market.

All of the remaining loans are reaching their final maturity
within the next 12 months.  At issuance the majority of the loans
had an average loan term of five years (including extensions).  As
lending standards have changed considerably from the time these
loans were originated, there is uncertainty as to whether or not
the loans will have issues securing financing at final maturity.

Under Fitch's methodology, approximately 60.4% of the pooled
balance is modeled to default in the base case stress scenario,
defined as the 'B' stress. In this scenario, the modeled average
cash flow decline is 8.8% and pooled expected losses are 4.5%.  To
determine a sustainable Fitch cash flow and stressed value, Fitch
analyzed servicer-reported operating statements and STR reports,
updated property valuations, and recent sales comparisons.  Fitch
estimates that average recoveries will be strong at approximately
92.6% in the base case.

The transaction is collateralized by 31 loans, 15 loans are
secured by office properties (48%), 12 by hotels (27.4%), two by
industrial properties (14.3%) and two by mixed use properties
(10.3%).  Nine loans (25.1%) mature in 2011, and 22 loans (72.7%)
mature in 2012.

Fitch's analysis resulted in loss expectations for 11 loans in the
pool.  The three largest pooled contributors to losses (by unpaid
principal balance) in the 'B' stress scenario are: the CalWest
Industrial Portfolio (14.4%), PHOV Hotel Portfolio (4.3%) and
Continental Grand Plaza I (1.3%).

The CalWest Industrial Portfolio is secured by 95 warehouse,
business park, and flex/office properties located in 12 distinct
markets across six states.  The portfolio was built between 1951
and 2007 and is comprised of 53 warehouse/industrial properties,
34 business parks, eight flex/office properties and one vacant
tract of land for a total of 23.4 million rentable sf.  In
addition to the $275 million included in the trust, there is
$825 million of pari passu debt and $1.348 billion of mezzanine
debt held outside the trust.

At issuance, the sponsor believed there was opportunity to sell
portions of the portfolio at a premium to their basis, which was
supported by several competing bids received by the seller for
individual markets in its purchase.  The sponsor also believed the
portfolio had upside potential through leasing up vacant space and
rolling below market leases to market.  However, since issuance,
occupancy has dropped as tenant leases have expired, no properties
have been sold, and in place rents have declined. Occupancy at
issuance was 92% with in place rents of approximately $7.29 psf.
As of December 2010, the portfolio was 82% occupied with average
in place rents of approximately $7.10 psf.  The loan has a final
maturity in June 2012.

The PHOV Hotel Portfolio consists of three hotel properties with a
total of approximately 1,132 rooms. The properties are located in
Burbank, CA, Pleasanton, CA and Denver, CO and are affiliated with
Marriott and Renaissance.  Since issuance, the borrower completed
a $52.9 million ($46,731 per key) capital improvement program
including guest room, corridor, and public area upgrades.  Two of
the properties were reflagged to Marriott from the Hilton and
Crowne Plaza flags.  The loan transferred to the special servicer
in April 2011 for imminent maturity default. The loan matures in
September 2011 and has no remaining extensions.  Performance
improved in 2010 but has not reached underwritten levels.  RevPAR
at issuance, 2008, 2009 and 2010 was $75, $80, $74 and $83,
respectively. The loan was underwritten by the issuer assuming a
stabilized RevPAR of $107.

The Continental Grand Plaza I loan is secured by a 239,296 sf
suburban office building located in El Segundo, CA.  The property
was 98% occupied at issuance with average rental rates of $25.61
psf.  Occupancy has decreased to 78% as a number of tenants have
vacated at lease expiration and average in-place rental rates have
also declined to $24.50 psf as of June 2011.  Per PPR the El
Segundo market lags behind the rest of the country in terms of job
growth, keeping office demand low and limiting landlords' pricing
power.  The loan will reach its final maturity in December 2011.

Fitch has affirmed these classes and revised Rating Outlooks as
indicated:

  -- $1,055,348,020 class A-1 at 'AAAsf'; Outlook Stable;
  -- $472,863,000 class A-2 at 'AAsf'; Outlook to Stable from
     Negative;
  -- $80,308,000 class A-3 at 'Asf'; Outlook to Stable from
     Negative;
  -- $52,674,000 class B at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $48,678,000 class C at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $31,839,000 class D at 'BBsf'; Outlook Negative;
  -- $28,756,000 class E at 'BBsf'; Outlook Negative;
  -- $28,756,000 class F at 'BBsf'; Outlook Negative;
  -- $28,756,000 class G at CCC/RR4';
  -- $51,761,000 class H at 'CCC/RR6';
  -- $57,513,000 class J at 'CC/RR6'.

Class X-1, has paid in full. Fitch does not rate classes CGC, CPE,
CQR-1, CQR-2, DMC-1, DMC-2, FBS-1, FBS-2, FTC-1, FTC-2, HAR-1,
HAR-2, HRH, HSS, INO, JHC, LCC, MVR, NOP-1, NOP-2, NOP-3, OCS,
ONA, OWS-1, OWS-2, PHO, SBG, SFO-1, SFO-2, SFO-3, SFO-4, SFO-5,
TSS-1, and TSS-2, UCP, VIS, and WHH.

Fitch withdrew the rating of the interest-only class X-2. (For
additional information, 'Fitch Revises Practice for Rating IO &
Pre-Payment Related Structured Finance Securities' dated June 23,
2010.)


LNR CDO: Fitch Withdraws 'Dsf' Rating on 10 Note Classes
--------------------------------------------------------
Fitch Ratings has downgraded 10 classes to 'Dsf' and withdrawn the
ratings on the notes issued by LNR CDO 2007-2, Ltd./LLC (VI).

On Dec. 2, 2010, the trustee notified noteholders of an event of
default (EOD) due to the failure to pay the full and timely
interest on the class B notes.  On June 28, 2011, the controlling
party declared all notes due and payable.  On August 3, 2011 all
liquidation proceeds were distributed according to the transaction
documents.

The class A-1 notes received 100% of their outstanding balance and
the class B notes received 99% of their outstanding balance. The
remaining classes have been completely written off due to
insufficient liquidation proceeds.

Fitch has taken these actions:

  -- $0 class A-1 marked 'PIF';
  -- $0 class B downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class C downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class D downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class E downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class F downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class G downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class H downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class J downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class K Preferred Shares downgraded to 'Dsf' from 'Csf'
        and withdrawn;
  -- $0 class L Preferred Shares downgraded to 'Dsf' from 'Csf'
        and withdrawn.


MARATHON REAL: Fitch Affirms Junk Rating on Four Note Classes
-------------------------------------------------------------
Fitch Ratings has affirmed all classes of Marathon Real Estate CDO
2006-1, Ltd./LLC (Marathon 2006-1) reflecting Fitch's base case
loss expectation of 26.8%, which is slightly improved from 30.9%
at last review.  Fitch's performance expectation incorporates
prospective views regarding commercial real estate market value
and cash flow declines.

Fitch affirms these classes and revises the Rating Outlooks as
indicated:

  -- $518,080,048 class A-1 at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $50,000,000 class A-2 at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $99,000,000 class B at 'BBsf'; Outlook Negative;
  -- $51,500,000 class C at 'Bsf'; Outlook Negative;
  -- $16,000,000 class D at 'Bsf'; Outlook Negative;
  -- $14,000,000 class E at 'Bsf'; Outlook Negative;
  -- $23,500,000 class F at 'CCCsf/RR5';
  -- $15,500,000 class G at 'CCCsf/RR6';
  -- $26,000,000 class H at 'CCCsf/RR6';
  -- $56,300,000 class J at 'CCCsf/RR6';
  -- $26,700,000 class K at 'CCCsf/RR6'.

The CDO exited its reinvestment period in May 2011.  Prior to
that date, the asset manager made significant changes to the
pool composition, with approximately 45 assets removed from the
pool, and a large addition of rated securities, which increased
the securities component of the pool to 39.9% from 24.8%.  Of
the collateral removed from the pool, losses to par exceeded
$100 million.

The transaction is collateralized by both senior and subordinate
commercial real estate (CRE) debt: 42% are either whole loans or
A-notes, 17.8% are either B-notes or mezzanine loans, and as
mentioned, approximately 40% are rated securities.  Since last
review, the average Fitch derived rating for the underlying CMBS
collateral improved slightly to 'BB+/BB' from 'BB-'.  Furthermore,
four loans (5.2%) are currently defaulted while two loans (9.5%)
are considered Fitch Loans of Concern. Fitch expects significant
losses on the delinquent assets and Loans of Concern.

Under Fitch's updated methodology, approximately 45% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress. In this scenario, the modeled average
cash flow decline is 7.8% from the most recent available cash
flows (generally year-end 2010).  Fitch estimates that recoveries
will average 40.5% in the base case.

The largest component of Fitch's base case loss expectation is a
whole loan (6.1%) secured by a 363-key limited service hotel
located on Manhattan's Upper West Side.  The sponsor has been
converting the property's single-occupancy rooms into traditional
rooms on an ongoing basis, and further planned an extensive
property improvement plan in order to convert the hotel into a
full-service hotel to be operated under a major flag.  The
renovations fell behind schedule during the recession, and the
property continues to struggle, with cash flow declining an
additional 30% from 2009 to 2010.

The next largest component of Fitch's base case loss expectation
is a B-note secured by a 190-key hotel in Boston, MA, located
between Boston's Financial District and the Beacon Hill/Back Bay
areas.  The property experienced a significant decline in cash
flow through the recession. Performance has since improved, but
remains below expectations from issuance.  The loan was recently
modified, which included an extension to May 2014, and a borrower
contribution of equity, which delevered the A-note slightly.  The
special servicer will continue to monitor the progress of the
asset.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to classes A-1 through E were then compared
to the modeled expected losses, and determined to be consistent
with the rating assigned below.  Based on prior modeling results,
no material impact was anticipated from cash flow modeling the
transaction. T he Rating Outlooks for classes A-1 and A-2 are
revised to Stable from Negative reflecting the slight improvement
in modeled expected losses and the senior position of the classes
within the capital structure, which will continue to pay down as
assets payoff going forward.

The 'CCC' and below ratings for classes F through K are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.


MASTR REPERFORMING: Moody's Lowers Rating of $415-Mil. RMBS
-----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 33
tranches from three deals issued by MASTR Reperforming Loan Trust.
The collateral backing these transactions consists primarily of
first-lien, fixed, and adjustable rate, mortgage loans insured by
the Federal Housing Administration (FHA) an agency of the U.S.
Department of Urban Development (HUD) or guaranteed by the
Veterans Administration (VA).

Complete rating actions are:

Issuer: MASTR Reperforming Loan Trust 2005-1

Cl. 1A1, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. 1A2, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. 1A3, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. 1A4, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. 1A5, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. 2A1, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

PO, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa2 (sf)
Placed Under Review for Possible Downgrade

AX, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa2 (sf)
Placed Under Review for Possible Downgrade

Cl. B1, Downgraded to Caa2 (sf); previously on Jul 27, 2011 B1
(sf) Placed Under Review for Possible Downgrade

Cl. B2, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Cl. B3, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Issuer: MASTR Reperforming Loan Trust 2005-2

Cl. 1A1F, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A1S, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A2, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A3, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A4, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 2A1, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. AX, Downgraded to B2 (sf); previously on Jul 27, 2011 Ba3 (sf)
Placed Under Review for Possible Downgrade

Cl. B1, Downgraded to Ca (sf); previously on Jul 27, 2011 B2 (sf)
Placed Under Review for Possible Downgrade

Cl. B2, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Cl. B3, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Cl. B4, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Issuer: MASTR Reperforming Loan Trust 2006-1

Cl. 1A1F, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A1S, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A2, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A3, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 1A4, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 2A1, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. AX, Downgraded to B3 (sf); previously on Jul 27, 2011 Ba3 (sf)
Placed Under Review for Possible Downgrade

Cl. B1, Downgraded to C (sf); previously on Jul 27, 2011 B2 (sf)
Placed Under Review for Possible Downgrade

Cl. B2, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Cl. B3, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

Cl. B4, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

RATINGS RATIONALE

The actions are a result of Moody's updated loss projection for
the RMBS FHA-VA portfolio. The updated projection accounts for
higher potential pool losses due to self-curtailment of claims by
servicers whereby they pass expenses as deemed reasonable to the
trusts instead of submitting them to HUD, and continued weaknesses
in the macro economy and the housing market.

A FHA guarantee covers 100% of a loan's outstanding principal and
a large portion of its outstanding interest and foreclosure-
related expenses in the event that the loan defaults. A VA
guarantee covers only a portion of the principal based on the
lesser of either the sum of the current loan amount, accrued and
unpaid interest, and foreclosure expenses, or the original loan
amount. HUD usually pays claims on defaulted FHA loans when
servicers submit the claims, but can impose significant penalties
on servicers if it finds irregularities in the claim process later
during the servicer audits. This can prompt servicers to push more
expenses to the trust that they deem reasonably incurred than
submit them to HUD and face significant penalty. The rating
actions consider the portion of a defaulted loan normally not
covered by the FHA or VA guarantee and other servicer expenses
they deemed reasonably incurred and passed on to the trust.

FHA/VA borrowers, in Moody's-rated transactions, are typically low
income borrowers with poor credit history who have been affected
by the weak economy and housing market. Moody's expects
delinquencies to remain high for this sector at 40%, 35%, and 30%
for the 2004, 2005, and 2006 vintages, respectively as house
prices continue to decline and unemployment rates remain high.
FHA/VA RMBS transactions have had very low losses to date (less
than 1%) despite high delinquency levels due to the FHA and VA
guarantees. However, Moody's expects this trend to change due to
the higher level of self-curtailments by the servicers.

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, 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. Moody's now
projects house price index to reach a bottom in the first quarter
of 2012, with a 2% remaining decline between the first quarter of
2011 and 2012, and unemployment rate to start declining by fourth
quarter of 2011.

The principal methodology used in these ratings is described in
the Monitoring and Performance Review section in "Moody's Approach
to Rating US Residential Mortgage-Backed Securities" published in
December 2008. Other methodology used in this rating was "FHA VA
US RMBS Surveillance Methodology" published in July 2011.


MAXIM HIGH: Fitch Withdraws 'Dsf' Rating on 10 Note Classes
-----------------------------------------------------------
Fitch Ratings has affirmed seven, downgraded three, and
subsequently withdrawn the ratings on all classes of notes issued
by Maxim High Grade CDO I, Ltd. (Maxim HG I):

  -- $858,225,336 class A-1 notes affirmed at 'Dsf' and withdrawn;
  -- $249,928,543 class A-2 notes affirmed at 'Dsf' and withdrawn;
  -- $249,928,543 class A-3 notes affirmed at 'Dsf' and withdrawn;
  -- $99,971,417 class A-4 notes affirmed at 'Dsf' and withdrawn;
  -- $99,971,417 class A-5notes affirmed at 'Dsf' and withdrawn;
  -- $33,990,282 class B notes affirmed at 'Dsf' and withdrawn;
  -- $20,380,676 class C notes affirmed at 'Dsf' and withdrawn;
  -- $15,739,001 class D notes downgraded to 'Dsf' from 'Csf' and
     withdrawn;
  -- $23,763,040 class E-1 notes downgraded to 'Dsf' from 'Csf'
     and withdrawn;
  -- $1,938,096 class E-2 notes downgraded to 'Dsf' from 'Csf' and
     withdrawn.

Maxim HG I entered an event of default in April 2008 and its
maturity was accelerated in December 2008.  On June 2, 2011, the
trustee was directed by the hedge counterparty and the requisite
majority of the aggregate outstanding amount of each class to
liquidate the portfolio.

The final distribution occurred on Aug. 5, 2011.  The trustee
reports showed that the proceeds available for distribution were
enough to pay accrued and defaulted interest to the class A-4
through class C notes and a portion of the outstanding class A-1
note balance.  None of the notes were paid in full.

Maxim HG I was a static cash flow structured finance (SF)
collateralized debt obligation (CDO) invested in residential
mortgage-backed securities and SF CDOs.


MERRILL LYNCH: Fitch Affirms 'Dsf' Rating on $45.2MM Certificates
-----------------------------------------------------------------
Fitch Ratings affirms Merrill Lynch Mortgage Trust (ML) commercial
mortgage pass-through certificates, series 1998-C1-CTL, and
revises Recovery Ratings as indicated:

  -- $45.2 million class F at 'Dsf'; RR to 'RR6' from 'RR4'.

Classes G and H remain at 'Dsf/RR6' due to realized losses.

Fitch does not rate classes A-1 through E or K.

This affirmation of class F reflects realized principle losses.

As of the July 2011 remittance report, the transaction has paid
down 51.0% to $316.3 million from $646.1 million at issuance.  Two
loans (89%) are in special servicing. Interest shortfalls are
affecting classes F through H.


MONTANA HIGHER: Fitch Affirms 'B' Rating on Seven Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed the senior student loan notes and the
subordinate notes issued by Montana Higher Education Assistance
Corp, 1993 Master Trust.  The Rating Outlook is Stable.

The ratings on the senior and subordinate notes are affirmed based
on the sufficient level of credit enhancement (combination of
overcollateralization, projected minimum excess spread, and
subordination) to cover the applicable risk factor stresses.

Fitch has taken these rating actions:

MHESAC 1993 Master Trust

  -- Class 1995-A affirmed at 'AAA'; Outlook Stable;
  -- Class 1995-B affirmed at 'AAA'; Outlook Stable;
  -- Class 1995-C affirmed at 'AAA'; Outlook Stable;
  -- Class 1998-A affirmed at 'AAA'; Outlook Stable;
  -- Class 1999-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2000-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2000-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2000-C affirmed at 'AAA'; Outlook Stable;
  -- Class 2001-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2001-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2001-C affirmed at 'AAA'; Outlook Stable;
  -- Class 2002-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2002-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2002-D affirmed at 'AAA'; Outlook Stable;
  -- Class 2003-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2003-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2003-C affirmed at 'AAA'; Outlook Stable;
  -- Class 2004-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2004-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2005-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-D affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-E affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-F affirmed at 'AAA'; Outlook Stable;
  -- Class 1998-B affirmed at 'B'; Outlook stable;
  -- Class 1999-B affirmed at 'B'; Outlook stable;
  -- Class 2002-E affirmed at 'B'; Outlook stable;
  -- Class 2003-D affirmed at 'B'; Outlook stable;
  -- Class 2004-C affirmed at 'B'; Outlook stable;
  -- Class 2006-C affirmed at 'B'; Outlook stable.
  -- Class 2006-G affirmed at 'B'; Outlook stable.


MORGAN STANLEY: Fitch Affirms Rating on Two Notes at 'Dsf'
----------------------------------------------------------
Fitch Ratings has affirmed three classes of notes issued by Morgan
Stanley 1997-RR (MS 1997-RR).  The affirmations reflect the
distressed nature of the underlying collateral of which
approximately 40.1% are non-rated or defaulted first-loss
commercial mortgage-backed securities (CMBS) bonds.

Since the last review in September 2010, cumulative losses on the
underlying collateral have increased to $110.8 million from $107.6
million at the last review.  The class F notes have 18.7% credit
enhancement as of the July 28, 2011 trustee report.

Given the high concentration of the pool, Fitch conducted an
asset-by-asset analysis of the underlying collateral to estimate
recoveries.  For each underlying transaction, Fitch used a
combination of Fitch's last CMBS review loss estimate, if rated by
Fitch, and the average loan loss severity estimate from Fitch's
most recent U.S. CMBS Loss Study, if not rated by Fitch, and
accounted for defeasance.  Based on this analysis, default appears
inevitable for class F.  However, Fitch estimates recovery on the
class to be over 80% of the current outstanding balance.

The class G notes have already experienced losses of approximately
$27.7 million and further losses are anticipated as losses on the
underlying collateral will directly impact them.

This review was conducted under the framework described in the
reports 'Global Structured Finance Rating Criteria' and 'Global
Rating Criteria for Structured Finance CDOs'.  However, given the
portfolio's distressed nature, Fitch believes that the probability
of default for all classes of notes can be evaluated without using
the Structured Finance Portfolio Credit Model (SF PCM) to estimate
potential further losses from the non-defaulted portion of the
portfolio.

MS 1997-RR is backed by CMBS B-pieces (the most junior bonds
of CMBS transactions) and closed on Nov. 26, 1997.  It is
collateralized by all or a portion of 12 classes of fixed-rate
CMBS in nine separate underlying transactions from the 1996 and
1997 vintages.

Fitch has affirmed the following classes:

  -- $54,598,830 class F notes at 'Csf';
  -- $7,394,510 class G-1 notes at 'Dsf';
  -- $5,224,370 class G-2 notes at 'Dsf'.

Classes A, B, C, D, E, and IO have been paid in full while classes
H-1 and H-2 have been reduced to zero due to realized losses.


MORGAN STANLEY: Fitch Revises Rating on 16 Notes to 'Dsf'
---------------------------------------------------------
Fitch Ratings has revised the ratings on 16 classes in Morgan
Stanley Capital I Inc. 2007-13.  These classes were downgraded
from 'Csf' and 'CCsf' to 'Dsf' on Feb. 25, 2011 in error based on
incorrect data received from a third party provider.  Had the
correct data been used for the actions taken June 7, 2011, Fitch
would have affirmed the ratings as listed below.

Fitch revised the following ratings:

Morgan Stanley Capital I Inc. 2007-13

  -- Class 5-A1 (61756HBH2) 'Csf/RR3';
  -- Class 5-A3 (61756HBK5) 'CCsf/RR3';
  -- Class 6-A1 (61756HBN9) 'Csf/RR3';
  -- Class 6-A3 (61756HBQ2) 'Csf/RR3';
  -- Class 6-A4 (61756HBR0) 'Csf/RR3';
  -- Class 6-A5 (61756HBS8) 'Csf/RR3';
  -- Class 7-A1 (61756HBT6) 'Csf/RR3';
  -- Class 7-A4 (61756HBW9) 'Csf/RR3';
  -- Class 7-A5 (61756HBX7) 'Csf/RR5';
  -- Class 7-A6 (61756HBY5) 'Csf/RR3';
  -- Class 7-A8 (61756HCA6) 'Csf/RR3';
  -- Class 7-A9 (61756HCB4) 'Csf/RR5';
  -- Class 7-A11 (61756HCD0) 'Csf/RR3';
  -- Class 7-A13 (61756HCF5) 'Csf/RR3';
  -- Class 7-A15 (61756HCH1) 'Csf/RR3';
  -- Class 7-A17 (61756HCK4) 'Csf/RR3'.


MORGAN STANLEY: Moody's Affirms Ratings of 19 CMBS Classes
----------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 19
classes of Morgan Stanley Capital I Trust 2004-HQ3, Commercial
Mortgage Pass-Through Certificates, Series 2004-HQ3:

Cl. A-3, Affirmed at Aaa (sf); previously on Mar 10, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Mar 10, 2004
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Feb 14, 2007 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Feb 14, 2007 Upgraded
to Aaa (sf)

Cl. D, Affirmed at Aaa (sf); previously on Sep 26, 2007 Upgraded
to Aaa (sf)

Cl. E, Affirmed at Aa1 (sf); previously on Sep 26, 2007 Upgraded
to Aa1 (sf)

Cl. F, Affirmed at Aa3 (sf); previously on Sep 26, 2007 Upgraded
to Aa3 (sf)

Cl. G, Affirmed at A2 (sf); previously on Feb 14, 2007 Upgraded to
A2 (sf)

Cl. H, Affirmed at Baa1 (sf); previously on Mar 10, 2004
Definitive Rating Assigned Baa1 (sf)

Cl. J, Affirmed at Baa2 (sf); previously on Mar 10, 2004
Definitive Rating Assigned Baa2 (sf)

Cl. K, Affirmed at Baa3 (sf); previously on Mar 10, 2004
Definitive Rating Assigned Baa3 (sf)

Cl. L, Affirmed at Ba1 (sf); previously on Mar 10, 2004 Definitive
Rating Assigned Ba1 (sf)

Cl. M, Affirmed at Ba2 (sf); previously on Mar 10, 2004 Definitive
Rating Assigned Ba2 (sf)

Cl. N, Affirmed at B1 (sf); previously on Nov 18, 2010 Downgraded
to B1 (sf)

Cl. O, Affirmed at B2 (sf); previously on Nov 18, 2010 Downgraded
to B2 (sf)

Cl. P, Affirmed at B3 (sf); previously on Nov 18, 2010 Downgraded
to B3 (sf)

Cl. Q, Affirmed at Caa3 (sf); previously on Nov 18, 2010
Downgraded to Caa3 (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on Mar 10, 2004
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on Mar 10, 2004
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 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
2.1% of the current balance. At last full review, Moody's
cumulative base expected loss was 2.4%. Moody's stressed scenario
loss is 7.5% 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.

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 performance in the commercial real
estate property markets. While commercial real estate property
markets are gaining momentum, a consistent upward trend will not
be evident until the volume of transactions increases, distressed
properties are cleared from the pipeline and job creation
rebounds. The hotel and multifamily sectors are continuing to show
signs of recovery through the first half of 2011, while recovery
in the non-core office and retail sectors are tied to pace of
recovery of the broader economy. Core office markets are showing
signs of recovery through lending and leasing activity. 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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

The principal methodology used in this rating was "Moody's
Approach to Rating Fusion U.S. CMBS Transactions" published in
April 2005. Moody's also considered in its analysis, "Moody's
Approach to Rating Large Loan/Single Borrower Transactions",
published in July 2000. Please see the Credit Policy page on
www.moodys.com for a copy of these methodologies.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.60 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) 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 (sf) 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 (sf) and B2 (sf),
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 16, the same as 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 8.1. 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 18, 2010. Please see
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

DEAL PERFORMANCE

As of the August 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 42% to $772.5
million from $1.32 billion at securitization. The Certificates are
collateralized by 79 mortgage loans ranging in size from less than
1% to 14% of the pool, with the top ten loans representing 54% of
the pool. Seven loans, representing 11% of the pool, have defeased
and are collateralized by U.S. Government securities. There are
two loans with investment-grade credit estimates, representing 19%
of the pool.

Twenty-nine loans, representing 33% 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 since securitization,
resulting in an aggregate $4.9 million loss (68% loss severity on
average). Currently, there are no loans in special servicing.
However, Moody's has assumed a high default probability for six
poorly performing loans representing 6% of the pool. Moody's has
estimated a $7.2 million loss (15% expected loss based on a 30%
probability default) from the troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 98% and 57%, respectively, of the pool.
Excluding troubled loans, Moody's weighted average LTV for the
conduit component is 86% compared to 87% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 12%
to the most recently available net operating income. Moody's value
reflects a weighted average capitalization rate of 9.4%.

Excluding troubled loans, Moody's actual and stressed DSCRs for
the conduit component are 1.30X and 1.21X, respectively, compared
to 1.31X and 1.19X 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 an investment-grade credit estimate is the
GIC Office Portfolio Loan ($106.5 million -- 13.8% of the pool),
which is a pari-passu interest in a $677.6 million first mortgage
loan. The loan is secured by a portfolio of 12 office properties
located in seven states and totalling 6.4 million square feet
(SF). The largest geographic concentrations are Illinois (39%),
Pennsylvania (17%) and California (12%). The portfolio was 87%
leased as of December 2010 compared to 90% as of December 2009.
The property is also encumbered by a $121.1 million B-note. The
loan had a 60-month interest only period and is amortizing on a
360-month schedule maturing in January 2014. Moody's current
credit estimate and stressed DSCR are Baa3 and 1.44X,
respectively, compared to Baa3 and 1.45X at Moody's last review.

The second loan with a credit estimate is the Stone Ridge at
University Center Loan ($40.0 million -- 5.2% of the pool), which
is secured by a 630-unit multifamily property located in Ashburn
(Loudoun County), Virginia. As of March 2011, the property was 93%
leased compared to 94% at last review. Moody's credit estimate and
stressed DSCR are Aa3 and 1.71X, respectively, compared to Aa3 and
1.56X at last review.

The top three conduit loans represent 23% of the pool. The largest
conduit loan is the Harbor Steps Pool Loan ($94.6 million -- 12.3%
of the pool), which is secured by four apartment buildings
containing 739 units and 83,000 SF of commercial space located in
Seattle's Financial District. The properties are also encumbered
by a $21.6 million B-note. As of March 2011, the portfolio was 98%
occupied, essentially the same as at last review. Property
performance remains stable. Moody's LTV and stressed DSCR are 82%
and 1.06X, respectively, compared to 83% and 1.04X at last review.

The second largest conduit loan is the Alamo Quarry Market &
Quarry Crossing Loan ($61.2 million -- 7.9% of the pool), which
represents a pari passu interest in a $96.7 million first mortgage
loan. The loan is secured by a 590,000 SF power center located in
San Antonio, Texas. As of March 2011, the center was 97% leased,
compared to 95% at last review. Major tenants include Regal
Cinema, Bed, Bath & Beyond and Whole Foods. The property's
performance has improved due to lower real estate taxes and the
loan benefits from amortization. Moody's LTV and stressed DSCR are
94% and 1.01X, respectively, compared to 96% and 1.37X at last
review.

The third largest conduit loan is the Lifetime Pool Loan ($23.0
million -- 3.0% of the pool), which is secured by the borrower's
interest in two health & fitness clubs totaling 279,000 SF. The
properties are located in Canton and Rochester Hills, Michigan.
The Lifetime Fitness leases run through October 2023. The
property's cash flow remains steady and the loan benefits from
amortization. Despite stable performance, Moody's analysis
incorporates Moody's concerns of a soft Detroit real estate market
and the special purpose usage. Moody's LTV and stressed DSCR are
93% and 1.71X, respectively, compared to 73% and 1.67X at last
review.


MORGAN STANLEY: Pay Downs Cues Fitch to Hold Ratings at 'Csf'
------------------------------------------------------------
Fitch Ratings has upgraded two and affirmed one class of notes
issued by Morgan Stanley 2004-RR (MS 2004-RR).  The upgrades
reflect the significant principal pay downs on the underlying
commercial mortgage-backed securities (CMBS).

Since Fitch's last review in September 2010, there have been
$24.4 million in principal pay downs, resulting in the full
repayment of classes F-2 through F-4.  Approximately $11.6 million
of the $24.4 million in pay downs were recoveries from defaulted
CMBS bonds.  As such, the credit enhancement to classes F-5 and F-
6 have increased significantly.

Given the high concentration of the pool, Fitch conducted an
asset-by-asset analysis of the underlying collateral to estimate
recoveries.  For each underlying transaction, Fitch used a
combination of Fitch's last CMBS review loss estimate, if rated by
Fitch, and the average loan loss severity estimate from Fitch's
most recent U.S. CMBS Loss Study, if not rated by Fitch, and
accounted for defeasance. Based on this analysis, the class F-5
notes have been upgraded to 'BBBsf', reflecting that 63.3% of the
principal balance is supported by defeased collateral.  The
upgrade to the class F-6 notes is a result of the increase in
credit enhancement and the ability for the notes to withstand
Fitch's loss estimate on the remaining bonds.  The class F-7 notes
are affirmed at 'Csf' as default continues to appear inevitable.
However, Fitch estimates the recovery on class F-7 to exceed 70%.

This review was conducted under the framework described in the
reports 'Global Structured Finance Rating Criteria' and 'Global
Rating Criteria for Structured Finance CDOs'.  However, given the
portfolio's distressed nature, Fitch believes that the probability
of default for all classes of notes can be evaluated without using
the Structured Finance Portfolio Credit Model (SF PCM) to estimate
potential further losses from the non-defaulted portion of the
portfolio.

The certificates of MS 2004-RR, which closed June 17, 2004,
represent beneficial ownership interest in the trust, assets of
which are $49,040,339 of the class F certificates from Morgan
Stanley Capital I Inc., series 1997-RR (MS 1997-RR), which is
backed by CMBS B-pieces.  The class F certificates are
collateralized by all or a portion of 11 classes of fixed-rate
CMBS in eight separate underlying transactions from the 1996 and
1997 vintages.

Fitch has upgraded the following classes:

  -- $13,605,587 class F-5 to 'BBBsf' from 'CCCsf'; Outlook
     Stable;
  -- $5,735,000 class F-6 to 'BBsf' from 'CCsf'; Outlook Stable.

In addition, Fitch as affirmed the following class:

  -- $29,699,752 class F-7 at 'Csf'.

Classes F-1 through F-4 have paid in full.


MOUNTAIN CAPITAL: Moody's Raises Ratings of 6 Classes of CLO Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Mountain Capital CLO V LTD.:

US$191,000,000 Class A-1L Floating Rate Notes Due September 2018
(current outstanding balance of $188,541,747), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$3,000,000 Class A-1LB Floating Rate Notes Due September 2018,
Upgraded to Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed
Under Review for Possible Upgrade;

US$15,000,000 Class A-2L Floating Rate Notes Due September 2018,
Upgraded to Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$19,000,000 Class A-3L Floating Rate Notes Due September 2018,
Upgraded to Baa1 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$11,000,000 Class B-1L Floating Rate Notes Due September 2018,
Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

US$10,500,000 Class B-2L Floating Rate Notes Due September 2018
(current outstanding balance of $9,718,389), Upgraded to Ba3 (sf);
previously on June 22, 2011 Caa3 (sf) Placed Under Review for
Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio since the rating action in September
2009. Based on the August 2011 trustee report, the weighted
average rating factor is currently 2587 compared to 2828 in
September 2009.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $286 million,
defaulted par of $8 million, a weighted average default
probability of 20.83% (implying a WARF of 2693), a weighted
average recovery rate upon default of 49.91%, and a diversity
score of 59. The 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.

Mountain Capital CLO V LTD., issued in June 2006, 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
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CLO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

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


N-STAR REL: Fitch Affirms Junk Rating on Nine Note Classes
----------------------------------------------------------
Fitch Ratings has affirmed all classes of N-Star REL CDO VIII,
Ltd./LLC (N-Star VIII) reflecting Fitch's base case loss
expectation of 47.2%.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market value and cash flow declines.

Since last review, the disposal of 25 assets from the
collateralized debt obligation (CDO) resulted in realized losses
to par of approximately $90 million.  These losses were offset by
par building of approximately $119 million from the purchase of
new assets, predominantly highly leveraged subordinate positions.
Fitch modeled these positions with substantial to full losses in
its base case.

N-Star VIII is collateralized by both senior and subordinate
commercial real estate (CRE) debt: 54.1% of total collateral is
either whole loans or A-notes and 36.7% is either B-notes or
mezzanine loans.  Fitch expects significant losses upon default
for the subordinate positions since they are generally highly
leveraged.  Additionally, Fitch is generally concerned with the
high percentage of the total collateral secured by land and
construction (20.6%).  Defaulted assets comprise 4.6% of the total
collateral and include one B-note (1.5%), one CRE CDO bond (0.7%),
and one commercial mortgage-backed security (CMBS) bond (2.4%).
An additional 13 loans (24.6%) were identified as Loans of
Concern.  These loans include seven mezzanine loans (12%) and six
whole loans/A-notes (12.6%).  Fitch modeled significant to full
losses on the defaulted assets and Loans of Concern.

N-Star VIII was initially issued as a $900 million CRE CDO managed
by NS Advisors, LLC.  The transaction has a five-year reinvestment
period during which principal proceeds may be used to invest in
substitute collateral.  The reinvestment period ends in February
2012. In November 2009, $31.1 million of notes were surrendered to
the trustee for cancellation.  All overcollateralization and
interest coverage ratios have remained above their covenants as of
the July 2011 trustee report.

As of the July 2011 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: whole loans/A-notes
(54.1%), mezzanine loans (28.1%), CRE CDOs (6.8%), preferred
equity (4.5%), B-notes (4.1%), and CMBS (2.4%).

Under Fitch's surveillance methodology, approximately 80.2% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 6.8% from the most recent available cash
flows (generally from year-end 2010). Fitch estimates that average
recoveries will be at 41.1%.

The largest component of Fitch's base case loss expectation is a
mezzanine loan (67%) secured by interests in a 1,020 unit
multifamily property located in Framingham, Massachusetts.
Although performance has been relatively stable, the loan is
highly leveraged.  Further, the sponsor of the loan is reported to
be under financial strain.  Fitch modeled a term default with a
full loss under its base case scenario.

The next largest component of Fitch's base case loss expectation
is a mezzanine loan (6.4%) secured by interests in a 2.2 million
square foot office complex located in Chicago, Illinois.  Although
current occupancy is greater than 90% and performance has been
relatively stable, the cash flow from the property does not
support debt service on a stressed basis. Fitch modeled a term
default with a full loss under its base case scenario.

The third largest component of Fitch's base case loss expectation
is a mezzanine loan (4%) secured by interests in a portfolio of 12
retail properties located in Phoenix, Arizona.  Fitch modeled a
term default with a full loss under its base case scenario due to
the loan's high leverage under Fitch's base case scenario.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Based on this analysis, the breakeven rates for classes A-1, A-R,
A-2, B, C, and D are generally consistent with the ratings
assigned below.

The 'CCC' and below ratings for classes E through N are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Classes A-1 through D maintain a Negative Rating Outlook
reflecting Fitch's expectation for further potential negative
credit migration of the underlying collateral.

Fitch has affirmed and revised RRs to these classes:

  -- $100,000,000 class A-1 at 'BBBsf'; Outlook Negative;
  -- $260,000,000 class A-R at 'BBBsf'; Outlook Negative;
  -- $103,050,000 class A-2 at 'BBsf'; Outlook Negative;
  -- $60,300,000 class B at 'BBsf'; Outlook Negative;
  -- $24,300,000 class C at 'Bsf'; Outlook Negative;
  -- $17,100,000 class D at 'Bsf'; Outlook Negative;
  -- $22,050,000 class E to 'CCCsf/RR4 from 'CCCsf/RR3';
  -- $25,200,000 class F at 'CCCsf/RR5';
  -- $9,100,000 class G at 'CCCsf/RR6';
  -- $20,700,000 class H at 'CCCsf/RR6';
  -- $12,000,000 class J at 'CCCsf/RR6';
  -- $18,900,000 class K at 'CCCsf/RR6';
  -- $22,050,000 class L at 'CCCsf/RR6';
  -- $14,850,000 class M at 'CCCsf/RR6';
  -- $22,500,000 class N at 'CCCsf/RR6'.


N-STAR REL: Fitch Affirms Junk Rating on Six Note Classes
---------------------------------------------------------
Fitch Ratings has affirmed all classes of N-Star REL CDO VI,
Ltd./LLC (N-Star VI) reflecting Fitch's base case loss expectation
of 47.1%.  Fitch's performance expectation incorporates
prospective views regarding commercial real estate market value
and cash flow declines.

Fitch has affirmed and revised Rating Outlooks and RRs to these
classes:

  -- $174,800,000 class A-1 at 'BBsf; Outlook to Stable from
     Negative;
  -- $70,000,000 class A-R at 'BBsf'; Outlook to Stable from
     Negative;
  -- $27,225,000 class A-2 at 'Bsf'; Outlook Negative;
  -- $21,825,000 class B at 'CCCsf'; RR to 'RR5' from 'RR4';
  -- $11,775,000 class C at 'CCCsf/RR6';
  -- $10,000,000 class D at 'CCCsf/RR6';
  -- $10,125,000 class E at 'CCCsf/RR6';
  -- $7,650,000 class F at 'CCCsf/RR6';
  -- $6,900,000 class G at 'CCCsf/RR6'.

Since Fitch's last review, the disposal of 10 assets from the
collateralized debt obligation (CDO) resulted in realized losses
to par of approximately $25 million.  These losses were offset by
par building of approximately $90 million from the purchase of new
assets, predominantly highly leveraged subordinate positions.
Fitch modeled these positions with substantial to full losses in
its base case.

N-Star VI is collateralized by both senior and subordinate
commercial real estate (CRE) debt: 41.6% of total collateral is
either whole loans or A-notes and 37% is either B-notes or
mezzanine loans.  Fitch expects significant losses upon default
for the subordinate positions since they are generally highly
leveraged.  Defaulted assets comprise 6.8% of the total collateral
and include two mezzanine loans (1.3%), one CRE CDO bond (2.5%),
and one commercial mortgage-backed security (CMBS) bond (3%).  An
additional five loans (19%) were identified as Loans of Concern.
These loans include one mezzanine loan (6.2%), one B-note (3.4%),
and three whole loans/A-notes (9.4%).  Fitch modeled significant
to full losses on the defaulted assets and Loans of Concern.

N-Star VI was initially issued as a $450 million CRE CDO managed
by NS Advisors, LLC.  The transaction has a five-year reinvestment
period during which principal proceeds may be used to invest in
substitute collateral.  The reinvestment period ended in June
2011.  In November 2009, $8 million of notes were surrendered to
the trustee for cancellation.  All overcollateralization and
interest coverage ratios remain above their covenants as of the
June 2011 trustee report.

As of the June 2011 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: whole loans/A-notes
(41.6%), mezzanine loans (20.7%), CRE CDOs (13.8%), B-notes
(12.9%), CMBS (7.6%), and preferred equity (3.4%).

Under Fitch's surveillance methodology, approximately 69.8% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 7% from the most recent available cash flows
(generally from year-end 2010).  Fitch estimates that average
recoveries will be at 32.6%.

The largest component of Fitch's base case loss expectation is
a mezzanine loan (6.2%) secured by interests in a 400-unit
multifamily property located in Ventura, California. Although
performance has been relatively stable, the loan is highly
leveraged.  Further, the sponsor of the loan is reported to be
under financial strain. Fitch modeled a term default with a full
loss under its base case scenario.

The next largest component of Fitch's base case loss expectation
is a mezzanine loan (6.2%) secured by interests in a 647-room
hotel located in Las Vegas, Nevada as well as the developments on
an adjacent 12-acre parcel of land. The business plan was to
expand the hotel, casino, retail, and food and beverage components
at the property.  While progress has been made on the development
and hotel performance continues to stabilize, property cash flow
remains significantly below original projections.  Fitch modeled a
term default with a full loss under its base case scenario.

The third largest component of Fitch's base case loss expectation
is an A-note (5%) secured by over 2,000 acres of land located in
the Pocono Mountains of Pennsylvania.  The initial business plan
was to develop the site in multiple phases, but due to economic
downturn, the plan was not realized.  Fitch modeled a term default
with a significant loss under its base case scenario.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Based on this analysis, the breakeven rates for classes A-1, A-R,
and A-2 are generally consistent with the ratings assigned below.

The 'CCC' and below ratings for classes B through K are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

The Rating Outlooks on classes A-1 and A-R were revised to Stable
based upon their senior position in the capital structure and the
expectation of paydown as the transaction exits its reinvestment
period.  Class A-2 maintains a Negative Rating Outlook reflecting
Fitch's expectation for further potential negative credit
migration of the underlying collateral.


NAAC REPERFORMING: Moody's Lowers Rating of $93.8-Mil. RMBS
-----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of seven
tranches issued by NAAC Reperforming Loan REMIC Trust Certificates
2004-R1. The collateral consists of fixed-rate mortgage loans
insured by the Federal Housing Administration (FHA) an agency of
the U.S. Department of Urban Development (HUD) or guaranteed by
the Veterans Administration (VA).

Complete rating actions are:

Issuer: NAAC Reperforming Loan Remic Trust Certificates, Series
2004-R1

Cl. A1, Downgraded to Baa3 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. A2, Downgraded to Baa3 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. PT, Downgraded to Baa3 (sf); previously on Jul 27, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. M, Downgraded to B1 (sf); previously on Jul 27, 2011 Baa2 (sf)
Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to Ca (sf); previously on Jul 27, 2011 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. B-2, Downgraded to C (sf); previously on Jul 27, 2011 Caa2
(sf) Placed Under Review for Possible Downgrade

Cl. B-3, Downgraded to C (sf); previously on Jul 24, 2009
Downgraded to Ca (sf)

RATINGS RATIONALE

The actions are a result of Moody's updated loss projection for
the RMBS FHA-VA portfolio. The updated projection accounts for
higher potential pool losses due to self-curtailment of claims by
servicers whereby they pass expenses as deemed reasonable to the
trusts instead of submitting them to HUD, and continued weaknesses
in the macro economy and the housing market.

A FHA guarantee covers 100% of a loan's outstanding principal and
a large portion of its outstanding interest and foreclosure-
related expenses in the event that the loan defaults. A VA
guarantee covers only a portion of the principal based on the
lesser of either the sum of the current loan amount, accrued and
unpaid interest, and foreclosure expenses, or the original loan
amount. HUD usually pays claims on defaulted FHA loans when
servicers submit the claims, but can impose significant penalties
on servicers if it finds irregularities in the claim process later
during the servicer audits. This can prompt servicers to push more
expenses to the trust that they deem reasonably incurred than
submit them to HUD and face significant penalty. The rating
actions consider the portion of a defaulted loan normally not
covered by the FHA or VA guarantee and other servicer expenses
they deemed reasonably incurred and passed on to the trust.

FHA/VA borrowers, in Moody's-rated transactions, are typically low
income borrowers with poor credit history who have been affected
by the weak economy and housing market. Moody's expects
delinquencies to remain high for this sector at 40%, 35%, and 30%
for the 2004, 2005, and 2006 vintages, respectively as house
prices continue to decline and unemployment rates remain high.
FHA/VA RMBS transactions have had very low losses to date (less
than 1%) despite high delinquency levels due to the FHA and VA
guarantees. However, Moody's expects this trend to change due to
the higher level of self-curtailments by the servicers.

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, 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. Moody's now
projects house price index to reach a bottom in the first quarter
of 2012, with a 2% remaining decline between the first quarter of
2011 and 2012, and unemployment rate to start declining by fourth
quarter of 2011.

The principal methodology used in these ratings is described in
the Monitoring and Performance Review section in "Moody's Approach
to Rating US Residential Mortgage-Backed Securities" published in
December 2008. Other methodology used in this rating was "FHA VA
US RMBS Surveillance Methodology" published in July 2011. Please
see the Credit Policy page on www.moodys.com for a copy of these
methodologies.


NATIONAL COLLEGIATE: S&P Cuts Ratings on 2 Classes of Notes to 'D'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class C and D notes from National Collegiate Student Loan Trust
2006-4 to 'D (sf)' from 'CCC (sf)'.

"We downgraded these classes to 'D (sf)' because the affected
classes did not receive interest payments on the Aug. 25, 2011,
distribution date. The transaction breached the class C note
interest trigger because it failed both its cumulative default
rate and parity tests, prompting the interest shortfalls. The
transaction tests monthly the class C note interest trigger, and
the transaction can cure the breach if it passes the appropriate
performance tests on subsequent distribution dates. We lowered our
rating on the class C and D notes on Nov. 29, 2010, to 'CCC (sf)'
because parity was declining and approaching the threshold in
which interest would be reprioritized," S&P related.

"We believe this transaction will continue to breach its class C
note interest trigger for the foreseeable future. Our opinion
reflects the continued adverse performance trends of the
underlying pool of private student loans, including the
accelerated pace at which the transaction has been realizing
defaults," S&P said.

The breach of the class C note interest trigger caused a
reprioritization of interest to pay down senior bonds, resulting
in interest shortfalls to the class C and D notes on the Aug. 25,
2011, distribution date. The transaction did not breach its class
D note interest trigger, but the waterfall provides for the class
D note interest payment only after the interest on class C has
been paid. The transaction may draw on its reserve account to
cover fees to the servicer, trustee, paying agent, and
administrator, as well as backup administrator fees and expenses,
and class A, B, C, and D note interest when no triggers are in
effect. However, the transaction cannot draw on the reserve
account to cover interest payments to the class C and D notes when
a class C note interest trigger is in effect.

Series 2006-4 breached its class C note interest trigger due to
the combined failure of the cumulative default rate and parity
tests. The transaction failed its cumulative default rate test
after it exceeded the cumulative default threshold rate, which
resets to a higher cumulative default rate trigger each year
through February 2014 (see table 1). As of the Aug. 25, 2011,
distribution date, the cumulative default rate was 22.21%, which
exceeds the threshold rate of 16.00% by 6.21%. The parity test
failed because the aggregate outstanding balance of the class A
and B notes exceeded the sum of the collateral balance plus the
amounts on deposit in the reserve account.

The parity test was 99.88% as of the Aug. 25, 2011, distribution
date, which is 12 basis points (bps) below par and 225 bps below
the 102.13% reported as of the Aug. 25, 2010, distribution date.

Table 1
Class C Cumulative Default Rate Threshold Resets
Series 2006-4
Date                      CDR (%)
2/1/2008                     3.00
2/1/2009                     7.00
2/1/2010                    12.00
2/1/2011                    16.00
2/1/2012                    19.00
2/1/2013                    21.00
2/1/2014                    23.00

CDR -- Cumulative default rate.


NORTHWESTERN INVESTMENTS: Fitch Hold Junk Rating on Notes Classes
-----------------------------------------------------------------
Fitch Ratings has affirmed two classes of notes issued by
Northwestern Investment Management Company CBO I Fund Ltd./Corp.
(Northwestern CBO I):

  -- $15,000,000 class B-1 notes at 'Csf/RR6';
  -- $11,000,000 class B-2 notes at 'Csf/RR6'.

As of the Aug. 26, 2011 trustee report there was one performing
bond remaining in the portfolio with a par balance of $3 million.
There are also several defaulted bonds and equity positions that
Fitch expects to have minimal recovery value.  The class A
overcollateralization test, currently reported at 27.3%, has been
failing since 2002.  As a result, the classes B-1 and B-2 notes
have not received any distributions since this time.  With over
$11.6 million of class A notes remaining, Fitch expects that the
class B notes will not receive any distributions at the next and
final payment date in January 2012.

Northwestern CBO I is a collateralized debt obligation (CDO) that
closed Dec. 15, 1999.  The proceeds of the issuance were invested
in a static portfolio consisting primarily of high yield corporate
bonds.  Fitch withdrew its rating on the class A notes in February
2010 as a result of its withdrawal of the rating of the wrap
provider, Financial Security Assurance.

This review did not utilize Fitch's Global Cash Flow model given
that the remaining portfolio contains just one performing bond.
Fitch determined, based on the remaining balance of the class A
notes, that there will not be sufficient proceeds to make any
future payments to the class B-1 and B-2 notes.


PETRA CRE: Fitch Affirms Junk Rating on Seven Note Classes
----------------------------------------------------------
Fitch Ratings has placed two classes on Rating Watch Evolving and
Negative, downgraded two classes, and affirmed the remaining seven
classes of Petra CRE CDO 2007-1 (Petra 2007-1) reflecting Fitch's
increased base case loss expectation of 63.3%.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market values and cash flow declines.

Since November 2010, the CDO has been failing interest coverage
and overcollateralization tests resulting in the diversion of
interest payments from classes F and below and significant paydown
to class A-1 of $238.9 million.  However, on the July 2011 payment
date, interest proceeds were insufficient to pay the interest due
on classes A-1, A-2, and B; the interest due on these classes was
paid from principal proceeds.  The interest shortfall was
primarily the result of the CDO's high default rate (51%);
additional assets that are either capitalizing interest or
suffering interest shortfalls (7%); and the fact that the
transaction is over-hedged with swaps that are 'out-of the-money'
and senior in priority to the CDO's interest payments.

The credit enhancement to class A-1 has significantly increased to
84.9% compared to 67.2% at last review. Relative to the base case
expected loss; the class' credit profile has improved.  However,
Fitch is concerned about the CDO's ability to continue to make
timely interest payments to this class given the diminished amount
of interest proceeds and significant swap counterparty payments.
While the asset manager terminated two swaps in July 2011,
alleviating some of the cash flow pressure, several others remain
in place.  Principal proceeds are expected to be available at the
next payment date from the discounted payoff of a credit risk loan
should they be needed for interest payments.  However, going
forward that may not be the case, especially if there are further
defaults or delinquencies on the underlying collateral.  Fitch has
placed this class on Rating Watch Evolving and will monitor the
net interest proceeds relative to the timely interest due, which
is expected to settle out in the coming months.

The credit enhancement to Class A-2 is consistent with a rating of
'BB'; however, Fitch is also concerned about the CDO's ability to
continue to make timely interest payments to this class.  Should
cash flow to the CDO be further depleted over the next few months,
this class may face a downgrade of one or two rating categories.

The downgrades of classes B and C are the result of the increased
base case expected loss of 63.3% from 48.8% at last review and the
increase in defaulted assets and loans of concern to 51% and 20%
from 41.1% and 11.2%, respectively at last review.

As of the July 2011 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: whole loans/A-notes
(48%); B-notes (6%), mezzanine debt (19%), preferred equity (3%);
CMBS (10%), CRE CDO securities (6%), REIT Debt (6%), and a real
estate bank loan (1%). Since last review, 14 assets were removed
from the CDO, all at losses to par; total losses were
$85.3 million.  The CDO also added 11 rated securities, which
were purchased at a discount and resulted in built par of
$31.9 million.

Under Fitch's surveillance methodology, approximately 88.6% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress. In this scenario, the modeled average
cash flow decline is 9% from the most recent available cash flows
(generally year-end 2010 or TTM 1st quarter 2011).  Fitch
estimates that average recoveries will be 28.6%.

The largest component of Fitch's base case loss expectation is the
modeled losses on the rated collateral (24%).

The next largest component to Fitch's base case loss expectation
is related to a defaulted A-note (8.4%) secured by a failed
condominium conversion project located in New York City.  Through
the worsening economy the borrower tried to adapt its business
plan to alternative uses, which interrupted progress on the
renovation.  The project is only 60% - 75% complete, and the loan
is non-performing.  Fitch modeled a significant loss on the loan
in its base case scenario.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.

The 'CCC' and below ratings for classes B through K are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Petra 2007-1 is managed by Petra Capital Management LLC. The CDO's
six-year reinvestment period ends in June 2013.

Fitch has placed this class on Rating Watch Evolving:

  -- $121.1 million class A-1 at 'BBBsf'.

Fitch has placed this class on Rating Watch Negative:

  -- $133.8 million class A-2 at 'BBsf'.

Fitch has downgraded these classes, as indicated:

  -- $76.8 million class B to 'CCCsf/RR2' from 'Bsf';
  -- $57.6 million class C to 'CCsf/RR6' from 'CCCsf/RR5';

Fitch has affirmed these classes, as indicated:

  -- $25.6 million class D at 'CCsf/RR6';
  -- $22.1 million class E at 'CCsf/RR6';
  -- $33.6 million class F at 'CCsf/RR6';
  -- $20.5 million class G at 'CCsf/RR6';
  -- $27.2 million class H at 'CCsf/RR6';
  -- $46.2 million class J at 'Csf/RR6';
  -- $37 million class K at 'Csf/RR6'.


RAIT CRE: Fitch Affirms Junk Rating on Eight Note Classes
---------------------------------------------------------
Fitch Ratings has affirmed 11 classes of RAIT CRE CDO I Ltd. (RAIT
CRE CDO I) reflecting Fitch's base case loss expectation of 50.7%.
Fitch's performance expectation incorporates prospective views
regarding commercial real estate market values and cash flow
declines.

Fitch has affirmed these classes, and revised an RR rating:

  -- $200,000,000 class A1A notes at 'BBsf'; Outlook Negative;
  -- $275,000,000 class A1B notes at 'BBsf'; Outlook Negative;
  -- $90,000,000 class A2 notes at 'Bsf'; Outlook Negative;
  -- $110,000,000 class B notes at 'CCCsf'; RR to 'RR5' from
     'RR4';
  -- $41,500,000 class C notes at 'CCCsf/RR6';
  -- $22,500,000 class D notes at 'CCCsf/RR6';
  -- $16,000,000 class E notes at 'CCCsf/RR6';
  -- $500,000 class F notes at 'CCCsf/RR6';
  -- $12,500,000 class G notes at 'CCCsf/RR6';
  -- $17,500,000 class H notes at 'CCsf/RR6';
  -- $35,000,000 class J notes at 'CCsf/RR6'.

RAIT CRE CDO I is collateralized by both senior and subordinate
commercial real estate (CRE) debt: 66.2% are either whole loans or
A-notes, while 30.7% consists of subordinate debt (B-notes [1.1%],
mezzanine loans [22.5%] and preferred equity [7.2%]), as of the
July 2011 trustee report.  Approximately 3% of the portfolio is
cash.  The CDO's five-year reinvestment period ends in November
2011.  As of the July 2011 trustee report, all over-
collateralization tests were in compliance.

Since last review, realized losses on defaulted/credit risk assets
totaled more than $20 million. Fitch expects significant losses
upon default for the subordinate positions, since they are
generally highly leveraged debt classes.  Further, 11 loans (5.5%)
are currently defaulted or delinquent while Fitch considers 17
loans (32.8%) to be Fitch Loans of Concern.

In August 2010, $32.5 million of notes were surrendered to the
trustee for cancellation, including partial amounts of classes D,
F, G and H.

Under Fitch's surveillance methodology, approximately 82.9% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 8% from the most recent available cash flows
(generally year-end 2010 or trailing 12 months first quarter
2011).  Fitch estimates that average recoveries will be 38.9%.

A preferred equity position (3.2% of the pool) on an office
complex located in Boca Raton, FL is the largest component of
Fitch's base case expected loss.  After a period of vacancy, the
property was recently 100% leased to a new tenant, which has not
yet commenced rental payments.  The property is overleveraged, and
Fitch modeled a substantial loss in its base case scenario on this
position.

The next largest component of Fitch's base case loss expectation
is a whole loan (7.3%) secured by a portfolio of industrial
(468,000 square feet [sf]) and retail (313,000 sf) properties
located primarily in Central and Northern New Jersey.  Overall
occupancy is reported at 69%. Current cash flow from the portfolio
does not support annual debt service.  The loan matures in
December 2011. Fitch modeled a significant loss on this
underperforming loan in its base case scenario.

The third largest component of Fitch's base case loss expectation
is a whole loan (3%) secured by a regional mall located in South
Carolina.  The property currently has negative cash flow.  While a
new movie theater tenant signed a 15-year lease and is expected to
open for business shortly, near-term cash flow is still not
expected to support debt service. Fitch modeled a substantial loss
in its base case scenario on this loan.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Based on this analysis, the breakeven rates for classes A1A, A1B,
and A2 are generally consistent with the ratings assigned below.

The 'CCC' and below ratings for classes B through J are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Classes A1A, A1B, and A2 maintain a Negative Rating Outlook
reflecting Fitch's expectation of further potential negative
credit migration of the underlying collateral.

RAIT CRE CDO I is managed by RAIT Partnership, L.P. Fitch notes
that RAIT affiliates have ownership interests in 19 of the CDO
assets totaling approximately $360 million.


RAMPART CLO: Moody's Upgrades Ratings of Four Classes of Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Rampart CLO 2007 Ltd.:

US$26,100,000 Class B Floating Rate Notes due 2021, Upgraded to
Aa3 (sf); previously on June 22, 2011 A1 (sf) Placed Under Review
for Possible Upgrade;

US$25,100,000 Class C Deferrable Floating Rate Notes due 2021,
Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$15,300,000 Class D Deferrable Floating Rate Notes due 2021,
Upgraded to Ba1 (sf); previously on June 22, 2011 Ba2 (sf) Placed
Under Review for Possible Upgrade; and

US$16,350,000 Class E Deferrable Floating Rate Notes due 2021,
Upgraded to Ba3 (sf); previously on June 22, 2011 B2 (sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect the consideration of an increase in the
transaction's overcollateralization ratios since the rating action
in September 2009. Based on the latest trustee report dated August
4, 2011, the Class A/B, Class C, Class D, and Class E
overcollateralization ratios are reported at 119.35%, 112.47%,
108.65%, and 104.84%, respectively, versus August 2009 levels of
116.77%, 110.03%, 106.29%, and 102.57%, respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $489.5 million,
defaulted par of $0.3 million, a weighted average default
probability of 22.0% (implying a WARF of 2665), a weighted average
recovery rate upon default of 48.4%, and a diversity score of 65.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Rampart CLO 2007 Ltd., issued in October 2007, 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
June 2011.

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 June 2011.

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 2013 and
2015 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 the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average coupon, and diversity score.
   However, as part of the base case, Moody's considered spread
   levels higher than the covenant level and weighted average
   rating factor lower than the covenant level due to the large
   difference between the reported and covenant levels.


RESOURCE REAL: Fitch Affirms Junk Rating on Nine Note Classes
-------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of Resource Real Estate
Funding CDO 2007-1 Ltd./LLC (RRE 2007-1), reflecting Fitch's base
case loss expectation of 36.4%.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market values and cash flow declines.

Fitch has affirmed these classes:

  -- $180,000,000 class A-1 at 'BBB' Rating Outlook Negative;
  -- $50,000,000 class A-1R at 'BBB' Rating Outlook Negative;
  -- $57,500,000 class A-2 at 'BB' Rating Outlook Negative;
  -- $15,000,000 class B at 'B' Rating Outlook Negative;
  -- $7,000,000 class C at 'B' Rating Outlook Negative;
  -- $26,750,000 class D at 'CCC/RR2';
  -- $11,875,000 class E at 'CCC/RR3';
  -- $5,375,000 class F at 'CCC/RR5';
  -- $5,000,000 class G at 'CCC/RR6';
  -- $625,000 class H at 'CCC/RR6';
  -- $11,250,000 class J at 'CCC/RR6';
  -- $10,000,000 class K at 'CCC/RR6';
  -- $18,750,000 class L at 'CCC/RR6';
  -- $28,750,000 class M at 'CC/RR6'.

RRE 2007-1 is collateralized by both senior and subordinate
commercial real estate (CRE) debt: 57.6% are either whole loans or
A-notes, while 9.7% are either B-notes or mezzanine loans as of
the July 2011 trustee report.  In addition, 15.2% are commercial
mortgage backed securities (CMBS) and 17.5% of the portfolio is
held in cash. As of the July 2011 trustee report, all over-
collateralization and interest coverage tests were in compliance.

Since last review, realized losses on defaulted/credit risk assets
totaled approximately $15 million.  Two loans (2.1%) are currently
defaulted or delinquent; Fitch considers nine other loans (32%) to
be Fitch Loans of Concern due to low current net operating income
relative to origination expectations.

Since last review, $30.9 million of notes were surrendered to the
trustee for cancellation, including partial amounts of classes B,
F, G and H.

Under Fitch's surveillance methodology, approximately 60.7% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 8.3% from the most recent available cash
flows (generally trailing 12 months first quarter 2011).  Fitch
estimates that average recoveries will be 40.0%.

The largest component of Fitch's base case loss expectation is the
expected loss assigned to the CMBS collateral.  The weighted
average Fitch derived rating for the CMBS collateral is 'B+/B'
compared to 'BB-' at last review.

The next largest component of Fitch's base case loss expectation
is a whole loan (6.2%) secured by a full-service hotel located in
Tucson, AZ.  Current cash flow from the portfolio does not support
annual debt service.  Fitch modeled a significant loss on this
underperforming loan in its base case scenario.

The third largest component of Fitch's base case loss expectation
is a whole loan (6.3%) secured by a multifamily property in
Renton, WA.  Although occupancy has remained in the 90% range,
rental rates have continued to be pressured.  Current occupancy is
94.6% as of March 2011. Fitch modeled a substantial loss in its
base case scenario on this loan.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to classes A-1 through C was then compared
to the modeled expected losses.  The credit enhancement was
determined to be consistent with the ratings assigned below.
Based on prior modeling results, no material impact was
anticipated from cash flow modeling the transaction.

The 'CCC' and below ratings for classes D through M are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Classes A-1 through C maintain their Negative Rating Outlook
reflecting Fitch's expectation of further potential negative
credit migration of the underlying collateral.

RRE 2007-1 is a $500 million CRE collateralized debt obligation
(CDO) managed by Resource Real Estate, Inc.  The transaction has a
five-year reinvestment period during which principal proceeds may
be used to invest in substitute collateral. The reinvestment
period ends in June 2012.


RESOURCE REAL: Fitch Affirms Junk Rating on Six Note Classes
------------------------------------------------------------
Fitch Ratings has affirmed 11 classes and withdrawn the rating on
one class of Resource Real Estate Funding CDO 2006-1 Ltd./LLC (RRE
2006-1) reflecting Fitch's base case loss expectation of 28.5%.
Fitch's performance expectation incorporates prospective views
regarding commercial real estate market values and cash flow
declines.

Fitch has affirmed the ratings and revised the Rating Outlooks for
these classes:

  -- $129,370,000 class A-1 'BBBsf'; Outlook to Stable from
     Negative;
  -- $5,000,000 class A-2 FX 'BBsf'; Outlook to Stable from
     Negative;
  -- $17,420,000 class A-2 FL 'BBsf'; Outlook to Stable from
     Negative;
  -- $13,000,000 class C 'Bsf'; Outlook to Stable from Negative;
  -- $10,000,000 class D 'Bsf'; Outlook to Stable from Negative.

Fitch has affirmed these classes:

  -- $13,700,000 class E at 'CCCsf/RR3';
  -- $14,580,000 class F at 'CCCsf/RR6';
  -- $17,250,000 class G at 'CCCsf/RR6';
  -- $12,930,000 class H at 'CCCsf/RR6';
  -- $14,660,000 class J at 'CCCsf/RR6';
  -- $28,460,000 class K at 'CCsf/RR6'.

Fitch has withdrawn the rating of class B following the full
surrender of those certificates. Fitch does not rate the
$36,260,000 preferred shares.

In June 2011, the trustee provided notice that $32,370,000 of RRE
2006-1 notes were submitted for cancellation.  The cancellations
were reflected in the June 27, 2011 trustee report and involved
the full cancellation of the class B notes and partial
cancellation of classes C through F.

Since Fitch's last review and as of the July 2011 trustee report,
the disposal of seven credit impaired assets has resulted in
realized losses to the CDO of $12.7 million.  Per the current
trustee reporting, the transaction passes all interest coverage
and overcollateralization tests.

Commercial real estate loans (CREL) comprise approximately 80.5%
of the collateral of the CDO. Two-thirds of the CREL are whole
loans or A-notes with the remainder B-notes or mezzanine loans.
Defaulted CREL assets have increased to 5.8% from 3%, while non-
defaulted loans of concern remained stable at approximately 25%
compared with last review.  CMBS/CDO collateral represents 10% of
the total collateral.  Compared with last review, the average
Fitch derived rating for the underlying CMBS/CDO collateral
remained unchanged at 'B-/CCC+'.

Under Fitch's updated methodology, approximately 57.3% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  Fitch estimates that average
recoveries will be relatively strong at 50.4% due to the generally
low loss expectations on the CREL collateral.

While the largest component of Fitch's base case loss expectation
is the modeled loss on the CMBS/CDO bond collateral, the second
largest component is an A-note (8.3%) secured by a 598-key hotel
in downtown Los Angeles.  The business plan at origination was
significantly affected by the designation of the property as
single room occupancy (SRO).  The borrower was unable to brand a
portion of the hotel under a nationally recognized flag and had
entered into litigation with the city of Los Angeles.  According
to the asset manager, the borrower has entered into settlement
proceedings with the city. The revised exit strategy now involves
conversion to mixed-use, which may include affordable/transitional
housing and hotel.  Due to the continued uncertainty surrounding
the business plan, Fitch modeled a term default with sizable
losses in its base case scenario.

The next largest component of Fitch's base case loss expectation
is a B-note (4.3%) secured by two office properties totaling
562,000 square feet (sf) located in Indianapolis, IN.  The loan is
in special servicing after failing to pay off at its July 1, 2011
final maturity.  According to the asset manager, the special
servicing is working on a short-term extension of the loan while
the single tenant's lease is being renegotiated.  Based on in-
place property cash flow, Fitch modeled a term default with
significant losses in its base case.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to classes A-1 through D was then compared
to the modeled expected losses.  Despite a much lower Fitch base
case loss expectation compared with Fitch's last full review, the
current credit enhancement was determined to be consistent with
the ratings assigned below since modeled values for several assets
were not yet fully supported by in-place property cash flows.
Based on prior modeling results, no material impact was
anticipated from cash flow modeling of the transaction.

The 'CCC' and below ratings for classes E through K are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Resource Real Estate, Inc., is the collateral asset manager for
the transaction. The CDO's reinvestment period ends Aug. 19, 2011.


RFC CDO: Fitch Affirms Junk Rating on All Notes Classes
-------------------------------------------------------
Fitch Ratings affirms all classes of RFC CDO 2007-1 (RFC 2007-1)
reflecting Fitch's base case loss expectation of 36.7%.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market value and cash flow declines.

RFC 2007-1 is a CRE CDO managed by CWCapital Investments.  As of
the June 2011 trustee report and per Fitch categorizations, the
CDO was substantially invested as follows: CRE whole loans
(49.1%), B-notes (14.1%), mezzanine loans (2.3%), commercial
mortgage-backed securities (25.6%), and CRE CDOs (1.3%).

The transaction currently has defaulted interests totaling 45% of
the pool.  Additionally, there are three loans (4.6%) that are
considered Fitch Loans of Concern. Fitch expects significant
losses on the defaulted assets and Fitch Loans of Concern.  Since
last review, seven assets were removed from the CDO, all at losses
to par; total losses were approximately $95 million.
Since 2009, the CDO has been failing interest coverage and
overcollateralization tests resulting in the diversion of interest
payments from classes C and below; and significant paydown to
classes A-1 and A-1R of over $150 million.  Given the expectation
of further defaults, Fitch considers it unlikely that classes C
and below will receive any further proceeds over the life of the
transaction.

Further, as of the September 2009 payment date, interest proceeds
were insufficient to pay the interest due on classes A-1, A-1R A-
2, A-2R, and B; the interest due on these classes was paid from
available principal cash or via proceeds advanced by the trustee
as backup advancing agent.  The interest shortfall was primarily
the result of asset defaults, and the fact that the transaction is
over-hedged with swaps that are 'out-of the-money' and senior in
priority to the CDO's interest payments.  Uncertainty surrounding
future advances and the backup agent's requirements to fund these
advances remains a concern.

Under Fitch's methodology, approximately 57.8% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress. In this scenario, the modeled average cash flow
decline is 9.3% from generally year-end 2010 net operating income
(NOI).  Fitch estimates that average recoveries will be low at
36.5%.

The largest component of Fitch's base case loss expectation is the
modeled losses on the rated securities (27%).

The largest defaulted loan (8%) is secured by a 380,602 square
foot (sf) office property located in downtown Phoenix, AZ.  The
building is 72.7% occupied as of April 2011, with minimal lease
rollover until 2013.  The loan transferred to special servicing in
May 2011 for maturity default after the borrower was unable to
refinance the debt.

The next defaulted loan (4%) is secured by a multi-family property
located in Aurora, CO.  This loan is cross-collateralized with a
second specially serviced loan (3.5%) -- also secured by a multi-
family property in Aurora, CO. Performance for both properties has
declined since issuance, and when amortization began in December
2009, the properties were not able to support the higher debt
service payment.  The loans were modified in April 2011 with an
extended maturity, a reversion to an interest-only debt service,
and minor pay-down of principal.  The special servicer continues
to monitor the loans.

The next largest defaulted loan (2.2%) is collateralized by two
office buildings located in Lake Mary, FL, and one office building
in Orlando, FL, totaling 36,404sf.  Occupancy remains below
expectations from origination, most recently reported at 75%.  The
special servicer continues to discuss workout options with the
borrower, including a possible modification.  Foreclosure is also
being discussed should terms of a modification not be worked out.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.

The 'CCC' and below ratings for all classes are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.
  Additionally, the ability of advancing to the timely classes was
also taken into account.

All classes were assigned Recovery Ratings (RR) in order to
provide a forward-looking estimate of recoveries on currently
distressed or defaulted structured finance securities.

Fitch affirms these classes, and revises the Recovery Ratings as
indicated:

  -- $352,726,573 class A-1 at 'CCC/RR1' from RR2;
  -- $39,191,841 class A-1R at 'CCC/RR1' from RR2;
  -- $125,000,000 class A-2 at 'CCC/RR5';
  -- $9,200,000 class A-2R at 'CCC/RR5';
  -- $86,500,000 class B at 'CCC/RR5';
  -- $49,189,591 class C at 'CC/RR6';
  -- $19,510,276 class D at 'CC/RR6';
  -- $15,418,422 class E at 'CC/RR6';
  -- $23,367,638 class F at 'C/RR6';
  -- $15,613,797 class G at 'C/RR6';
  -- $25,181,053 class H at 'C/RR6';
  -- $18,327,420 class J at 'C/RR6';
  -- $16,899,973 class K at 'C/RR6';
  -- $10,534,630 class L at 'C/RR6'.


SALOMON BROTHER: Fitch Holds Rating on $21.5MM Cl. H Notes at Csf
-----------------------------------------------------------------
Fitch Ratings downgrades three classes of Salomon Brothers
Mortgage Securities VII, Inc., commercial mortgage pass through
certificates, series 2000-C2.

The downgrades are due to the expectation of losses on specially
serviced loans in addition to interest shortfalls being incurred
on these classes.  The Negative Outlook on class E reflects the
potential for future interest shortfalls if there is an increase
in specially serviced loans or an increase in fees and expenses.
Should the class incur a shortfall it would no longer be
consistent with Fitch's rating definition of 'AAA'.  Fitch expects
losses of 34.0% from loans in special servicing and loans that
cannot refinance at maturity.  These losses will be absorbed by
classes H, J and K.

As of the August 2011 distribution date, the pool's certificate
balance has paid down 89.4% to $82.7 million from $781.6 million
at issuance.  There are 24 remaining loans from the original 193
loans at issuance.

There are eight specially serviced loans (78.5%) in the pool. Of
the eight loans, one loan (2.1%) is in foreclosure, four loans
(35.7%) are real estate owned (REO), one loan (6.2%) is 90 days
delinquent and one loan (31.3%) is current.

The largest contributor to Fitch expected losses is a 251,365
square foot (sf) retail center in Baltimore, MA.  The asset has
been REO since February 2006.  Litigation against the guarantor
over carve-out claims have concluded. The property is currently
being marketed for sale.  Although the potential litigation
proceeds could pay off the debt, Fitch's losses are based upon the
valuation of the property until the final outcome of the
litigation is known.  Fitch anticipates significant losses upon
sale of the asset based on valuations obtained by the special
servicer.

The second largest contributor to losses is a 201,148 sf office
building in Milwaukee, WI.  The asset has been REO since December
2009. Servicer is working to increase occupancy of the property
and has recently negotiated a renewal and executed two new leases.

Fitch affirms the following classes as indicated:

  -- $1.9 million class C at 'AAAsf'; Outlook Stable;
  -- $7.8 million class D at 'AAAsf; Outlook Stable;
  -- $11.7 million class E at 'AAAsf; Outlook Negative;
  -- $13.7 million class J at 'Csf/RR6'.

Fitch downgrades and revises the Recovery Rating of the following
classes as indicated:

  -- $13.7 million class F to 'Asf' from 'AAsf; Outlook Negative;
  -- $9.8 million class G to 'BBBsf' from 'A-sf; Outlook Negative;
  -- $21.5 million class H to 'Csf/RR4' from 'CCCsf/RR6;

Fitch does not rate class P. Classes A-1, A-2 and B have paid in
full.  Fitch maintains the rating of 'D/RR6' on classes K, L, M
and N.


SIERRA TIMESHARE: Fitch To Rate $23.8 Million Notes at 'BBsf'
-------------------------------------------------------------
Fitch Ratings expects to rate Sierra Timeshare 2011-2 Receivables
Funding LLC (Sierra 2011-2) as follows:

  -- $168,470,000 class A notes 'Asf'; Outlook Stable;
  -- $55,710,000 class B notes 'BBBsf'; Outlook Stable;
  -- $25,820,000 class C notes 'BBsf'; Outlook Stable.

Fitch's stress and rating sensitivity analysis are discussed in
the presale report titled 'Sierra Timeshare 2011-2 Receivables
Funding LLC', dated August 22, 2011.


SILVER MARLIN: Fitch Withdraws 'D' Rating on Nine Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed five, downgraded four, and subsequently
withdrawn the ratings on all classes of notes issued by Silver
Marlin CDO I, Ltd. (Silver Marlin I):

  -- $184,950,499 class A-1 notes downgraded to 'Dsf' from 'Csf'
     and withdrawn;
  -- $437,345,970 class A-2 notes affirmed at 'Dsf' and withdrawn;
  -- $62,477,996 class A-3 notes affirmed at 'Dsf' and withdrawn;
  -- $66,976,411 class A-4 notes affirmed at 'Dsf' and withdrawn;
  -- $21,492,431 class B notes affirmed at 'Dsf' and withdrawn;
  -- $9,396,691 class C notes affirmed at 'Dsf' and withdrawn;
  -- $8,283,962 class D notes downgraded to 'Dsf' from 'Csf' and
     withdrawn;
  -- $4,642,426 class E notes downgraded to 'Dsf' from 'Csf' and
     withdrawn;
  -- $12,235,379 class F notes downgraded to 'Dsf' from 'Csf' and
     withdrawn.

Silver Marlin I entered an event of default in February 2008 and
its maturity was accelerated in August 2008.  On June 2, 2011, the
trustee was directed by the hedge counterparty and the requisite
majority of the aggregate outstanding amount of each class to
liquidate the portfolio.

The final distribution occurred on Aug. 1, 2011.  The trustee
reports showed that the proceeds available for distribution were
insufficient to pay the class A-1 notes in full.  Consequently,
there were no available funds to make any payments on any other
classes of notes.

Silver Marlin I was a managed cash flow structured finance (SF)
collateralized debt obligation (CDO) invested in residential
mortgage-backed securities, CDOs and asset-backed securities.


SILVERADO CLO: Moody's Upgrades Ratings of CLO Notes
----------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Silverado CLO 2006-I Limited:

US$144,000,000 Class A-1 Senior Secured Floating Rate Notes due
2020, Upgraded to Aaa (sf); previously on June 22, 2011 Aa1 (sf)
Placed Under Review for Possible Upgrade;

US$7,500,000 Class A-1-J Senior Secured Floating Rate Notes due
2020, Upgraded to Aa1 (sf); previously on June 22, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade;

US$15,000,000 Class A-2 Senior Secured Floating Rate Notes due
2020, Upgraded to Aa3 (sf); previously on June 22, 2011 A2 (sf)
Placed Under Review for Possible Upgrade;

US$16,500,000 Class B Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to A3 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$15,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to Ba1 (sf); previously on June 22, 2011
B1 (sf) Placed Under Review for Possible Upgrade;

US$9,000,000 Class D Secured Deferrable Floating Rate Notes due
2020, Upgraded to Ba3 (sf); previously on June 22, 2011 Caa2 (sf)
Placed Under Review for Possible Upgrade;

US$6,3750,00 Type I Composite Notes due 2020 (current rated
balance of $ 4,209,279), Upgraded to Aa2 (sf); previously on
June 22, 2011 A1 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio since the rating action in August 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2530 compared to 2800 in June 2009.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $289 million,
defaulted par of $0 million, a weighted average default
probability of 20.70% (implying a WARF of 2705), a weighted
average recovery rate upon default of 52.09%, and a diversity
score of 48. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Silverado CLO 2006-I Limited , issued in April 2006, 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
June 2011.

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 June 2011.

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 2013 and
2015 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 the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score.


SIMSBURY CLO: Fitch Lifts Junk Rating on $1 Mil. Notes to 'BBsf'
----------------------------------------------------------------
Fitch Ratings has upgraded this class of notes issued by Simsbury
CLO, Ltd/Corp. (Simsbury CLO):

  -- $1,048,819 class V mezzanine notes to 'BBsf' Outlook Stable
     from 'CCsf/RR1'.

The upgrade of the class V notes is due to the increased credit
enhancement resulting from the deleveraging of the capital
structure and the collateral coverage remaining for the notes.
Since the last review, the class IVA senior and IVB mezzanine
notes were paid in full, leaving the class V notes as the senior-
most remaining class.  At the last payment date in March 2011, the
class V notes received more than half of their $3.2 million
outstanding principal balance.

The remaining performing portfolio collateral is comprised of high
yield loans and bonds issued by four unique obligors, with an
aggregate par balance of $3.8 million.  In addition, there is
currently $3.1 million of defaulted assets in the portfolio, which
Fitch expects to recover approximately 25% on average.
Approximately 47% of the performing portfolio balance is scheduled
to mature after the stated legal final of the transaction in
September 2011, exposing the notes to potential market value risk.
One obligor with a par value of $2 million and a Fitch derived
rating in the 'BB' category is scheduled to mature prior to the
stated maturity.  Fitch expects available proceeds received prior
to maturity to be sufficient to pay the class V notes in full at
their scheduled maturity in September 2011.

This review did not utilize Fitch's Global Cash Flow model given
the short remaining tenor of the transaction and the high obligor
concentration of the portfolio.  Instead, the credit quality of
the single performing obligation maturing prior to the stated
legal maturity date of the notes was used to determine the long-
term credit rating of the remaining liabilities.  The structural
features of the transaction were also factored into the analysis.

Simsbury is a collateralized loan obligation (CLO) which closed
Sept. 15, 1999, and is managed by Babson Capital Management LLC.
The stated maturity of the transaction is Sept. 24, 2011.


SLM STUDENT: Fitch Affirms 'BBsf' Rating on Class B Note
--------------------------------------------------------
Fitch Ratings affirms the senior notes at 'AAAsf' and subordinate
student loan note at 'BBsf' issued by SLM Student Loan Trust
Series 2003-10 The Rating Outlook remains Stable for both senior
and subordinate bonds.

The ratings on the senior and subordinate notes are affirmed based
on the sufficient level of credit enhancement to cover the
applicable basis factor stress.

Credit enhancement for Class B consists of projected minimum
excess spread.  Class A notes benefit from subordination provided
by the lower priority notes.

The loans are serviced and originated by SLM Corp. SLM Corp.
provides funds for educational loans, primarily federal guaranteed
student loans originated under the FFELP.  SLM Corp. and its
subsidiaries are not sponsored by or agencies of the U.S.
government.  Fitch has assigned SLM Corp. long- and short-term
Issuer Default Ratings (IDRs) of 'BBB-' and 'F3', respectively.
Fitch affirms these classes of SLM Student Loan Trust Series 2003-
10:

  -- Class A-1A at 'AAAsf;
  -- Class A-1B at 'AAAsf';
  -- Class A-1C at 'AAAsf';
  -- Class A-1D at 'AAAsf';
  -- Class A-1E at 'AAAsf';
  -- Class A-1F at 'AAAsf';
  -- Class A-1G at 'AAAsf';
  -- Class A-1H at 'AAAsf';
  -- Class A-2 at 'AAAsf';
  -- Class A-3 at 'AAAsf';
  -- Class A-4 at 'AAAsf';
  -- Class B at 'BBsf'.

The Rating Outlooks for all classes is Stable


SOLSTICE ABS: Fitch Affirms Junk Rating on Four Note Classes
------------------------------------------------------------
Fitch Ratings has affirmed four classes of notes issued by
Solstice ABS CDO III, Ltd. (Solstice III).  Fitch has also marked
one class of notes as paid-in-full (PIF):

  -- $0 class A-1 notes PIF;
  -- $100,770,203 class A-2 notes at 'Csf';
  -- $47,500,000 class B notes at 'Csf';
  -- $22,127,876 class C-1 notes at 'Csf';
  -- $6,529,375 class C-2 notes at 'Csf'.

The rating affirmations reflect Fitch's belief that principal
shortfall continues to appear inevitable for all classes of notes
at stated maturity, based on the expected losses from the
distressed and defaulted assets in the portfolio (rated 'CCsf' and
lower) and the reliance on recoveries on defaulted securities for
the ultimate return of principal.  In Fitch's view, the class A-2
and class B notes' increased credit enhancement (CE) levels,
resulting from the continued de-leveraging of the capital
structure, has not mitigated the effect of the portfolio
deterioration.

Since Fitch's last rating action in August 2010, the credit
quality of the collateral has further deteriorated, with the
Trustee reported Fitch weighted average rating factor (WARF)
declining to 31.6 ('B/B-') from 18.0 ('BB/BB-') at the last review
and is failing the transaction's covenant of 4.0 ('BBB/BBB-').
The exposure to defaulted securities, as defined in the
transaction's governing documents, has increased to 56.9% of the
portfolio, from 51.6% at last review.  This increase is due to a
combination of additional defaults occurring and performing assets
amortizing leaving a greater concentration of non-performing
securities.  Additionally, a portion of the principal collections
continues to be used to cover shortfalls in interest collections,
which is contributing to the erosion of credit enhancement.  Over
the last four payment dates, approximately $0.6 million of
principal proceeds was used to pay part of the class B accrued
interest.

In this review, Fitch used the analytical framework described in
the reports 'Global Structured Finance Rating Criteria' and
'Global Rating Criteria for Structured Finance CDOs'.  The
Structured Finance Portfolio Credit Model (SF PCM) and Fitch's
cash flow model were not utilized in the analysis of this
transaction, due to the degree of credit deterioration in the
underlying portfolio.

Following the redemption of the class A-1 notes in December 2010,
the class A-2 notes became the senior-most class outstanding and
began amortizing on the same distribution date.  Since then,
through the use of principal proceeds only, approximately
$6.7 million, or 6.3%, of the class A-2 notes' original balance
has paid down over the last three quarterly distribution dates.
While the credit profile of these notes has improved since the
last review, the class' current CE level is only marginally higher
than the expected losses from the distressed and defaulted assets
in the portfolio.  Fitch believes that the ultimate repayment of
the class A-2 notes' principal remains highly dependent on the
amount of interest proceeds generated by the underlying pool and
recoveries on the defaulted securities.

The class B notes continue to receive their timely interest
payments, partially through the use of principal proceeds.  Fitch
expects these notes to remain current on their interest payments;
however, default continues to appear inevitable as the expected
losses significantly exceed the class' current CE level.

Interest payments due on the class C-1 and C-2 (together, class C)
notes continue to be capitalized, with the notes' principal
balances written up by $3.1 million to date.  Since the last
review, the class C notes' subordination has declined as a result
of $1.1 million of principal writedowns on the defaulted
collateral.  Currently, they are undercollateralized by
approximately $11.2 million.

Solstice III is a cash flow structured finance collateralized debt
obligation (SF CDO) that closed on Nov. 13, 2003 and is monitored
by Rabobank International. As per the June 2011 trustee report,
the current portfolio is primarily composed of residential
mortgage-backed securities (50.5%), corporate CDOs (28%), SF CDOs
(18%), and commercial and consumer asset-backed securities (3.5%),
all from the 2002 through 2006 vintage transactions.


TRADEWINDS II: S&P Lowers Rating on Class A Notes to 'D'
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
on the class A notes from Tradewinds II CDO SPC Series 2006-1
Segregated Portfolio, a U.S. collateralized debt obligation (CDO)
transaction backed by Lehman Bros. Treasury Co. BV (LBT) floating-
rate European medium-term notes, ML CBO Series 1998-Deltec-1's
class B-1 and B-2, and a synthetic reference portfolio of
corporate entities..

"The downgrade reflects our opinion that the transaction had
insufficient collateral to return the rated principal amount due
on the class A notes at maturity," S&P related.

Rating Action

Tradewinds II CDO SPC Series 2006-1 Segregated Portfolio
                        Rating
Class              To           From
A                  D (sf)       CC (sf)


US CMBS: Fitch Lowers Ratings on 21 Bonds to 'D'
------------------------------------------------
Fitch Ratings has downgraded 21 bonds in 13 U.S. commercial
mortgage-backed securities (CMBS) transactions to 'D', as the
bonds have incurred a principal write-down.  The bonds were all
previously rated 'CC', or 'C', which indicates that Fitch expected
a default.

[The] action is limited to just the bonds with write-downs.  The
remaining bonds in these transactions have not been analyzed as
part of this review.  Fitch downgrades bonds to 'D' as part of the
ongoing surveillance process and will continue to monitor these
transactions for additional defaults.

Fitch has also withdrawn the ratings of classes K, L, and M of
Wachovia Bank Commercial Mortgage Trust 2007-ESH.  The classes had
been rated 'D/RR6' as a result of principal losses.  The
transaction is no longer outstanding.

The spreadsheet also details Fitch's Recovery Ratings (RRs)
assigned to the transactions.  The RR scale is based upon the
expected relative recovery characteristics of an obligation.  For
structured finance, RRs are designed to estimate recoveries on a
forward-looking basis while taking into account the time value of
money.


US RMBS: Fitch Downgrades 856 Bonds in 53 Transactions to 'Dsf'
---------------------------------------------------------------
Fitch Ratings has downgraded 856 bonds in 513 U.S. RMBS
transactions to 'Dsf'.  The downgrades indicate that the bonds in
question have incurred a principal write-down.  Of the bonds that
Fitch is downgrading to 'Dsf' 98.2% were previously rated 'Csf',
indicating an expected default. The remaining bonds were rated
'CCsf'.  The action is limited to just the bonds with write-downs.
The remaining bonds in these transactions have not been analyzed
and the Recovery Ratings have not been updated as part of this
review.

Of the 513 transactions affected by these downgrades, 210 are
Prime, 118 are Alt-A and 153 are Subprime.  The remaining
transaction types are other sectors.  The majority of the bonds
(63%) have a Recovery Rating of 'RR5' or 'RR6' indicating that
minimal recovery is expected.  Some 34% of the bonds have Recovery
Ratings of either 'RR2' or 'RR3', which indicates anywhere from
50%-90% of the outstanding balance is expected to be recovered.

The downgrades are part of Fitch's ongoing surveillance process.
Fitch will continue to monitor these transactions for additional
defaults.

A spreadsheet detailing Fitch's rating actions can be found at
'www.fitchratings.com' by performing a title search for 'Fitch
Downgrades 856 bonds to 'Dsf' in 513 U.S. RMBS Transactions'.
These actions were reviewed by a committee of Fitch analysts.  The
spreadsheet provides the contact information for the performance
analyst.

The spreadsheet also details Fitch's assignment of Recovery
Ratings (RRs) to the transactions.  The Recovery Rating scale is
based upon the expected relative recovery characteristics of an
obligation.  For structured finance, Recovery Ratings are designed
to estimate recoveries on a forward-looking basis while taking
into account the time value of money.


WACHOVIA 2003-C3: Stable Performance Cues Fitch to Affirm Ratings
-----------------------------------------------------------------
Fitch Ratings has affirmed Wachovia Bank Commercial Mortgage
Trust, series 2003-C3 commercial mortgage pass-through
certificates.

The affirmations are due to stable performance and low Fitch
expected losses.  Fitch modeled losses of 1.80% of the remaining
pool.  As of the July 2011 distribution date, the pool's aggregate
balance has been reduced by 30.59% (including 4% in realized
losses) to $650.58 million from $937.26 million at issuance.
Currently, 21 loans (23.44%) are defeased.

Fitch has identified 15 Loans of Concern (14.94%) including three
assets in special servicing.

The largest contributor to loss (1.58% of pool balance) is a 464-
unit multifamily property in San Antonio, Texas.  The loan was
transferred to the special servicer because of deferred
maintenance and poor performance on the property.  The borrower is
currently coming out of pocket to keep the loan current because
the property experienced severe declines in occupancy due to
economic conditions.

The second largest contributor to loss (1.19% of pool balance) is
a 108,738 square foot office property located in San Diego, CA.
The property is current; however, the current occupancy of the
building is at 71.76% and there is significant roll-over risk with
20 tenants (62.23% of square footage) leases expiring before the
end of 2012.

Fitch has taken the following actions:

  -- $9.8 million class A-1 affirmed at 'AAAsf'; Outlook Stable;
  -- $477.8 million class A-2 affirmed at 'AAAsf'; Outlook Stable;
  -- $36.3 million class B affirmed at 'AAAsf'; Outlook Stable;
  -- $12.8 million class C affirmed at 'AAAsf'; Outlook Stable;
  -- $25.7 million class D affirmed at 'AAAsf'; Outlook to
     Positive from Negative.
  -- $12.8 million class E affirmed at 'AAsf'; Outlook to Positive
     from Negative;
  -- $10.5 million class F affirmed at 'Asf'; Outlook to Positive
     from Negative;
  -- $12.8 million class G affirmed at 'BBBsf'; Outlook to Stable
     from Negative;
  -- $12.8 million class H affirmed at 'BBsf'; Outlook to Stable
     from Negative;
  -- $22.2 million class J affirmed at 'CCCsf/RR1';
  -- $9.3 million class K affirmed at 'CCCsf/RR1';
  -- $7 million class L affirmed at 'Dsf'; to 'RR3' from 'RR1';

Classes M, N, and O remain 'Dsf' due to realized losses.  The
Recovery Ratings (RRs) of classes M and N have been revised as
shown:

  -- Class M to 'D/RR6' from 'D/RR3';
  -- Class N to 'D/RR6' from 'D/RR4';
  -- Class O remains at 'D/RR6'.

Fitch does not rate class P.  The class IO-I notes were previously
withdrawn and the class IO-II notes have paid in full.


WACHOVIA BANK: Moody's Affirms Ratings of 23 CMBS Classes
---------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 23
classes of Wachovia Bank Commercial Mortgage Securities Trust
Commercial Mortgage Pass-Through Certificates, Series 2006-C28:

Cl. A-2, Affirmed at Aaa (sf); previously on Jan 22, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-PB, Affirmed at Aaa (sf); previously on Jan 22, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jan 22, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Jan 22, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4FL, Affirmed at Aaa (sf); previously on Jan 22, 2007
Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Jan 22, 2007
Definitive Rating Assigned Aaa (sf)

Cl. IO, Affirmed at Aaa (sf); previously on Jan 22, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aa3 (sf); previously on Nov 11, 2010
Downgraded to Aa3 (sf)

Cl. A-J, Affirmed at Ba1 (sf); previously on Nov 11, 2010
Downgraded to Ba1 (sf)

Cl. B, Affirmed at Ba3 (sf); previously on Nov 11, 2010 Downgraded
to Ba3 (sf)

Cl. C, Affirmed at B3 (sf); previously on Nov 11, 2010 Downgraded
to B3 (sf)

Cl. D, Affirmed at Caa1 (sf); previously on Nov 11, 2010
Downgraded to Caa1 (sf)

Cl. E, Affirmed at Caa2 (sf); previously on Nov 11, 2010
Downgraded to Caa2 (sf)

Cl. F, Affirmed at Caa3 (sf); previously on Nov 11, 2010
Downgraded to Caa3 (sf)

Cl. G, Affirmed at Ca (sf); previously on Nov 11, 2010 Downgraded
to Ca (sf)

Cl. H, Affirmed at C (sf); previously on Nov 11, 2010 Downgraded
to C (sf)

Cl. J, Affirmed at C (sf); previously on Nov 11, 2010 Downgraded
to C (sf)

Cl. K, Affirmed at C (sf); previously on Nov 11, 2010 Downgraded
to C (sf)

Cl. L, Affirmed at C (sf); previously on Nov 19, 2009 Downgraded
to C (sf)

Cl. M, Affirmed at C (sf); previously on Nov 19, 2009 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Nov 19, 2009 Downgraded
to C (sf)

Cl. O, Affirmed at C (sf); previously on Nov 19, 2009 Downgraded
to C (sf)

Cl. P, Affirmed at C (sf); previously on Nov 19, 2009 Downgraded
to C (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
10.1% of the current balance. At last review, Moody's cumulative
base expected loss was 10.0%. Moody's stressed scenario loss is
24.6% 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.

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 performance in the commercial real
estate property markets. While commercial real estate property
markets are gaining momentum, a consistent upward trend will not
be evident until the volume of transactions increases, distressed
properties are cleared from the pipeline and job creation
rebounds. The hotel and multifamily sectors are continuing to show
signs of recovery through the first half of 2011, while recovery
in the non-core office and retail sectors are tied to pace of
recovery of the broader economy. Core office markets are showing
signs of recovery through lending and leasing activity. 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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.6 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) 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 (sf) 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 (sf) and B2 (sf),
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 40, compared to 41 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 November 11, 2010.

DEAL PERFORMANCE

As of the August 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 3.5% to
$3.47 billion from $3.59 billion at securitization. The
Certificates are collateralized by 202 mortgage loans ranging in
size from less than 1% to 7% of the pool, with the top ten loans
representing 36% of the pool. The pool does not contain any
defeased loans or loans with credit estimates.

Fifty-five loans, representing 19% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (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.

Three loans have been liquidated from the pool since
securitization, resulting in an aggregate $16.5 million loss (64%
loss severity on average). Currently, there are 32 loans,
representing 20% of the pool, in special servicing. The largest
specially serviced loan is the Montclair Plaza Loan ($190.0
million -- 5.5% of the pool), which is secured by a 875,085 square
foot regional mall located in Montclair, California. The mall is
anchored by Macy's, Sears and JC Penney. The loan was transferred
to special servicing in January 2010 for monetary default and is
now real estate owned (REO).

The remaining 31 specially serviced loans are secured by a mix of
property types. The master servicer has recognized an aggregate
$178.7 million appraisal reduction for 26 of the specially
serviced loans. Moody's has estimated an aggregate $223.4 million
loss (33% expected loss on average) for the specially serviced
loans.

Moody's has assumed a high default probability for 15 poorly
performing loans, representing 6% of the pool, and estimated an
aggregate $29.1 million loss (15% expected loss based on a 50%
probability of default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 93% and 47% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 119%, the same as at last review. Moody's net cash
flow reflects a weighted average haircut of 10% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.5%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.21X and 0.89X, respectively, compared to
1.22X and 0.87X 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 conduit loans represent 17% of the outstanding pool
balance. The largest loan is the Gas Company Tower loan ($229.0
million - 6.6% of the pool), which represents a pari passu
interest in a $458.0 million first mortgage loan. The loan is
secured by a 1.3 million square foot Class A office building
located in downtown Los Angeles, California. The largest tenant is
the Southern California Gas Company, which leases 43% of the
premises through November 2011. As reported by the servicer, the
lease has been renewed for a term of 15 years with four options of
five-year extension terms each. As of December 2010, the property
was 95% leased compared 99% at last review. The sponsor is Maguire
Properties LP. Moody's LTV and stressed DSCR are 133% and 0.71X,
respectively, the same as at last review.

The second largest loan is the 1180 Peachtree St. Loan ($193.9
million -- 5.6% of the pool), which is secured by a 669,711 square
foot office building located in Atlanta, Georgia. The largest
tenant is King & Spalding, which leases 64% of the premises
through March 2021. As of December 2010, the property was 91%
leased compared to 90% at last review. Moody's LTV and stressed
DSCR are 125% and 0.8X, respectively, the same as at last review.

The third largest loan is 311 South Wacker Drive Loan ($158.6
million -- 4.6% of the pool), which is secured by a 1.4 million
square foot office tower located in downtown Chicago. The largest
tenant is Freeborn & Peters LLP, which leases 10% of the premises
through November 2022. As of May 2011, the property was 90% leased
compared to 92% at last review. Moody's LTV and stressed DSCR are
104% and 0.94X, respectively compared to 109% and 0.89X at last
review.


WACHOVIA BANK: Moody's Affirms Ratings of 27 CMBS Classes of Notes
------------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 27
classes of Wachovia Bank Commercial Mortgage Trust, Commercial
Mortgage Pass-Through Certificates, Series 2007-C31:

Cl. A-2, Affirmed at Aaa (sf); previously on May 29, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on May 29, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-PB, Affirmed at Aaa (sf); previously on May 29, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aa2 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. A-5, Affirmed at Aa2 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. A-5FL, Affirmed at Aa2 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. A-1A, Affirmed at Aa2 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. A-M, Affirmed at Baa2 (sf); previously on Dec 2, 2010
Downgraded to Baa2 (sf)

Cl. A-J, Affirmed at B2 (sf); previously on Dec 2, 2010 Downgraded
to B2 (sf)

Cl. B, Affirmed at Caa1 (sf); previously on Dec 2, 2010 Downgraded
to Caa1 (sf)

Cl. C, Affirmed at Caa3 (sf); previously on Dec 2, 2010 Downgraded
to Caa3 (sf)

Cl. D, Affirmed at Ca (sf); previously on Dec 2, 2010 Downgraded
to Ca (sf)

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

Cl. F, Affirmed at C (sf); previously on Dec 2, 2010 Downgraded to
C (sf)

Cl. G, Affirmed at C (sf); previously on Dec 2, 2010 Downgraded to
C (sf)

Cl. H, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. J, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. K, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. L, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. M, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. N, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. O, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. P, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. Q, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. S, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. T, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. IO, Affirmed at Aaa (sf); previously on May 29, 2007
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
12.1% of the current total pool balance compared to 12.2% at last
review. Moody's stressed scenario loss is 27.4% of the current
total pool balance, down from 32.3% at last review. 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.

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 performance in the commercial real
estate property markets. While commercial real estate property
markets are gaining momentum, a consistent upward trend will not
be evident until the volume of transactions increases, distressed
properties are cleared from the pipeline and job creation
rebounds. The hotel and multifamily sectors are continuing to show
signs of recovery through the first half of 2011, while recovery
in the non-core office and retail sectors are tied to pace of
recovery of the broader economy. Core office markets are showing
signs of recovery through lending and leasing activity. 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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.60 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) 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 (sf) level are driven by a pay down 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 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (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 December 2, 2010.

DEAL PERFORMANCE

As of the August 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 5% to $5.5 billion
from $5.8 billion at securitization. The Certificates are
collateralized by 182 mortgage loans ranging in size from less
than 1% to 10% of the total pool, with the top ten loans
representing 45% of the total pool. The total pool includes one
loan with an investment grade credit estimate, representing 3% of
the total pool.

Forty-seven loans, representing 36% of the total 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.

Nine loans have paid off or have been liquidated from the total
pool since securitization, resulting in an aggregate $25.5 million
loss (5% loss severity on average). There was $1.7 million in
realized losses from a single loan at last review. Twenty-two
loans, representing 24% of the total pool, are currently in
special servicing. The largest specially serviced loan is the 666
Fifth Avenue Loan ($395 million -- 7.1% of the total pool), which
represents a pari-passu interest in a $1.2 billion first mortgage
loan spread among three other CMBS deals. There is also a $200
million mezzanine loan secured by the borrower's interest. The
loan is secured by a 1.5 million square foot (SF) Class A office
building located in Manhattan. A June 2011 appraisal valued the
property at $820 million and the special servicer is in
negotiations with the borrower for a loan modification since loan
reserves have been depleted, occupancy has declined since
securitization and the loan is now 30 days past due.

The second largest loan in special servicing is the Beacon D.C. &
Seattle Pool Loan ($307.3 million -- 5.5% of the total pool) which
represents a pari-passu interest in a $1.2 billion first mortgage
loan spread across five other CMBS deals. There is also a $205
million mezzanine loan secured by the borrower's interest. The
loan is secured by 16 (originally 20 properties at securitization)
office properties located in Washington, Virginia and Washington,
D.C totalling 10.0 million SF. This loan was transferred to
special servicing in April 2010 due to imminent default. The loan
was recently modified and is current. The loan modification
includes a five-year extension, a coupon reduction along with an
unpaid interest accrual feature and a yield maintenance period
waiver to facilitate property sales. The Market Square and 1300
North 17th Street office buildings sold between March and May 2011
while Key Center and Liberty Place sold in June 2011. The
borrower, Beacon Capital Partners, is actively marketing other
properties for sale and the special servicer expects the loan to
be transferred back to the master servicer by May 2012.

The third largest specially serviced loan is the Peter Cooper
Village/Stuyvesant Town Loan ($247.7 million -- 4.5% of the total
pool) which represents a pari-passu interest in a $3.0 billion
first mortgage loan spread across four other CMBS deals. There is
also a $1.4 billion mezzanine loan secured by the borrower's
interest. The loan is secured by two adjacent multifamily
apartment complexes with 11,227 units located on the east side of
Manhattan. A September 2010 appraisal valued the property at $2.8
billion, leading the master servicer to recognize a $50.8 million
appraisal reduction in November 2010, increasing to $61.7 million
in July 2011.

The remaining 19 specially serviced loans are secured by a mix of
property types. The master servicer has recognized an aggregate
$154.5 million appraisal reduction for all of the remaining
specially serviced loans. Moody's has estimated an aggregate
$383.0 million loss (28% expected loss on average) for all of the
specially serviced loans.

Moody's has assumed a high default probability for 27 poorly
performing loans representing 19% of the total pool and has
estimated an aggregate $211.7 million loss (20% expected loss
based on a 50% probability of default) from these troubled loans.
Based on the most recent remittance statement, Classes P through U
have experienced cumulative interest shortfalls totaling $9.8
million. Interest shortfalls decreased from Class K to Class P in
July 2011 based on net sale proceeds from several recent REO and
foreclosed loan sales. Despite this recent decline, Moody's
anticipates that the pool will continue to experience interest
shortfalls because of the high exposure to specially serviced
loans. Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, ASERs and extraordinary
trust expenses.

Moody's was provided with full year 2010 operating results for 96%
of the pool's loans (excluding specially serviced loans) and
partial year 2011 operating results for 55% of the pool (excluding
specially serviced loans). Excluding specially serviced and
troubled loans, Moody's weighted average LTV for the conduit
component is 124% compared to 138% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 9.6%
to the most recently available net operating income (NOI). Moody's
value reflects a weighted average capitalization rate of 8.7%.

Moody's actual and stressed DSCRs for the performing conduit loans
are 1.28X and 0.81X, respectively, compared to 1.15X and 0.75X at
last review. Moody's actual DSCR is based on Moody's net cash flow
(NCF) and the loan's actual debt service. Moody's stressed DSCR is
based on Moody's NCF and a 9.25% stressed rate applied to the loan
balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a conduit loan Herf of 21 compared to 29 at Moody's prior
review.

The loan with an investment grade credit estimate is the Hyatt
Regency Grand Cypress Loan ($177.2 million -- 3.2% of the total
pool), which is secured by a 750-room resort hotel property
located in Orlando, Florida. The property is 100% leased to a
subsidiary of Hyatt Hotels Corporation (Hyatt; senior unsecured
rating Baa2, stable outlook) under a 30-year triple-net (NNN)
lease. Moody's credit estimate is Baa2, the same as at the prior
review.

The three largest conduit loans represent 18% of the total pool
balance. The largest loan is the Five Times Square Loan ($536.0
million -- 9.7% of the total pool), which represents a 50% pari-
passu interest in a $1.07 billion first mortgage loan. The A note
had $184.0 million in mezzanine debt and a $67.0 million B note
behind it at securitization. The loan is secured by a 550,000 SF
Class A office building located in Midtown Manhattan, New York.
The property has maintained 100% occupancy since securitization.
The office component represents 97% of the total building's net
rentable area (NRA) of which 89% is leased to Ernst and Young
through May 2022 and serves as their U.S. World Headquarters.
Performance has been stable. The loan is on the servicer's
watchlist due to low debt service coverage. The loan is interest
only for the full ten-year term. Moody's LTV and stressed DSCR are
159% and 0.58X, respectively, compared to 159% and 0.54X at last
review.

The second largest loan is the Mall at Rockingham Park Loan
($260.0 million -- 4.7% of the total pool), which is secured by a
382,012 SF anchored retail center located in Salem, New Hampshire.
The property was 96% leased as of June 2010; the same as at last
review. Anchor tenants include Sears, Macy's and J.C. Penney.
Financial performance has been consistent in 2009 and 2010 after
declining from higher NOI in 2008. The loan is interest only for
its entire ten-year term. Moody's LTV and stressed DSCR are 105%
and 0.8X, respectively, compared to 112% and 0.75X at last review.

The third largest loan is the Boston Marriott Long Wharf Loan
($176.0 million -- 3.2% of the total pool) which is secured by a
402-room full-service hotel located in downtown Boston,
Massachusetts. Occupancy and RevPAR for the trailing twelve months
ending June 30, 2011 were 83% and $200, respectively compared to
82% and $148 at last review. With limited delivery of new hotel
rooms and a rebounding economy, the hotel's financial performance
has improved and the loan is current. The loan has been and
continues to be cited on the servicer's watchlist due to low debt
service coverage. The loan is interest-only for the entire ten-
year term. Due to the poor performance Moody's has classified this
loan as a troubled loan. Moody's LTV and stressed DSCR are 156%
and 0.71X, respectively, compared to 174% and 0.64X at last
review.


WAMU MORTGAGE: Moody's Lowers Rating of $129.5-Mil. of FHA-VA RMBS
------------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 10
tranches issued by WaMu Mortgage Pass-Through Certificates Series
2004-RP1. The collateral consists primarily of first-lien, fixed
and adjustable rate, mortgage loans insured by the Federal Housing
Administration (FHA) an agency of the U.S. Department of Urban
Development (HUD) or guaranteed by the Veterans Administration
(VA).

Complete rating actions are:

Issuer: WaMu Mortgage Pass-Through Certificates Series 2004-RP1 Tr

Cl. I-F, Downgraded to Baa2 (sf); previously on Jul 27, 2011 A2
(sf) Placed Under Review for Possible Downgrade

Cl. I-HJ, Downgraded to Baa2 (sf); previously on Jul 27, 2011 A2
(sf) Placed Under Review for Possible Downgrade

Cl. I-S, Downgraded to Baa2 (sf); previously on Jul 27, 2011 A2
(sf) Placed Under Review for Possible Downgrade

Cl. I-B-1, Downgraded to Ba3 (sf); previously on Jul 27, 2011 Baa3
(sf) Placed Under Review for Possible Downgrade

Cl. I-B-2, Downgraded to Caa2 (sf); previously on Jul 24, 2009
Downgraded to B1 (sf)

Cl. II-A, Downgraded to Baa2 (sf); previously on Jul 27, 2011 Aa2
(sf) Placed Under Review for Possible Downgrade

Cl. II-B-1, Downgraded to Ba2 (sf); previously on Jul 27, 2011 A2
(sf) Placed Under Review for Possible Downgrade

Cl. II-B-2, Downgraded to B1 (sf); previously on Jul 27, 2011 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. II-B-3, Downgraded to Caa3 (sf); previously on Jul 27, 2011
Ba2 (sf) Placed Under Review for Possible Downgrade

Cl. II-B-4, Downgraded to C (sf); previously on Jul 27, 2011 B2
(sf) Placed Under Review for Possible Downgrade

RATINGS RATIONALE

The actions are a result of Moody's updated loss projection for
the RMBS FHA-VA portfolio. The updated projection accounts for
higher potential pool losses due to self-curtailment of claims by
servicers whereby they pass expenses as deemed reasonable to the
trusts instead of submitting them to HUD, and continued weaknesses
in the macro economy and the housing market.

A FHA guarantee covers 100% of a loan's outstanding principal and
a large portion of its outstanding interest and foreclosure-
related expenses in the event that the loan defaults. A VA
guarantee covers only a portion of the principal based on the
lesser of either the sum of the current loan amount, accrued and
unpaid interest, and foreclosure expenses, or the original loan
amount. HUD usually pays claims on defaulted FHA loans when
servicers submit the claims, but can impose significant penalties
on servicers if it finds irregularities in the claim process later
during the servicer audits. This can prompt servicers to push more
expenses to the trust that they deem reasonably incurred than
submit them to HUD and face significant penalty. The rating
actions consider the portion of a defaulted loan normally not
covered by the FHA or VA guarantee and other servicer expenses
they deemed reasonably incurred and passed on to the trust.

FHA/VA borrowers, in Moody's-rated transactions, are typically low
income borrowers with poor credit history who have been affected
by the weak economy and housing market. Moody's expects
delinquencies to remain high for this sector at 40%, 35%, and 30%
for the 2004, 2005, and 2006 vintages, respectively as house
prices continue to decline and unemployment rates remain high.
FHA/VA RMBS transactions have had very low losses to date (less
than 1%) despite high delinquency levels due to the FHA and VA
guarantees. However, Moody's expects this trend to change due to
the higher level of self-curtailments by the servicers.

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, 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. Moody's now
projects house price index to reach a bottom in the first quarter
of 2012, with a 2% remaining decline between the first quarter of
2011 and 2012, and unemployment rate to start declining by fourth
quarter of 2011.

The principal methodology used in these ratings is described in
the Monitoring and Performance Review section in "Moody's Approach
to Rating US Residential Mortgage-Backed Securities" published in
December 2008. Other methodology used in this rating was "FHA VA
US RMBS Surveillance Methodology" published in July 2011.


WASHINGTON MUTUAL: Modeled Losses Cue Fitch to Downgrade Ratings
----------------------------------------------------------------
Fitch Ratings downgrades three and upgrades five classes of
Washington Mutual Asset Securities Corporation (WAMU) commercial
mortgage pass-through certificates, series 2005-C1.

The downgrades are the result an increase in Fitch modeled losses
attributed primarily to delinquent loans. Fitch modeled losses of
4.6% of the remaining pool.  The upgrades of the senior classes
are the result of increased credit enhancement due to paydown
which is sufficient to offset Fitch expected losses.

As of the July 2011 distribution date, the pool's collateral
balance has paid down 87% to $87.1 million from $649.5 million at
issuance.  Two loans (11.3%) are currently in special servicing.
Fitch has identified 12 loans (32%) as Fitch loans of concern
including the two (11.3%) specially serviced loans.

The largest contributor to Fitch modeled loss (9.2%) is secured by
a single tenant office building located in Seattle, WA.  The
property vacated at their lease expiration in July 2011 and the
property is not 100% vacant.  The loan is scheduled to mature in
November 2011 and Fitch expects the borrower may be unable to
refinance without a replacement tenant.

The largest specially serviced loan (6.3%) is secured by a 60,448
square foot (sf) office building located in Bothell, WA.  The loan
transferred to special servicing in February 2011 due to a
maturity default.  The borrower is expected to refinance the loan
once the lease renewal with the tenant, McGraw Hill is executed.
McGraw Hill's current lease expires on Dec. 31, 2011.  The
borrower continues to make the monthly debt service payments.

Fitch downgrades and revises these Recovery Ratings (RR) Outlooks:

  -- $2.4 million class K to 'Bsf' from 'BB-sf'; Outlook Negative;
  -- $2.4 million class L to 'CCsf/RR2' from 'B+sf';
  -- $812,000 class M to 'Csf/RR6' from 'CCCsf/RR2'.

Fitch also upgrades and revises rating outlooks on these classes:

  -- $4.1 million class D to 'AAAsf' from 'AAsf'; Outlook Stable;
  -- $5.7 million class E to 'AAAsf' from 'A+sf'; Outlook Stable;
  -- $4.9 million class F to 'AAsf' from 'Asf'; Outlook Stable;
  -- $5.7 million class G to 'Asf' from 'BBB+sf'; Outlook to
     Stable from Negative;
  -- $8.1 million class H to 'BBBsf' from 'BB+sf'; Outlook to
     Stable from Negative.

In addition, Fitch affirms these classes as indicated:

  -- $26.3 million class A-J at 'AAAsf'; Outlook Stable;
  -- $8.9 million class B at 'AAAsf'; Outlook Stable;
  -- $13 million class C at 'AAAsf'; Outlook Stable;
  -- $3.3 million class J at 'BBsf'; Outlook Negative.

The $1.5 million class N remains at 'D' recovery rating revised to
'RR6' from 'RR2'.

Classes A-1 and A-2 are paid in full.

Fitch withdraws the rating of the interest-only class X.  For
additional information on the withdrawal of the rating on the
interest-only classes, see 'Fitch Revises Practice for Rating IO &
Pre-Payment Related Structured Finance Securities', dated June 23,
2010.


WB 2005-WHALE: Fitch Affirms Junk Rating on $10.8MM Class L Cert.
-----------------------------------------------------------------
Fitch Ratings has affirmed Wachovia Bank Commercial Mortgage
Trust commercial mortgage pass-through certificates, series 2005-
WHALE 5.  Fitch expects minimal, if any, losses to the rated
certificates based on the stable performance of the underlying
assets.  Fitch analyzed servicer-reported operating statements,
rent rolls, sales reports in addition to other information
received from the servicer.

The remaining loan in the transaction is the $28.7 million
Lightstone Portfolio 2, which is collateralized by two regional
malls.  In addition, there is a $9.1 million B-note held outside
of the trust.  The loan is collateralized by two regional malls:
Shawnee Mall in Shawnee OK, and Brazos Mall in Jackson, TX.  The
Shawnee Mall is anchored by Sears which is part of the collateral,
and Dillard's and JC Penney's, both of which are not part of the
collateral. T he Brazos Mall is anchored by JC Penney's and Sears
which are part of the collateral and Dillard's, which is not part
of the collateral.

The loan transferred to special servicing in December 2009 due to
imminent default; the loan's final maturity was in January 2010,
and the initial borrower indicated that they would not be able to
payoff the loan.  The loan is now classified as real-estate owned
(REO).  The special servicer continues to sweep all excess cash
flow.  The most recently reported appraisal value indicated a
value above the trust debt amount.  The recent remittance reports
indicated the junior participant holder is pursuing takeout
financing and to ultimately take possession of the collateral.

Overall and inline occupancy at the two retail malls has improved
since issuance.  At issuance, total mall and inline occupancy for
the Shawnee and Brazos Malls were 57% and 32.6%; and 73.5% and
22.8%, respectively.  As of the July 2011 rent roll, the Shawnee
and Brazos Mall total collateral and inline occupancy were 80% and
93%, and 80% and 68%, respectively.

Fitch has affirmed and revised Rating Outlooks on these
certificates:

  -- $6.6 million class J at 'AAAsf'; Outlook Stable;
  -- $11.4 million class K at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $10.8 million class L at 'CCCsf/RR1'.

Fitch previously withdrew the ratings of the interest-only classes
X-1B and X-2.

Classes A-1 through H, interest-only classes X-1A, X-3, X-4 and
various classes related to individual loans have paid in full.
Fitch does not rate the PIF class AG.


WESTWOOD CDO: Moody's Upgrades Ratings of 6 Classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Westwood CDO I, Ltd.

US$342,000,000 Class A-1 Senior Secured Floating Rate Notes due
2021 Notes, Upgraded to Aa1 (sf); previously on Jun 22, 2011 Aa3
(sf) Placed Under Review for Possible Upgrade

US$22,500,000 Class A-2 Senior Secured Floating Rate Notes due
2021 Notes, Upgraded to Aa3 (sf); previously on Jun 22, 2011 A2
(sf) Placed Under Review for Possible Upgrade

US$30,000,000 Class B Senior Secured Deferrable Floating Rate
Notes due 2021 Notes, Upgraded to Baa1 (sf); previously on Jun 22,
2011 Ba1 (sf) Placed Under Review for Possible Upgrade

US$16,600,000 Class C-1 Senior Secured Deferrable Floating Rate
Notes due 2021 Notes, Upgraded to Ba1 (sf); previously on Jun 22,
2011 B1 (sf) Placed Under Review for Possible Upgrade

US$4,400,000 Class C-2 Senior Secured Deferrable Fixed Rate Notes
due 2021 Notes, Upgraded to Ba1 (sf); previously on Jun 22, 2011
B1 (sf) Placed Under Review for Possible Upgrade

US$13,500,000 Class D Secured Deferrable Floating Rate Notes due
2021 Notes, Upgraded to Ba2 (sf); previously on Jun 22, 2011 Caa2
(sf) Placed Under Review for Possible Upgrade

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, 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 $433.9 million,
defaulted par of $5.1million, a weighted average default
probability of 23.08% (implying a WARF of 2882, a weighted average
recovery rate upon default of 53.9%, and a diversity score of 63.
The 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.

Westwood CDO I, Ltd., issued in January 2007, 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
June 2011.

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 June 2011.

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 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties. Moody's analyzed
   defaulted recoveries assuming the lower of the market price and
   the recovery rate in order to account for potential volatility
   in market prices.

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted 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/coupon/diversity levels higher than
   the covenant levels due to the large difference between the
   reported and covenant levels.


WFDB COMMERCIAL: Fitch Puts Low-B Rating on Four Note Classes
-------------------------------------------------------------
Fitch rates the Wells Fargo Commercial Securities, Inc., WFDB
2011-BXR Certificates as follows:

  -- $695,000,000 class A 'AAAsf'; Outlook Stable;
  -- $61,350,000 class B 'AAsf'; Outlook Stable;
  -- $76,490,000 class C 'Asf'; Outlook Stable;
  -- $45,890,000 class D 'BBBsf'; Outlook Stable;
  -- $30,590,000 class E 'BBB-sf'; Outlook Stable;
  -- $90,680,000 class F 'BBsf'; Outlook Stable;
  -- $695,000,000* class X-A 'AAAsf'; Outlook Stable;
  -- $305,000,000* class X-B 'BBsf'; Outlook Stable;
  -- $1,000,000,000* class X-C 'BBsf'; Outlook Stable.

*Notional amount and interest only.

The certificates represent the beneficial ownership in the trust,
primary assets of which are secured by the mortgage interest in
107 retail properties located in 27 states across the U.S.  The
notes are secured by a $1 billion mortgage loan with $400 million
of mezzanine loans held outside the trust.  The financing is
associated with the purchase of the entire Centro Properties Group
(Centro) U.S. retail portfolio by Blackstone Real Estate Advisors.


WFRBS COMMERCIAL: Fitch Puts Low-B Rating on Two Class Certs.
-------------------------------------------------------------
Fitch Ratings has assigned these ratings to Wells Fargo Bank, N.A.
WFRBS Commercial Mortgage Trust 2011-C4 commercial mortgage pass-
through certificates:

  -- $93,159,000 class A-1 'AAAsf'; Outlook Stable;
  -- $201,377,000 class A-2 'AAAsf'; Outlook Stable;
  -- $164,861,000 class A-3 'AAAsf'; Outlook Stable;
  -- $90,000,000** class A-FL 'AAAsf'; Outlook Stable;
  -- $0 class A-FX 'AAAsf'; Outlook Stable;
  -- $681,432,000 class A-4 'AAAsf'; Outlook Stable;
  -- $1,230,829,000* class X-A 'AAAsf'; Outlook Stable;
  -- $42,570,000 class B 'AAsf'; Outlook Stable;
  -- $42,570,000 class C 'A+sf'; Outlook Stable;
  -- $33,316,000 class D 'A-sf'; Outlook Stable;
  -- $51,824,000 class E 'BBB-sf'; Outlook Stable;
  -- $20,360,000 class F 'BBsf'; Outlook Stable;
  -- $18,508,000 class G 'Bsf'; Outlook Stable.

  * Notional amount and interest only
** Floating Rate

Fitch does not rate the $249,868,059 interest-only class X-B, or
the $40,720,059 class H.

Wells Fargo Bank, N.A., will be the swap counterparty for the
floating rate class A-FL.  In the event that any swap breakage
costs are due to the swap counterparty from the trust, any
breakage costs will only be paid after all payments on the class
A-FL certificates have been paid in full.  The aggregate balance
of the class A-FL may be adjusted as a result of the exchange of
all or a portion of the class A-FL certificates for the non-
offered class-AFX.

A detailed description of Fitch's rating analysis including key
rating drivers, stresses, rating sensitivity, analysis, model,
criteria application and data adequacy is available in Fitch's New
Issue Report.


* S&P Lowers Ratings on 117 Classes from 26 RMBS Transactions
-------------------------------------------------------------
Standard & Poor's Ratings Services assigned ratings to 21 classes
from 10 U.S. residential mortgage-backed securities (RMBS)
transactions previously not rated. "In addition, we lowered
our ratings on 117 classes from 26 transactions and removed nine
of them from CreditWatch with negative implications. We also
affirmed our ratings on 309 classes from 23 of the transactions
with lowered ratings and seven additional transactions and removed
two of them from CreditWatch negative. Lastly, we withdrew our
ratings on seven interest-only (IO) classes, one of which was on
CreditWatch negative," S&P related.

Various collateral types back the 33 transactions in this review,
which were issued in 1999-2008.

"The newly assigned ratings reflect the fact that, prior to
issuance, we conducted credit analysis to assess the
creditworthiness of certain components of these classes without
assigning public ratings at the class level. The newly assigned
ratings reflect our view of this creditworthiness and apply to
each individual class in addition to their components," S&P
related.

"The downgrades reflect our view that the credit enhancement
projected to be available to the affected classes to maintain the
previous ratings is insufficient, given current projected losses,"
S&P stated.

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

"The withdrawals reflect the application of our interest-only
criteria whereby the rating of securities that reference either
the entire asset pool or one or more rated classes of a
securitization, will be withdrawn when all principal and interest
paying classes rated 'AA-' or higher have been retired or
downgraded below that rating level," S&P said.

Standard & Poor's has established loss projections for all the
closed-end second-lien transactions rated in 2005, 2006, and 2007.
"We derived these losses using our criteria outlined in 'How
Standard & Poor's Is Revising Its Loss Curves For U.S. Closed-End
Second-Lien RMBS,' published Dec. 20, 2007, and 'S&P Applies
Cumulative Loss Curve To U.S. HELOC RMBS Deals Issued In
2004-2007,' published May 22, 2008," S&P said. S&P changed its
lifetime projected losses for this transaction:

                                     Orig. bal.       Lifetime
Transaction                           (mil. $)       exp. loss (%)
Terwin Mortgage Trust 2005-3SL          400            13.45

"To assess the creditworthiness of each class, we reviewed the
transaction's ability to withstand additional credit deterioration
and the effect that projected losses will likely have on each
class. We reviewed these deals with updated loss projections and
updated structure level loss severities where applicable, using
observed liquidation data from the last 12 months (see
'Transaction-Specific Lifetime Loss Projections For Prime,
Subprime, And Alternative-A U.S. RMBS Issued In 2005-2007', on
June 27, 2011). In order to maintain a 'B' rating on a class for
prime transactions, 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 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 an
'AAA' rating). For example, we would assess whether one class
could withstand approximately 130% of our additional base-case
loss assumptions to maintain a 'BB' rating. However, to maintain a
'BBB' rating, we would assess whether a different class could
withstand approximately 155% of our additional base-case loss
assumptions," according to S&P.

"In order to maintain a 'B' rating on a class for Alt-A, closed-
end second-lien, and subprime transactions, we assessed whether,
in our view, a class could absorb the remaining base-case loss
assumptions we used in our analysis. In order to maintain a rating
higher than 'B', we assessed whether the class could withstand
losses exceeding our remaining base-case loss assumptions at a
percentage specific to each rating category (up to 150% for an
'AAA' rating). For example, in general, we would assess whether
one class could withstand approximately 110% of our remaining
base-case loss assumptions to maintain a 'BB' rating. However, to
maintain a 'BBB' rating, we would assess whether a different class
could withstand approximately 120% of our remaining base-case loss
assumptions. Each class with an affirmed 'AAA' rating can, in our
view, withstand approximately 150% of our remaining base-case loss
assumptions under our analysis," S&P stated.

Subordination provides credit support for the affected
transactions. Various types of mortgage loans secured by first
liens on one- to four-family residential properties serve as
collateral for these deals.

Rating Actions

Banc of America Alternative Loan Trust 2004-4
Series 2004-4
                               Rating
Class      CUSIP       To                   From
3-A-1      05948KPN3   AA+ (sf)             AAA (sf)
4-A-2      05948KPR4   AA+ (sf)             AAA (sf)
4-A-3      05948KPS2   AA+ (sf)             AAA (sf)
4-A-4      05948KPT0   AA+ (sf)             AAA (sf)
4-A-5      05948KPU7   AA+ (sf)             AAA (sf)
30-B-1     05948KQB8   CCC (sf)             BB (sf)
30-B-2     05948KQC6   CC (sf)              CCC (sf)
30-B-3     05948KQD4   CC (sf)              CCC (sf)

Banc of America Alternative Loan Trust 2006-8
Series 2006-8
                               Rating
Class      CUSIP       To                   From
1-A-2      06050AAB9   CC (sf)              CCC (sf)

Banc of America Funding 2004-3 Trust
Series      2004-3
                               Rating
Class      CUSIP       To                   From
2-X-PO                 AA+ (sf)             AAA (sf)
X-PO       05946XHE6   AA+ (sf)             NR

Banc of America Mortgage Trust 2004-5
Series 2004-5
                               Rating
Class      CUSIP       To                   From
1-A-PO                 A+ (sf)              AA (sf)
3-A-PO                 A+ (sf)              AAA (sf)
15-IO      05948X7D7   AAA (sf)             NR
30-IO      05948X7E5   AAA (sf)             NR
A-PO       05948X7C9   A+ (sf)              NR

Banc of America Mortgage Trust 2004-6
Series 2004-6
                               Rating
Class      CUSIP       To                   From
1-A-1      05949AJM3   AA+ (sf)             AAA (sf)
1-A-2      05949AJN1   AA+ (sf)             AAA (sf)
1-A-3      05949AJP6   AA+ (sf)             AAA (sf)
1-A-6      05949AJS0   AA+ (sf)             AAA (sf)
1-A-8      05949AJU5   AA+ (sf)             AAA (sf)
1-A-9      05949AJV3   AA+ (sf)             AAA (sf)
1-A-10     05949AJW1   AA+ (sf)             AAA (sf)
1-A-11     05949AJX9   AA+ (sf)             AAA (sf)
1-A-12     05949AJY7   AA+ (sf)             AAA (sf)
1-A-PO                 AA+ (sf)             AAA (sf)
2-A-PO                 AA+ (sf)             AAA (sf)
1-B-1      05949AKK5   CCC (sf)             B (sf)
A-PO       05949AKH2   AA+ (sf)             NR
30-IO      05949AKJ8   AAA (sf)             NR

CHL Mortgage Pass-Through Trust 2004-HYB7
Series 2004-HYB7
                               Rating
Class      CUSIP       To                   From
M          12669GCG4   B- (sf)              B (sf)
B-1        12669GCH2   CC (sf)              CCC (sf)

CHL Mortgage Pass-Through Trust 2004-J9
Series 2004-J9
                               Rating
Class      CUSIP       To                   From
1-A-1      12669GFE6   BB (sf)              AA (sf)
2-A-1      12669GFF3   BB+ (sf)             AA+ (sf)
2-A-2      12669GFG1   BB+ (sf)             AA+ (sf)
2-A-3      12669GFH9   BB+ (sf)             AAA (sf)
2-A-4      12669GFJ5   BB (sf)              AAA (sf)
2-A-5      12669GFK2   BB (sf)              AAA (sf)
2-A-6      12669GFL0   BB (sf)              AA (sf)
3-A-1      12669GFM8   BB+ (sf)             AAA (sf)
4-A-1      12669GFN6   BBB+ (sf)            AA (sf)
X-A-1                  NR                   AA (sf)
X-A-2                  NR                   AAA (sf)
X-B-1                  NR                   AAA (sf)
X-B-2                  NR                   AA (sf)
PO-A       12669GFR7   BB (sf)              AA (sf)
PO-B       12669GFS5   BB (sf)              AAA (sf)

Deutsche Mortgage Securities Inc. Mortgage Loan Trust Series 2004-
4
Series 2004-4
                               Rating
Class      CUSIP       To                   From
I-A-5      251563EN8   AA (sf)              AAA (sf)
VII-AR-1   251563FD9   A- (sf)              A (sf)
II-MR-1    251563EW8   BB- (sf)             BBB- (sf)
I-M-1      251563ER9   CCC (sf)             BB+ (sf)
M          251563FK3   CC (sf)              CCC (sf)
I-M-2      251563ES7   CC (sf)              CCC (sf)
II-MR-2    251563EX6   CC (sf)              CCC (sf)

Harborview Mortgage Loan Trust 2004-4
Series 2004-4
                               Rating
Class      CUSIP       To                   From
B-2        41161PEA7   CC (sf)              CCC (sf)

Lehman Mortgage Trust 2005-2
Series 2005-2
                               Rating
Class      CUSIP       To                   From
1-A3       52520MBQ5   CC (sf)              CCC (sf)
1-A4       52520MBR3   CC (sf)              CCC (sf)
2-A1       52520MBS1   CCC (sf)             B (sf)
2-A4       52520MBV4   CCC (sf)             B (sf)
2-A5       52520MBW2   CCC (sf)             B (sf)
2-A6       52520MBX0   CC (sf)              CCC (sf)
3-A1       52520MBY8   CC (sf)              CCC (sf)
3-A3       52520MCA9   CC (sf)              CCC (sf)
4-A2       52520MCG6   CC (sf)              CCC (sf)
5-A1       52520MCH4   CC (sf)              CCC (sf)
5-A2       52520MCJ0   CC (sf)              CCC (sf)
5-A3       52520MCK7   CC (sf)              CCC (sf)
5-A4       52520MCL5   CC (sf)              CCC (sf)
5-A5       52520MCM3   CC (sf)              CCC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-3
Series 2007-3
                               Rating
Class      CUSIP       To                   From
2-A1       86363GAD6   CC (sf)              CCC (sf)
3-A1       86363GAF1   CC (sf)              CCC (sf)
4-A1       86363GAJ3   CC (sf)              CCC (sf)
4-A2       86363GAK0   CC (sf)              CCC (sf)
4-A3       86363GAL8   CC (sf)              CCC (sf)
4-A4       86363GAM6   CC (sf)              CCC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-8
Series 2007-8
                               Rating
Class      CUSIP       To                   From
2-A1       86362NAE0   CCC (sf)             B- (sf)/Watch Neg
2-A2       86362NAF7   CC (sf)              CCC (sf)
2-A3       86362NAG5   CC (sf)              CCC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-1
Series 2007-1
                               Rating
Class      CUSIP       To                   From
2-A1       86362TAD9   CC (sf)              CCC (sf)
2-A2       86362TAE7   CC (sf)              CCC (sf)
2-A3       86362TAF4   CC (sf)              CCC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-11
Series 2007-11
                               Rating
Class      CUSIP       To                   From
1-A2       86364YAB0   CC (sf)              CCC (sf)
2-A1       86364YAE4   CC (sf)              CCC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-5
Series 2007-5
                               Rating
Class      CUSIP       To                   From
1-A2       86363XAB3   CC (sf)              CCC (sf)
2-A1       86363XAD9   CC (sf)              CCC (sf)
2-A2       86363XAE7   CC (sf)              CCC (sf)
2-A3       86363XAF4   CC (sf)              CCC (sf)
3-A1       86363XAJ6   CC (sf)              CCC (sf)

Structured Asset Securities Corp.
Series 2001-19
                               Rating
Class      CUSIP       To                   From
B1         86358RTF4   B (sf)               NR
B2         86358RTG2   B (sf)               NR
B3         86358RTH0   B (sf)               NR
B4         86358RSN8   B (sf)               NR
B5         86358RSP3   CC (sf)              NR

Structured Asset Securities Corp.
Series 2002-AL1
                               Rating
Class      CUSIP       To                   From
B3         86358RYE1   BBB- (sf)            BBB (sf)
APO        86358RYB7   AAA (sf)             NR
A1         86358RXX0   AAA (sf)             NR
A2         86358RXY8   AAA (sf)             NR
A3         86358RXZ5   AAA (sf)             NR
AIO        86358RYA9   AAA (sf)             NR

Structured Asset Securities Corp.
Series 2003-8
                               Rating
Class      CUSIP       To                   From
1-A6       86359ASA2   NR                   AAA (sf)
B3 (1)                 B (sf)               BBB (sf)
B3 (2)                 B (sf)               BBB (sf)
B3         86359ASZ7   B (sf)               NR

Structured Asset Securities Corp.
Series 2003-14
                               Rating
Class      CUSIP       To                   From
B1         86359AUJ0   BB (sf)              AA (sf)
B2         86359AUK7   B (sf)               A (sf)
B3         86359AUN1   CCC (sf)             BB (sf)
B3(3)      86359AUY7   CCC (sf)             BBB (sf)
3B4        86359AVJ9   B+ (sf)              BB (sf)
3B5        86359AVK6   CC (sf)              B (sf)

Structured Asset Securities Corp.
Series 2003-21
                               Rating
Class      CUSIP       To                   From
2-A6       86359AN82   NR                   AAA (sf)
1B2        86359AP49   BBB (sf)             BBB+ (sf)
2B1        86359AP56   CCC (sf)             AA (sf)
2B2        86359AP64   CCC (sf)             A (sf)
B3(2)                  CCC (sf)             B (sf)
2B4        86359AL92   CC (sf)              CCC (sf)
B3         86359AP72   CCC (sf)             NR

Structured Asset Securities Corp.
Series 2004-11XS
                               Rating
Class      CUSIP       To                   From
1-A4A      86359BUD1   A (sf)               AAA (sf)
1-A4B      86359BVC2   A (sf)               AAA (sf)
1-A5A      86359BUE9   A (sf)               AAA (sf)
1-A5B      86359BUF6   A (sf)               AAA (sf)
1-A6       86359BUG4   A (sf)               AAA (sf)
M3(2)      86359B9O1   D (sf)               CC (sf)
M3         86359BUM1   D (sf)               NR

Structured Asset Securities Corporation Assistance Loan Trust
2003-AL1
Series 2003-AL1
                               Rating
Class      CUSIP       To                   From
B2         86359AMJ9   BBB (sf)             BBB+ (sf)
B3         86359AMK6   CCC (sf)             B (sf)

Structured Asset Securities Corporation Assistance Loan Trust
2003-AL2
Series 2003-AL2
                               Rating
Class      CUSIP       To                   From
A          86359AWR0   AA+ (sf)             AAA (sf)
APO        86359AWT6   AA+ (sf)             AAA (sf)
AIO        86359AWS8   AA+ (sf)             AAA (sf)
B1         86359AWU3   BB+ (sf)             BBB+ (sf)
B2         86359AWV1   CCC (sf)             B (sf)

Terwin Mortgage Trust 2005-3SL
Series 2005-3SL
                               Rating
Class      CUSIP       To                   From
M-1        881561SU9   AA (sf)              AA (sf)/Watch Neg
M-2        881561SV7   A (sf)               A (sf)/Watch Neg

WaMu Mortgage Pass-Through Certificates Series 2007-HY5 Trust
Series 2007-HY5
                               Rating
Class      CUSIP       To                   From
2-AB 1     92990G9A3   D (sf)               CC (sf)
2AB        92990GAH6   D (sf)               NR

Wells Fargo Mortgage Backed Securities 2002-22 Trust
Series 2002-22
                               Rating
Class      CUSIP       To                   From
A-WIO      94979NBF5   AAA (sf)             NR

Wells Fargo Mortgage Backed Securities 2005-AR1 Trust
Series 2005-AR1
                               Rating
Class      CUSIP       To                   From
I-A-1      949781AA6   A- (sf)              AAA (sf)/Watch Neg
I-A-2      949781AB4   B+ (sf)              A (sf)/Watch Neg
I-A-IO                 NR                   AAA (sf)/Watch Neg
II-A-1     949781AC2   B (sf)               A- (sf)/Watch Neg
I-B-1      949781AG3   CC (sf)              B- (sf)/Watch Neg
II-B-1     949781AK4   CC (sf)              B- (sf)/Watch Neg
I-B-2      949781AH1   CC (sf)              CCC (sf)
II-B-2     949781AL2   CC (sf)              CCC (sf)

Wells Fargo Mortgage Backed Securities 2007-10 Trust
Series 2007-10
                               Rating
Class      CUSIP       To                   From
I-A-29     949837BE7   CCC (sf)             B (sf)/Watch Neg
I-A-32     949837BH0   CCC (sf)             B (sf)/Watch Neg
I-A-34     949837BK3   CCC (sf)             B (sf)/Watch Neg

Wells Fargo Mortgage Backed Securities 2008-1 Trust
Series 2008-1
                               Rating
Class      CUSIP       To                   From
IV-A-1     949819AP1   AA- (sf)             AA (sf)

NR-Not rated.

Ratings Affirmed

Banc of America Alternative Loan Trust 2004-4
Series 2004-4
Class      CUSIP       Rating
1-A-1      05948KPH6   AAA (sf)
2-A-1      05948KPM5   AAA (sf)
CB-IO      05948KPP8   AAA (sf)
4-A-1      05948KPQ6   AAA (sf)
4-IO       05948KPV5   AAA (sf)
30-B-IO    05948KQA0   AAA (sf)
30-B-4     05948KQV4   CC (sf)

Banc of America Funding 2004-3 Trust
Series 2004-3
Class      CUSIP       Rating
1-A-1      05946XGP2   AAA (sf)
1-A-2      05946XGQ0   AAA (sf)
1-A-3      05946XGR8   AAA (sf)
1-A-4      05946XGS6   AAA (sf)
1-A-5      05946XGT4   AAA (sf)
1-A-6      05946XGU1   AAA (sf)
1-A-7      05946XGV9   AAA (sf)
1-A-8      05946XGW7   AAA (sf)
1-A-9      05946XGX5   AAA (sf)
1-A-10     05946XGY3   AA+ (sf)
1-A-11     05946XGZ0   AA+ (sf)
1-X-PO                 AA+ (sf)
30-IO      05946XHD8   AAA (sf)
2-A-1      05946XHB2   AAA (sf)
2-A-2      05946XHC0   AAA (sf)
15-PO      05946XHF3   AAA (sf)
15-IO      05946XHG1   AAA (sf)
30-B-1     05946XHH9   B- (sf)
30-B-2     05946XHJ5   CC (sf)
15-B-2     05946XHM8   A (sf)
30-B-3     05946XHK2   CC (sf)
15-B-3     05946XHN6   BBB (sf)
30-B-4     05946XHP1   CC (sf)
15-B-4     05946XHS5   B- (sf)
15-B-5     05946XHT3   CC (sf)
15-B-1     05946XHL0   AA (sf)

Banc of America Mortgage 2003-B Trust
Series 2003-B
Class      CUSIP       Rating
1-A-1      06050HC63   BB (sf)
2-A-1      06050HD21   BB (sf)
2-A-2      06050HD39   BB (sf)
2-A-7      06050HD88   BB (sf)
2-A-8      06050HD96   BB (sf)
2-A-P      06050HE38   BB (sf)
B-1        06050HE46   B (sf)
B-2        06050HE53   CCC (sf)
B-3        06050HE61   CC (sf)
B-4        06050HE95   CC (sf)
B-5        06050HF29   CC (sf)

Banc of America Mortgage Trust 2004-4
Series 2004-4
Class      CUSIP       Rating
1-A-1      05949AEB2   AAA (sf)
1-A-2      05949AEC0   AAA (sf)
1-A-3      05949AED8   AAA (sf)
1-A-4      05949AEE6   AAA (sf)
1-A-5      05949AEF3   AAA (sf)
1-A-6      05949AEG1   AAA (sf)
1-A-7      05949AEH9   AAA (sf)
1-A-8      05949AEJ5   AAA (sf)
1-A-9      05949AEK2   AAA (sf)
1-A-10     05949AEL0   AAA (sf)
1-A-11     05949AEM8   AAA (sf)
1-A-12     05949AEN6   AAA (sf)
2-A-1      05949AEU0   AAA (sf)
2-A-2      05949AEV8   AAA (sf)
2-A-3      05949AEW6   AAA (sf)
2-A-5      05949AEY2   AAA (sf)
2-A-6      05949AEZ9   AAA (sf)
3-A-1      05949AFA3   AAA (sf)
3-A-2      05949AFB1   AAA (sf)
3-A-3      05949AFC9   AAA (sf)
3-A-4      05949AFD7   AAA (sf)
4-A-1      05949AFE5   AAA (sf)
4-A-2      05949AFF2   AAA (sf)
5-A-1      05949AFG0   AAA (sf)
15-IO      05949AFJ4   AAA (sf)
30-IO      05949AFK1   AAA (sf)
A-PO       05949AFH8   AAA (sf)
30-B-1     05949AFL9   A+ (sf)
X-B-1      05949AFP0   BB+ (sf)
15-B-1     05949AFS4   BBB+ (sf)
30-B-2     05949AFM7   B+ (sf)
X-B-2      05949AFQ8   B- (sf)
15-B-2     05949AFT2   B+ (sf)
30-B-3     05949AFN5   CCC (sf)
X-B-3      05949AFR6   CC (sf)
15-B-3     05949AFU9   CCC (sf)
30-B-4     05949AFW5   CC (sf)
X-B-4      05949AFZ8   CC (sf)
15-B-4     05949AGC8   CC (sf)
30-B-5     05949AFX3   CC (sf)
X-B-5      05949AGA2   CC (sf)
15-B-5     05949AGD6   CC (sf)

Banc of America Mortgage Trust 2004-5
Series 2004-5
Class      CUSIP       Rating
1-A-1      05948X6F3   AAA (sf)
1-A-2      05948X6G1   AA (sf)
1-A-3      05948X6H9   AA (sf)
1-A-4      05948X6J5   AA (sf)
1-A-6      05948X6L0   AA (sf)
1-A-7      05948X6M8   AA (sf)
1-A-8      05948X6N6   AA (sf)
1-A-9      05948X6P1   AA (sf)
1-30-IO                AAA (sf)
2-A-1      05948X6S5   AA+ (sf)
2-A-2      05948X6T3   AA+ (sf)
2-A-3      05948X6U0   AAA (sf)
2-A-4      05948X6V8   A+ (sf)
2-A-PO                 A+ (sf)
2-30-IO                AAA (sf)
3-A-1      05948X6W6   AAA (sf)
3-A-2      05948X6X4   AAA (sf)
3-A-3      05948X6Y2   AAA (sf)
3-A-4      05948X6Z9   AAA (sf)
3-A-5      05948X7A3   AAA (sf)
3-A-6      05948X7B1   AAA (sf)
3-15-IO                AAA (sf)
4-A-1      05948X7Q8   AAA (sf)
4-A-PO                 A+ (sf)
4-15-IO                AAA (sf)
30-B-1     05948X7F2   B (sf)
X-B-1      05948X7J4   CC (sf)
15-B-1     05948X7M7   BB+ (sf)
30-B-2     05948X7G0   CCC (sf)
X-B-2      05948X7K1   CC (sf)
15-B-2     05948X7N5   B- (sf)
30-B-3     05948X7H8   CC (sf)
X-B-3      05948X7L9   CC (sf)
15-B-3     05948X7P0   CCC (sf)
30-B-4     05949AGF1   CC (sf)
X-B-4      05949AGM6   CC (sf)
15-B-4     05949AGJ3   CC (sf)
30-B-5     05949AGG9   CC (sf)
15-B-5     05949AGK0   CC (sf)

Banc of America Mortgage Trust 2004-6
Series 2004-6
Class      CUSIP       Rating
1-A-4      05949AJQ4   AAA (sf)
1-A-5      05949AJR2   AAA (sf)
1-A-7      05949AJT8   AAA (sf)
1-30-IO                AAA (sf)
2-A-1      05949AKA7   AAA (sf)
2-A-2      05949AKB5   AAA (sf)
2-A-3      05949AKC3   AAA (sf)
2-A-4      05949AKD1   AAA (sf)
2-A-5      05949AKE9   AAA (sf)
2-A-6      05949AKF6   AAA (sf)
2-A-7      05949AKG4   AAA (sf)
2-30-IO                AAA (sf)
2-B-1      05949AKN9   B+ (sf)
1-B-2      05949AKL3   CC (sf)
2-B-2      05949AKP4   CCC (sf)
1-B-3      05949AKM1   CC (sf)
2-B-3      05949AKQ2   CC (sf)
1-B-4      05949AKR0   CC (sf)
2-B-4      05949AKU3   CC (sf)
2-B-5      05949AKV1   CC (sf)

CHL Mortgage Pass-Through Trust 2004-HYB7
Series 2004-HYB7
Class      CUSIP       Rating
1-A-1      12669GBY6   A- (sf)
1-A-2      12669GBZ3   A- (sf)
1-A-3      12669GDG3   BBB (sf)
2-A        12669GCA7   BBB (sf)
3-A        12669GCB5   BBB+ (sf)
4-A        12669GCD1   BBB (sf)
5-A        12669GCE9   BBB (sf)
B-2        12669GCJ8   CC (sf)

Deutsche Mortgage Securities Inc. Mortgage Loan Trust Series 2004-
4
Series 2004-4
Class      CUSIP       Rating
I-A-4      251563EM0   AAA (sf)
I-A-6      251563EP3   AAA (sf)
II-AR-1    251563EU2   AAA (sf)
II-AR-2    251563EV0   AAA (sf)
III-AR-1   251563EZ1   A- (sf)
IV-AR-1    251563FA5   A- (sf)
V-AR-1     251563FB3   A- (sf)
VI-AR-1    251563FC1   A (sf)
VII-AR-2   251563FE7   AA- (sf)
VII-AR-3   251563FP2   AA- (sf)
B-1        251563FL1   CC (sf)
II-MR-3    251563EY4   CC (sf)

Harborview Mortgage Loan Trust 2004-4
Series 2004-4
Class      CUSIP       Rating
1-A        41161PDV2   AAA (sf)
2-A        41161PDW0   AAA (sf)
3-A        41161PEM1   AAA (sf)
X-1        41161PDX8   AAA (sf)
X-2        41161PFN8   AAA (sf)
B-1        41161PDZ3   A- (sf)

Lehman Mortgage Trust 2005-2
Series 2005-2
Class      CUSIP       Rating
1-A1       52520MBN2   BBB (sf)
2-A3       52520MBU6   CCC (sf)
3-A4       52520MCB7   CCC (sf)
3-A5       52520MCC5   CCC (sf)
3-A6       52520MCD3   CC (sf)
3-A7       52520MCE1   CC (sf)
4-A1       52520MCF8   CCC (sf)

Lehman XS Trust Series 2007-12N
Series 2007-12N
Class      CUSIP       Rating
1-A3A      52524YAC7   CC (sf)
2-A1       52524YAF0   CCC (sf)
3-A1       52524YAK9   CCC (sf)
3-A2       52524YAL7   CC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-3
Series 2007-3
Class      CUSIP       Rating
4-A5       86363GAN4   CC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-8
Series 2007-8
Class      CUSIP       Rating
1-A1       86362NAA8   CCC (sf)
1-A2       86362NAB6   CCC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-11
Series 2007-11
Class      CUSIP       Rating
1-A1       86364YAA2   CCC (sf)
3-A1       86364YAH7   CCC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2007-5
Series 2007-5
Class      CUSIP       Rating
1-A1       86363XAA5   CCC (sf)

Structured Asset Securities Corp.
Series 1999-ALS3
Class      CUSIP       Rating
1-PO       863572F40   AAA (sf)
2-PO       863572F65   AAA (sf)

Structured Asset Securities Corp.
Series 2001-19
Class      CUSIP       Rating
1-AP       86358RSV0   BB (sf)
2-AP       86358RTD9   BB (sf)
B1 (1)                 B (sf)
B1 (2)     86358R9M8   B (sf)
B2 (1)                 B (sf)
B2 (2)     86358R9N6   B (sf)
B3 (1)                 B (sf)
B3 (2)     86358R9O3   B (sf)

Structured Asset Securities Corp.
Series 2002-AL1
Class      CUSIP       Rating
A1(B)      86358R9T3   AAA (sf)
A2(1)                  AAA (sf)
A2(2)      86358R9V9   AAA (sf)
A3(1)                  AAA (sf)
A3(2)      86358R9X5   AAA (sf)
A3(3)      86358R9Y2   AAA (sf)
AIO(1)                 AAA (sf)
AIO(2)     86358ROA3   AAA (sf)
AIO(3)     86358ROB2   AAA (sf)
APO(1)                 AAA (sf)
APO(2)     86358ROD0   AAA (sf)
APO(3)     86358ROE9   AAA (sf)
B1         86358RYC5   AA (sf)
B2         86358RYD3   A (sf)

Structured Asset Securities Corp.
Series 2003-8
Class      CUSIP       Rating
1-A2       86359ARW5   AAA (sf)
1-A4       86359ARY1   AAA (sf)
1-A5       86359ARZ8   AAA (sf)
1-AX       86359ASB0   AAA (sf)
1-AP       86359ASC8   AAA (sf)
2-A1       86359ASD6   AAA (sf)
2-A3       86359ASF1   AAA (sf)
2-A4       86359ASG9   AAA (sf)
2-A5       86359ASH7   AAA (sf)
2-A6       86359ASJ3   AAA (sf)
2-A7       86359ASK0   AAA (sf)
2-A8       86359ASL8   AAA (sf)
2-A9       86359ASM6   AAA (sf)
2-A10      86359ASN4   AAA (sf)
2-A11      86359ASP9   AAA (sf)
2-A12      86359ASQ7   AAA (sf)
2-A13      86359ASR5   AAA (sf)
2-AX       86359ASS3   AAA (sf)
2-PAX      86359AST1   AAA (sf)
2-AP       86359ASU8   AAA (sf)
1B1        86359ASV6   AA+ (sf)
1B2        86359ASW4   A (sf)
2B1        86359ASX2   AA+ (sf)
2B2        86359ASY0   A+ (sf)
1B4        86359ATB9   BB (sf)
2B4        86359ATE3   CC (sf)
1B5        86359ATC7   B (sf)

Structured Asset Securities Corp.
Series 2003-14
Class      CUSIP       Rating
1-A1       86359ATT0   AAA (sf)
1-A2       86359ATU7   AAA (sf)
1-A3       86359ATV5   AAA (sf)
1-A4       86359ATW3   AAA (sf)
1-A5       86359ATX1   AAA (sf)
1-A6       86359ATY9   AAA (sf)
1-A7       86359ATZ6   AAA (sf)
1-AX       86359AUA9   AAA (sf)
1-PAX      86359AUB7   AAA (sf)
1-AP       86359AUC5   AAA (sf)
2-A1       86359AUD3   AAA (sf)
2-AX       86359AUE1   AAA (sf)
2-AP       86359AUF8   AAA (sf)
3-A1       86359AUG6   AAA (sf)
3-A2       86359AUH4   AAA (sf)
3B1        86359AUL5   AA (sf)
3B2        86359AUM3   A (sf)
B4         86359AVF7   CCC (sf)
B5         86359AVG5   CC (sf)

Structured Asset Securities Corp.
Series 2003-21
Class      CUSIP       Rating
1-A1       86359AM42   AAA (sf)
1-A2       86359AM59   AAA (sf)
1-A3       86359AM67   AAA (sf)
1-A4       86359AM75   AAA (sf)
1-AX       86359AM83   AAA (sf)
1-PAX      86359AM91   AAA (sf)
1-AP       86359AN25   AAA (sf)
2-A2       86359AN41   AAA (sf)
2-A3       86359AN58   AAA (sf)
2-A4       86359AN66   AAA (sf)
2-A5       86359AN74   AAA (sf)
2-AX       86359AN90   AAA (sf)
2-AP       86359AP23   AAA (sf)
1B1        86359AP31   AA (sf)
B3(1)                  CCC (sf)
1B4        86359AL68   CC (sf)
2B5        86359AM26   CC (sf)

Structured Asset Securities Corp.
Series 2004-11XS
Class      CUSIP       Rating
2-A2       86359BUJ8   AAA (sf)
2-M1       86359BUL3   AA+ (sf)
1-M1       86359BUK5   CCC (sf)
2-M2       86359BVD0   A+ (sf)
1-M2       86359BUN9   CC (sf)

Structured Asset Securities Corporation Assistance Loan Trust
2003-AL1
Series 2003-AL1
Class      CUSIP       Rating
A          86359AME0   AAA (sf)
APO        86359AMG5   AAA (sf)
AIO        86359AMF7   AAA (sf)
B1         86359AMH3   AA (sf)
B4         86359AML4   CC (sf)

Structured Asset Securities Corporation Assistance Loan Trust
2003-AL2
Series 2003-AL2
Class      CUSIP       Rating
B3         86359AWW9   CC (sf)

WaMu Mortgage Pass-Through Certificates Series 2007-HY5 Trust
Series 2007-HY5
Class      CUSIP       Rating
1-A1       92990GAA1   CC (sf)
2-A-1      92990GAC7   CC (sf)
2-A-2      92990GAD5   CC (sf)
2-A-3      92990GAE3   CC (sf)
2-A-4      92990GAF0   CC (sf)
2-A-5      92990GAG8   CC (sf)
3-A1       92990GAJ2   CCC (sf)
3-A2       92990GAK9   CC (sf)

Wells Fargo Mortgage Backed Securities 2002-22 Trust
Series 2002-22
Class      CUSIP       Rating
II-A-PO    94979NBC2   AAA (sf)
I-A-WIO    94979NBK4   AAA (sf)
II-A-WIO   94979NBL2   AAA (sf)
B-1        94979NBG3   AAA (sf)
B-2        94979NBH1   AAA (sf)
B-3        94979NBJ7   AAA (sf)

Wells Fargo Mortgage Backed Securities 2005-AR1 Trust
Series 2005-AR1
Class      CUSIP       Rating
II-B-3     949781AM0   CC (sf)

Wells Fargo Mortgage Backed Securities 2007-10 Trust
Series 2007-10
Class      CUSIP       Rating
II-A-9     949837CC0   CCC (sf)
II-A-11    949837CE6   CCC (sf)

Wells Fargo Mortgage Backed Securities 2008-1 Trust
Series 2008-1
Class      CUSIP       Rating
I-A-1      949819AA4   CCC (sf)
I-A-2      949819AB2   CCC (sf)
I-A-3      949819AC0   CCC (sf)
IV-A-2     949819AQ9   BBB- (sf)


* S&P Puts Ratings on 59 Classes from 37 RMBS Deals on Watch Neg
----------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 59
classes from 37 U.S. residential mortgage-backed securities (RMBS)
transactions on CreditWatch with negative implications. In
addition, ratings on 14 other classes from eight of these
transactions remain on CreditWatch negative.

"The CreditWatch placements follow our review of certain classes
from 45 RMBS transactions and reflect current interest shortfalls
we observed on such classes. For those classes we placed on
CreditWatch and remaining on CreditWatch, the interest shortfalls
varied in size, cause, and recoverability. The shortfalls varied
from as low as a few basis points of the outstanding principal
balance to several debt service payments. Reported shortfalls may
have resulted from loan modifications, servicer reimbursements,
insufficient servicer advances, and undercollateralization, among
other credit-related causes, as well as non-credit-related basis
risk or net prepayment interest shortfalls," S&P related.

Rating Distribution Of Affected Classes

Rating    No. of classes
AAA                   20
AA+                    2
AA                     7
A+                     1
A                      5
A-                     2
BBB+                   2
BBB                    3
BBB-                   2
BB+                    1
BB                     4
BB-                    2
B+                     2
B                     13
B-                     7

"Over the next several months, we plan to evaluate the nature of
the interest shortfalls and resolve the CreditWatch placements. We
will also take any rating actions that we consider appropriate
based on our criteria, including the possibility of lowering some
ratings to 'D'," S&P said.

Rating Actions

ABFC 2005-HE2 Trust
Series 2005-HE2
                               Rating
Class      CUSIP       To                   From
M-1        04542BNJ7   A- (sf)/Watch Neg    A- (sf)
M-2        04542BNK4   B- (sf)/Watch Neg    B- (sf)

ACE Securities Corp. Home Equity Loan Trust, Series 1999-LB2
Series 1999-LB2
                               Rating
Class      CUSIP       To                   From
A          004421AD5   AAA (sf)/Watch Neg   AAA (sf)
M-1        004421AE3   AA (sf)/Watch Neg    AA (sf)
M-2        004421AF0   A (sf)/Watch Neg     A (sf)

ACE Securities Corp. Home Equity Loan Trust, Series 2003-FM1
Series 2003-FM1
                               Rating
Class      CUSIP       To                   From
M-1        004421BR3   AA (sf)/Watch Neg    AA (sf)

Alternative Loan Trust 2002-17
Series 2002-33
                               Rating
Class      CUSIP       To                   From
M          12669DKE7   AAA (sf)/Watch Neg   AAA (sf)
B-1        12669DKF4   AAA (sf)/Watch Neg   AAA (sf)

Alternative Loan Trust 2003-J2
Series 2003-J12
                               Rating
Class      CUSIP       To                   From
A-1        12669E4A1   AAA (sf)/Watch Neg   AAA (sf)
M          12669E4E3   AAA (sf)/Watch Neg   AAA (sf)
B-1        12669E4F0   BBB (sf)/Watch Neg   BBB (sf)

Amortizing Residential Collateral Trust 2002-BC7
Series 2002-BC7
                               Rating
Class      CUSIP       To                   From
A1         86358R7H4   AAA (sf)/Watch Neg   AAA (sf)

Banc of America Funding 2006-G Trust
Series 2006-G
                               Rating
Class      CUSIP       To                   From
3-A-1      05950MAG5   AAA (sf)/Watch Neg   AAA (sf)
3-A-2      05950MAH3   BBB- (sf)/Watch Neg  BBB- (sf)


Bayview Commercial Asset Trust 2005-1
Series 2005-1
                               Rating
Class      CUSIP       To                   From
A-1        07324SBE1   AAA (sf)/Watch Neg   AAA (sf)
B-2        07324SBK7   B (sf)/Watch Neg     B (sf)

Bayview Commercial Asset Trust 2005-2
Series 2005-2
                               Rating
Class      CUSIP       To                   From
A-1        07324SBN1   AAA (sf)/Watch Neg   AAA (sf)
M-5        07324SBU5   B (sf)/Watch Neg     B (sf)

Bayview Financial Mortgage Pass-Through Trust, Series 2005-D
Series 2005-D
                               Rating
Class      CUSIP       To                   From
M-1        07325NCD2   B+ (sf)/Watch Neg    B+ (sf)

Bear Stearns ALT-A Trust 2004-11
Series 2004-11
                               Rating
Class      CUSIP       To                   From
II-A-4     07386HMY4   AA (sf)/Watch Neg    AA (sf)

Bear Stearns ARM Trust 2004-8
Series 2004-8
                               Rating
Class      CUSIP       To                   From
I-2-A-1    07384M2B7   BB- (sf)/Watch Neg   BB- (sf)

Bear Stearns Asset Backed Securities Trust 2004-AC1
Series 2004-AC1
                               Rating
Class      CUSIP       To                   From
A-1        07384YQJ8   AAA (sf)/Watch Neg   AAA (sf)

Carrington Mortgage Loan Trust, Series 2006-FRE1
Series 2006-FRE1
                               Rating
Class      CUSIP       To                   From
A-2        144538AB1   B (sf)/Watch Neg     B (sf)

Chevy Chase Funding LLC Trust, Series 2006-1
Series 2006-1
                               Rating
Class      CUSIP       To                   From
A-NA       16678RIS9   B- (sf)/Watch Neg    B- (sf)

CHL Mortgage Pass-Through Trust 2004-J9
Series 2004-J9
                               Rating
Class      CUSIP       To                   From
1-A-1      12669GFE6   AA (sf)/Watch Neg    AA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Series 2004-4
                               Rating
Class      CUSIP       To                   From
D-B-3      22541SVR6   B+ (sf)/Watch Neg    B+ (sf)

CSFB ABS Trust Series 2001-HE25
Series 2001-HE25
                               Rating
Class      CUSIP       To                   From
M-1        22540VHE5   B- (sf)/Watch Neg    B- (sf)

CSFB Mortgage-Backed Trust Series 2003-29
Series 2003-29
                               Rating
Class      CUSIP       To                   From
D-B-3      22541Q4N9   B- (sf)/Watch Neg    B- (sf)

CSFB Trust 2003-CF14
Series 2003-CF14
                               Rating
Class      CUSIP       To                   From
M-1        22541N7N3   AA (sf)/Watch Neg    AA (sf)

Delta Funding Home Equity Loan Trust 1999-2
Series 1999-2
                               Rating
Class      CUSIP       To                   From
A-7F       24763LFN5   AAA (sf)/Watch Neg   AAA (sf)

Deutsche Mortgage Securities Inc Mortgage Loan Trust Series 2004-5
Series 2004-5
                               Rating
Class      CUSIP       To                   From
A-3        251563FY3   AAA (sf)/Watch Neg   AAA (sf)
A-4A       251563FZ0   AAA (sf)/Watch Neg   AAA (sf)
A-4B       251563GG1   AAA (sf)/Watch Neg   AAA (sf)

Fannie Mae REMIC Trust 2002-W1
Series 2002-W1
                               Rating
Class      CUSIP       To                   From
M          31392CML5   AA (sf)/Watch Neg    AA (sf)
B-1        31392CMM3   A (sf)/Watch Neg     A (sf)
B-2        31392CMN1   BBB (sf)/Watch Neg   BBB (sf)

First Franklin Mortgage Loan Trust 2004-FFH2
Series 2004-FFH2
                               Rating
Class      CUSIP       To                   From
M-1        32027NHY0   AA+ (sf)/Watch Neg   AA+ (sf)
M-2        32027NHZ7   BB (sf)/Watch Neg    BB (sf)
M-3        32027NJA0   B (sf)/Watch Neg     B (sf)

First Horizon Mortgage Pass Through Trust 2006-AR1
Series 2006-AR1
                               Rating
Class      CUSIP       To                   From
IV-A-1     32051GY74   BB (sf)/Watch Neg    BB (sf)

HarborView Mortgage Loan Trust 2004-5
Series 2004-5
                               Rating
Class      CUSIP       To                   From
3-A        41161PEZ2   A- (sf)/Watch Neg    A- (sf)
B1         41161PFC2   B- (sf)/Watch Neg    B- (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR4
Series 2004-AR4
                               Rating
Class      CUSIP       To                   From
1-A        45660NQ24   A+ (sf)/Watch Neg    A+ (sf)

IndyMac Loan Trust 2004-L1
Series 2004-L1
                               Rating
Class      CUSIP       To                   From
B          45660YAK7   BB (sf)/Watch Neg    BB (sf)

MASTR Specialized Loan Trust 2004-02
Series 2004-02
                               Rating
Class      CUSIP       To                   From
M-3        576436AN9   BBB (sf)/Watch Neg   BBB (sf)
M-4        576436AP4   BBB- (sf)/Watch Neg  BBB- (sf)
B          576436AQ2   B (sf)/Watch Neg     B (sf)

Morgan Stanley Mortgage Loan Trust 2006-17XS
Series 2006-17XS
                               Rating
Class      CUSIP       To                   From
A-2-W      61751DAD6   B (sf)/Watch Neg     B (sf)
A-5-W      61751DAH7   B (sf)/Watch Neg     B (sf)

Option One Mortgage Loan Trust 2001-4
Series 2001-4
                               Rating
Class      CUSIP       To                   From
A          68389FBW3   A (sf)/Watch Neg     A (sf)

Ryland Mortgage Securities Corp.
Series 1991-14
                               Rating
Class      CUSIP       To                   From
14B-1      783766GG7   BBB+ (sf)/Watch Neg  BBB+ (sf)

Saxon Asset Securities Trust 2002-2
Series 2002-2
                               Rating
Class      CUSIP       To                   From
AV         805564LW9   AAA (sf)/Watch Neg   AAA (sf)
M-1        805564LY5   B (sf)/Watch Neg     B (sf)

Securitized Asset Backed Receivables LLC Trust 2005-FR2
Series 2005-FR2
                               Rating
Class      CUSIP       To                   From
M-2        81375WEF9   B (sf)/Watch Neg     B (sf)

Structured Asset Investment Loan Trust 2003-BC2
Series 2003-BC2
                               Rating
Class      CUSIP       To                   From
A1         86358EAJ5   AAA (sf)/Watch Neg   AAA (sf)
A2         86358EAK2   AAA (sf)/Watch Neg   AAA (sf)
A3         86358EAL0   AAA (sf)/Watch Neg   AAA (sf)

Structured Asset Securities Corp.
Series 2003-28XS
                               Rating
Class      CUSIP       To                   From
A4         86359AQ48   AAA (sf)/Watch Neg   AAA (sf)

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

Ratings Remaining on CreditWatch Negative

Aames Mortgage Investment Trust 2005-1
Series 2005-1
Class      CUSIP       Rating
M6         00252FBD2   BBB+ (sf)/Watch Neg
M7         00252FBE0   B- (sf)/Watch Neg

Credit Suisse First Boston Mortgage Securities Corp.
Series 2005-3
Class      CUSIP       Rating
II-A-1     225458JV1   BB (sf)/Watch Neg

Deutsche Alt-A Securities, Inc. Mortgage Loan Trust, Series 2005-
AR2
Series 2005-AR2
Class      CUSIP       Rating
VII-A-1    251510GZ0   B- (sf)/Watch Neg

Merrill Lynch Mortgage Investors Trust, Series 2006-3
Series 2006-3
Class      CUSIP       Rating
M-1        59023PAD5   BB- (sf)/Watch Neg

Morgan Stanley Mortgage Loan Trust 2007-8XS
Series 2007-8XS

Class      CUSIP       Rating
A-3-W      61754PAD6   B (sf)/Watch Neg

Morgan Stanley Re-REMIC Trust 2010-R5
Series 2010-R5
Class      CUSIP       Rating
2-B        61759HAY3   A (sf)/Watch Neg
2-A        61759HAD9   AAA (sf)/Watch Neg

RFMSI Series 2005-SA1 Trust
Series 2005-SA1
Class      CUSIP       Rating
I-A-1      76111XTB9   B (sf)/Watch Neg
I-A-2      76111XTC7   B (sf)/Watch Neg
I-A-3      76111XTD5   B (sf)/Watch Neg

Terwin Mortgage Trust 2005-4HE
Series 2005-4HE
Class      CUSIP       Rating
M-1        881561SC9   AA+ (sf)/Watch Neg
M-2        881561SD7   AA (sf)/Watch Neg
M-3        881561SE5   A (sf)/Watch Neg

                           *********

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, 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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