TCR_Public/111106.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

             Sunday, November 6, 2011, Vol. 15, No. 308

                            Headlines

ABACUS 2005-2: S&P Cuts Ratings on 2 Tranches From 'CCC-' to 'CC'
ACE SECURITIES: Moody's Reviews 'Caa1' Rating of Green Tree
AERCO LIMITED: Fitch Affirms 'Dsf' Ratings on Two Note Classes
AMERICREDIT AUTOMOBILE: S&P Gives 'BB+' Rating on Class E Notes
AMMC VIII: S&P Raises Rating on Class E Notes From 'B+' to 'BB'

ARCC COMMERCIAL: Moodys Upgrades Ratings of CLO Notes
BCAP LLC: S&P Lowers Ratings on 3 Classes of Re-REMIC to 'D'
BLUEGREEN CORPORATION: Moody's Raises Cl. D Notes Rating to Baa2
BRASCAN REAL ESTATE: Moody's Upgrades Ratings of Two Notes Classes
BRASCAN STRUCTURED: Moody's Raises Rating of Cl. D Notes to 'Ba3'

BSCMS 2006-TOP24: Moody's Affirms Ratings of Eight CMBS Classes
BUCKEYE TOBACCO: S&P Puts 8 Asset-Backed Classes Ratings on Watch
CABELA'S CREDIT: DBRS Assigns Class D Notes at 'BB'
CABELA'S CREDIT: Fitch Puts Rating on $8.25 Mil. Notes at 'BB+sf'
CALIFORNIA STATEWIDE: Moody's Raises LOC Rating to Aa3 From Ba3

CAPITALSOURCE 2006-1: Moody's Confirms Cl. D Notes Rating at Ba2
CAPITALSOURCE 2006-2: Moody's Raises Rating of Cl. E Notes to Ba1
CAPMARK VII-CRE: S&P Cuts Ratings on 6 Classes From 'CCC-' to 'D'
CCMSC 1998-1: Moody's Affirms Ratings of Five CMBS Classes
CD 2007-CD4: S&P Lowers Ratings on 3 Classes of Certs. to 'D'

CHATHAM LIGHT: S&P Withdraws 'CCC-' Ratings on 2 Classes of Notes
CHURCHILL FINANCIAL: Moody's Upgrades Ratings of CLO Notes
CIFC FUNDING: Moody's Raises Rating of US$25-Mil. Notes to 'Ba3'
CLARIS IV: DBRS Confirms Class I-C Swap, Series 29 at 'BB'
CLARIS IV: DBRS Downgrades Class I-B Swap, Series 28 to 'BB'

CLARIS IV: DBRS Downgrades Class I-C Swap, Series 25 to 'BB'
CLARIS IV SERIES 25: DBRS Confirms 'BB' Rating on Class I-C Swap
CLARIS IV SERIES 28: DBRS Confirms 'BB' Rating on Class I-C Swap
CLARIS IV SERIES 29: DBRS Confirms 'BB' Rating on Class I-C Swap
CNH CAPITAL: Moody's Assigns Provisional Ratings to Three Classes

COAST INVESTMENT: S&P Withdraws 'B+' Ratings on 2 Classes of Notes
COMM 2004-LNB3: Moody's Affirms Ratings of 17 CMBS Classes
CORTS TRUST: Moody's Raises Rating of US$12-Mil. Notes to 'Ba2'
CREST 2002-1: Moody's Lowers Rating of Class B-1 Notes to 'Caa1'
CSFB 2004-C1: Moody's Affirms Ratings of 15 CMBS Classes

CSMC 2006-C5: Moody's Reviews Ratings for Possible Downgrade
DRUG ROYALTY: Moody's Assigns Provisional Rating to ABS
FALL CREEK: Fitch Downgrades Rating on 8 Note Classes to 'Dsf'
FIRST HORIZON: S&P Lowers Rating on Class B-1 From 'CCC' to 'CC'
FIRST INVESTORS: DBRS Assigns Series 2011-2 Notes, Class E at 'BB'

FORD MOTOR: Moody's Raises Rating of US$2.34-Mil. Notes to 'Ba2'
FOXE BASIN: Moody's Raises Rating of Class C Notes to 'Ba3'
FRASER SULLIVAN: S&P Gives 'BB' Rating on Class D Deferrable Notes
FRIEDBERGMILSTEIN PRIVATE: Moody's Ups Rating of Class D-1 to Ba1
GENESIS CLO: S&P Raises Rating on Class E Notes to 'BB+'

GMAC 2003-C3: Moody's Affirms Ratings of 16 CMBS Classes
GOLUB CAPITAL: Moody's Upgrades Rating of Class E Notes to 'Ba2'
GRAMERCY REAL: S&P Affirms 'CCC-' Ratings on 2 Classes
GULF COUNTY: Fitch Ups Rating on $3.5MM Bonds to 'BBB-' From 'BB'
HEWETT'S ISLAND: S&P Raises Rating on Class D Notes to 'CCC-'

HIGHLAND CREDIT: S&P Puts 'BB' Rating on Class C 2006 on Watch Neg
JEFFERIES RESECURITIZATION: S&P Cuts Ratings on 5 Classes to 'CC'
JFIN CLO: S&P Removes 'BB+' Rating on Class D Notes From Watch Pos
JPMCC 2005-LDP2: Moody's Affirms Ratings of 22 CMBS Classes
JPMCC 2007-CIBC20: Moody's Affirms Ratings of 19 CMBS Classes

KATONAH IV: S&P Raises Ratings on 2 Classes of Notes From 'BB+'
KEYCORP STUDENT: Fitch Holds Junk Rating on Class II-C Notes
KIMBERLITE CDO: Moody's Downgrades Cl. A Notes Rating to 'C'
LB-UBS 2004-C7: S&P Lowers Ratings on 6 Classes of Certs. to 'D'
LBUBS 2006-C4: Moody's Affirms Ratings of 30 CMBS Classes

LBUBS 2006-C6: Moody's Affirms Ratings of 21 CMBS Classes
LCM II: S&P Hikes Ratings on 2 Classes of Notes From 'B+' to 'BB+'
LEAF CAPITAL: Moody's Gives 'Ba1' Rating to Class E-1 Notes
LEGG MASON: Moody's Affirms Rating of Class C Notes at 'Ba2'
LEHMAN MANUFACTURED: Fitch Affirms Rating on Two Notes at 'Dsf'

MAC CAPITAL: Moody's Raises Rating of Class B-1F Notes to 'Ba1'
MAPS CLO: Moody's Upgrades Rating of Class C Notes to 'Ba1'
MERRILL LYNCH: S&P Lowers Ratings on 2 Classes of Certs. to 'D'
MORGAN STANLEY: DBRS Downgrades Class Q Rating to 'D'
MORGAN STANLEY: S&P Lowers Rating on Class F Certs. to 'CCC+'

MORGAN STANLEY: S&P Lowers Ratings on 3 Classes of Certs. to 'D'
MSC 2006-HQ10: Moody's Affirms Ratings of 18 CMBS Classes
MSC 2007-TOP25: Moody's Reviews Ratings for Possible Downgrade
NATIONAL COLLEGIATE: Fitch Holds Rating on Subor. Notes at 'CCsf'
NAVIGATOR CDO: S&P Raises Ratings on 2 Classes of Notes to 'B+'

NYCTL 2011-A: Moody's Assigns Provisional Rating to Bonds
OHA INTERPID: S&P Affirms 'BB' Rating on Class E Deferrable Notes
PACIFIC SHORES: S&P Lowers Ratings on 2 Classes of Notes to 'CC'
PARCS-R MASTER: S&P Lowers Rating on Class Trust Unit to 'CC'
PIMA & TUCSON: Moody's Lowers Rating of Series 2007A-2 to Ba3

PREFERREDPLUS TRUST: Moody's Raises Rating of 7.4% Certs to Ba2
PUBLIC STEERS: Moody's Raises Rating of $106.903-Mil. Notes to Ba2
RELATED CAPITAL: Moody's Lowers Rating of Series F Funds to 'B3'
RUTLAND RATED: S&P Withdraws 'CCC-' Ratings on 2 Classes of Notes
SCHOONER TRUST: DBRS Confirms Class K at 'B'

SIERRA TIMESHARE: Fitch to Rate $25.2 Mil. Note Class at 'BBsf'
SPRING ROAD: Moody's Raises Rating of Class E Notes to 'Ba2'
STARWOOD VACATION: Moody's Upgrades Rating of 2 Classes of Notes
SYMPHONY CLO: S&P Affirms 'BB' Rating on Class E Notes
TELOS CLO 2006-1: Moody's Upgrades Rating of Class D Notes to Ba1

TELOS CLO 2007-2: Moody's Raises Rating of Class D Notes to 'Ba1'
TERRA CDO: S&P Withdraws 'CCC-' Rating on Class A1 Notes
TRUST CERTIFICATES: Moody's Raises Rating of $1.28MM Notes to Ba2
UBS 2007-FL1: Moody's Affirms Ratings of 14 CMBS Classes
US COMMERCIAL: Fitch Lowers Ratings on 18 Bonds to 'D'

US RMBS: Fitch Lowers Rating on 270 Distressed Bonds to 'Dsf'
WACHOVIA BANK: Moody's Upgrades Rating of Two Classes of Notes
WBCMT 2003-C6: Moody's Affirms Ratings of 12 CMBS Classes
WBCMT 2004-C10: Moody's Affirms Ratings of 14 CMBS Classes
WBCMT 2005-C22: Moody's Reviews Ratings for Possible Downgrade

WBCMT 2006-WHALE7: Moody's Affirms Ratings of 11 CMBS Classes
WELLS FARGO: Fitch Affirms 'Bsf' Rating on Class F Certificate
WELLS FARGO: S&P Raises Ratings on 3 Classes From 'D' to 'CC'
WFRBS 2011: Moody's Assigns (P)Ba2 Rating to Cl. F Notes
WHITEHORSE II: S&P Raises Rating on Class B-1L Notes to 'BB+'

WORLD OMNI: Moody's Assigns Provisional Ratings to 5 Notes Classes

* S&P Raises Ratings on 8 Ford Motor-Related Transactions to 'BB+'
* S&P Lowers Ratings on Six Classes of Certificates to 'D'
* S&P Lowers Ratings on 955 Classes From 89 US RMBS Transactions
* S&P Lowers Ratings on 15 Classes of Certificates to 'D'



                            *********



ABACUS 2005-2: S&P Cuts Ratings on 2 Tranches From 'CCC-' to 'CC'
-----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 39
tranches from 18 corporate-backed synthetic collateralized debt
obligation (CDO) transactions and removed 29 of them from
CreditWatch with positive implications. "At the same time, we
lowered our ratings on 12 tranches from 10 synthetic CDO
transactions backed by residential mortgage-backed securities
(RMBS), 32 tranches from 13 synthetic CDO transaction backed by
commercial mortgage-backed securities (CMBS), two tranches from
two corporate-backed synthetic CDOs. In addition, we affirmed
our ratings on 11 tranches from 11 synthetic CDO transactions,"
S&P related.

"We raised our ratings on synthetic CDOs that experienced a
combination of upward rating migration in their underlying
reference portfolios and seasoning of the underlying reference
names. The upgrades also reflect an increase in the synthetic
rated overcollateralization (SROC) ratios above 100% at higher
rating levels as of the October 2011 review and at our projection
of the SROC ratios in 90 days assuming no credit migration. We
lowered our ratings on synthetic CDOs that had experienced
negative rating migration in their underlying reference
portfolios. The affirmations reflect our opinion of the
availability of sufficient credit support at the current rating
levels," S&P related.

Rating Actions

ABACUS 2005-2 Ltd.
                                 Rating
Class                    To                  From
A-1                      CC (sf)             CCC- (sf)
A-2                      CC (sf)             CCC- (sf)

Abacus 2006-10 Ltd.
                                 Rating
Class                    To                  From
K                        CC (sf)             CCC- (sf)
L                        CC (sf)             CCC- (sf)

ABSpoke 2005-IVA Ltd.
                                 Rating
Class                    To                  From
ABSpoke                  CC (sf)             CCC- (sf)

ABSpoke 2005-VA Ltd.
                                 Rating
Class                    To                  From
ABSpoke                  CC (sf)             CCC- (sf)

Aphex Capital NSCR 2006-1 Ltd.
                                 Rating
Class                    To              From
Notes                    B- (sf)         B (sf)/Watch Neg

Aphex Capital NSCR 2006-2 Ltd.
                                 Rating
Class                    To              From
B                        CCC- (sf)       CCC (sf)/Watch Neg
C                        CCC- (sf)       CCC (sf)/Watch Neg
D                        CCC- (sf)       CCC (sf)/Watch Neg

Aphex Capital NSCR 2007-5 Ltd.
                                 Rating
Class                    To             From
A-1FL                    CCC (sf)       CCC+ (sf)/Watch Neg
A-1FX                    CCC (sf)       CCC+ (sf)/Watch Neg

Aphex Capital NSCR 2007-6 Ltd.
                                 Rating
Class                    To                  From
A-1                      CC (sf)             CCC- (sf)
A-2                      CC (sf)             CCC- (sf)
B                        CC (sf)             CCC- (sf)
C-FL                     CC (sf)             CCC- (sf)
C-FX                     CC (sf)             CCC- (sf)

Calculus CMBS Resecuritization Trust Series 2006-8
                                 Rating
Class                    To             From
TrustUnits               CCC+ (sf)      B- (sf)/Watch Neg

Cloverie PLC
Series 2007-25
                                 Rating
Class                    To                  From
2007-25                  B- (sf)             B- (sf)/Watch Pos

Corsair (Jersey) No. 4 Ltd.
Series I
                                 Rating
Class                    To             From
Def Fx Rt                BBB- (sf)      BB+ (sf)/Watch Pos

Credit Default Swap
$10 mil HSBC Bank USA NA - The Hongkong and Shanghai Banking Corp.
Ltd.
Series 227212/227229/227230
                                 Rating
Class                    To           From
Tranche                  BB-srp (sf)  BB-srp (sf)/Watch Pos

Credit Default Swap
$187.5 mil Swap Risk Rating - Portfolio CDS Ref No.
PYR_8631051_82386541_Zicavo
                                 Rating
Class                    To             From
Swap                     A+srp (sf)     Asrp (sf)/Watch Pos

Credit Default Swap
$500 mil Credit Default Swap - CRA700426
                                 Rating
Class                    To             From
Swap                     A+srp (sf)     Asrp (sf)/Watch Pos

Credit Default Swap
$500 mil Credit Default Swap - CRA700436
                                 Rating
Class                    To             From
Swap                     A+srp (sf)     Asrp (sf)/Watch Pos

Credit Default Swap
$950 mil Swap Risk Rating-Portfolio, CDS Reference # 06ML23332A
                                 Rating
Class                 To              From
06ML23332A            BBB-srp (sf)    BBBsrp (sf)/Watch Neg

Eirles Two Ltd.
Series 208
                                 Rating
Class                    To                  From
Series 208               CC (sf)             CCC- (sf)

Khamsin Credit Products (Netherlands) II B.V.
Series 26
                                 Rating
Class                    To               From
Tranche                  AA (sf)          AA (sf)/Watch Neg

Khamsin Credit Products (Netherlands) II B.V.
Series 27
                                 Rating
Class                    To               From
Tranche                  AA (sf)          AA (sf)/Watch Neg

Khamsin Credit Products (Netherlands) II B.V.
Series 29
                                 Rating
Class                    To               From
LvrgdSprSr               AA (sf)          AA (sf)/Watch Neg

Khamsin Credit Products (Netherlands) II B.V.
Series 30
                                 Rating
Class                    To               From
LvrgdSprSr               AA (sf)          AA (sf)/Watch Neg

Landgrove Synthetic CDO SPC
Series 2007-2
                                 Rating
Class                    To                From
A                        B (sf)            B (sf)/Watch Pos

Lorally CDO Ltd. Series 2006-2
                                 Rating
Class                    To             From
2006-2                   A- (sf)        BBB+ (sf)/Watch Pos

Lorally CDO Ltd. Series 2006-4
                                 Rating
Class                    To             From
2006-4                   A- (sf)        BBB+ (sf)/Watch Pos

Lorally CDO Ltd. Series 2007-3
                                 Rating
Class                    To             From
2007-3                   A- (sf)        BBB+ (sf)/Watch Pos

Maclaurin SPC
$118 mil Maclaurin SPC, acting on behalf of and for the account of
the
Series 2007-1 Segregated Portfolio
                                 Rating
Class                    To                  From
A                        CC (sf)             CCC- (sf)
B                        CC (sf)             CCC- (sf)
C                        CC (sf)             CCC- (sf)
D                        CC (sf)             CCC- (sf)
E                        CC (sf)             CCC- (sf)
F                        CC (sf)
   CCC- (sf)
G                        CC (sf)             CCC- (sf)
H                        CC (sf)             CCC- (sf)
J                        CC (sf)             CCC- (sf)

Magnolia Finance II PLC
Series 2006-6D
                                 Rating
Class                    To                  From
Series D                 CC (sf)             CCC- (sf)

Magnolia Finance II PLC
Series 2006-6E
                                 Rating
Class                    To                  From
Series E                 CC (sf)             CCC- (sf)

Magnolia Finance II PLC
Series 2006-7A2
                                 Rating
Class                    To              From
Notes                    BBB+ (sf)       AA+ (sf)/Watch Neg

Magnolia Finance II PLC
Series 2006-7B
                                 Rating
Class                    To              From
Notes                    BB+ (sf)        A+ (sf)/Watch Neg

Morgan Stanley ACES SPC
Series 2005-12
                                 Rating
Class                    To              From
Fltg Rt Nt               BB- (sf)        B+ (sf)/Watch Pos

Morgan Stanley ACES SPC
Series 2007-6
                                 Rating
Class                    To             From
IIA                      BB- (sf)       B (sf)/Watch Pos
IIIA                     B (sf)         CCC+ (sf)/Watch Pos

Morgan Stanley ACES SPC
Series 2007-9
                                 Rating
Class                    To               From
III                      B+p (sf)         Bp (sf)/Watch Pos

Morgan Stanley ACES SPC
Series 2007-35
                                 Rating
Class                    To                  From
C                        BBB+ (sf)           BBB+ (sf)

Morgan Stanley ACES SPC
Series 2008-8
                                 Rating
Class                    To                From
IA                       A+ (sf)           A (sf)/Watch Pos

Morgan Stanley Managed ACES SPC
Series 2005-1
                                 Rating
Class                    To              From
Jr Sup Sr                AA- (sf)        A+ (sf)/Watch Pos
I A                      A (sf)          A- (sf)/Watch Pos
II A                     BBB- (sf)       BB+ (sf)/Watch Pos
II B                     BBB- (sf)       BB+ (sf)/Watch Pos
IV B                     CCC- (sf)       CCC- (sf)

Morgan Stanley Managed ACES SPC
Series 2006-4
                                 Rating
Class                    To              From
IA                       A (sf)          A- (sf)/Watch Pos
IB                       A (sf)          A- (sf)/Watch Pos
II                       BBB- (sf)       BB+ (sf)/Watch Pos

Morgan Stanley Managed ACES SPC US
$75 mil Morgan Stanley Managed ACES SPC (Aviva) Series 2007-12
                                 Rating
Class                    To               From
IIIA                     B (sf)           B- (sf)/Watch Pos
IVA                      CCC- (sf)        CCC- (sf)

Nomura International plc
$1 bil NSCR 2006-1 Class A-1 Nomura Synthetic CMBS
Resecuritization
                                 Rating
Class                    To              From
Tranche                  B+ (sf)         BB- (sf)/Watch Neg

Nomura International plc
$1 bil NSCR 2006-2 2.75%-7% SCDO
                                 Rating
Class                    To             From
Tranche                  B-srp (sf)     Bsrp (sf)/Watch Neg

Nomura International plc
$20 mil NSCR 2006-1 Class FL Nomura Synthetic CMBS
Resecuritization
                                 Rating
Class                    To             From
First Loss               CCC (sf)       CCC+ (sf)/Watch Neg

North Street Referenced Linked Notes 2005-8 Ltd.
                                 Rating
Class                    To                  From
B                        CC (sf)             CCC- (sf)

North Street Referenced Linked Notes 2005-9 Ltd.
                                 Rating
Class                    To                  From
F                        CCC- (sf)           CCC- (sf)

North Street Referenced Linked Notes 2004-6 Ltd.
                                 Rating
Class                    To                  From
A                        CC (sf)             CCC- (sf)

Repacs Trust Series: Bayshore I
                                 Rating
Class                    To              From
A                        BB (sf)         BB- (sf)/Watch Pos
B                        BB- (sf)        B+ (sf)/Watch Pos

REVE SPC
EUR50 mil, 3 bil, $154 mil REVE SPC Dryden XVII Notes Series
2007-1
                                 Rating
Class                    To              From
JSS Ser23                BBB- (sf)       BB+ (sf)/Watch Pos
A Series 4               BB (sf)         BB- (sf)/Watch Pos
A Series 7               BB (sf)         BB- (sf)/Watch Pos
A Series 9               BB (sf)         BB- (sf)/Watch Pos

Rutland Rated Investments
EUR5 mil, $197 mil Dryden XII - IG Synthetic CDO 2006-1
                                 Rating
Class                    To              From
A1A-$LS                  A+ (sf)         B+ (sf)/Watch Pos
A2-$LS                   BBB+ (sf)       CCC (sf)/Watch Pos
A3-$LS                   BBB- (sf)       CCC- (sf)
A3B-$LS                  BBB- (sf)       CCC- (sf)
A3C-$LS                  BBB- (sf)       CCC- (sf)
A5-$LS                   BB (sf)         CCC- (sf)
A7-$LS                   B+ (sf)         CCC- (sf)
A7B-$FS                  B+ (sf)         CCC- (sf)
A7B-$LS                  B+ (sf)         CCC- (sf)
A7-ELS                   B+ (sf)         CCC- (sf)
B1-$LS                   B (sf)          CCC- (sf)
B1B-$LS                  B (sf)          CCC- (sf)

SPGS SPC, acting for the account of SRRSPOKE 2007-IA Segregated
Porfolio
                                 Rating
Class                    To                  From
I                        CC (sf)             CCC- (sf)
Sub Notes                CC (sf)             CCC- (sf)

SPGS SPC, acting for the account of SRRSPOKE 2007-IB Segregated
Portfolio
                                 Rating
Class                    To                  From
I                        CC (sf)             CCC- (sf)
Sub Notes                CC (sf)             CCC- (sf)

STARTS (Cayman) Ltd.
Series 2006-5
                                 Rating
Class                    To              From
A2-D2                    BBB- (sf)       BB+ (sf)/Watch Pos

Structured Investments Corp. III
$1.8 mil Structured Investments Corporation III Issue of USD
1,800,000 SIC
III Series 2007-3 South Coast Notes Due 2038
                                 Rating
Class                    To                  From
2007-3                   D (sf)              CC (sf)

Structured Investments Corp. III
$8.1 mil USD 8,100,000 SIC III Series 2007-2 Laguna Seca
Notes Due 2047
                                 Rating
Class                    To                  From
2007-2                   D (sf)              CC (sf)


ACE SECURITIES: Moody's Reviews 'Caa1' Rating of Green Tree
-----------------------------------------------------------
Moody's Investors Service has placed 68 manufactured housing
loans including some stick-built single family home loans-
backed securities (MH) aggregating $1.5 billion from 37 deals
on review for possible downgrade and 35 MH securities aggregating
$569 million from 25 deals on review for possible upgrade. The
collateral backing these transactions consists primarily of
manufactured housing loans. The MH securities are very seasoned
and were issued between 1992 and 2007.

RATINGS RATIONALE

The loss projections account for continued weakness in the macro
economy and the recent performance of the sector. Cumulative
losses have increased modestly and serious delinquencies, measured
as a percentage of outstanding balance, have remained stable at
approximately 3%.

Payment deferrals, a common loss mitigation tool masks true
delinquencies and can account up to half the outstanding pool
balance. Deferments are granted to borrowers who could not pay the
full arrears but have demonstrated the ability to make future
installments. Repayment plans are the capitalization of past due
payments to cure the delinquencies. While deferrals can reduce
overall default rates, deferred accounts that are re-classified as
current are still riskier than loans that have been contractually
current. Re-default rates on deferred accounts are similar to
subprime borrowers at 65%.

To estimate losses, Moody's first forecasted losses on the loans
that had a payment deferral based on 65% re-default rates and 85%
severity assumptions. Secondly, losses were projected on the
remaining loans that have not had any payment deferral based on
Moody's annual conditional prepayment rates (CPR), annual constant
default rates (CDR), and 85% severity assumptions.

The CPR rate is derived from the average of actual CPR observed
over the last six months. The CDR rate is based on pipeline
defaults -- derived from days-aged delinquencies and Moody's
assumptions for default based on days delinquent or REO (15% for
30 days delinquent loans, 30% for 60 days delinquent loans, 90%
for more than 90 days delinquent loans, and 100% for loans in
REO). Moody's has further assumed that both CDR and CPR will
remain constant over the life of each deal. A sudden reversal in
the existing trend of projected prepayments, defaults and losses
is not anticipated for these deals as they are well seasoned.

The losses from loans that had a deferrals and those from the
remaining loans based on the CPR-CDR approach are weighed to
calculate the total projected loss for the deal.

Rating Actions

To assess the rating implications Moody's will calculate a deal
specific loss projection and compare it to the tranches' credit
enhancement from subordination; excess spread; and reserve account
and third-party support (if any) and the timing of principal
repayment.

Overall, the impact on ratings due to Moody's loss expectations is
expected to be small where only around 4% of the investment grade
ratings are expected to migrate below investment grade. Moody's
also placed 6% of the MH tranches on review for possible upgrade
primarily because of the increase in credit support and relatively
steady performance since Moody's previous rating actions on select
MH deals in 2010Q4.

Moody's also placed on review bonds rated Aaa, Aa, A, and Baa
where full expected principal repayment exceeds 5, 7, 10, and 10
years respectively because of uncertainty of cash flows and
losses. A- rated bonds will likely migrate to Baa rating level and
Baa rated bonds will likely migrate to Ba rating level even though
they have the same pay-index.

For securities insured by a financial guarantor, the rating on the
securities is the higher of (i) the guarantor's financial strength
rating and (ii) the current underlying rating (i.e., absent
consideration of the guaranty) on the security. Securities wrapped
by Ambac Assurance Corporation are rated at their underlying
rating without consideration of Ambac's guaranty. The principal
methodology used in determining the underlying rating is the same
methodology for rating securities that do not have a financial
guaranty and is as described earlier.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high. Moody's now projects unemployment rate to start declining by
fourth quarter of 2011.

The principal methodology used in these ratings was "Moody's
Approach to Rating US Residential Mortgage-Backed Securities"
published in December 2008.

During the review period Moody's will further refine its
assumptions relating to expected frequency of default and severity
of loss on a deal-by-deal basis. Moody's expects to resolve the
review and take final action on all bonds placed on review within
the next 8 weeks.

Other methodologies and factors that may have been considered in
the process of rating this issuer can also be found on Moody's
website.

Complete rating actions are:

Issuer: ACE Securities Corp. Manufactured Housing Trust 2003-MH1

Cl. M-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jul 25, 2003 Assigned Aa2 (sf)

Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jul 25, 2003 Assigned Aaa (sf)

Issuer: BankAmerica MH Contract 1997-2

A-IO, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Oct 5, 2004 Confirmed at Aa2 (sf)

Issuer: CountryPlace Manufactured Housing Contract 2005-1

Cl. A-3, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jan 16, 2009 Downgraded to Baa1 (sf)

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

Cl. A-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jan 16, 2009 Downgraded to Baa1 (sf)

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

Issuer: Green Tree Financial Corporation MH 1992-02

B, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 29, 2003 Downgraded to Caa1 (sf)

Issuer: Green Tree Financial Corporation MH 1993-01

B, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Aug 2, 2006 Downgraded to Caa1 (sf)

Issuer: Green Tree Financial Corporation MH 1993-02

B, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 13, 2004 Downgraded to Caa1 (sf)

Issuer: Green Tree Financial Corporation MH 1993-03

A-7, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Aug 2, 2006 Downgraded to Aa2 (sf)

B, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 29, 2003 Downgraded to Caa1 (sf)

Issuer: Green Tree Financial Corporation MH 1993-04

A-5, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Aug 2, 2006Downgraded to Aa2 (sf)

Issuer: Green Tree Financial Corporation MH 1994-01

A-5, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 29, 2003 Downgraded to Aa2 (sf)

Issuer: Green Tree Financial Corp. MH Series 1996-2

M-1, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Sep 23, 2009 Confirmed at B3 (sf)

Issuer: Green Tree Financial Corporation MH 1996-06

M-1, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 30, 2009 Downgraded to Caa1 (sf)

Issuer: Green Tree Financial Corporation MH 1998-8

A-1, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Aug 2, 2006 Downgraded to Ba2 (sf)

Issuer: Green Tree Financial Corporation-MH Contract Series 1997-5

M-1, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 13, 2004 Downgraded to B2 (sf)

Issuer: Lehman ABS Manufactured Housing Contract
Senior/Subordinate Asset-Backed Certificates, Series 2001-B

Cl. A-4, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 10, 2009 Upgraded to A2 (sf)

Cl. A-1, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 10, 2009 Upgraded to A2 (sf)

Cl. A-2, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 10, 2009 Upgraded to A2 (sf)

Cl. A-3, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 10, 2009 Upgraded to A2 (sf)

Cl. A-5, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 10, 2009 Upgraded to A2 (sf)

Cl. A-6, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 10, 2009 Upgraded to A2 (sf)

Cl. A-7, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 10, 2009 Upgraded to A2 (sf)

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

Cl. A-IOC, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 10, 2009 Upgraded to A2 (sf)

Issuer: Lehman ABS Manufactured Housing Contract Trust 2002-A

Cl. A, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Sep 24, 2002 Assigned Aaa (sf)

Issuer: Madison Avenue Manufactured Housing Contract Trust 2002-A

Cl. A-IO, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Jan 16, 2009 Upgraded to A1 (sf)

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

Issuer: Mid-State Capital Corp. 2005-1

Cl. A, A1 (sf) Placed Under Review for Possible Downgrade;

Cl. M-1, Baa1 (sf) Placed Under Review for Possible Downgrade;

Issuer: Mid-State Trust VI

A-4, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2011 Confirmed at Baa3 (sf)

A-1, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2011 Confirmed at Aa1 (sf)

A-2, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2011 Confirmed at Aa3 (sf)

A-3, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2011 Confirmed at A2 (sf)

Issuer: Mid-State Trust VII

Notes, Baa1 (sf) Placed Under Review for Possible Downgrade;

Underlying Rating: Baa1 (sf) Placed Under Review for Possible
Downgrade

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

Issuer: Origen Manufactured Housing Conract Trust 2005-A

Cl. M-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2005 Assigned Aa2 (sf)

Cl. M-2, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2005 Assigned A2 (sf)

Cl. B, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 14, 2010 Downgraded to Baa3 (sf)

Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2005 Assigned Aaa (sf)

Issuer: Origen Manufactured Housing Conract Trust Collateralized
Notes, Series 2005-B

Cl. M-1, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 14, 2010 Downgraded to A1 (sf)

Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Dec 21, 2005 Assigned Aaa (sf)

Issuer: Origen Manufactured Housing Contract Trust 2004-A

Cl. M-1, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 31, 2004 Assigned Aa2 (sf)

Cl. M-2, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 31, 2004 Assigned A2 (sf)

Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Mar 31, 2004 Assigned Aaa (sf)

Issuer: Origen Manufactured Housing Contract Trust 2006-A

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

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

Issuer: Origen Manufactured Housing Contract Trust Collateralized
Notes, Series 2004-B

Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Oct 12, 2004 Assigned Aaa (sf)

Cl. M-2, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Oct 12, 2004 Assigned A2 (sf)

Issuer: Origen Manufactured Housing Contract Trust Collateralized
Notes, Series 2007-A

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

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

Issuer: Security Pacific Acceptance Corp., Seller, Manufactured
Housing Contract Senior/Subordinate Pass-Through Certificates,
Series 1995-1

A-4, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Jan 16, 2009 Upgraded to A1 (sf)

Financial Guarantor: Capital Markets Assurance Corporation
(Downgraded to B3, Outlook Negative on Jun 25, 2009)

Issuer: UCFC funding Corporation Series 1997-2

M, B2 (sf) Placed Under Review for Possible Downgrade; previously
on Sep 28, 2004 Downgraded to B2 (sf)

Issuer: Vanderbilt Acquisition Loan Trust (VALT) Manufactured
Housing Contract, Series 2002-1

Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jun 21, 2002 Assigned Aaa (sf)

Cl. A-5, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 21, 2002 Assigned Aa2 (sf)

Cl. M-1, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 21, 2002 Assigned A2 (sf)

Issuer: Vanderbilt Mortgage and Finance Inc. 1999A

IA-6, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 30, 2009 Downgraded to A2 (sf)

IM-1, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 30, 2009 Downgraded to Baa1 (sf)

Issuer: Vanderbilt Mortgage and Finance Senior/Subordinate Pass-
Through Certificates, Series 2002-B

Cl. A-5, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 16, 2010 Downgraded to A1 (sf)

Cl. M-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 16, 2010 Downgraded to Baa2 (sf)

Issuer: Vanderbilt Mortgage and Finance, Inc. 2000A

Cl. IIA-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Feb 29, 2000 Assigned Aaa (sf)

Cl. IM-1, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Feb 29, 2000 Assigned A2 (sf)

Issuer: Vanderbilt Mortgage and Finance, Inc. 2000-B

Cl. IM-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 30, 2009 Downgraded to Baa2 (sf)

Issuer: Vanderbilt Mortgage and Finance, Inc. Series 1999-C

IA-5, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Aug 27, 1999 Assigned Aa3 (sf)

IM-1, A2 (sf) Placed Under Review for Possible Downgrade;
previously on Aug 27, 1999 Assigned A2 (sf)

Issuer: Vanderbilt Mortgage and Finance, Inc. Series 1999-D

Cl. IIA-1, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Sep 23, 2009 Confirmed at Aaa (sf)

Cl. IA-5, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 16, 2010 Downgraded to A1 (sf)

Cl. IM-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 16, 2010 Downgraded to Baa2 (sf)

Issuer: Vanderbilt Mortgage and Finance, Inc., Series 2000-D

Cl. A-5, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Nov 30, 2000 Assigned Aa3 (sf)

Cl. M-1, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 16, 2010 Downgraded to Baa1 (sf)

Issuer: Vanderbilt Mortgage and Finance, Inc. Series 2001-B

Cl. A-4, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Aug 23, 2001 Assigned Aaa (sf)

Issuer: Vanderbilt Mortgage and Finance, Inc. Series 2003-A

Cl. M-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Dec 16, 2010 Downgraded to Baa2 (sf)

Cl. B-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 25, 2003 Assigned Baa2 (sf)

Issuer: Signal Securitization Corp. Series 1998-1

Class A, Baa1 (sf) Placed Under Review for Possible Upgrade;
previously on Oct 29, 2004 Downgraded to Baa1 (sf)

Issuer: Deutsche Financial Capital Securitization, 1997-I

Class A-3, A3 (sf) Placed Under Review for Possible Upgrade;
previously on Apr 8, 2004 Downgraded to A3 (sf)

Class A-4, A3 (sf) Placed Under Review for Possible Upgrade;
previously on Apr 8, 2004 Downgraded to A3 (sf)

Class A-5, A3 (sf) Placed Under Review for Possible Upgrade;
previously on Apr 8, 2004 Downgraded to A3 (sf)

Class A-6, A3 (sf) Placed Under Review for Possible Upgrade;
previously on Apr 8, 2004 Downgraded to A3 (sf)

Issuer: FirstFed Corp. Manufactured Housing Contract Series 1997-1

Class B, Ba3 (sf) Placed Under Review for Possible Upgrade;
previously on Oct 29, 2004 Downgraded to Ba3 (sf)

Issuer: Green Tree Financial Corporation - Green Tree MH
Contracts, Series 1995-2

B-1, Ba1 (sf) Placed Under Review for Possible Upgrade; previously
on Dec 29, 2003 Downgraded to Ba1 (sf)

Issuer: Green Tree MH Sr/Sub Series 1995-7

M-1, Baa2 (sf) Placed Under Review for Possible Upgrade;
previously on Dec 29, 2003 Downgraded to Baa2 (sf)

Issuer: Green Tree Series 1995-4

M-1, A3 (sf) Placed Under Review for Possible Upgrade; previously
on Dec 29, 2003 Downgraded to A3 (sf)

Issuer: GreenTree Manufactured Housing Contract Senior/Subordinate
Pass-Through Certificates, Series 1995-5

M-1, A2 (sf) Placed Under Review for Possible Upgrade; previously
on Dec 29, 2003 Downgraded to A2 (sf)

Issuer: Greenwich Capital Acceptance, Inc. MH Contract Series
1995-BA1

B-1, Ba3 (sf) Placed Under Review for Possible Upgrade; previously
on Oct 18, 2004 Downgraded to Ba3 (sf)

Issuer: Madison Avenue Manufactured Housing Contract Trust 2002-A

Cl. M-1, Baa1 (sf) Placed Under Review for Possible Upgrade;
previously on Aug 2, 2006 Upgraded to Baa1 (sf)

Issuer: MERIT Securities Corporation Collateralized Bonds, Series
12

1-A-3, Baa2 (sf) Placed Under Review for Possible Upgrade;
previously on May 13, 2004 Downgraded to Baa2 (sf)

Issuer: MERIT Securities Corporation Collateralized Bonds, Series
13

A4, Baa3 (sf) Placed Under Review for Possible Upgrade; previously
on Feb 24, 2004 Downgraded to Baa3 (sf)

Issuer: Oakwood Mortgage Investors, Inc. Series 1997-D

A-3, A2 (sf) Placed Under Review for Possible Upgrade; previously
on Mar 25, 2004 Downgraded to A2 (sf)

A-4, A2 (sf) Placed Under Review for Possible Upgrade; previously
on Mar 25, 2004 Downgraded to A2 (sf)

A-5, A2 (sf) Placed Under Review for Possible Upgrade; previously
on Mar 25, 2004 Downgraded to A2 (sf)

Issuer: Oakwood Mortgage Investors, Inc. Series, 1998-A

A-4, A3 (sf) Placed Under Review for Possible Upgrade; previously
on Mar 25, 2004 Downgraded to A3 (sf)

A-5, A3 (sf) Placed Under Review for Possible Upgrade; previously
on Mar 25, 2004 Downgraded to A3 (sf)

Issuer: UCFC Funding Corporation 1996-2

Class A, A1 (sf) Placed Under Review for Possible Upgrade;
previously on Jan 16, 2009 Upgraded to A1 (sf)

Financial Guarantor: MBIA Insurance Corporation (Downgraded to B3,
Outlook Negative on Jun 25, 2009)

Issuer: UCFC Funding Corporation Series 1997-3

A-4, Baa2 (sf) Placed Under Review for Possible Upgrade;
previously on Sep 28, 2004 Downgraded to Baa2 (sf)

Issuer: UCFC Funding Corporation Series 1997-4

A-4, B1 (sf) Placed Under Review for Possible Upgrade; previously
on Sep 28, 2004 Downgraded to B1 (sf)

Issuer: BankAmerica Manufactured Housing Contract Trust II Series
1997-1

M, B1 (sf) Placed Under Review for Possible Upgrade; previously on
Feb 8, 2006 Downgraded to B1 (sf)

Issuer: BankAmerica MH Contract 1998-2

M, Ba2 (sf) Placed Under Review for Possible Upgrade; previously
on Feb 8, 2006 Downgraded to Ba2 (sf)

Issuer: BankAmerica MH Contract, Series 1998-1

M, Baa1 (sf) Placed Under Review for Possible Upgrade; previously
on Oct 5, 2004 Downgraded to Baa1 (sf)

Issuer: Conseco Finance Securitizations Corp. Manufactured Housing
Contract Senior/Subordinate Pass-Through Certificates

Cl. A-5, Ca (sf) Placed Under Review for Possible Upgrade;
previously on Mar 30, 2009 Downgraded to Ca (sf)

Issuer: Conseco Finance Securitizations Corp. Series 2000-5

Cl. A-6, Ca (sf) Placed Under Review for Possible Upgrade;
previously on Mar 30, 2009 Downgraded to Ca (sf)

Issuer: Conseco Finance Securitizations Corp. Series 2002-1

Class A-1, Baa1 (sf) Placed Under Review for Possible Upgrade;
previously on Aug 2, 2006 Downgraded to Baa1 (sf)

Issuer: Green Tree Financial Corporation - MH Contract Ser. 1997-2

A-6, Baa1 (sf) Placed Under Review for Possible Upgrade;
previously on Dec 13, 2004 Downgraded to Baa1 (sf)

Issuer: Green Tree Financial Corporation MH Series 1997-1

A-5, A2 (sf) Placed Under Review for Possible Upgrade; previously
on Dec 13, 2004 Downgraded to A2 (sf)

A-6, A2 (sf) Placed Under Review for Possible Upgrade; previously
on Dec 13, 2004 Downgraded to A2 (sf)

Issuer: Greenpoint Manufactured Housing Contract Trust 1999-5

Cl. A-4, Ba1 (sf) Placed Under Review for Possible Upgrade;
previously on Oct 6, 2004 Downgraded to Ba1 (sf)

Cl. A-5, Ba1 (sf) Placed Under Review for Possible Upgrade;
previously on Oct 6, 2004 Downgraded to Ba1 (sf)

Cl. M-1A, Ca (sf) Placed Under Review for Possible Upgrade;
previously on Oct 6, 2004 Downgraded to Ca (sf)

Cl. M-1B, Ca (sf) Placed Under Review for Possible Upgrade;
previously on Oct 6, 2004 Downgraded to Ca (sf)


AERCO LIMITED: Fitch Affirms 'Dsf' Ratings on Two Note Classes
--------------------------------------------------------------
Fitch Ratings has taken these rating actions on AerCo Limited:

  -- Class A-3 notes affirmed at 'BBsf', Rating Outlook Negative;
  -- Class B-1 and B-2 revised to 'Csf/RR6' from 'Csf/RR5';
  -- Class C-1, C-2, and D-2 affirmed at 'Dsf/RR6'.

Consistent with Fitch's criteria titled 'Global Rating Criteria
for Aircraft Operating Lease ABS,' dated April 25, 2011, Fitch's
analysis incorporated the expected net cash flow to be available
to service debt over the remaining life of the transaction.
Fitch's expected cash flow takes several factors into account,
including aircraft age, portfolio value, Fitch's expectations for
the commercial aviation industry, remarketing expenses and
downtime, potential lease rates on the aircraft, and perceived
liquidity of the aircraft in the portfolio.

The affirmation of the class A-3 notes at 'BBsf' with a Negative
Outlook is representative of multiple factors. Under Fitch's cash
flow analysis, the class A-3 notes were found to be modestly short
of passing certain 'BBsf' stressed-case scenarios.  However, the
collateral position of the notes, as measured by the loan to value
(LTV) ratio, has improved since the last review due to principal
amortization and the payout of the class A-4 notes.  As such,
Fitch has not downgraded the notes at this time, since leverage
has improved, the transaction has a long remaining term, and the
currently strong airline operating environment could support
improving lease rates in the near term.

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

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


AMERICREDIT AUTOMOBILE: S&P Gives 'BB+' Rating on Class E Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
AmeriCredit Automobile Receivables Trust 2011-5's $900 million
automobile receivables-backed notes.

The note issuance is an asset-backed securities transaction backed
by subprime auto loan receivables.

The ratings reflect:

    "The availability of approximately 44.1%, 39.1%, 32.1%, 25.8%,
    and 22.9% credit support for the class A, B, C, D, and E notes
    (based on stressed cash-flow scenarios, including excess
    spread), which provide coverage of more than 3.50x, 3.00x,
    2.55x, 1.75x, and 1.60x our 11.75%-12.25% expected cumulative
    net loss range for the class A, B, C, D, and E notes. These
    credit support levels are commensurate with the assigned 'AAA
    (sf)', 'AA (sf)', 'A+ (sf)', 'BBB (sf)', and 'BB+ (sf)'
    ratings on the class A, B, C, D, and E notes," S&P related.

    "Our expectation that under a moderate, or 'BBB', stress
    scenario, our ratings on the class A, B, and C notes will
    remain within one rating category of the ratings (all else
    being equal) during the first year. This is within the one-
    category tolerance for 'AAA' and 'AA' rated securities and
    within the two-category tolerance for 'A' rated securities, as
    outlined in our credit stability criteria (see 'Methodology:
    Credit Stability Criteria,' published May 3, 2010). In
    addition, under this moderate stress scenario, we expect that
    our ratings on the class D and E notes will remain within the
    two-category tolerance for 'BBB' and 'BB' rated securities
    over the first year," S&P said.

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

    The timely interest and ultimate principal payments made under
    the stressed cash-flow modeling scenarios, which are
    consistent with the assigned ratings.

    The collateral characteristics of the securitized pool of
    subprime auto loans.

    "General Motors Financial Co. Inc.'s (GM Financial's, formerly
    known as AmeriCredit Corp.; B+/Stable/--) extensive
    securitization performance history since 1994. On March 30,
    2011, Standard & Poor's raised its long-term counterparty
    credit rating on GM Financial to 'B+' from 'B' and removed the
    rating from CreditWatch positive, where we had placed it on
    Oct. 8, 2010," S&P said.

    The transaction's payment and legal structures.

            Standard & Poor's 17g-7 Disclosure Report

SEC Rule 17g-7 requires an NRSRO, for any report accompanying a
credit rating relating to an asset-backed security as defined in
the Rule, to include a description of the representations,
warranties and enforcement mechanisms available to investors and a
description of how they differ from the representations,
warranties and enforcement mechanisms in issuances of similar
securities.

The Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at

   http://standardandpoorsdisclosure-17g7.com/1111222.pdf

Ratings Assigned
AmeriCredit Automobile Receivables Trust 2011-5

Class    Rating        Type            Interest        Amount
                                       rate          (mil. $)
A-1      A-1+ (sf)     Senior          Fixed          147.300
A-2      AAA (sf)      Senior          Fixed          344.600
A-3      AAA (sf)      Senior          Fixed          145.983
B        AA (sf)       Subordinate     Fixed           69.231
C        A+ (sf)       Subordinate     Fixed           85.943
D        BBB (sf)      Subordinate     Fixed           84.510
E        BB+ (sf)      Subordinate     Fixed           22.433


AMMC VIII: S&P Raises Rating on Class E Notes From 'B+' to 'BB'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1, A-2, B, C, D, and E notes from AMMC VIII Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
American Money Management Corp. "At the same time, we removed our
ratings on the class A-1, A-2, and B notes from CreditWatch, where
we placed them with positive implications on Aug. 2, 2011," S&P
related.

"The upgrades reflect improved performance we have observed
in the deal's underlying asset portfolio since we lowered our
ratings on all of the classes on Jan. 11, 2010, following the
application of our September 2009 corporate collateralized debt
obligation (CDO) criteria. As of the Sept. 20, 2011, trustee
report, the transaction's asset portfolio had $5.74 million
in defaulted obligations and approximately $15.97 million in
assets from obligors with a Standard & Poor's rating less than
or equal to 'CCC+'. This was a decrease from $14.68 million
in defaulted obligations and approximately $72.57 million in
assets from obligors with a Standard & Poor's rating less than
or equal to 'CCC+' noted in the Nov. 17, 2009, trustee report,
which we used for our January 2010 rating actions," S&P stated.

"We also observed an increase in the overcollateralization
available to support the rated notes," S&P said. The trustee
reported these par value ratios in the Sept. 20, 2011, monthly
report:

    The class A/B par value ratio was 121.83%, compared with a
    reported ratio of 117.45% in November 2009;

    The class C par value ratio was 116.00%, compared with a
    reported ratio of 111.82% in November 2009; and

    The class D par value ratio was 110.70%, compared with a
    reported ratio of 106.72% in November 2009; and

    The class E par value ratio was 106.95%, compared with a
    reported ratio of 103.08% in November 2009.

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

Rating And CreditWatch Actions

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


ARCC COMMERCIAL: Moodys Upgrades Ratings of CLO Notes
-----------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by ARCC Commercial Loan Trust 2006:

Class A-1B Floating Rate Notes Due 2019, Upgraded to Aaa (sf);
Previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

Class B Floating Rate Deferrable Interest Notes Due 2019-1,
Upgraded to Aaa (sf); Previously on June 22, 2011 Aa3 (sf) Placed
Under Review for Possible Upgrade;

Class C Floating Rate Deferrable Interest Notes Due 2019, Upgraded
to Aaa (sf); Previously on June 22, 2011 Baa2 (sf) Placed Under
Review for Possible Upgrade;

Class D Floating Rate Deferrable Interest Notes Due 2019, Upgraded
to A1 (sf); Previously on June 22, 2011 Ba3 (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 rating actions also reflect consideration of delevering of the
senior notes since the rating action in September 2010. Moody's
notes that the Class A Notes have been paid down by approximately
41.8% or $76.1 million since the rating action in September 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 $265.3 million,
defaulted par of $0 million, a weighted average default
probability of 36.0% (implying a WARF of 6070), a weighted average
recovery rate upon default of 49.9%, and a diversity score of 19.
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.

ARCC Commercial Loan Trust 2006, issued in July 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans of middle market issuers.

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, 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates. Moody's also conducted stress tests to assess
the collateral pool's concentration risk in obligors bearing a
credit estimate that constitute more than 3% of the collateral
pool.


BCAP LLC: S&P Lowers Ratings on 3 Classes of Re-REMIC to 'D'
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on 12
classes from three U.S. residential mortgage-backed securities
(RMBS) resecuritized real estate mortgage investment conduit (re-
REMIC) transactions issued in 2004-2010 and removed 11 of them
from CreditWatch negative. "In addition, we affirmed our ratings
on 12 classes from three transactions with lowered ratings and one
other transaction and removed nine of them from CreditWatch
negative. We also withdrew our ratings on three classes from two
transactions based on our interest-only criteria, two of which
were on CreditWatch negative prior to the ratings withdrawal," S&P
said.

Three of the transactions reviewed (Bear Stearns Structured
Products Inc. Trust Series 2008-R2, Bear Stearns Structured
Products Trust 2008-R3, and BCAP LLC 2010-RR5 Trust) pay interest
on a pro rata basis and the other three pay interest sequentially.

"On Dec. 15, 2010, we placed our ratings on 22 classes from the
six
transactions within this review on CreditWatch negative, along
with ratings from a group of other RMBS re-REMIC securities (for
more information, see 'S&P Corrects: 1,196 Ratings on 129 U.S.
RMBS Re-REMIC Transactions Placed on CreditWatch Negative').
Additionally, on April 1, 2011, we provided an update on the
CreditWatch placements and provided clarification regarding our
analysis of interest payment amounts within re-REMIC transactions
(see 'Standard & Poor's Provides An Update On Outstanding RMBS Re-
REMIC CreditWatch Placements And Outlines Their Resolution')," S&P
said.

"We intend for our ratings on the re-REMIC classes to address the
timely payment of interest and ultimate payment of principal. We
reviewed the interest and principal amounts due on the underlying
securities, which are then passed through to the applicable re-
REMIC classes. When performing this analysis, we applied our loss
assumptions and projections to the underlying collateral to
identify the principal and interest amounts that could be passed
through from the underlying securities under our rating scenario
stresses. We stressed our loss projections at various rating
categories to assess whether the re-REMIC classes could withstand
the stressed losses associated with their ratings while receiving
timely payment of interest and principal consistent with our
criteria," S&P said.

"As noted, in applying our loss projections we incorporated, where
applicable, our current loss assumptions as outlined in 'Revised
Lifetime Loss Projections For Prime, Subprime, And Alt-A U.S. RMBS
Issued In 2005-2007,' published on March 25, 2011, into our
review. Such updates pertain to the 2005-2007 vintage prime,
subprime, and Alternative-A (Alt-A) transactions, some of which
are associated with the re-REMICs we reviewed (see tables 1 and
2 for the overall prior and revised vintage- and product-specific
lifetime loss projections as percentages of the original structure
balance)," S&P said.

Table 1
Lifetime Loss Projections For Prime And Subprime RMBS
(Percent of original balance)
              Prime RMBS      Subprime RMBS
               Aggregate        Aggregate
Vintage     Updated  Prior    Updated  Prior
2005            5.5   4.00      18.25  15.40
2006           9.25   6.60      38.25  35.00
2007          11.75   9.75      48.50  43.20

Table 2
Lifetime Loss Projections For Alternative-A RMBS
(Percent of original balance)
                                 Fixed/
             Aggregate         long-reset
Vintage    Updated  Prior    Updated  Prior
2005         13.75  11.25      12.75   9.60
2006         29.50  26.25      25.25  25.00
2007         36.00  31.25      31.75  26.25

            Short-reset
               hybrid          Option ARM
Vintage    Updated  Prior    Updated  Prior
2005         13.25  14.75      15.50  13.25
2006         30.00  30.50      34.75  26.75
2007         41.00  40.75      43.50  37.50

"We also based our downgrades on our assessment as to whether
there were principal and/or interest shortfalls, as well as on our
projections of principal losses from the underlying securities
that would impair the re-REMIC classes at the applicable rating
stresses," S&P related.

"In the BCAP LLC 2010-RR5-I Trust transaction, class III-A3, which
we downgraded to 'D (sf)' from 'AAA (sf)', had sufficient
projected credit enhancement to pay ultimate principal under our
'AAA' projected loss stress. And classes III-A1 and III-A4 from
the same transaction, which we downgraded to 'D (sf)' from 'A
(sf)', had sufficient projected credit enhancement to pay ultimate
principal under our 'BBB' projected loss stress. However, the
downgrades to 'D (sf)' reflect the correction on our analysis of
interest payments, as well as our assessment of the impact of
observed interest shortfalls, which have occurred over the
previous 12 months and which we have deemed to be nonrecoverable
applying our criteria as outlined in 'Methodology For Assessing
the Impact Of Interest Shortfalls On U.S. RMBS', published Sept.
23, 2011," S&P said.

"The affirmations reflect our assessment of the likelihood that
the re-REMIC classes will receive timely interest and the ultimate
payment of principal under the applicable stressed assumptions,"
S&P said.

Rating Actions

BCAP LLC 2010-RR5-I Trust
Series      2010-RR5-I
                               Rating
Class      CUSIP       To                   From
III-A4     05532UAW9   D (sf)               A (sf)/Watch Neg
I-A2       05532UAB5   BB+ (sf)             AA (sf)/Watch Neg
II-A9      05532UAR0   BBB (sf)             BBB (sf)/Watch Neg
III-A3     05532UAV1   D (sf)               AAA (sf)/Watch Neg
II-A3      05532UAK5   A (sf)               A (sf)/Watch Neg
III-A1     05532UAT6   D (sf)               A (sf)/Watch Neg
I-A1       05532UAA7   BB+ (sf)             AAA (sf)/Watch Neg
I-A5       05532UAE9   BB (sf)              BBB (sf)/Watch Neg
II-A4      05532UAL3   BBB (sf)             BBB (sf)/Watch Neg
II-A6      05532UAN9   A (sf)               A (sf)/Watch Neg
I-A3       05532UAC3   BB (sf)              BBB (sf)/Watch Neg
I-A6       05532UAF6   BB (sf)              BBB (sf)/Watch Neg
II-A7      05532UAP4   BBB (sf)             BBB (sf)/Watch Neg
II-A2      05532UAJ8   AA (sf)              AA (sf)/Watch Neg
I-A4       05532UAD1   BB+ (sf)             AA (sf)/Watch Neg
II-A8      05532UAQ2   BBB (sf)             BBB (sf)/Watch Neg
II-A5      05532UAM1   AA (sf)              AA (sf)/Watch Neg

CMO Holdings III Ltd.
Series      2007-R4
                               Rating
Class      CUSIP       To                   From
A-2        12587PDG2   BBB (sf)             BBB (sf)/Watch Neg

CMO Holdings III Ltd.
Series      2008-R2
                               Rating
Class      CUSIP       To                   From
I-A-1      12587PFK1   CC (sf)              CCC (sf)
II-A-1     12587PFM7   CCC (sf)             B- (sf)/Watch Neg

CMO Holdings III Ltd.
Series      2008-R3
                               Rating
Class      CUSIP       To                   From
II-A-1     12587PFR6   CCC (sf)             BBB (sf)/Watch Neg

Structured Asset Securities Corp.
Series      2004-1
                               Rating
Class      CUSIP       To                   From
A          86359BJY8   NR                   AAA (sf)/Watch Neg
R          86359BJZ5   NR                   AAA (sf)

Structured Asset Securities Corp.
Series      2005-8
                               Rating
Class      CUSIP       To                   From
A          86359DAA5   NR                   AA+ (sf)/Watch Neg


RATINGS AFFIRMED

BCAP LLC 2010-RR5-I Trust
Series      2010-RR5-I
Class      CUSIP       Rating
II-A1      05532UAH2   AAA (sf)

CMO Holdings III Ltd.
Series      2008-R2
Class      CUSIP       Rating
II-A-2     12587PFN5   CC (sf)

CMO Holdings III Ltd.
Series      2008-R3
Class      CUSIP       Rating
II-A-2     12587PFS4   CC (sf)


BLUEGREEN CORPORATION: Moody's Raises Cl. D Notes Rating to Baa2
----------------------------------------------------------------
Moody's Investors Service upgraded three classes of notes from BXG
Receivables Note Trust 2004-B, which is sponsored by Bluegreen
Corporation (Bluegreen). The underlying collateral consists of
timeshare loan receivables issued and serviced by Bluegreen.

RATINGS RATIONALE

The upgrades reflect the buildup in credit enhancement and
continued improvement in the performance of the underlying
collateral. The trust is currently at its overcollateralization
target of 9% of the outstanding pool balance. The non-declining
reserve further increased to 18.9% as of the September 2011 report
from 16.6% when the notes were placed on review in July 2011. The
6-month average monthly gross charge-off rate was approximately
0.7%, which is consistent with the pre-crisis level. 60 day plus
delinquency levels remain stable at 1.5-2% as a percentage of the
current pool balance and is close to the historical low since
closing.

The principal methodology used in the rating action was "Moody's
Approach to Rating Vacation Timeshare Loan Securitizations",
published on September 19, 2011. Other methodologies and factors
that may have been considered in the process of rating this issue
can also be found in the Rating Methodologies sub-directory on
Moody's website.

Our expected lifetime net loss as a percentage of the original
pool balance plus cumulative substitutions for defaulted loans is
approximately 28.6%. The ratings of Class B, C and D could be
upgraded in the future if the lifetime expected net losses are 5%
lower, or downgraded if the lifetime expected net losses are 5%
higher than the levels indicated above, on a relative basis.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected
range will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of uncertainty with
regard to expected losses are the weak economic environment, which
adversely impacts the income-generating ability of the borrowers.
Overall, Moody's expects overall a sluggish recovery in most of
the world largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

RATINGS

Issuer: BXG Receivables Note Trust 2004-B

Cl. B, Upgraded to Aa1 (sf); previously on Jul 19, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

Cl. C, Upgraded to Aa3 (sf); previously on Jul 19, 2011 A3 (sf)
Placed Under Review for Possible Upgrade

Cl. D, Upgraded to Baa2 (sf); previously on Jul 19, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade


BRASCAN REAL ESTATE: Moody's Upgrades Ratings of Two Notes Classes
------------------------------------------------------------------
Moody's has affirmed the ratings of one class, upgraded the
ratings of two classes and downgraded the ratings of one class
of Notes issued by Brascan Real Estate CDO 2004-1 due to
deterioration in the underlying collateral as evidenced by the
Moody's weighted average rating factor (WARF) and recovery rate
(WARR). The upgrades are due to material amortization since
Moody's last review and the affirmation is due to key transaction
parameters performing within levels commensurate with the existing
ratings levels. The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation (CRE CDO CLO) transactions.

Moody's rating action is:

Cl. B, Affirmed at Aaa (sf); previously on Dec 1, 2010 Upgraded to
Aaa (sf)

Cl. C, Upgraded to Aaa (sf); previously on Dec 1, 2010 Upgraded to
Aa1 (sf)

Cl. D, Upgraded to Aa2 (sf); previously on Dec 1, 2010 Upgraded to
A1 (sf)

Cl. E, Downgraded to Baa1 (sf); previously on Dec 1, 2010 Upgraded
to A3 (sf)

RATINGS RATIONALE

Brascan Real Estate CDO 2004-1 is currently a static cash CRE CDO
transaction (the reinvestment period ended January 2010) backed by
a portfolio of commercial mortgage backed securities (CMBS) (80.2%
of the pool balance), commercial real estate CDOs (CRE CDOs)
(3.7%) and one B-Note (16.1%). As of the October 17, 2011 Trustee
report, the aggregate Note balance of the transaction, including
preferred shares, was reduced to $79.7 million from $300.7 million
at issuance due to amortization and payoffs of the underlying
collateral. As a result, Classes A Notes have been retired.

There are no assets that are considered Defaulted Securities as of
the October 17, 2011 Trustee report.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: weighted average
rating factor (WARF), weighted average life (WAL), weighted
average recovery rate (WARR), and Moody's asset correlation (MAC).
These parameters are typically modeled as actual parameters for
static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 2,654 compared to 2,208 at last review. The
distribution of current ratings and credit estimates is: Aaa-Aa3
(29.7% compared to 31.9% at last review), A1-A3 (9.0% compared to
14.7% at last review), Baa1-Baa3 (14.8% compared to 7.0% at last
review), Ba1-Ba3 (12.1% compared to 10.6% at last review), B1-B3
(14.3% compared to 14.0% at last review), and Caa1-C (20.0%
compared to 21.7% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 2.6 years compared
to 2.7 at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
31.2% compared to 39.5% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 10.1% compared to 5.9% at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

The cash flow model, CDOEdge(R) v3.2.1.0, was used to analyze the
cash flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
31.2% to 21.2% or up to 41.2% would result in average rating
movement on the rated tranches of two notches downward and one to
two notches upward, respectively.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected
range will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of assumption uncertainty
are the current sluggish macroeconomic environment and 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 methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in November 2010, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


BRASCAN STRUCTURED: Moody's Raises Rating of Cl. D Notes to 'Ba3'
-----------------------------------------------------------------
Moody's has affirmed the ratings of one class and upgraded the
rating of one class of Notes issued by Brascan Structured Notes
2005-2 due to significant amortization since Moody's last review
in November 2010. The affirmation is due to key transaction
parameters performing within levels commensurate with the existing
ratings levels. The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation (CRE CDO CLO) transactions.

Moody's rating action is:

Cl. D, Upgraded to Ba3 (sf); previously on November 17, 2010
Downgraded to B3 (sf)

Cl. E, Affirmed at Caa3 (sf); previously on November 17, 2010
Downgraded to Caa3 (sf)

RATINGS RATIONALE

Brascan Structured Notes 2005-2 is currently a static cash
CRE CDO transaction (the reinvestment period ended December
2010) backed by a portfolio of B-Notes (34.5% of the pool
balance) and mezzanine loans (65.5%). As of the September 15, 2011
Trustee report, the aggregate Note balance of the transaction,
including preferred shares, was reduced to $106.4 million from
$300.0 million at issuance due to amortization and payoffs of the
underlying collateral. As a result, Classes A, B and C Notes have
been retired. In addition, two JPMorgan Portfolio loans in the
amount of $5.1 million paid off on September 26, 2011, which is
reflected in the analysis.

There are two assets with a par balance of $25.0 million (21.8% of
the current pool balance) that are considered Defaulted Securities
as of the September 15, 2011 Trustee report. Both assets (100% of
the defaulted balance) are mezzanine loans. Defaulted Securities
that are not CMBS are defined as assets which are 60 or more days
delinquent in their debt service payment. While there have been no
realized losses to date, Moody's does expect significant losses to
occur once they are realized.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: weighted average
rating factor (WARF), weighted average life (WAL), weighted
average recovery rate (WARR), and

Moody's asset correlation (MAC). These parameters are typically
modeled as actual parameters for static deals and as covenants for
managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 8,788 compared to 6,762 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (0.0% compared to 8.1% at last review), A1-A3
(0.0% compared to 0.0% at last review), Baa1-Baa3 (0.0% compared
to 0.0% at last review), Ba1-Ba3 (0.0% compared to 20.3% at last
review), B1-B3 (0.0% compared to 9.7% at last review), and Caa1-C
(100% compared to 61.9% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 2.0 years compared
to 3.2 at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
0.0% compared to 11.1% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 99.9%, the same as at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

The cash flow model, CDOEdge(R) v3.2.1.0, was used to analyze the
cash flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption from 0%
up to 2% would result in average rating movement on the rated
tranches of 1 to 2 notches upward.

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 methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in November 2010, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


BSCMS 2006-TOP24: Moody's Affirms Ratings of Eight CMBS Classes
---------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded these ratings of six
classes and affirmed eight classes of Bear Stearns Commercial
Mortgage Securities Trust, Commercial Mortgage Pass-Through
Certificates, Series 2006-TOP24:

Cl. A-3, Affirmed at Aaa (sf); previously on Nov 6, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Nov 6, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Nov 6, 2006
Definitive Rating Assigned Aaa (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on Nov 6, 2006
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on Nov 6, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Upgraded to A1 (sf); previously on Nov 17, 2010
Downgraded to A2 (sf)

Cl. A-J, Upgraded to Ba3 (sf); previously on Nov 17, 2010
Downgraded to B1 (sf)

Cl. B, Upgraded to B2 (sf); previously on Nov 17, 2010 Downgraded
to B3 (sf)

Cl. C, Upgraded to B3 (sf); previously on Nov 17, 2010 Downgraded
to Caa1 (sf)

Cl. D, Upgraded to Caa3 (sf); previously on Nov 17, 2010
Downgraded to Ca (sf)

Cl. E, Upgraded to Ca (sf); previously on Nov 17, 2010 Downgraded
to C (sf)

Cl. F, Affirmed at C (sf); previously on Nov 17, 2010 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Nov 17, 2010 Downgraded
to C (sf)

Cl. H, Affirmed at C (sf); previously on Nov 17, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

The upgrades are due to lower than expected losses from liquidated
loans along with increased credit support due to loan payoffs and
amortization. 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
6.0% of the current balance. At last full review, Moody's
cumulative base expected loss was 9.7%. Moody's stressed scenario
loss is 13.5% of the current balance.  Depending on the timing of
loan payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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 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 26, compared to 27 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.

DEAL PERFORMANCE

As of the October 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 21% to
$1.22 billion from $1.53 billion at securitization. The
Certificates are collateralized by 145 mortgage loans ranging in
size from less than 1% to 15% of the pool, with the top ten loans
representing 44% of the pool. The pool includes three loans with
investment grade credit estimates, representing 3% of the pool. A
fourth loan, Lincroft Office Center ($10.0 million -- 0.8% of the
pool), had a credit estimate at last review but due to a decline
in performance it is now analyzed as part of the conduit pool. Two
loans, representing 1% of the pool, have defeased and are
collateralized with U.S. Government securities.

Thirty-five loans, representing 18% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Eight loans have been liquidated from the pool since
securitization, resulting in an aggregate realized loss of
$45.1 million (36% loss severity). Five loans, representing 6%
of the pool, are currently in special servicing. The largest
specially serviced loan is the Hilton Tapatio Loan ($53.3 million
-- 4.4% of the pool), which is secured by a 585 key hotel located
in Phoenix, Arizona. The loan was transferred to special servicing
in October 2009 due to imminent default and is currently real
estate owned (REO). The master servicer has recognized a
$10.6 million appraisal reduction on the loan. The remaining
four specially serviced loans are secured by a mix of property
types. Moody's has estimated an aggregate $20.3 million loss (30%
expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for 18 poorly
performing loans representing 15% of the pool and has estimated an
aggregate $22.1 million loss (20% 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 95% and 76%, respectively, of the performing
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV for the conduit component is 100% compared to
104% at Moody's prior review. Moody's net cash flow reflects a
weighted average haircut of 14% to the most recently available net
operating income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.6%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.43X and 1.09X,
respectively, compared 1.39X and 1.04X 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
Lee Harrison Center Loan ($15.0 million -- 1.2% of the pool),
which is secured by a 110,000 square foot retail center located in
Arlington, Virginia. The center was 100% leased as of December
2010, essentially the same as at last review. Performance has been
stable. Moody's credit estimate and stressed DSCR are Baa1 and
1.79X, respectively, compared to Baa1 and 1.82X at last review.

The second loan with an investment grade credit estimate is the
461 Fifth Avenue Loan ($15.0 million -- 1.2% of the pool), which
is secured by a fee position in a parcel of land located in the
Grand Central submarket of Manhattan. Moody's credit estimate and
stressed DSCR are Aaa and 1.51X, respectively, the same as last
review.

The third loan with an investment grade credit estimate is the
City National Bank Building Loan ($10.2 million -- 0.8% of the
pool), which is secured by a 109,000 square foot office building
located in North Hollywood, California. The property was 96%
leased as of March 2011, essentially the same as at last review.
Performance has improved due to higher revenues. Moody's credit
estimate and stressed DSCR are Baa1 and 1.85X, respectively,
compared to Baa2 and 1.66X at last review.

The top three performing conduit loans represent 25% of the
pool balance. The largest loan is the US Bancorp Tower Loan
($186.6 million -- 15.3% of the pool), which is secured by a
1.1 million square foot office building located in Portland,
Oregon. The property was 93% leased as of March 2011, essentially
the same as last review and securitization. Performance has been
stable. Moody's LTV and stressed DSCR are 109% and 0.91X,
respectively, compared to 109% and 0.92X at last review.

The second largest loan is the Dulles Executive Plaza Loan
($68.8 million -- 5.6% of the pool), which is secured by a
380,000 square foot office building located in Herndon, Virginia.
The property was 100% leased as of December 2010, the same as last
review. The largest tenant, Lockheed Martin Corporation (senior
unsecured rating Baa1, stable outlook) leases 90% of the net
rentable area (NRA) through February 2013. Moody's analysis
incorporates a significant downward adjustment to the borrower's
reported NOI to reflect potential volatility due to near term
rollover risk. Moody's LTV and stressed DSCR are 93% and 1.11X,
respectively, the same as last review.

The third largest loan is the Potomac Place Shopping Center Loan
($44.0 million -- 3.6% of the pool), which is secured by a 79,654
square foot retail center located in Potomac, Maryland. The
property was 96% leased as of June 2011, essentially the same as
at last review. Performance has been stable. Moody's LTV and
stressed DSCR are 97% and 0.97X, respectively, the same as at last
review.


BUCKEYE TOBACCO: S&P Puts 8 Asset-Backed Classes Ratings on Watch
-----------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 86
classes from 23 securitizations backed by payments from
participating tobacco manufacturers under the Master Settlement
Agreement (MSA) on CreditWatch with negative implications.

The CreditWatch placements follow Standard & Poor's revised
assumptions for cigarette volume declines, the percent of the MSA
paid into a disputed payment account]payment withheld into the
disputed payment account, and the recovery amounts the
securitizations expect to receive from the disputed payment
account (see Tobacco securitizations are independent of the
issuing municipality and are backed only by payments made by the
participating tobacco manufacturers (PMs) under the MSA, which was
signed in 1998. The PMs are designated either as original
participating manufacturers (OPMs) or subsequent participating
manufacturers (SPMs). The MSA requires the PMs to make payments to
each state annually, in perpetuity. After the agreement was
signed, many state and local governments sold all or a portion of
their rights to receive future settlement proceeds to investors in
exchange for a payment at the time of the sale.

Revised assumptions include:

    "We expect PM-disputed amounts to increase to 15% from our
    previous assumption of 10%. We base this on our view that
    going forward Philip Morris USA could continue to dispute its
    portion by paying into the disputed account," S&P related.

    "We lowered our recovery assumptions to 50%-75% from 80%-90%
    of the original disputed amounts in our nonparticipating
    manufacturer (NPM) adjustment liquidity stress. These recovery
    rates are now also tiered based on the rating on the classes
    (as detailed in the table below)," S&P said.

    Table 1
    Tiered NPM Recovery Rates
    Rating      Recovery rate (%)
    A                          50
    BBB                        65
    BB                         70
    B                          75

    "We are extending our 3.5% cigarette volume decline assumption
    another year. Our base-case projections are that shipments
    will likely decline 3.5% in 2011, between 3.25% and 3.75% in
    2012, and then between 2.75% and 3.25% annually in perpetuity.
    The criteria apply stresses that increase the volume decline
    assumption by 50 basis points for each rating category above
    'B' (see table 4 in 'Revised Assumptions For US Tobacco
    Settlement-Backed Transactions,' published Oct. 27, 2011, on
    RatingsDirect on the Global Credit Portal)," S&P said.

    "We maintain our assumptions about the duration of the
    disputes, base-case market shares, and reinvestment income of
    the reserve account funds," S&P said.

"We placed on CreditWatch negative the ratings on the classes that
exhibit an inability to pay timely interest or full principal at
their current rating level under at least one of a number of cash
flow scenarios under our revised assumptions," S&P said.

"Standard & Poor's expects to resolve the CreditWatch placements
within the next three months after we conduct a more detailed
review and may take further rating actions as we consider
appropriate based on our criteria," S&P said.

Ratings On CreditWatch Negative

Buckeye Tobacco Settlement Financing Authority
$5.532 bil tobacco settlement asset-backed bonds series 2007
                Sale amount       Rating
Class    Maturity  (mil. $) To                      From
2007 A-2 06/01/24  949.53   BB- (sf)/ Watch Neg     BB-(sf)
2007-A-2 06/01/24  200.00   BB- (sf)/ Watch Neg     BB- (sf)
2007 A-2 06/01/30  687.60   BB- (sf)/ Watch Neg     BB- (sf)
2007 A-2 06/01/34  505.20   BB- (sf)/ Watch Neg     BB- (sf)
2007-A-3 06/01/37  274.75   BB- (sf)/ Watch Neg     BB- (sf)
2007 A-2 06/01/42  250.00   BB- (sf)/ Watch Neg     BB- (sf)
2007 A-2 06/01/47  1383.72  BB- (sf)/ Watch Neg     BB- (sf)
2007 A-2 06/01/47  750.00   BB- (sf)/ Watch Neg     BB- (sf)

California County Tobacco Securitization Agency (Fresno County
Tobacco Funding Corp.)
$92.955 mil tobacco settlement asset backed bonds series 2002
                Sale amount       Rating
Class    Maturity  (mil. $) To                      From
2035     06/01/35  35.27    BBB (sf)/ Watch Neg     BBB (sf)
2038     06/01/38  18.50    BBB (sf)/ Watch Neg     BBB (sf)

California County Tobacco Securitization Agency (Gold Country
Settlement Funding Corp.)
$59.372 mil tobacco settlement asset backed bonds, gold county
settlement funding corp., series 2006
                Sale amount       Rating
Class    Maturity  (mil. $) To                      From
2006A    06/01/46  45.00    B- (sf)/ Watch Neg      B- (sf)
2006B    06/01/33  14.37    B- (sf)/ Watch Neg      B- (sf)

California County Tobacco Securitization Agency (Sonoma County
Securitization Corp.)
$83.06 mil tobacco settlement asset backed refunding bonds Sonoma
county securitization corp. series 2005
                Sale amount       Rating
Class   Maturity  (mil. $) To                       From
2005    06/01/26  9.92     BBB (sf)/ Watch Neg      BBB (sf)
2005    06/01/38  31.05    BBB (sf)/ Watch Neg      BBB (sf)
2005    06/01/45  27.26    BBB- (sf)/ Watch Neg     BBB- (sf)

California County Tobacco Securitization Agency (Kern County
Tobacco Funding Corp.)
$105.245 mil tobacco settlement asset-backed bonds
                Sale amount       Rating
Class    Maturity  (mil. $) To                      From
2002A    06/01/43  40.96    BBB (sf)/ Watch Neg     BBB (sf)
2002B    06/01/29  27.88    BBB (sf)/ Watch Neg     BBB (sf)
2002B    06/01/37  29.01    BBB (sf)/ Watch Neg     BBB (sf)

Children's Trust
$1.171 bil tobacco settlement asset-backed bonds series 2002
                Sale amount       Rating
Class    Maturity  (mil. $) To                      From
2039     05/15/39  310.38   BBB (sf)/ Watch Neg     BBB (sf)
2043     05/15/43  296.26   BBB (sf)/ Watch Neg     BBB (sf)

Erie Tobacco Asset Securitization Corp.
$318.835 mil tobacco settlement asset backed bonds series 2005 A&E
                Sale amount       Rating
Class    Maturity  (mil. $) To                    From
2005 A   06/01/45  111.48   BBB (sf)/ Watch Neg     BBB (sf)
2005 A   06/01/38  74.69    BBB (sf)/ Watch Neg     BBB (sf)
2005-A   06/01/31  30.33    BBB (sf)/ Watch Neg     BBB (sf)

Golden State Tobacco Securitization Corp.
$4.447 bil tobacco settlement asset backed bonds series 2007
               Sale amount       Rating
Class    Maturity (mil. $) To                        From
2007A-1  06/01/27  863.10  BBB- (sf)/ Watch Neg      BBB- (sf)
2007A-1  06/01/33  610.53  BB+ (sf)/ Watch Neg       BB+ (sf)
2007A-1  06/01/47  693.58  BB+ (sf)/ Watch Neg       BB+ (sf)
2007A-1  06/01/47  1250.00 BB+ (sf)/ Watch Neg       BB+ (sf)
2007A-2  06/01/37  389.19  BB+ (sf)/ Watch Neg       BB+ (sf)
2007-B   06/01/47  271.96  B (sf)/ Watch Neg         B (sf)
2007-C   06/01/47  78.55   B- (sf)/ Watch Neg        B- (sf)

Iowa Tobacco Settlement Authority
$838.962 mil tobacco settlement authority (Iowa) series 2005 A B C
D
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2005A    06/01/46  229.91   BBB (sf)/Watch Neg         BBB (sf)
2005B    06/01/34  159.37   BBB (sf)/Watch Neg         BBB (sf)
2005C    06/01/38  103.48   BBB (sf)/Watch Neg         BBB (sf)
2005C    06/01/46  174.13   BBB (sf)/Watch Neg         BBB (sf)
2005C    06/01/42  135.12   BBB (sf)/Watch Neg         BBB (sf)
2005D    06/01/46  15.78    BB+ (sf)/Watch Neg         BB+ (sf)

Michigan Tobacco Settlement Finance Authority
$490.501 mil taxable tobacco settlement asset backed bonds series
2006 A B C
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2006 A   06/01/34  363.12   BB+ (sf)/Watch Neg         BB+ (sf)

Michigan Tobacco Settlement Finance Authority
$522.992 mil tobacco settlement asset backed bonds series 2007 A B
C
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2007-A   06/01/22  57.19    BBB (sf)/Watch Neg         BBB (sf)
2007-A   06/01/48  290.09   BB (sf)/Watch Neg          BB (sf)
2007-A   06/01/22  20.00    BBB (sf)/Watch Neg         BBB (sf)
2007-A   06/01/34  112.86   BB (sf)/Watch Neg          BB (sf)
2007-B   06/01/52  35.65    B (sf)/Watch Neg           B (sf)
2007-C   06/01/52  7.22     B- (sf)/Watch Neg          B- (sf)

Nassau County Tobacco Settlement Corp.
$431.043 mil tobacco settlement asset backed bonds series 2006
                Sale amount       Rating
Class    Maturity  (mil. $) To                          From
2006A-1  06/01/19  42.65    BBB (sf)/Watch Neg          BBB (sf)
2006A-2  06/01/25  37.91    BBB (sf)/Watch Neg          BBB (sf)
2006A-3  06/01/35  97.01    BBB- (sf)/Watch Neg         BBB- (sf)
2006A-3  06/01/46  194.54   BB- (sf)/Watch Neg          BB- (sf)

New York Counties Tobacco Trust IV
$539.197 mil tobacco settlement pass-through bonds
               Sale amount       Rating
Class   Maturity  (mil. $) To                          From
2005A   06/01/45  83.88    BB (sf)/Watch Neg           BB (sf)
2005A   06/01/42  84.98    BBB- (sf)/Watch Neg         BBB- (sf)
2010 A  06/01/45  124.40   BB+ (sf)/Watch Neg          BB+ (sf)

Rockland Tobacco Asset Securitization Corp.
$47.75 mil tobacco settlement asset backed bonds series 2001
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2035     08/15/35  15.23    BBB (sf)/Watch Neg         BBB (sf)
2043     08/15/43  18.62    BBB (sf)/Watch Neg         BBB (sf)

Tobacco Securitization Authority of Southern California
$583.631 mil tobacco asset backed bonds (San Diego County) Series
2006
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2006A    06/01/37  186.44   BBB (sf)/Watch Neg         BBB (sf)
2006A    06/01/46  236.31   BBB (sf)/Watch Neg         BBB (sf)
2006B    06/01/46  19.77    BB- (sf)/Watch Neg         BB- (sf)
2006C    06/01/46  8.69     B+ (sf)/Watch Neg          B+ (sf)
2006D    06/01/46  20.57    B- (sf)/Watch Neg          B- (sf)

Tobacco Securitization Corp. of Northern California
$255.487 mil asset backed bonds series 2005A-1 series 2005A-2
series 2005B
series 2005C(Sacramento County)
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2005A-1  06/01/23  45.83    BBB (sf)/Watch Neg         BBB (sf)
2005A-1  06/01/38  87.29    BB (sf)/Watch Neg          BB (sf)
2005A-1  06/01/45  86.57    BB- (sf)/Watch Neg         BB- (sf)
2005A-2  06/01/27  12.47    BBB (sf)/Watch Neg         BBB (sf)
2005B    06/01/45  11.67    B (sf)/Watch Neg           B (sf)
2005C    06/01/45  11.66    B- (sf)/Watch Neg          B- (sf)

Tobacco Settlement Finance Authority (West Virginia)
$911.142 mil taxable tobacco settlement asset backed bonds series
2007
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2007A    06/01/47  845.81   BB+ (sf)/Watch Neg         BB+ (sf)
2007B    06/01/47  65.33    B (sf)/Watch Neg           B (sf)

Tobacco Settlement Financing Corp. (Virginia)
$1.149 bil tobacco settlement asset backed bonds series 2007
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2007A-1  06/01/46  682.65   BB (sf)/Watch Neg          BB (sf)
2007B-1  06/01/47  335.63   BB- (sf)/Watch Neg         BB- (sf)
2007B-2  06/01/47  26.81    BB- (sf)/Watch Neg         BB- (sf)
2007-C   06/01/47  77.10    B+ (sf)/Watch Neg          B+ (sf)
2007D    06/01/47  27.09    B- (sf)/Watch Neg          B- (sf)

Tobacco Settlement Financing Corp. (Rhode Island)
$685.39 mil tobacco settlement asset backed bonds series 2002A and
2002B
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2002-A   06/01/32  168.26   BBB (sf)/Watch Neg         BBB (sf)
2002-A   06/01/42  371.70   BBB (sf)/Watch Neg         BBB (sf)

Tobacco Settlement Financing Corp. (Rhode Island)
$194.31 mil tobacco settlement asset backed bonds series 2007
                Sale amount       Rating
Class    Maturity  (mil. $) To                         From
2007A    06/01/52  176.97   B (sf)/Watch Neg           B (sf)
2007B    06/01/52  17.34    B- (sf)/Watch Neg          B- (sf)

Tobacco Settlement Financing Corp. (New Jersey)
$3.622 bil tobacco settlement asset backed bonds series 2007-1
               Sale amount       Rating
Class    Maturity (mil. $) To                          From
2007-1A  06/01/23  623.71  BBB (sf)/Watch Neg          BBB (sf)
2007-1A  06/01/26  287.62  BBB (sf)/Watch Neg          BBB (sf)
2007-1A  06/01/29  332.27  BBB- (sf)/Watch Neg         BBB- (sf)
2007-1A  06/01/34  672.95  BB+ (sf)/Watch Neg          BB+ (sf)
2007-1A  06/01/41  1263.59 BB- (sf)/Watch Neg          BB- (sf)
2007-1B  06/01/41  126.20  B (sf)/Watch Neg            B (sf)
2007-1C  06/01/41  59.79   B- (sf)/Watch Neg           B- (sf)

TSASC Inc.
$1.354 bil tobacco settlement asset backed bonds series 2006-1
               Sale amount       Rating
Class   Maturity  (mil. $) To                          From
2006    06/01/42  559.03   BBB- (sf)/Watch Neg         BBB- (sf)
2006    06/01/34  372.65   BBB (sf)/Watch Neg          BBB (sf)
2006    06/01/26  137.77   BBB (sf)/Watch Neg          BBB (sf)
2006    06/01/22  284.07   BBB (sf)/Watch Neg          BBB (sf)

Westchester Tobacco Asset Securitization Corp.
$216.6 mil tobacco settlement asset backed bonds series 2005
               Sale amount       Rating
Class   Maturity  (mil. $) To                          From
2005    06/01/45  81.70    BBB- (sf)/Watch Neg         BBB- (sf)


CABELA'S CREDIT: DBRS Assigns Class D Notes at 'BB'
---------------------------------------------------
DBRS has assigned final ratings to these classes issued by
Cabela's Credit Card Master Note Trust Series 2011-IV:

  -- Series 2011-IV Notes, Class A-1 rated AAA (sf)
  -- Series 2011-IV Notes, Class A-2 rated AAA (sf)
  -- Series 2011-IV Notes, Class B rated A (high) (sf)
  -- Series 2011-IV Notes, Class C rated BBB (sf)
  -- Series 2011-IV Notes, Class D rated BB (sf)

DBRS has also confirmed all its outstanding ratings for the
Cabela's Credit Card Master Note Trust.


CABELA'S CREDIT: Fitch Puts Rating on $8.25 Mil. Notes at 'BB+sf'
-----------------------------------------------------------------
Fitch Ratings assigns these ratings to Cabela's Credit Card Master
Note Trust's asset-backed notes, series 2011-IV:

  -- $165,000,000 Class A-1 fixed-rate 'AAAsf'; Outlook Stable;
  -- $90,000,000 Class A-2 floating-rate 'AAAsf'; Outlook Stable;
  -- $24,000,000 Class B fixed-rate 'A+sf'; Outlook Stable;
  -- $12,750,000 Class C fixed-rate 'BBB+sf'; Outlook Stable;
  -- $8,250,000 Class D fixed-rate 'BB+sf'; Outlook Stable.

Fitch's ratings are based on the underlying receivables pool,
available credit enhancement, World's Foremost Bank's underwriting
and servicing capabilities, and the transaction's legal and cash
flow structures, which employ early redemption triggers.


CALIFORNIA STATEWIDE: Moody's Raises LOC Rating to Aa3 From Ba3
---------------------------------------------------------------
Moody's Investors Service has upgraded to Aa3/VMIG 1 from Ba3/SG
the letter of credit-backed rating of California Statewide
Communities Development Authority Variable Rate Demand Revenue
Bonds (YMCA of the East Bay Project), Series 2006 (the "Bonds") in
conjunction with the substitution of the current letter of credit
securing the Bonds provided Allied Irish Banks, PLC with a new
letter of credit to be provided by Wells Fargo Bank, N.A.

SUMMARY RATINGS RATIONALE

Upon the substitution of the letter of credit, currently scheduled
for October 12, 2011, the rating will be based upon: (i) the
direct-pay letter of credit provided by the Bank, (ii) the
structure and legal protections of the transaction, which ensure
timely payment of debt service and purchase price to bondholders;
and (iii) Moody's evaluation of the credit quality of the Bank
issuing the letter of credit.

Wells Fargo Bank, N.A. is currently rated Aa3 for long-term other
senior obligations ("OSO") and Prime-1 for short-term OSO.

WHAT COULD CHANGE THE RATING-UP

Long-Term: The long-term rating on the Bonds could be raised if
the long-term OSO rating on the Bank was upgraded.

Short-Term: Not applicable.

WHAT COULD CHANGE THE RATING-DOWN

Long-Term: The long-term rating on the Bonds could be lowered if
the long-term OSO rating on the Bank was downgraded.

Short-Term: The short-term rating on the Bonds could be lowered if
the short-term OSO rating on the Bank was downgraded.

PRINCIPAL METHODOLOGY USED

The principal methodology used in this rating was Moody's
Methodology for Rating U.S. Public Finance Transactions Based on
the Credit Substitution Approach published in August 2009.


CAPITALSOURCE 2006-1: Moody's Confirms Cl. D Notes Rating at Ba2
----------------------------------------------------------------
Moody's Investors Service has confirmed the ratings of these notes
issued by CapitalSource Commercial Loan Trust 2006-1:

US$68,447,000 Class C Notes (current outstanding balance of
$11,538,450), Confirmed at Aa1 (sf); previously on June 22, 2011
Aa1 (sf) Placed Under Review for Possible Upgrade;

US$52,803,000 Class D Notes (current outstanding balance of
$24,371,449), Confirmed at Ba2 (sf); previously on June 22, 2011
Ba2 (sf) Placed Under Review for Possible Upgrade.

US$31,290,000 Class E Notes (current outstanding balance of
$14,442,033), Confirmed at Caa3 (sf); previously on June 22, 2011
Caa3 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, while the transaction has benefited from
deleveraging, the rating actions reflect concerns related to the
low portfolio diversity and lack of granularity. The rated notes
are highly dependent on the credit conditions of a few large
obligors whose default probabilities are assessed through credit
estimates and the largest of which represents about 45% of the
portfolio.

Moody's notes that the actions also reflect the application of
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 $66.9 million, a
weighted average default probability of 52.02% (implying a WARF of
7740), a weighted average recovery rate upon default of 46.05%,
and a diversity score of 5. 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.

CapitalSource Commercial Loan Trust 2006-1, issued in April 2006,
is a collateralized loan obligation backed primarily by a
portfolio of senior secured loans of middle market issuers.

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. In addition, due to the low
diversity of the collateral pool, CDOROM v.2.8 was used to
simulate a default distribution that was then applied as an input
in the cash flow model. Moody's also supplemented its modeling
with individual scenario analysis to assess the ratings impact of
jump-to-default by certain large obligors.

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

2) Recovery of defaulted assets: Market value fluctuations in
defaulted assets reported by the trustee and those assumed to be
defaulted by Moody's may create volatility in the deal's
overcollateralization levels. Further, the timing of recoveries
and the manager's decision to work out versus sell defaulted
assets create additional uncertainties.

3) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates. Moody's also conducted stress tests to assess
the collateral pool's concentration risk in obligors bearing a
credit estimate that constitute more than 3% of the collateral
pool.

4) Lack of portfolio granularity: The performance of the portfolio
depends to a large extent on the credit conditions of a few large
obligors that are rated Caa1 or lower/non investment grade,
especially when they experience jump to default. Due to the deal's
low diversity score and lack of granularity, Moody's supplemented
its typical Binomial Expansion Technique analysis with a simulated
default distribution using Moody's CDOROM software and/or
individual scenario analysis.


CAPITALSOURCE 2006-2: Moody's Raises Rating of Cl. E Notes to Ba1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by CapitalSource Commercial Loan Trust 2006-2:

US$157,500,000 Class C Floating Rate Deferrable Asset Backed Notes
Notes (current outstanding balance of $114,755,719.59), Upgraded
to Aaa (sf); previously on June 22, 2011 Baa1 (sf) Placed Under
Review for Possible Upgrade;

US$101,250,000 Class D Floating Rate Deferrable Asset Backed
Notes, Upgraded to Aa3 (sf); previously on June 22, 2011 B2 (sf)
Placed Under Review for Possible Upgrade;

US$56,250,000 Class E Floating Rate Deferrable Asset Backed Notes,
Upgraded to Ba1 (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 result
primarily from the delevering of the notes. Since the last rating
action in December 2010, the Class A and Class B Notes, with a
previous cumulative balance of $197.3 million, have been
completely repaid. Additionally, the Class C Notes have been paid
down by approximately 27.14% or $42.7 million since December 2010
based on the servicer report dated October 10, 2011. Moody's also
notes that the substantial delevering of the notes more than
offsets the underlying pool's credit deterioration and heightened
concentration risk in a small number of industries and issuers.

The actions also reflect consideration of the application of
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 $379.2 million, a
weighted average default probability of 38.52% (implying a WARF of
6965), a weighted average recovery rate upon default of 43.42%,
and a diversity score of 18. 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.

CapitalSource Commercial Loan Trust 2006-2, issued in September
2006, is a collateralized loan obligation backed primarily by a
portfolio of senior secured loans of middle market issuers.

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. In addition, due to the low
diversity of the collateral pool, CDOROM 2.8 was used to simulate
a default distribution that was then applied as an input in the
cash flow model. Moody's also supplemented its modeling with
individual scenario analysis to assess the ratings impact of jump-
to-default by certain large obligors.

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

2) Recovery of defaulted assets: Market value fluctuations in
defaulted assets reported by the trustee and those assumed to be
defaulted by Moody's may create volatility in the deal's
overcollateralization levels. Further, the timing of recoveries
and the manager's decision to work out versus sell defaulted
assets create additional uncertainties.

3) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates. Moody's also conducted stress tests to assess
the collateral pool's concentration risk in obligors bearing a
credit estimate that constitute more than 3% of the collateral
pool.

4) Lack of portfolio granularity: The performance of the portfolio
depends to a large extent on the credit conditions of a few large
obligors that are rated Caa1 or lower/non investment grade,
especially when they experience jump to default. Due to the deal's
low diversity score and lack of granularity, Moody's supplemented
its typical Binomial Expansion Technique analysis with a simulated
default distribution using Moody's CDOROMTM software and/or
individual scenario analysis.


CAPMARK VII-CRE: S&P Cuts Ratings on 6 Classes From 'CCC-' to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes from Capmark VII-CRE Ltd. (Capmark VII), a U.S. commercial
real estate collateralized debt obligation (CRE CDO) transaction.
"At the same time, we affirmed our ratings on two other classes
from the same transaction," S&P related.

"The rating actions primarily reflect our analysis of the deal
following the deterioration in the transaction's collateralization
ratio. As of the Oct. 7, 2011, trustee report, the transaction's
collateral totaled $476.8 million while the transaction's
liability totaled $626.7 million, which includes capitalized
interest," S&P said.

The rating actions also reflect reported defaulted assets in the
amount of $108.8 million (22.8%) in the transaction's collateral
pool. The volume of defaulted assets has caused further
deterioration in the collateralization of the transaction. The
downgrades also reflect the transaction's potential to experience
an event of default under the transaction's document if class A/B
principal coverage ratio falls below 96%. "We lowered our ratings
on classes D through J to 'D (sf)' from 'CCC- (sf)' because we
determined that the classes were unlikely to be repaid in full,"
S&P said.

According to the Oct. 7, 2011, trustee report, the transaction's
current assets included 32 whole loans and senior interest loans
totaling $476.8 million.

Standard & Poor's reviewed and updated credit estimates for all
of the nondefaulted loan assets. "We based the analyses on our
adjusted net cash flow, which we derived from the most recent
financial data provided by the collateral manager, Urdang Capital
Management Inc., and the trustee, U.S. Bank N.A., as well as
market and valuation data from third-party providers," S&P
related.

The trustee report noted nine defaulted loans ($108.8 million,
22.8%) in the transaction. Standard & Poor's estimated specific
recovery rates for the defaulted loans with a weighted average of
57%. "We based the recovery rates on information from the
collateral manager, special servicer, and third-party data
providers," S&P said. The defaulted loan assets are:

    The National Gateway at Potomic Yard loan ($25.2 million,
    5.3%);

    The Centerview Crossing loan ($20.9 million, 4.4%);

    The Endevco Office Building loan ($13 million, 2.7%);

    The Belmont Apartments loan ($12 million, 2.5%);

    The Baywood Apartments loan ($8 million, 1.7%);

    The Beltway 8 loan ($8 million, 1.7%);

    The Classic loan ($7.7 million, 1.6%);

    The North Central Business Center loan ($7.4 million, 1.5%);
    and

    The Cedarwood Apartments loan ($6.7 million, 1.4%).

According to the trustee report, the deal is failing all three
principal coverage tests but passing its interest coverage tests.

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

Ratings Lowered

Capmark VII-CRE Ltd.
                  Rating
Class     To                   From
A-2       CCC+ (sf)            B+ (sf)
B         CCC (sf)             CCC+ (sf)
D         D (sf)               CCC- (sf)
E         D (sf)               CCC- (sf)
F         D (sf)               CCC- (sf)
G         D (sf)               CCC- (sf)
H         D (sf)               CCC- (sf)
J         D (sf)               CCC- (sf)

Ratings Affirmed

Capmark VII-CRE Ltd.

Class     Rating
A-1       BBB- (sf)
C         CCC- (sf)


CCMSC 1998-1: Moody's Affirms Ratings of Five CMBS Classes
----------------------------------------------------------
Moody's Investors Service (Moody's) affirmed these ratings of
five CMBS classes of Chase Commercial Mortgage Securities Corp.,
Commercial Mortgage Pass-Through Certificates, Series 1998-1:

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

Cl. G, Affirmed at A1 (sf); previously on May 7, 2009 Upgraded to
A1 (sf)

Cl. H, Affirmed at Ba3 (sf); previously on May 7, 2009 Upgraded to
Ba3 (sf)

Cl. I, Affirmed at Caa3 (sf); previously on Dec 17, 2010
Downgraded to Caa3 (sf)

Cl. X, Affirmed at Aaa (sf); previously on Mar 9, 2011 Confirmed
at 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. Although Moody's current cumulative base loss
has increased since last review, it is offset by increased credit
subordination due to loan amortizaion. Based on Moody's current
base expected loss, the credit enhancement levels for the affirmed
classes are sufficient to maintain the existing ratings.

Moody's rating action reflects a cumulative base expected loss
of 11.5% ($8.1 million) of the current balance compared to 7.5%
($5.9 million) at last review. Moody's stressed scenario loss is
22.5% of the current balance.  Depending on the timing of loan
payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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 methodologies used in this rating were "Moody's Approach to
Rating U.S. CMBS Conduit Transactions" published in September
2000, "CMBS: Moody's Approach to Rating Credit Tenant Lease (CTL)
Backed Transactions" published in October 1998, and "Moody's
Approach to Rating CMBS Large Loan/Single Borrower Transactions"
published in July 2000.

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 underlying ratings 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 underlying ratings
in the same transaction.

In rating this transaction, Moody's used its credit-tenant lease
("CTL") financing methodology approach ("CTL" approach) for the
CTL component. Under Moody's CTL approach, the rating of a
transaction's certificates is primarily based on the senior
unsecured debt rating (or the corporate family rating) of the
tenant, usually an investment grade rated company, leasing the
real estate collateral supporting the bonds. This tenant's credit
rating is the key factor in determining the probability of default
on the underlying lease. The lease generally is "bondable", which
means it is an absolute net lease, yielding fixed rent paid to the
trust through a lock-box, sufficient under all circumstances to
pay in full all interest and principal of the loan. The leased
property should be owned by a bankruptcy-remote, special purpose
borrower, which grants a first lien mortgage and assignment
of rents to the securitization trust. The dark value of the
collateral, which assumes the property is vacant or "dark", is
then examined to determine a recovery rate upon a loan's default.
Moody's also considers the overall structure and legal integrity
of the transaction. For deals that include a pool of credit tenant
loans, Moody's currently uses a Gaussian copula model,
incorporated in its public CDO rating model CDOROMv2.8 to generate
a portfolio loss distribution to assess the ratings.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 10 compared to 11 at last review.

In cases where the Herf falls below 20, Moody's also employs
the large loan/single borrower methodology. This methodology uses
the excel-based Large Loan Model v 8.2 and then reconciles and
weights the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 17, 2010.

DEAL PERFORMANCE

As of the October 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 91% to
$70.7 million from $817.9 million at securitization. The
Certificates are collateralized by 14 mortgage loans ranging
in size from less than 1% to 14% of the pool, with the top ten
loans representing 90% of the pool. The pool contains seven loans,
representing 53% of the pool, that are CTL loans.

Two loans, representing 3% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $6.02 million (47% loss severity
overall). Currently one loan, representing 13% of the pool, is in
special servicing. The Pine Tree Mall Loan ($9.3 million -- 13.2%
of the pool), is secured by a 261,700 square foot (SF) anchored
retail center located in Marinette, Wisconsin. The loan was
transferred to special servicing in March 2008 for maturity
default. The special servicer granted a forbearance period, which
ended in January 2009 and the borrower filed for bankruptcy in
February 2009. The special servicer engaged counsel and filed
foreclosure in April 2010. The loan was sold at auction in June
2011 and is currently real estate owned (REO). As of June 2011,
the property was 84% leased compared to 85% at last review. The
master servicer recognized a $3.3 million appraisal reduction for
this loan in November 2010. Moody's has estimated a $3.8 million
loss (41% expected loss) for the specially serviced loan.

Moody's was provided with full-year 2010 and partial year 2011
operating results for 100% and 86% of the pool, respectively.
Excluding specially serviced and CTL loans, Moody's weighted
average LTV is 39% compared to 46% at last review. Moody's net
cash flow reflects a weighted average haircut of 20% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 10.1%.

Excluding specially serviced and CTL loans, Moody's actual and
stressed DSCRs are 2.15X and 4.13X, respectively, compared to
1.58X and 2.64X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing conduit loans represent 28% of the pool
balance. The largest loan is the 299 Broadway Loan ($8.7 million -
- 12.4% of the pool), which is secured by a 229,770 SF office
building located in New York City. As of March 2011, the property
was 95% leased compared to 96% at last review. Performance has
improved due to higher revenues and lower operating expenses. The
loan has amortized 5% since last review and 32% since
securitization. Moody's LTV and stressed DSCR are 23% and 4.69X,
respectively, compared to 41% and 2.67X at last review.

The second largest loan is the Columbia Wellness Center Loan
($7.5 million -- 10.7% of the pool), which is secured by a
61,127 SF medical office building located in Framingham,
Massachusetts. The property is 100% leased by two tenants, Metro
Wellness Center (66% of the net rentable area (NRA); lease
expiration in January 2013) and Southboro Medical Group (34% of
the NRA; leases expiration in November 2020). Property performance
has improved due to higher base rents. Moody's LTV and stressed
DSCR are 59% and 1.85X, respectively, compared to 66% and 1.63X at
last review.

The third largest loan is the Royal Palm Apartments Loan
($3.3 million -- 4.6% of the pool), which is secured by a 288-unit
multifamily property located in Orland, Florida. As of June 2011
the property was 96% leased compared to 90% at last review.
Performance has slightly decreased due to lower base rent and
higher operating expenses. Moody's LTV and stressed DSCR are 41%
and 2.48X, respectively, compared to 40% and 2.60X at last review.

The CTL component includes seven loans secured by 23 properties
leased to three tenants. The exposures are Brinker International,
Inc. ($23.3 million; Moody's senior unsecured rating Ba2, stable
outlook; 33.0% of the pool), Star Market ($8.1 million; an
affiliate of Supervalu, Inc. which has a Moody's senior unsecured
rating B2, stable outlook; 11.5% of the pool), and H.E. Butt
Grocery Stores ($5.9 million -- 8.3% of the pool). The bottom-
dollar weighted average rating factor (WARF) for this CTL pool is
2,187 compared to 1,641 at last review. WARF is a measure of the
overall quality of a pool of diverse credits. The bottom-dollar
WARF is a measure of the default probability within the pool.


CD 2007-CD4: S&P Lowers Ratings on 3 Classes of Certs. to 'D'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on seven
classes of commercial mortgage pass-through certificates from CD
2007-CD4, a U.S. commercial mortgage-backed securities (CMBS)
transaction. "In addition, we affirmed our ratings on nine other
classes from the same transaction," S&P related.

"Our rating actions follow our analysis of the transaction
primarily using our U.S. conduit/fusion CMBS criteria, the deal
structure, and the liquidity available to the trust. The
downgrades reflect credit support erosion that we anticipate will
occur upon the resolution of 44 ($1.3 billion, 20.5%) of the
48 specially serviced assets ($1.4 billion, 22.0%) and two loans
($10.0 million, 0.1%) that we determined to be credit-impaired. We
also considered the monthly interest shortfalls that are affecting
the trust and the potential for additional interest shortfalls
associated with loan modifications and/or revised appraisal
reduction amounts (ARAs) on the specially serviced assets.
We lowered our ratings on the class C, D, and E certificates to 'D
(sf)' because we expect interest shortfalls to continue and
believe the accumulated interest shortfalls will remain
outstanding for the foreseeable future," S&P said.

"The affirmed ratings on the principal and interest certificates
reflect subordination and liquidity support levels that are
consistent with the outstanding ratings. We affirmed our 'AAA
(sf)' ratings on the class XC, XP, and XW interest-only
certificates based on our current criteria," S&P related.

"Our analysis included a review of the credit characteristics
of the remaining assets in the pool. Using servicer-provided
financial information, we calculated an adjusted debt service
coverage (DSC) of 1.46x and a loan-to-value (LTV) ratio of
105.6%. We further stressed the loans' cash flows under our
'AAA' scenario to yield a weighted average DSC of 0.90x and
an LTV ratio of 144.0%. The implied defaults and loss severity
under the 'AAA' scenario were 83.3% and 41.9%. The DSC and LTV
calculations noted above exclude 44 ($1.3 billion, 20.5%) of the
48 specially serviced assets ($1.4 billion, 22.0%) and two loans
($10.0 million, 0.1%) that we determined to be credit-impaired.
We separately estimated losses for these specially serviced and
credit-impaired assets and included them in our 'AAA' scenario
implied default and loss severity figures," S&P said.

As of the Oct. 14, 2011, trustee remittance report, the trust
experienced monthly interest shortfalls totaling $2.7 million
primarily related to appraisal subordinate entitlement reduction
(ASER) amounts of $1.4 million, interest rate reduction due to
loan modifications of $670,721, interest not advanced of $636,864,
and special servicing fees of $284,586. The interest shortfalls
affected all classes subordinate to and including class C.
"Classes C, D, and E experienced cumulative interest shortfalls
for one month, and we expect these interest shortfalls to continue
in the near term. Consequently, we downgraded these classes to 'D
(sf)'," S&P said.

                     Credit Considerations

As of the Oct. 14, 2011, trustee remittance report, 48 assets
($1.4 billion, 22.0%) in the pool were with the special servicer,
CWCapital Asset Management LLC (CWCapital). The reported payment
status of the specially serviced assets as of the October 2011
trustee remittance report is: 25 are real estate owned (REO;
$734.8 million, 11.6%), 12 are in foreclosure ($472.3 million,
7.4%), seven are 90-plus-days delinquent ($55.3 million, 0.9%),
one is 60 days delinquent ($5.3 million, 0.1%), one is less than
30 days delinquent ($34.3 million, 0.5%), and two are current
($93.1 million, 1.5%). ARAs totaling $615.6 million are in effect
against 43 of the specially serviced assets. Details of the five
largest specially serviced assets, three of which are top 10
assets, are:

The Citadel Mall and Northwest Arkansas Mall Portfolio asset
($261.6 million, 4.1%), the fourth-largest asset in the pool,
consists of two regional malls: 453,579 sq. ft. of a 1.1 million-
sq.-ft. regional mall in Colorado Springs, Colorado and 589,038
sq. ft. of a 811,460-sq.-ft. regional mall in Fayetteville,
Arkansas. The asset was transferred to the special servicer on
Oct. 23, 2009, due to imminent monetary default and became REO on
Sept. 14, 2011. The reported combined DSC for the six months ended
June 30, 2011, was 0.87x and occupancy was 78.6% as of February
2011 for the Citadel Mall asset and 63.9% as of December 2010 for
the Northwest Arkansas Mall asset. CWCapital indicated that it
plans to stabilize the properties. "We anticipate a significant
loss upon the eventual resolution of this asset," S&P said.

The Four Seasons Resort Maui loan, the sixth-largest asset in
the pool has a whole-loan balance of $425.0 million that is
split into two pari passu pieces: $250.0 million makes up 3.9%
of the pool trust balance. The remaining $175.0 million is in
the GE Commercial Mortgage Corp.'s series 2007-C1 (GECM 2007-C1)
transaction. The loan is secured by a 380-room full-service
luxury resort hotel in Wailea (in Maui County), Hawaii. The loan
was transferred to CWCapital on April 6, 2010, due to monetary
default. Although the loan has a reported foreclosure payment
status as of the October 2011 remittance report date, CWCapital
stated that the loan has since been modified and the payment
status is current. The modification terms include, but are not
limited to, bifurcating the trust's $250.0 million note into a
$205.9 million senior A note and a $44.1 million subordinate B
note, establishing debt service, operating loss and capital
reserves, extending the loan's maturity from Jan. 1, 2014 to
Jan. 1, 2019, and deferring debt service payments on the B
note. The remaining $175.0 million note that is in the GECM
2007-C1 trust is split into a $144.1 million senior A note and
a $30.9 million subordinate B note. The reported DSC was 1.09x
for the trailing 12-months ending Aug. 31, 2011. An ARA of
$103.4 million is in effect against the loan. "We expect a
moderate loss upon the eventual resolution of this loan," S&P
related.

The Riverton Apartments asset ($225.0 million, 3.5%), the seventh-
largest asset in the pool, consists of 12 apartment buildings
totaling 1,228 units in New York City. The asset was transferred
to CWCapital on Aug. 7, 2008, due to imminent monetary default and
became REO on March 11, 2010. According to CWCapital, it plans to
complete capital expenditures and stabilize operating expenses at
the property before marketing it for sale. The current reported
occupancy is 98.0% at the property. An ARA of $154.9 million is in
effect against the asset. "We expect a significant loss upon the
eventual resolution of this asset," S&P said.

The Loews Lake Las Vegas loan ($117.0 million, 1.8%) is secured
by a 493-room full-service hotel in Henderson, Nevada. The loan
has a reported foreclosure payment status, and was transferred
to CWCapital on March 4, 2009, due to imminent default. CWCapital
indicated that it is exploring franchise rebranding options
and plans to hold and stabilize the property. The reported net
operating income for the eight months ended Aug. 31, 2011, is not
sufficient to cover operating expenses. An ARA of $112.3 million
is in effect against the loan. "We expect a significant loss upon
the eventual resolution of this loan," S&P said.

The Manhattan Towers loan ($75.0 million, 1.2%) is secured by
a 309,735-sq.-ft. suburban office building in Manhattan Beach,
Calif. The loan was transferred to the special servicer on
March 18, 2011, due to imminent monetary default and the reported
payment status is current. CWCapital stated that a deed-in-lieu of
foreclosure occurred on Sept. 6, 2011. The current reported
occupancy is 21.0%. An ARA of $34.9 million is in effect against
the loan. "We expect a significant loss upon the eventual
resolution of this loan," S&P said.

The 43 remaining specially serviced assets have individual
balances that represent less than 0.75% of the pooled trust
balance. ARAs totaling $210.1 million are in effect against 39
of these assets. "We estimated losses for 39 of the 43 assets,
arriving at a weighted-average loss severity of 54.2%. While
three of the remaining four loans have been corrected and/or
assumed, CWCapital has informed us that it is in discussions with
the borrower for a loan modification on the fourth loan," S&P
related.

Subsequent to the Oct. 14, 2011, trustee remittance report, the
master servicer informed us that the 200 West Adams Street loan
($100.0 million, 1.6%) has recently been transferred to the
special servicer due to imminent maturity default. The loan
matures on Jan. 1, 2012, and the borrower indicated that it will
not able to obtain refinancing proceeds by the maturity date. The
loan is secured by a 677,222-sq.-ft. office building in Chicago.
The master servicer reported a 1.16x DSC for year-end 2010 and
86.2% occupancy as of June 30, 2011.

"In addition to the specially serviced assets, we determined two
loans ($10.0 million, 0.1%) to be credit-impaired due primarily to
a reported delinquent payment status. The La Jolla and Nautilus
loan ($8.3 million, 0.1%) has a reported 30 days delinquent
payment status and is secured by a 23,764-sq.-ft. office/retail
property in La Jolla, Calif. The reported DSC was 1.04x for
year-end 2010. The master servicer indicated that the loan may be
transferred due to imminent default," S&P stated.

The other loan, the Shops of Sedona loan ($1.7 million), which has
a reported 60 days delinquent payment status, is secured by a
14,960-sq.-ft. retail property in Olathe, Kansas. The reported DSC
was 0.34x for year-end 2010. The master servicer indicated that
the loan was recently transferred to special servicing due to
payment default. "As a result, we viewed both loans to be at
an increased risk of default and loss," S&P related.

                       Transaction Summary

As of the Oct. 14, 2011 trustee remittance report, the collateral
pool balance was $6.4 billion, which is 96.3% of the balance at
issuance. The pool comprises 343 loans and 25 REO assets, down
from 378 loans at issuance. The master servicers, Berkadia
Commercial Mortgage LLC, Midland Loan Services, and Wells Fargo
Bank N.A., provided financial information for 90.9% of the loans
in the pool: 76.7% was partial- or full-year 2010 data, 1.4% was
partial-year 2011 data, and the remainder was 2009 data.

"We calculated a weighted average DSC of 1.31x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.46x and 105.6%. Our adjusted DSC and LTV
figures excluded 44 ($1.3 billion, 20.5%) of the 48 specially
serviced assets in the trust ($1.4 billion, 22.0%) and two loans
($10.0 million, 0.1%) that we determined to be credit-impaired. We
separately estimated losses for these specially serviced and
credit-impaired assets and included them in our 'AAA' scenario
implied default and loss severity figures. Our adjusted DSC
and LTV ratio also considered an anticipated increase in net
cash flow for the largest asset in the pool, the 9 West 57th
Street loan ($400.0 million, 6.3%). The transaction has
experienced $18.8 million in principal losses from 16 assets
to date. Ninety-seven loans ($1.7 billion, 26.9%) in the pool
are on the master servicers' combined watchlist. Seventy loans
($907.3 million, 14.3%) have a reported DSC of less than 1.00x,
and 24 loans ($295.3 million, 4.7%) have a reported DSC between
1.00x and 1.10x," S&P said.

                    Summary Of Top 10 Assets

"The top 10 assets have an aggregate outstanding balance of
$2.6 billion (40.3%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.49x for seven of the
top 10 assets. The remaining three assets ($736.6 million,
11.5%) are with the special servicer. In addition, two of the
top 10 assets ($580.0 million, 9.1%) are on the master servicers'
combined watchlist. Our adjusted DSC and LTV ratio for seven of
the top 10 assets were 1.72x and 84.6%. Our adjusted DSC and LTV
ratio also considered an anticipated increase in net cash flow for
the largest asset in the pool, the 9 West 57th Street loan," S&P
related.

The 9 West 57th Street loan ($400.0 million, 6.3%), the largest
asset in the pool, is the largest loan on the master servicers'
combined watchlist. The loan is secured by a 1.6 million-sq.-ft.
office building in Manhattan. The loan is on the master servicers'
combined watchlist due to a low reported DSC and occupancy.
The reported DSC and occupancy for year-end 2010 were 1.13x
and 49.6%. According to the master servicer, two new tenants
comprising 2.9% of the net rentable area recently signed leases
totaling $7.6 million of annual base rental income. "Our analysis
considered the addition of these two tenants. The loan matures on
Feb. 1, 2012," S&P said.

The CGM AmeriCold Portfolio loan, the eighth-largest asset in the
pool, has a whole-loan balance of $325.0 million that is split
into two pari passu pieces, $180.0 million of which makes up
2.8% of the pool trust balance. The loan is secured by 15 owner-
occupied warehouse/distribution facilities totaling 4.2 million
sq. ft. in 10 U.S. states. The loan appears on the master
servicers' combined watchlist because operations ceased at two
of the properties, one of which has deferred maintenance items.
The reported combined DSC was 1.74x for year-end 2010.

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

Ratings Lowered

CD 2007-CD4
Commercial mortgage pass-through certificates
                Rating
Class      To           From       Credit enhancement (%)
A-MFX      BB+ (sf)     BBB- (sf)                   20.47
A-MFL      BB+ (sf)     BBB- (sf)                   20.47
A-J        CCC+ (sf)    B+ (sf)                     11.26
B          CCC (sf)     B+ (sf)                     10.61
C          D (sf)       CCC+ (sf)                    9.18
D          D (sf)       CCC (sf)                     8.27
E          D (sf)       CCC- (sf)                    7.62

Ratings Affirmed

CD 2007-CD4
Commercial mortgage pass-through certificates

Class      Rating              Credit enhancement (%)
A-2A       AAA (sf)                             30.85
A-2B       AAA (sf)                             30.85
A-3        AAA (sf)                             30.85
A-SB       AAA (sf)                             30.85
A-4        A- (sf)                              30.85
A-1A       A- (sf)                              30.85
XC         AAA (sf)                               N/A
XP         AAA (sf)                               N/A
XW         AAA (sf)                               N/A

N/A -- Not applicable.


CHATHAM LIGHT: S&P Withdraws 'CCC-' Ratings on 2 Classes of Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on seven
classes of notes from three U.S. collateralized debt obligation
(CDO) transactions.

"The withdrawals follow the complete paydown of the notes on their
most recent payment dates," S&P said.

Bacchus (U.S.) 2006-1 Ltd., a collateralized loan obligation (CLO)
transaction, paid the class X notes down in full on the Oct. 20,
2011, payment date, from a $0.20 million outstanding balance.

Chatham Light CLO Ltd., also a CLO, paid the class A-1, A-2, B, C-
1, and C-2 notes down in full following a notice of optional
redemption. The Oct. 7, 2011, notice indicated that at least a
majority of the income notes had directed a full redemption of all
outstanding notes. The transaction paid these classes down in full
on the Oct. 24, 2011, payment date, from outstanding balances of
$13.71 million, $28.50 million, $27.00 million, $19.00 million,
and $5.00 million.

SFR Ltd., a CLO transaction, paid the class A notes down in full
following a notice of optional redemption. The Sept. 7, 2011,
notice indicated that the subordinated notes had directed a full
redemption of all outstanding notes. The transaction paid the
class A notes down in full on the Oct. 25, 2011, payment date,
from a $57.04 million outstanding balance.

Ratings Withdrawn

Bacchus (U.S.) 2006-1 Ltd.
                            Rating
Class               To                  From
X                   NR                  AAA (sf)

Chatham Light CLO Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)
A-2                 NR                  AA (sf)
DEF B               NR                  BBB+ (sf)
DEF C-1             NR                  CCC- (sf)
DEF C-2             NR                  CCC- (sf)

SFR Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)

NR -- Not rated.


CHURCHILL FINANCIAL: Moody's Upgrades Ratings of CLO Notes
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Churchill Financial Cayman Ltd.:

US$87,500,000 Class B Floating Rate Second Priority Senior Secured
Term Notes Due 2019 (current outstanding balance of $86,500,000),
Upgraded to Aaa (sf); previously on June 22, 2011 Aa2 (sf) Placed
Under Review for Possible Upgrade;

US$93,750,000 Class C Floating Rate Third Priority Senior Secured
Deferrable Interest Term Notes Due 2019 (current outstanding
balance of $91,750,000), Upgraded to Aa3 (sf); previously on
June 22, 2011 Baa1 (sf) Placed Under Review for Possible Upgrade;

US$65,000,000 Class D-1 Floating Rate Fourth Priority Senior
Secured Deferrable Interest Term Notes Due 2019 (current
outstanding balance of $59,000,000), Upgraded to Baa1 (sf);
previously on June 22, 2011 Ba3 (sf) Placed Under Review for
Possible Upgrade;

US$10,000,000 Class D-2 Fixed Rate Fourth Priority Senior Secured
Deferrable Interest Term Notes Due 2019, Upgraded to Baa1 (sf);
previously on June 22, 2011 Ba3 (sf) Placed Under Review for
Possible Upgrade; and

US$62,500,000 Class E Floating Rate Fifth Priority Senior Secured
Deferrable Interest Term Notes Due 2019 (current outstanding
balance of $ 44,716,308.16), Upgraded to Baa3 (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 credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in October
2009. Based on the latest trustee report dated September 27, 2010,
the weighted average rating factor is currently 3,103 compared to
3,501 in August 2009. Also, the Class A/B, Class C, Class D and
Class E overcollateralization ratios are reported at 138.6%,
125.1%, 116.6%, and 111.6%, respectively, versus August 2009
levels of 136.7%, 122.4%, 113.1%, and 107.0%, 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 $1,222.8 million,
defaulted par of $38.6 million, a weighted average default
probability of 25.2% (implying a WARF of 3,600), a weighted
average recovery rate upon default of 49.25%, and a diversity
score of 51. The performing par and principal proceeds balance
reflect the assumption that currently unfunded Class A-1
Commitments is funded in full. 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.

Churchill Financial Cayman Ltd., issued in July 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.

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.

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/diversity levels higher than the covenant levels due to the
large difference between the reported and covenant levels.

4) The deal is exposed to a large number of securities whose
default probabilities are assessed through credit estimates. In
the event that Moody's is not provided the necessary information
to update the credit estimates in a timely fashion, the
transaction may be impacted by any default probability stresses
Moody's may assume in lieu of updated credit estimates.

5) The deal has a pay-fixed receive-floating interest rate swap
that is currently out of the money. If fixed rate assets prepay or
default, there would be a more substantial mismatch between the
swap notional and the amount of fixed assets. In such cases,
payments to hedge counterparties may consume a large portion or
all of the interest proceeds, leaving the transaction, even with
respect to the senior notes, with poor interest coverage. Payment
timing mismatches between assets and liabilities may cause
additional concerns. If the deal does not receive sufficient
projected principal proceeds on the payment date to supplement the
interest proceeds shortfall, a heightened risk of interest payment
default could occur. Similarly, if principal proceeds are used to
pay interest, there may ultimately be a risk of payment default on
the principal of the notes.


CIFC FUNDING: Moody's Raises Rating of US$25-Mil. Notes to 'Ba3'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by CIFC Funding 2006-II, Ltd.

US$36,000,000 Class A-3L Floating Rate Notes Due March 2021,
Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$23,000,000 Class B-1L Floating Rate Notes Due March 2021,
Upgraded to Ba1 (sf); previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$25,000,000 Class B-2L Floating Rate Notes Due March 2021
(current outstanding balance of $24,074,261.58), Upgraded to Ba3
(sf); previously on June 22, 2011 B3 (sf) Placed Under Review for
Possible Upgrade.

In addition, Moody's has confirmed the ratings of the following
notes:

US$40,000,000 Class A-1LB Floating Rate Notes Due March 2021,
Confirmed at Aa1 (sf); previously on June 22, 2011 Aa1 (sf) Placed
Under Review for Possible Upgrade;

US$35,000,000 Class A-2L Floating Rate Notes Due March 2021,
Confirmed at A1 (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 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 September 2009. Based on the latest trustee report dated
September 21, 2011, the Senior Class A, Class A, Class B-1L, and
Class B-2L overcollateralization ratios are reported at 122.8%,
114.6%, 109.8%, and 105.1%, respectively, versus August 2009
levels of 119.8%, 111.7%, 107.1%, and 102.5%, respectively.
Moody's notes the Class B-2L Notes have amortized by approximately
$0.9 million or 3.7% since the rating action in September 2009 due
to the diversion of excess interest to delever the Class B-2L
Notes as a result of the Additional Collateral Deposit
Requirement.

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 $613 million
(assuming the Class A-1LR notes are fully drawn), defaulted par of
$0.4 million, a weighted average default probability of 23.9%
(implying a WARF of 3100), a weighted average recovery rate upon
default of 50.6%, and a diversity score of 61. 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.

CIFC Funding 2006-II, Ltd., issued in December 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans with significant exposure to loans of middle
market issuers.

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 spread,
weighted average coupon, and diversity score. However, as a part
of the base case, Moody's considered the diversity and spread
levels higher than the covenant level due to the large difference
between the reported and covenant levels.

3. Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates.


CLARIS IV: DBRS Confirms Class I-C Swap, Series 29 at 'BB'
----------------------------------------------------------
DBRS, Inc., has confirmed these ratings on the Class I Swaps
issued by Claris IV Limited - Series 29:

  -- Class I-A Swap, Series 29 at AA (low) (sf)
  -- Class I-B Swap, Series 29 at BBB (low) (sf)
  -- Class I-C Swap, Series 29 at BB (low) (sf)

Claris IV Limited - Series 29 is collateralized primarily by a
portfolio of U.S. residential mortgage-backed securities (RMBS)
and other asset-backed securities (ABS).  The DBRS ratings of the
Class I-A Swap, Class I-B Swap, and Class I-C Swap address the
probability of breaching their respective attachment points as
defined in the transaction documents at or prior to their maturity
dates.

The principal methodology is Rating US & European Structured
Finance CDO Restructurings, which can be found on DBRS' website
under Methodologies.


CLARIS IV: DBRS Downgrades Class I-B Swap, Series 28 to 'BB'
------------------------------------------------------------
DBRS, Inc., has downgraded the Class I-B Swap, Series 28 issued by
Claris IV Limited - Series 28 from a BBB (low) (sf) rating to a BB
(sf).

DBRS has confirmed the Class I-C Swap, Series 28 issued by Claris
IV Limited - Series 28 at BB (low) (sf).

Claris IV Limited Series 28 is collateralized primarily by a
portfolio of U.S. residential mortgage-backed securities (RMBS),
commercial mortgage-backed securities (CMBS) and other asset-
backed securities (ABS).  The DBRS ratings of the Class I-B Swap
and the Class I-C Swap address the probability of breaching their
respective attachment points as defined in the transaction
documents at or prior to their maturity dates.

The actions reflect the deterioration in credit quality of the
underlying collateral pool since the transaction was last assigned
a DBRS rating on August 11, 2010.

The principal methodology is Rating US & European Structured
Finance CDO Restructurings, which can be found on DBRS' website
under Methodologies.


CLARIS IV: DBRS Downgrades Class I-C Swap, Series 25 to 'BB'
------------------------------------------------------------
DBRS, Inc., has confirmed these ratings on the Class I Swaps
issued by Claris IV Limited - Series 25:

  -- Class I-A Swap, Series 25 at AA (low) (sf)
  -- Class I-B Swap, Series 25 at BBB (low) (sf)
  -- Class I-C Swap, Series 25 at BB (low) (sf)

Claris IV Limited - Series 25 is collateralized primarily by a
portfolio of U.S. residential mortgage-backed securities (RMBS)
and other asset-backed securities (ABS).  The DBRS ratings of the
Class I-A Swap, Class I-B Swap, and Class I-C Swap address the
probability of breaching their respective attachment points as
defined in the transaction documents at or prior to their maturity
dates.

The principal methodology is Rating US & European Structured
Finance CDO Restructurings, which can be found on DBRS' website
under Methodologies.


CLARIS IV SERIES 25: DBRS Confirms 'BB' Rating on Class I-C Swap
----------------------------------------------------------------
DBRS, Inc., has confirmed these ratings on the Class I Swaps
issued by Claris IV Limited - Series 25:

  -- Class I-A Swap, Series 25 at AA (low) (sf)
  -- Class I-B Swap, Series 25 at BBB (low) (sf)
  -- Class I-C Swap, Series 25 at BB (low) (sf)

Claris IV Limited - Series 25 is collateralized primarily by a
portfolio of U.S. residential mortgage-backed securities (RMBS)
and other asset-backed securities (ABS).  The DBRS ratings of the
Class I-A Swap, Class I-B Swap, and Class I-C Swap address the
probability of breaching their respective attachment points as
defined in the transaction documents at or prior to their maturity
dates.

The principal methodology is Rating US & European Structured
Finance CDO Restructurings, which can be found on DBRS' website
under Methodologies.


CLARIS IV SERIES 28: DBRS Confirms 'BB' Rating on Class I-C Swap
----------------------------------------------------------------
DBRS, Inc., has downgraded the Class I-B Swap, Series 28 issued by
Claris IV Limited - Series 28 from a BBB (low) (sf) rating to a BB
(sf).

DBRS has confirmed the Class I-C Swap, Series 28 issued by Claris
IV Limited - Series 28 at BB (low) (sf).

Claris IV Limited Series 28 is collateralized primarily by a
portfolio of U.S. residential mortgage-backed securities (RMBS),
commercial mortgage-backed securities (CMBS) and other asset-
backed securities (ABS).  The DBRS ratings of the Class I-B Swap
and the Class I-C Swap address the probability of breaching their
respective attachment points as defined in the transaction
documents at or prior to their maturity dates.

The actions reflect the deterioration in credit quality of the
underlying collateral pool since the transaction was last assigned
a DBRS rating on August 11, 2010.

The principal methodology is Rating US & European Structured
Finance CDO Restructurings, which can be found on DBRS' website
under Methodologies.


CLARIS IV SERIES 29: DBRS Confirms 'BB' Rating on Class I-C Swap
----------------------------------------------------------------
DBRS, Inc., has confirmed these ratings on the Class I Swaps
issued by Claris IV Limited - Series 29:

  -- Class I-A Swap, Series 29 at AA (low) (sf)
  -- Class I-B Swap, Series 29 at BBB (low) (sf)
  -- Class I-C Swap, Series 29 at BB (low) (sf)

Claris IV Limited - Series 29 is collateralized primarily by a
portfolio of U.S. residential mortgage-backed securities (RMBS)
and other asset-backed securities (ABS).  The DBRS ratings of the
Class I-A Swap, Class I-B Swap, and Class I-C Swap address the
probability of breaching their respective attachment points as
defined in the transaction documents at or prior to their maturity
dates.

The principal methodology is Rating US & European Structured
Finance CDO Restructurings, which can be found on DBRS' website
under Methodologies.


CNH CAPITAL: Moody's Assigns Provisional Ratings to Three Classes
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to the
notes to be issued by CNH Capital Canada Receivables Trust 2011-1
(CCCRT 2011-1), sponsored by CNH Capital Canada Ltd.(CNH), an
affiliate of CNH Global N.V. (Ba2).

The complete rating actions are:

Issuer: CNH Capital Canada Receivables Trust 2011-1

Fixed-rate Class A-1 Notes, rated (P)Aaa (sf)

Fixed-rate Class A-2 Notes, rated (P)Aaa (sf)

Fixed-rate Class B Notes, rated (P)A1 (sf)

RATINGS RATIONALE

The ratings are based primarily on an analysis of the credit
quality of the collateral, the historical performance of similar
collateral originated by the sponsor, the servicing ability of CNH
Capital Canada Ltd., the back-up servicing arrangement and the
servicing ability of Systems & Services Technologies, Inc., and
the level of credit enhancement available under the proposed
capital structure. The collateral for the transaction is primarily
comprised of loans originated by CNH and secured primarily by
agricultural equipment, which constitute 94.11% of the pool
balance, with the remaining 5.89% being secured by construction
equipment. New equipment comprises 44.07% of the pool and the
remaining 55.93% of the pool is secured by used equipment.

Moody's median cumulative net loss expectation and Aaa volatility
proxy level for the 2011-1 transaction are 0.70% and 6.00%
respectively. Expected loss is based on an analysis of the
historical performance of static pools of CNH's quarterly
originations, stratified along certain key credit metrics and
adjusted to reflect differences between the economic conditions
underlying the historical performance and Moody's expectation of
future economic conditions. The key credit metrics considered
include agricultural and construction equipment mix and, within
each, the new and used equipment mix. The stratified historical
performance helps ensure comparability between the securitized and
referenced collateral pools, allowing for more accurate
inferences. The expected loss is also informed by the observed
performance of CNH's managed portfolio and the performance of past
securitizations sponsored by CNH. While supported by a limited
number of data points so far, the performance of deals from the
more recent vintages is especially strong and supports the
reasonableness of the expected loss for this transaction.

All classes of notes are enhanced by a spread account funded at
closing in the amount equal to 2.60% of the initial note balance
of the receivables which will build to a target of 3.50% of the
initial note balance through the retention of excess spread. The
spread account balance can step down, however, to target of 2.30%,
1.90%, 1.55% and 1.20% at months 18, 24, 30 and 36 after closing,
respectively, if certain collateral performance (delinquency and
loss level) based triggers are not breached. In the case of the
Class A notes, the credit enhancement also includes subordination
in the form of Class B notes at 2.40%. This form of credit
enhancement is non-declining, given the sequential pay structure
utilized in this deal. Additionally, the transaction will benefit
from available excess spread.

PRINCIPAL METHODOLOGY

The principal methodology used in this rating is "Moody's Approach
to Rating Securities Backed by Equipment Leases and Loans," March
2007.

V-SCORE AND PARAMETER SENSITIVITY

The V Score for this transaction is Low/Medium, which is in
line with the score assigned to the Canadian Agricultural and
Construction Equipment Loan ABS sector. The V Score indicates
"Low/Medium" uncertainty about critical assumptions. Overall,
Moody's views the credit risk for this asset class to be
relatively straight-forward and well understood given the high
granularity of the collateral pools and the revenue-producing
nature of the equipment. The Low/Medium assessment is primarily
driven by the non-homogenous nature of the assets and the varying
sensitivity of the obligors to changes in economic conditions,
given that the obligors can vary from small and medium businesses
to large corporations. Agricultural equipment receivables account
for a majority (94%) of the collateral securitized in this deal,
which is a credit positive given that the construction equipment
receivables have performed significantly worse historically.

Moody's Parameter Sensitivities: If the net loss used in
determining the initial rating were changed to 2.50%, 3.50%, or
4.00%, the initial model-indicated output for the Class A notes
might change from Aaa to Aa1, Aa3, and A1, respectively. If the
net loss used in determining the initial rating were changed to
1.00%, 1.50%, or 2.00%, the initial model-indicated output for the
Class B notes might change from A1 to A2, Baa2, and Ba1,
respectively.

Parameter Sensitivities are not intended to measure how the rating
of the security might migrate over time, rather they are designed
to provide a quantitative calculation of how the initial rating
might change if key input parameters used in the initial rating
process differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.


COAST INVESTMENT: S&P Withdraws 'B+' Ratings on 2 Classes of Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on seven
classes of notes from six U.S. collateralized debt obligation
(CDO) transactions.

The rating withdrawals follow the complete paydown of the notes on
their most recent payment dates.

Coast Investment Grade 2000-1, Ltd. is a CDO backed by other CDOs.
The transaction paid the class B-1 and B-2 notes down in full on
the Oct. 17, 2011, payment date, from outstanding balances of
$16.83 million and $5.61 million.

Foxe Basin CLO 2003 Ltd. is a collateralized loan obligation
(CLO). The transaction paid the class A-2 notes down in full on
the Sept. 15, 2011, payment date, from an outstanding balance of
$4.84 million.

GE Commercial Loan Trust Series 2006-2, also a CLO, paid the class
C notes down in full on the Oct. 19, 2011, payment date, from an
outstanding balance of $2.28 million.

GE Commercial Loan Trust Series 2006-3, a CLO, paid the class B
notes down in full on the Oct. 19, 2011, payment date, from an
outstanding balance of $76.25 thousand.

TCW Select Loan Fund Ltd. is a CLO. The transaction paid the class
C notes down in full on the Oct. 11, 2011, payment date, from an
outstanding balance of $0.16 million.

Tropic CDO I Ltd. is a CDO backed by trust preferred securities.
The transaction paid the class A-1L notes down in full on the
Oct. 17, 2011 payment date, from an outstanding balance of
$1.34 million.

Ratings Withdrawn

Coast Investment Grade 2000-1 Ltd.
                            Rating
Class               To                  From
B-1                 NR                  B+ (sf)
B-2                 NR                  B+ (sf)

Foxe Basin CLO 2003 Ltd.
                            Rating
Class               To                  From
A-2                 NR                  AAA (sf)

GE Commercial Loan Trust Series 2006-2
                            Rating
Class               To                  From
C                   NR                  CCC- (sf)

GE Commercial Loan Trust Series 2006-3
                            Rating
Class               To                  From
B                   NR                  CCC- (sf)

TCW Select Loan Fund Ltd.
                            Rating
Class               To                  From
C                   NR                  A+ (sf)

Tropic CDO I Ltd.
                            Rating
Class               To                  From
A-1L                NR                  A+ (sf)

NR -- Not rated.


COMM 2004-LNB3: Moody's Affirms Ratings of 17 CMBS Classes
----------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 17
classes of COMM 2004-LNB3, Commercial Mortgage Pass-Through
Certificates:

Cl. A-4, Affirmed at Aaa (sf); previously on Jul 1, 2004 Assigned
Aaa (sf)

Cl. A-5, Affirmed at Aaa (sf); previously on Jul 1, 2004 Assigned
Aaa (sf)

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

Cl. B, Affirmed at Aaa (sf); previously on Oct 29, 2008 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aa2 (sf); previously on Dec 2, 2010 Confirmed
at Aa2 (sf)

Cl. D, Affirmed at A2 (sf); previously on Dec 2, 2010 Confirmed at
A2 (sf)

Cl. E, Affirmed at Baa2 (sf); previously on Dec 2, 2010 Downgraded
to Baa2 (sf)

Cl. F, Affirmed at Ba2 (sf); previously on Dec 2, 2010 Downgraded
to Ba2 (sf)

Cl. G, Affirmed at B2 (sf); previously on Dec 2, 2010 Downgraded
to B2 (sf)

Cl. H, Affirmed at Caa2 (sf); previously on Dec 2, 2010 Downgraded
to Caa2 (sf)

Cl. J, Affirmed at Ca (sf); previously on Dec 2, 2010 Downgraded
to Ca (sf)

Cl. K, Affirmed at C (sf); previously on Dec 2, 2010 Downgraded to
C (sf)

Cl. L, Affirmed at C (sf); previously on Dec 2, 2010 Downgraded to
C (sf)

Cl. M, Affirmed at C (sf); previously on Dec 2, 2010 Downgraded to
C (sf)

Cl. N, Affirmed at C (sf); previously on Dec 2, 2010 Downgraded to
C (sf)

Cl. O, Affirmed at C (sf); previously on Dec 2, 2010 Downgraded to
C (sf)

Cl. X, Affirmed at Aaa (sf); previously on Jul 1, 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 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
3.5% of the current balance. At last review, Moody's cumulative
base expected loss was 3.2%. Moody's stressed scenario loss is
10.8% of the current balance. Moody's base expected loss is a
function of the total anticipated losses for the loans remaining
in the pool.  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 methodologies used in this rating were "Moody's Approach to
Rating Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000.

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
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 13 compared to 16 at Moody's prior review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.1 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST (R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 2, 2010.

DEAL PERFORMANCE

As of the October 11, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 32% to
$907.1 million from $1.3 billion at securitization. The
Certificates are collateralized by 74 mortgage loans ranging in
size from less than 1% to 14% of the pool, with the top ten non-
defeased loans representing 56% of the pool. The pool contains
three loans with investment grade credit estimates that comprise
32% of the pool. Nine loans have been defeased by US Government
securities and comprise 20% of the pool.

Sixteen loans, representing 11% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (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.

Four loans have been liquidated from the pool, resulting in a
realized loss of $18.8 million (49% loss severity). Currently two
loans, representing 4% of the pool, are in special servicing. The
largest specially serviced loan is the Beau Terre Office Building
Loan ($34.6 million -- 3.8% of the pool), which is secured by a
371,083 square foot (SF) office building located in Bentonville,
Arkansas. The loan was transferred to special servicing in May
2010 due to imminent default. As of March 2010, the property was
64% leased compared to 97% at securitization. The special servicer
rejected a borrower proposed loan modification in June 2011 and is
pursuing a foreclosure.

The other specially serviced loan represents less than 1% share of
the pool by outstanding balance. Moody's estimates an aggregate
$22.0 million loss for the specially serviced loans (58% expected
loss on average).

Moody's has assumed a high default probability for four poorly
performing loans representing 2% of the pool and has estimated an
aggregate $9.6 million loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 90%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 91% compared to 94% 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 9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.34X and 1.13X, respectively, compared to
1.48X and 1.10X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the Garden State Plaza
Loan ($130.0 million -- 14.3% of the pool), which represents a 25%
pari-passu interest in a first mortgage loan. The loan is secured
by a 1.5 million SF portion of a 2.0 million SF super-regional
mall located in Paramus, New Jersey. The mall is anchored by
Macy's, Nordstrom, J.C. Penney, Neiman Marcus and Lord & Taylor. A
$62 million expansion that added 150,000 SF to the collateral was
completed in early 2007. As of December 2010, the property was 98%
leased, which is the same as the prior year and securitization.
The loan is interest only for its entire 10-year term. The loan
sponsors are Westfield America Inc. and affiliates of Prudential
Assurance Co. Ltd. Property performance improved since the prior
review due to an approximately 3% growth in revenue that was only
partially offset by increased expenses. Moody's current credit
estimate and stressed DSCR are Aa3 and 1.52X, respectively,
compared to A1 and 1.47X at the prior review.

The second largest credit estimate is the 731 Lexington Avenue --
Bloomberg Headquarters Loan ($101.9 million -- 11.2% of the pool),
which represents a 39.8% pari-passu interest in a first mortgage
loan. The property is also encumbered by an $86.0 million junior
note held outside of the trust. The loan is secured by a 694,000
SF of office condominium space that is part of a 1.4 million SF
complex located in the Plaza District submarket of Manhattan.
Bloomberg, L.P. has leased all of the office space through 2028.
The loan contains a structural covenant that calls for a period of
hyper-amortization that will fully amortize the A-Note and the
whole loan in the 16th and 18th years of the Bloomberg lease,
respectively, if the loan is not paid off by its anticipated
repayment date in March 2014. Moody's current credit estimate and
stressed DSCR are A3 and 2.09, which are in-line with last review.

The third credit estimate is the Tysons Corner Center Loan ($56.9
million -- 6.3% of the pool), which represents an 18.4% pari-passu
interest in a first mortgage loan. The loan is secured by the
borrower's 1.6 million SF interest in a 2.0 million SF super-
regional mall located in McLean, Virginia. The mall is anchored by
Bloomingdale's, Macy's, Nordstrom and Lord & Taylor. The
property's financial performance has improved since securitization
due higher rental rates and additional rental income from a
265,000 SF expansion that was completed in 2007. The property was
96% leased as of June 2011. The loan has amortized 9% since
securitization. Moody's current credit estimate and stressed DSCR
are Aaa and 2.29X, respectively, the same as at last review.

The top three conduit loans represent 14% of the pool. The largest
conduit loan is the Centreville Square I & II Loan ($56.4 million
-- 6.2% of the pool), which is secured by a 312,000 SF grocery
anchored retail center located 30 miles southwest of Washington,
D.C. in Centreville, Virginia. As of July 2011, the center was 95%
leased compared to 89% in December 2009 and 100% at
securitization. Moody's analysis incorporated some near term
tenancy risk due to leases accounting for approximately 45% of the
net rentable area (NRA) expiring within the next 24 months.
Moody's LTV and stressed DSCR are 93% and 1.02X, respectively,
compared to 89% and 1.06X at last review.

The second largest loan is the 3 Beaver Valley Loan ($37.9 million
-- 4.2% of the pool), which is secured by a 263,000 SF office
building located in suburban Wilmington, Delaware. The property is
100% leased to 21st Century Insurance Company, a subsidiary of
Farmers Insurance Group. The lease expiration date is co-terminus
with the loan's maturity date. Moody's analysis incorporated the
"dark" value of the property, which is the property's value at
100% vacancy, to account for the risk associated with the lack of
tenant diversity and concurrent lease expiration and loan
maturity. The same approach was used at the last review. Moody's
LTV and stressed DSCR are 87% and 1.12X, respectively, compared to
90% and 1.09X at last review.

The third largest conduit loan is the Alexan Mira Vista Loan
($32.3 million -- 3.6% of the pool), which secured a 528-unit
garden style apartment property located six miles from the CBD of
Austin, Texas. The property was constructed in 2002. As of
December 2010, the property was 95% leased compared to 89% a year
earlier and 92% at securitization. Property performance improved
in 2010 from the prior year due to increased revenue from higher
occupancy and a decline in expenses. Moody's LTV and stressed DSCR
are 119% and 0.75X, respectively, compared to 130% and 0.69X at
last review.


CORTS TRUST: Moody's Raises Rating of US$12-Mil. Notes to 'Ba2'
---------------------------------------------------------------
Moody's Investors Service has upgraded the rating of these
certificates issued by CorTS Trust for Ford Debentures:

US$12,000,000 7.40% Corporate-Backed Trust Securities (CorTS)
Certificates; Upgraded to Ba2; Previously on October 7, 2011 Ba3,
Placed on Review for Possible Upgrade

RATINGS RATIONALE

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction. The rating action is a result of the change of the
rating of 7.40% Debentures due November 1, 2046 issued by Ford
Motor Company which were upgraded to Ba2 by Moody's on October 27,
2011.

The principal methodology used in this rating was "Moody's
Approach to Rating Repackaged Securities" published in April 2010.


CREST 2002-1: Moody's Lowers Rating of Class B-1 Notes to 'Caa1'
----------------------------------------------------------------
Moody's has upgraded the ratings of one class and downgraded the
ratings of two classes of Notes issued by Crest 2002-1 Ltd. The
upgrade is due to a change in the underlying collateral credit
distribution and rate of amortization of the Class A. The
downgrades are due to due to an increase in high credit risk
assets since last review. The rating action is the result
of Moody's on-going surveillance of commercial real estate
collateralized debt obligation (CRE CDO and ReRemic) transactions.

Class A Senior Secured Floating Rate Term Notes, Upgraded to Aa2
(sf); previously on Nov 11, 2010 Upgraded to Aa3 (sf)

Class B-1 Second Priority Fixed Rate Term Notes, Downgraded to
Caa1 (sf); previously on Nov 11, 2010 Downgraded to B3 (sf)

Class B-2 Second Priority Floating Rate Term Notes, Downgraded to
Caa1 (sf); previously on Nov 11, 2010 Downgraded to B3 (sf)

RATINGS RATIONALE

Crest 2002-1, Ltd. is a quarterly paying static cash CRE CDO
transaction backed by a portfolio of commercial mortgage backed
securities (CMBS) (77.9% of the pool balance) and real estate
investment trust (REIT) debt (22.1%). As of the September 30th,
2011 Trustee report, the aggregate Note balance of the
transaction, including preferred shares, was $239.9 million from
$500.0 million at issuance, with the amortization directed to the
Class A Note.

There are 5 assets with a par balance of $30.5 million (13.8% of
the current pool balance) that are considered Defaulted Securities
as of the September 30th, 2011 Trustee report. 100% of these
assets are CMBS collateral. While there have been no losses to the
deal to date, Moody's does expect losses to occur from the
defaulted securities once they are realized.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: weighted average
rating factor (WARF), weighted average life (WAL), weighted
average recovery rate (WARR), and

Moody's asset correlation (MAC). These parameters are typically
modeled as actual parameters for static deals and as covenants for
managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 5,40 compared to 3,556 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (2.7% compared to 0% at last review), A1-A3 (0.6%
compared to 6.0% at last review), Baa1-Baa3 (22.1% compared to
37.8% at last review), Ba1-Ba3 (6.7% compared to 12.5% at last
review), B1-B3 (21.6% compared to 11.4% at last review), and Caa1-
C (46.2% compared to 32.3% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 1.6 years, the same
as at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
13.5% compared to 22.4% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 4.8% compared to 5.5% at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

The cash flow model, CDOEdge(R) v3.2.1.0, was used to analyze the
cash flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
13.5% to 3.5% or up to 23.5% would result in average rating
movement on the rated classes of 0 to 2 notches downward, or 0 to
2 notches upward.

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 methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in November 2010, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


CSFB 2004-C1: Moody's Affirms Ratings of 15 CMBS Classes
--------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of two
classes and affirmed 15 classes of Credit Suisse First Boston
Mortgage Securities Corp., Commercial Mortgage Pass-Through
Certificates, Series 2004-C1:

Cl. A-3, Affirmed at Aaa (sf); previously on March 9, 2011
Confirmed at Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on March 9, 2011
Confirmed at Aaa (sf)

Cl. B, Upgraded to Aaa (sf); previously on March 9, 2011 Confirmed
at Aa1 (sf)

Cl. C, Upgraded to Aa2 (sf); previously on March 22, 2004
Definitive Rating Assigned Aa3 (sf)

Cl. D, Affirmed at A2 (sf); previously on March 22, 2004
Definitive Rating Assigned A2 (sf)

Cl. E, Affirmed at Baa1 (sf); previously on December 17, 2010
Downgraded to Baa1 (sf)

Cl. F, Affirmed at Baa3 (sf); previously on December 17, 2010
Downgraded to Baa3 (sf)

Cl. G, Affirmed at Ba3 (sf); previously on December 17, 2010
Downgraded to Ba3 (sf)

Cl. H, Affirmed at B3 (sf); previously on December 17, 2010
Downgraded to B3 (sf)

Cl. J, Affirmed at Caa3 (sf); previously on December 17, 2010
Downgraded to Caa3 (sf)

Cl. K, Affirmed at C (sf); previously on December 17, 2010
Downgraded to C (sf)

Cl. L, Affirmed at C (sf); previously on December 17, 2010
Downgraded to C (sf)

Cl. M, Affirmed at C (sf); previously on December 17, 2010
Downgraded to C (sf)

Cl. N, Affirmed at C (sf); previously on December 17, 2010
Downgraded to C (sf)

Cl. O, Affirmed at C (sf); previously on December 17, 2010
Downgraded to C (sf)

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

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

RATINGS RATIONALE

The upgrades are due to the significant increase in subordination
due to loan payoffs and amortization and overall stable pool
performance. The pool has paid down by 4% since Moody's last
review.

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
4.0% of the current balance. At last review, Moody's cumulative
base expected loss was 5.4%. Moody's stressed scenario loss is
6.9% of the current balance.  Depending on the timing of loan
payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment
grade classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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 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 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 17, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 31% to $1.1 billion
from $1.6 billion at securitization. The Certificates are
collateralized by 224 mortgage loans ranging in size from less
than 1% to 12% of the pool, with the top ten loans representing
43% of the pool. The pool contains two loans with investment grade
credit estimates that represent 19% of the pool. Nineteen loans,
representing 11% of the pool, have defeased and are collateralized
with U.S. Government securities.

Forty loans, representing 13% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (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.

Fifteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $20.7 million (32% loss severity
overall). Excluding liquidated loans with less than a 1% loss
severity, the overall loss severity is 56%. Eight loans,
representing 4% of the pool, are currently in special servicing.
The master servicer has recognized an aggregate $18.0 million
appraisal reduction for six of the specially serviced loans.
Moody's has estimated an aggregate $24.6 million loss (54%
expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for 17 poorly
performing loans representing 6% of the pool and has estimated a
$10.5 million aggregate loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full and partial year 2010 and partial
year 2011 operating results for 94% and 39% of the pool's non-
defeased and non-specially serviced loans, respectively. Excluding
specially serviced and troubled loans, Moody's weighted average
LTV is 83% compared to 84% at Moody's prior review. Moody's net
cash flow reflects a weighted average haircut of 11% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.5%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.44X and 1.34X, respectively, compared to
1.47X and 1.34X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 20 compared to 21 at Moody's prior review.

The largest loan with an investment grade credit estimate is the
Bay Plaza Community Center Loan ($125.1 million -- 11.2% of the
pool), which is secured by a mixed use development consisting of a
385,000 square foot (SF) retail component and a 125,000 SF office
component. The property is located in the Bronx, New York. The
property was 89% leased as of September 2011 compared to 83% as of
October 2010. Performance has increased due to the decline in
vacancy. Moody's credit estimate and stressed DSCR are Baa2 and
1.40X, respectively, compared to Baa2 and 1.30X at last review.

The second loan with a credit estimate is the Beverly Center Loan
($91.4 million -- 8.2% of the pool), which represents a 32.6% pari
passu interest in a first mortgage loan. The property was also
encumbered by a non-pooled $41.0 million B Note at securitization.
The loan is secured by a leasehold interest in an 855,000 SF
regional mall located in Los Angeles, California. The mall is
anchored by Bloomingdale's, Macy's and Bed Bath & Beyond. The mall
was 94% leased as of June 2011 compared to 95% as of December 2010
and 91% as of December 2009. Performance has declined slightly due
to a decrease in base rents and expense reimbursements. Moody's
credit estimate and stressed DSCR are A2 and 1.45X, respectively,
essentially the same as at last review.

The top three performing conduit loans represent 6% of the pool
balance. The largest loan is the Northfield Square Mall Loan
($26.9 million -- 2.4% of the pool), which is secured by a 558,000
SF regional mall located in Bourbonnais, Illinois. The center is
anchored by Sears, J.C. Penney and Carson Pirie Scott. The mall
was 87% leased as of June 2011, the same as of June 2010.
Performance has declined due to a decrease in effective gross
income. Moody's LTV and stressed DSCR are 98% and 1.05X,
respectively, compared to 91% and 1.12X at last review.

The second largest loan is the Canterbury Apartments Loan
($23.0 million -- 2.1% of the pool), which is secured by a 480-
unit multifamily complex located in Nashua, New Hampshire. The
property was 86% leased as of July 2011 compared to 80% as of
December 2010 and 84% as of December 2009. Despite the increase
in occupancy, performance has declined due to an increase in
operating expenses. Moody's LTV and stressed DSCR are 97% and
1.03X, respectively, compared to 89% and 1.12X at last review.

The third largest loan is the Bristol Park at Encino Commons
Apartments Loan ($21.9 million -- 1.9% of the pool), which is
secured by a 324-unit multifamily property located in San Antonio,
Texas. The property was 95% leased as of June 2011 compared to
96% as of December 2010 and 93% as of December 2009. Property
performance improved due to an increase in effective gross income.
However, the loan is on the servicer's watchlist due to low debt
service coverage. Moody's LTV and stressed DSCR are 125% and
0.72X, respectively, compared to 140% and 0.64X at last review.


CSMC 2006-C5: Moody's Reviews Ratings for Possible Downgrade
------------------------------------------------------------
Moody's Investors Service (Moody's) placed eight classes of Credit
Suisse Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2006-C5 on review for possible downgrade:

Cl. A-M, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on March 9, 2011 Confirmed at Aa1 (sf)

Cl. A-J, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on December 16, 2009 Downgraded to Baa1 (sf)

Cl. B, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on December 16, 2009 Downgraded to Baa2 (sf)

Cl. C, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on December 16, 2009 Downgraded to Ba1 (sf)

Cl. D, B2 (sf) Placed Under Review for Possible Downgrade;
previously on December 16, 2009 Downgraded to B2 (sf)

Cl. E, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on January 13, 2011 Downgraded to Caa2 (sf)

Cl. F, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on January 13, 2011 Downgraded to Caa3 (sf)

Cl. G, Ca (sf) Placed Under Review for Possible Downgrade;
previously on January 13, 2011 Downgraded to Ca (sf)

RATINGS RATIONALE

Classes A-M through G were placed on review for possible downgrade
due to higher realized losses and anticipated losses from loans in
special servicing and on the watch list.

The rating actions 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 (Moody's Surveillance Trends) and CMM
(Commercial Mortgage Metrics) on Trepp -- and on a periodic basis
through a comprehensive review. Moody's prior full review is
summarized in a press release dated January 13, 2011.

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

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 11% to $3.1 billion
from $3.5 billion at securitization and 5% since Moody's prior
review in January 2011. The Certificates are collateralized by 277
mortgage loans ranging in size from less than 1% to 6% of the
pool, with the top ten loans representing 38% of the pool. No
loans have defeased.

Ninety-two loans, representing 27.2% of the pool, are on the
master servicer's watchlist compared to 54 or 19.0% of the pool at
last review. The watchlist includes loans which meet certain
portfolio review guidelines established as part of the CRE Finance
Council (CREFC) monthly reporting package. As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Twenty-four loans have been liquidated from the pool, resulting in
an aggregate realized loss of $51.5 million (24% loss severity
overall). At last review the pool had experienced an aggregate
$40.5 million loss from 19 loans. Thirty-one loans, representing
17% of the pool, are currently in special servicing compared to 26
loans representing 13% of the pool at last review.

Based on the most recent remittance statement, Classes F through Q
have experienced cumulative interest shortfalls totaling $15.6
million, higher reported realized losses and increased appraisal
reductions from specially serviced loans. Moody's anticipates that
the pool will continue to experience interest shortfalls because
of the high exposure to specially serviced loans. Interest
shortfalls are caused by special servicing fees, including workout
and liquidation fees, appraisal subordinate entitlement reductions
(ASERs) and extraordinary trust expenses. Moody's also anticipates
higher realized losses based on high loan-to-value (LTV) and low
debt service coverage ratios which when combined, contribute to
looming refinance risk.


DRUG ROYALTY: Moody's Assigns Provisional Rating to ABS
-------------------------------------------------------
Moody's Investors Service has assigned the provisional rating
of Baa2 (sf) to the Secured Notes, Series 2011-1 to be issued by
Drug Royalty LP 1 (Issuer), a indirect subsidiary of the sponsor,
DRI Capital Inc.. The Issuer is a bankruptcy-remote limited
partnership that issues notes under a master indenture. Series
2011-1 is comprised of floating rate notes (Class A-1), and fixed
rate notes (Class A-2), which rank pari-passu for all purposes.
The complete rating action is as follows:

Issuer: Drug Royalty LP 1

Secured Notes Series 2011-1 Class A-1, Assigned (P) Baa2 (sf)

Secured Notes, Series 2011-1 Class A-2, Assigned (P) Baa2 (sf)

RATING RATIONALE

Collateral for Series 2011-1, shared with the other series (Series
2007-1) of notes issued under the master trust indenture, consists
of 18 drug royalty streams generated from the global sales of 14
drugs. The provisional rating is based on following (1) expected
royalty payments from a moderately diversified portfolio with a
mix of pharmaceutical products that target diversified ailments
with a concentration in drugs specifically targeting auto-immune
diseases, (2) drugs that are well seasoned in various markets
since their regulatory approval, (3) strength of the marketers of
the drugs in the portfolio, which include some of the world's
leading pharmaceutical companies, (4) sizing of the outstanding
notes relative to the expected cash flows, (5) capability of DRI
Capital Inc, in its capacity as primary servicer and provider of
issuer forecasts; and (6) the structure of the transaction,
including legal protections.

Credit support to the notes includes (i) dynamic
overcollateralization with a minimum size of 30% of the net
present value of the aggregate forecasted royalty revenues and
(ii) reserve account sized to cover 6 months of interest, with the
floor of $1 million.

The total present value (PV), discounted back to October 15, 2011,
of the future royalty payments based on the Issuer's forecast at
the discount rate of 7% is $533.5 million. The weighted average
years in market for these products based on present value of the
associated royalty payments is 10.8 years and the years remaining
in term of purchase agreement relating to the royalty payments is
5.4 years. There is a moderate amount of diversification by drug
in the portfolio. The biggest drug in the portfolio, by present
value of expected future cash flows, is Enbrel (31.1%). The top 3
drugs (Enbrel, Remicade and Peg-Intron) constitute 57.2% of the
portfolio. Mitigating the lack of diversification at the top are
the length of time that each drug has been on the market since
getting its regulatory approval (over 10 years in market for each
drug) and the recognition of the efficacy of these drugs in
addressing specific chronic ailments.

The asset value of the portfolio is determined based on a revenue
forecast. This forecast is updated at least annually and more
often if the aggregate royalty amounts received over the prior
four quarters are less than 15% of the most recent forecast of the
Issuer. In addition, the Issuer's projections, as provided by DRI
Capital Inc, are cross referenced to an independent pharmaceutical
industry consultant's forecasts. Historically, DRI Capital's
royalty projections for the portfolio have been conservative
relative to actual royalties collected.

Finally, it should be noted that Moody's ratings address only the
timely payment of interest and ultimate payment of principal on or
before the legal final date of this transaction.

V-SCORE AND LOSS SENSITIVITY

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

This transaction has an overall "medium" score because of
uncertainty from the lack of historical data from a sector
(pharmaceutical) that has not experienced a stress scenario which
is largely mitigated due to (i) quality of royalty forecast
measured against royalties collected, historically, (ii) simple
transaction structure, (iii) low market value risk in the
transaction and (iv)the lack of complexity in servicing.

Moody's Parameter Sensitivities. For this exercise, stress
scenarios were analyzed to assess the potential model-indicated
ratings impact if (a) the base case assumed haircut to royalties
forecast was increased from 20% to 30% and 40%, and (b) the
probability of cliff event for each drug was increased to 2-times
that of the base case. Applying such assumptions, the Baa2 initial
rating of the notes might change as follows: (i) with the base
case probability of a Cliff event for each drug, the Baa2 initial
note rating would (a) remain at Baa2 if the haircut is 30% and (b)
drop to Ba3 if the haircut is 40%, and (ii) if the cliff event
probability is two times that of the base case, the Baa2 initial
note rating would (a) remain at Baa2 if haircut is 20%, (b) drop
to Ba1 if haircut is 30%, and (c) drop to B3 if haircut is 40%.

Parameter Sensitivities are not intended to measure how the rating
of the security might migrate over time; rather they are designed
to provide a quantitative calculation of how the initial rating
might change if key input parameters used in the initial rating
process differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.

PRINCIPAL METHODOLOGY

Moody's uses a Monte Carlo simulation based analysis across
various scenarios that affect how royalty cash flows pay down the
Notes. For each scenario, simulation output, which are probability
and severity of default of the Notes, guides Moody's opinion on
the rating of the Notes.

The key variables identified by Moody's to rate notes backed by
drug royalty transactions include 1) projected sales and royalties
of the pharmaceutical products in the portfolio; 2) probability of
a cliff event for a drug- arising due to product withdrawal and/or
competition; 3) probability of default of the manufacturer and/or
marketer of a drug ; 4) shift in exchange rate relative to US
Dollar (USD) that affect royalty payments from non USD denominated
sales.

In determining the parameters for each variable, Moody's relies on
a combination of historical data, market knowledge of current and
future trends in the pharmaceutical industry, and the servicer's
track record in royalty payment projection. More specifically, for
the haircut applied to the Issuer's projection on the sales and
royalties of the pharmaceutical products, Moody's analyst covering
pharmaceutical companies is consulted; the Issuer's projection is
compared with that provided by a third party consultant; and the
accuracy of the Issuer's projection is reviewed by comparing
historical projections with actual collections. Cliff risk for
each product in the portfolio is assessed individually based on
its seasoning, the product type, competitive landscape ,
characteristics of the underlying patent(s), and trends in the
pharmaceutical industry. The manufacturer and/or marketer's
default probability is based on a two notch downgrade to its
current Moody's rating. For manufacturers and/or marketers not
rated by Moody's, a credit rating of Caa2 is assumed.

In Moody's approach, simulation results across various scenarios
are studied. In each scenario, the following are assumed (a) fixed
haircut to projected royalties, (b) for foreign (non USD
denominated) sales, fixed shift in exchange rate versus USD, and
(c) 3-month LIBOR curve. For each scenario, the Monte-Carlo based
model simulates for each drug its (a) cliff event, using the
probability assumed for the cliff event for that drug, and (b) the
manufacturer/marketer default, using the probability of default
implied by a two notch downgrade to the then current marketer's
credit rating. Once a cliff event occurs for a drug, the
associated cash flow is decreased to 0 over x quarters (where, x
is a model input. Moody's considered scenarios where x ranged from
2 quarters to 12 quarters) and stays at 0 for the remaining term
of the purchase agreement. If the manufacturer or marketer
defaults during the life of the transaction, the associated cash
flow goes to 0 immediately to reflect the uncertainty of the
bankruptcy proceedings. However, after two quarters, a Baa3-rated
manufacturer and/or marketer is assumed to take over the product
and the cash flow reverts back to the pre-bankruptcy projections.
This assumption reflects Moody's belief that the pharmaceutical
products are valuable assets and they will be sold and marketed
even if the manufacturer or marketer files for bankruptcy. As long
as the products are sold, the manufacturer or marketer is
obligated to pay royalties. Cash flow, thus simulated, pays down
the Notes as per the applicable priority of payments.

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


FALL CREEK: Fitch Downgrades Rating on 8 Note Classes to 'Dsf'
--------------------------------------------------------------
Fitch Ratings has downgraded eight classes of notes issued by Fall
Creek CLO, Ltd. (Fall Creek) and withdrawn the rating as follows:

  -- $18,127,181 Class C notes downgraded to 'Dsf' from 'Csf/RR5'
     and withdrawn;
  -- $3,753,484 Class C-1 notes downgraded to 'Dsf' from 'Csf/RR5'
     and withdrawn;
  -- $2,000,000 Class D-1 notes downgraded to 'Dsf' from 'Csf/RR6'
     and withdrawn;
  -- $3,160,000 Class D-1A notes downgraded to 'Dsf' from
     'Csf/RR6' and withdrawn;
  -- $1,697,000 Class D-1B notes downgraded to 'Dsf' from
     'Csf/RR6' and withdrawn;
  -- $2,092,000 Class D-1C notes downgraded to 'Dsf' from
     'Csf/RR6' and withdrawn;
  -- $8,319,000 Class D-1D notes downgraded to 'Dsf' from
     'Csf/RR6' and withdrawn;
  -- $5,167,000, Class D-2 notes downgraded to 'Dsf' from
     'Csf/RR6' 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
June 22, 2011.  At the direction of the class D-1, D-1A, D-1B, D-
1C, D-1D and D-2 (Class D) noteholders and with consent of 100% of
the class C and C-1 (Class C) noteholders, an optional redemption
was declared.  The portfolio collateral was subsequently
liquidated and proceeds were distributed according to the
transaction documents.  The class A-2 and B notes were paid in
full, while the class C notes received only partial payment (61%
of the original balance) and the class D notes received no
distributions. Fall Creek has no assets remaining in its
portfolio.

Fall Creek is a collateralized loan obligation (CLO) that closed
on Sept. 8, 2005 and was amended and restructured on Nov. 24,
2008.  The portfolio was selected and monitored by 40|86 Advisors,
Inc.


FIRST HORIZON: S&P Lowers Rating on Class B-1 From 'CCC' to 'CC'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes from four U.S. residential mortgage-backed securities
(RMBS) transactions backed by re-performing and Alternative-A
(Alt-A) mortgage loans issued in 2003-2006. "In addition, we
affirmed our ratings on seven classes from these same
transactions," S&P related.

"The downgrades reflect our opinion that projected credit support
for the affected classes will be insufficient to cover projected
losses at the previous rating levels due to increased
delinquencies," S&P said.

"To assess the creditworthiness of each class, we reviewed the
individual delinquency and loss trends of each transaction for
changes, if any, in risk characteristics and the ability to
withstand additional credit deterioration. In order to maintain a
'B' rating on a class, we assessed whether, in our view, a class
could absorb the 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 a '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, while we would assess whether a different
class could withstand approximately 120% of our remaining base-
case loss assumptions to maintain a 'BBB' rating. 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 related.

"The affirmed ratings 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 said.

Subordination, overcollateralization (prior to its depletion), and
excess spread provide credit support for the affected
transactions. The underlying collateral for these deals consists
of fixed- and adjustable-rate U.S. re-performing and Alt-A
mortgage loans secured by first liens on one- to four-family
residential properties.

Rating Actions

First Horizon Alternative Mortgage Securities Trust 2004-AA6
Series      2004-AA6
                               Rating
Class      CUSIP       To                   From
A-2        32051GCC7   B (sf)               BBB+ (sf)
B-1        32051GCF0   CC (sf)              CCC (sf)

GSRPM Mortgage Loan Trust 2004-1
Series      2004-1
                               Rating
Class      CUSIP       To                   From
B-2        36242DGM9   D (sf)               B (sf)
B-3        36242DGN7   D (sf)               CCC (sf)

Salomon Mortgage Loan Trust, Series 2003-CB1
Series      2003-CB1
                               Rating
Class      CUSIP       To                   From
M-1        79549ARX9   B (sf)               AAA (sf)
M-2        79549ARY7   CC (sf)              B (sf)
B-1        79549ARZ4   CC (sf)              CCC (sf)

Truman Capital Mortgage Loan Trust 2006-1
Series      2006-1
                               Rating
Class      CUSIP       To                   From
M-1        89789KAB1   CC (sf)              CCC (sf)

RATINGS AFFIRMED

First Horizon Alternative Mortgage Securities Trust 2004-AA6
Series      2004-AA6
Class      CUSIP       Rating
A-1        32051GCB9   AAA (sf)
A-IO       32051GCD5   AAA (sf)

GSRPM Mortgage Loan Trust 2004-1
Series      2004-1
Class      CUSIP       Rating
M-1        36242DGJ6   AA (sf)
M-2        36242DGK3   A (sf)
B-1        36242DGL1   BBB+ (sf)

Salomon Mortgage Loan Trust, Series 2003-CB1
Series      2003-CB1
Class      CUSIP       Rating
AF         79549ARU5   AAA (sf)

Truman Capital Mortgage Loan Trust 2006-1
Series      2006-1
Class      CUSIP       Rating
A          89789KAA3   B (sf)


FIRST INVESTORS: DBRS Assigns Series 2011-2 Notes, Class E at 'BB'
------------------------------------------------------------------
DBRS, Inc., has assigned final ratings to the notes issued by
First Investors Auto Owner Trust 2011-2.

First Investors Auto Owner Trust 2011-2 Series 2011-2 Notes, Class
E Provis.-Final BB (sf) -- Oct 21, 2011


FORD MOTOR: Moody's Raises Rating of US$2.34-Mil. Notes to 'Ba2'
----------------------------------------------------------------
Moody's Investors Service has upgraded the rating of these
certificates issued by Corporate Backed Trust Certificates, Ford
Motor Co. Debenture-Backed Series 2001-36 Trust:

US$2,340,040 Corporate Backed Trust Certificates, Ford Motor Co.
Debenture-Backed Series 2001-36, Class A-1; Upgraded to Ba2;
Previously on October 7, 2011 Ba3, Placed on Review for Possible
Upgrade

RATINGS RATIONALE

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction. The rating action is a result of the change of the
rating of 7.70% Debentures due May 15, 2097 issued by Ford Motor
Company which were upgraded to Ba2 by Moody's on October 27, 2011.

The principal methodology used in this rating was "Moody's
Approach to Rating Repackaged Securities" published in April 2010.


FOXE BASIN: Moody's Raises Rating of Class C Notes to 'Ba3'
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Foxe Basin CLO 2003, Ltd.:

US$24,500,000 Class B Floating Rate Senior Subordinate Notes Due
2015, Upgraded to Aaa (sf); previously on June 22, 2011 A2 (sf)
Placed Under Review for Possible Upgrade;

US$22,000,000 Class C Floating Rate Subordinate Notes Due 2015
(current outstanding balance of $16,719,851), Upgraded to Ba3
(sf); previously on June 22, 2011 Caa1 (sf) Placed Under Review
for Possible Upgrade;

US$3,000,000 Class Q-2 Notes Due 2015 (current rated balance of
$843,662), Upgraded to Baa1 (sf); previously on June 22, 2011 Ba3
(sf) Placed Under Review for Possible Upgrade.

In addition, Moody's confirmed the rating of these notes:

US$10,000,000 Class D Floating Rate Junior Subordinate Notes Due
2015 (current outstanding balance of $7,577,894), Confirmed at C
(sf); previously on June 22, 2011 C (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 deleveraging of the
senior notes since the rating action in May 2011. The Class A-3
Notes have been paid down by approximately 66% or $21 million
since May 2011. As a result of the deleveraging, the senior
overcollateralization ratios have increased. Based on the latest
trustee report dated October 2, 2011, the Class A and Class B
overcollateralization ratios are reported at 480.45% and 148.87%,
respectively, versus May 2011 levels of 178.17% and 128.29%,
respectively.

Moody's notes that the transaction is exposed to a significant
concentration of securities rated Caa1 or lower. Securities rated
Caa1 or below are of lower credit quality and typically have
higher risk of default compared to other securities with ratings
of B3 or above. Based on the October 2011 trustee report,
securities rated Caa1 or lower currently make up approximately
29.11% of the underlying portfolio.

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 $53 million,
defaulted par of $12 million, a weighted average default
probability of 19.20% (implying a WARF of 3636), a weighted
average recovery rate upon default of 49.23%, and a diversity
score of 18. 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.

Foxe Basin CLO 2003, Ltd., issued in December 2003, 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. In addition, the methodology "Using the Structured Note
Methodology to Rate CDO Combo-Notes" published in February 2004
was also used.

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

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

3) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates. Moody's also conducted stress tests to assess
the collateral pool's concentration risk in obligors bearing a
credit estimate that constitute more than 3% of the collateral
pool.

4) Low diversity and lack of granularity: The rated notes are
highly dependent on the credit conditions of a few large obligors,
the largest of which represents about 7% of the portfolio.


FRASER SULLIVAN: S&P Gives 'BB' Rating on Class D Deferrable Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Fraser Sullivan CLO VI Ltd./Fraser Sullivan CLO VI
Corp.'s up to $355.2 million floating-rate notes.

The note issuance is a collateralized loan obligation
securitization backed by a revolving pool consisting primarily of
broadly syndicated senior secured loans.

The preliminary ratings are based on information as of Nov. 1,
2011. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

    The credit enhancement provided to the preliminary rated notes
    through the subordination of cash flows that are payable to
    the subordinated notes.

    The transaction's credit enhancement, which is sufficient to
    withstand the defaults applicable for the supplemental tests
    (not counting excess spread), and cash flow structure, which
    can withstand the default rate projected by Standard & Poor's
    CDO Evaluator model, as assessed by Standard & Poor's using
    the assumptions and methods outlined in its corporate
    collateralized debt obligation (CDO) criteria (see "Update To
    Global Methodologies And Assumptions For Corporate Cash Flow
    And Synthetic CDOs," published Sept. 17, 2009).

    The transaction's legal structure, which is expected to be
    bankruptcy remote.

    The diversified collateral portfolio, which primarily
    comprises broadly-syndicated speculative-grade senior secured
    term loans.

    The asset manager's experienced management team.

    "Our projections regarding the timely interest and ultimate
    principal payments on the preliminary rated notes, which we
    assessed using our cash flow analysis and assumptions
    commensurate with the assigned preliminary ratings under
    various interest-rate scenarios, including LIBOR ranging from
    0.4318%-13.8391%," S&P related.

    The transaction's overcollateralization and interest coverage
    tests, a failure of which will lead to the diversion of
    interest and principal proceeds to reduce the balance of the
    rated notes outstanding.

           Standard & Poor's 17g-7 Disclosure Report

SEC Rule 17g-7 requires an NRSRO, for any report accompanying a
credit rating relating to an asset-backed security as defined in
the Rule, to include a description of the representations,
warranties and enforcement mechanisms available to investors and a
description of how they differ from the representations,
warranties and enforcement mechanisms in issuances of similar
securities.

The Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at

   http://standardandpoorsdisclosure-17g7.com/1111234.pdf

Preliminary Ratings Assigned
Fraser Sullivan CLO VI Ltd./Fraser Sullivan CLO VI Corp.

Class               Rating           Amount
                                (mil. $)(i)
A-1                  AAA (sf)         265.0
A-2                  AA (sf)           16.0
B (deferrable)       A (sf)            36.3
C (deferrable)       BBB (sf)          18.3
D (deferrable)       BB (sf)           19.6
Subordinated notes   NR               53.49

NR -- Not rated.


FRIEDBERGMILSTEIN PRIVATE: Moody's Ups Rating of Class D-1 to Ba1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by FriedbergMilstein Private Capital Fund I:

US$54,100,000 Class B-1 Second Priority Secured Floating Rate
Notes due 2019, Upgraded to Aaa (sf); previously on June 22, 2011
A1 (sf) Placed Under Review for Possible Upgrade;

US$17,000,000 Class B-2 Second Priority Secured Fixed Rate Notes
due 2019, Upgraded to Aaa (sf); previously on June 22, 2011 A1
(sf) Placed Under Review for Possible Upgrade;

US$20,750,000 Class C-1 Third Priority Secured Deferrable Floating
Rate Notes due 2019, Upgraded to Aa1 (sf); previously on June 22,
2011 Baa3 (sf) Placed Under Review for Possible Upgrade;

US$13,000,000 Class C-2 Third Priority Secured Deferrable Fixed
Rate Notes due 2019, Upgraded to Aa1 (sf); previously on June 22,
2011 Baa3 (sf) Placed Under Review for Possible Upgrade;

US$21,000,000 Class D-1 Fourth Priority Secured Deferrable
Floating Rate Notes due 2019 (current outstanding balance of
$21,408,655), Upgraded to Ba1 (sf); previously on June 22, 2011 B3
(sf) Placed Under Review for Possible Upgrade;

US$12,750,000 Class D-2 Fourth Priority Secured Deferrable Fixed
Rate Notes due 2019 (current outstanding balance of $12,998,111),
Upgraded to Ba1 (sf); previously on June 22, 2011 B3 (sf) Placed
Under Review for Possible Upgrade;

US$10,000,000 Combination Securities Due 2019 (current outstanding
rated balance of $5,316,158), Upgraded to Baa1 (sf); previously on
June 22, 2011 B1 (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 deleveraging of the transaction.
The Class A notes have been paid down from approximately
$204 million to approximately $22 million since the last
rating action in September 2010. As a result of the delevering,
the overcollateralization ratios have improved. Based on the
October 2011 trustee report, the Class A/B, Class C, and Class
D overcollateralization ratios are reported at 188.42%, 143.93%,
and 115.56%, respectively, versus August 2010 levels of 138.06%,
122.97%, and 110.08%, respectively.

The actions also reflect consideration 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 balance, including principal proceeds, of
$194 million, defaulted par of $42.7 million, a weighted average
default probability of 24.0% (implying a WARF of 3941), a weighted
average recovery rate upon default of 46.3%, and a diversity score
of 38. 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.

FriedbergMilstein Private Capital Fund I, issued in December 2004,
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. Additionally, the methodology "Using the Structured
Note Methodology to Rate CDO Combo-Notes" published in February
2004 was also used.

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.

Sources of additional performance uncertainties are:

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

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

3. Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates.


GENESIS CLO: S&P Raises Rating on Class E Notes to 'BB+'
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B, C, D, and E notes from Genesis CLO 2007-1 Ltd., a U.S.
collateralized loan obligation (CLO) transaction. "At the same
time, we removed our ratings on the class B, C, D, and E notes
from CreditWatch, where we placed them with positive implications
on Aug. 2, 2011. We also affirmed our 'AAA (sf)' rating on the
class A notes," S&P related.

"The upgrades reflect a paydown to the class A notes and the
improved performance we have observed in the deal's underlying
asset portfolio since our December 2010 rating actions. Since that
time, the transaction has paid down the class A notes by
approximately $463 million, reducing the balance to about 27% of
the original balance. According to the Oct. 4, 2011, trustee
report, the transaction's asset portfolio held $35 million in
defaulted assets, down from the $63 million noted in the December
2010 trustee report," S&P said.

The underlying portfolio held $282 million (approximately 30% of
the pool) in long-dated corporate assets noted in the October 2011
trustee report. "According to our criteria (see 'CDO Spotlight:
General Cash Flow Analytics For CDO Securitizations,' published
Aug. 25, 2004), the par credit for the long-dated assets was
reduced by applying a present value of 10% per year to each
principal payment due on the asset beyond the legal final maturity
date of the transaction. This adjustment stressed the transaction
with a potential par loss incurred for the forced sale of the
asset under less than ideal market conditions," S&P said.

"We affirmed our rating on the class A notes to reflect the
sufficient credit support available at the current rating level,"
S&P related.

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

Rating And Creditwatch Actions

Genesis CLO 2007-1 Ltd.
                         Rating
Class                To           From
B                    AA+ (sf)     AA (sf)/Watch Pos
C                    A+ (sf)      A (sf)/Watch Pos
D                    BBB+ (sf)    BBB- (sf)/Watch Pos
E                    BB+ (sf)     BB- (sf)/Watch Pos

Rating Affirmed

Genesis CLO 2007-1 Ltd.
Class                Rating
A                    AAA (sf)


GMAC 2003-C3: Moody's Affirms Ratings of 16 CMBS Classes
--------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of four
classes and affirmed 16 classes of GMAC Commercial Mortgage
Securities, Inc., Commercial Mortgage Pass-Through Certificates,
Series 2003-C3:

Cl. A-3, Affirmed at Aaa (sf); previously on May 14, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on May 14, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on May 14, 2004
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on February 27, 2007
Upgraded to Aaa (sf)

Cl. C, Affirmed at Aa1 (sf); previously on February 27, 2007
Upgraded to Aa1 (sf)

Cl. D, Affirmed at Aa3 (sf); previously on March 18, 2008 Upgraded
to Aa3 (sf)

Cl. E, Affirmed at A2 (sf); previously on March 18, 2008 Upgraded
to A2 (sf)

Cl. F, Affirmed at Baa3 (sf); previously on December 10, 2010
Downgraded to Baa3 (sf)

Cl. G, Upgraded to Ba3 (sf); previously on December 10, 2010
Downgraded to B2 (sf)

Cl. H, Upgraded to B2 (sf); previously on December 10, 2010
Downgraded to Caa1 (sf)

Cl. J, Upgraded to Caa1 (sf); previously on December 10, 2010
Downgraded to Caa3 (sf)

Cl. K, Upgraded to Caa3 (sf); previously on December 10, 2010
Downgraded to C (sf)

Cl. L, Affirmed at C (sf); previously on December 10, 2010
Downgraded to C (sf)

Cl. M, Affirmed at C (sf); previously on December 10, 2010
Downgraded to C (sf)

Cl. N, Affirmed at C (sf); previously on December 10, 2010
Downgraded to C (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on May 14, 2004
Definitive Rating Assigned Aaa (sf)

Cl. S-AFR1, Affirmed at A3 (sf); previously on May 14, 2004
Definitive Rating Assigned A3 (sf)

Cl. S-AFR2, Affirmed at Baa1 (sf); previously on May 14, 2004
Definitive Rating Assigned Baa1 (sf)

Cl. S-AFR3, Affirmed at Baa2 (sf); previously on May 14, 2004
Definitive Rating Assigned Baa2 (sf)

Cl. S-AFR4, Affirmed at Baa3 (sf); previously on May 14, 2004
Definitive Rating Assigned Baa3 (sf)

RATINGS RATIONALE

The upgrades are due to lower than expected losses from specially
serviced and troubled loans along with increased credit support
due to loan payoffs and amortization. The pool has paid down by 6%
since Moody's last review.

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
3.8% of the current balance. At last review, Moody's cumulative
base expected loss was 6.6%. Moody's stressed scenario loss is
8.9% of the current balance.  Depending on the timing of loan
payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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 methodologies used in this rating were "Moody's Approach to
Rating Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000.

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 19 compared to 20 at Moody's prior full review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.2 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST (R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 10, 2010.

DEAL PERFORMANCE

As of the October 11, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 45% to
$739.4 million from $1.3 billion at securitization. The
Certificates are collateralized by 55 mortgage loans ranging in
size from less than 1% to 9% of the pool, with the top ten loans
representing 57% of the pool. The pool contains two loans with
investment grade credit estimates that represent 16% of the pool.
Nine loans, representing 14% of the pool, have defeased and are
collateralized with U.S. Government securities.

Thirteen loans, representing 10% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Five loans have been liquidated from the pool, resulting in an
aggregate realized loss of $31.0 million (25% loss severity
overall). One loan, representing 2% of the pool, is currently
in special servicing. The master servicer has recognized a
$11.7 million appraisal reduction for the specially serviced
loan. Moody's has estimated a $11.4 million loss (76% expected
loss) for the specially serviced loan.

Moody's has assumed a high default probability for seven poorly
performing loans representing 5% of the pool and has estimated a
$5.6 million aggregate loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full and partial year 2010 and partial
year 2011 operating results for 98% and 74% of the pool's non-
defeased and non-specially serviced loans, respectively. Excluding
specially serviced and troubled loans, Moody's weighted average
LTV is 79% compared to 81% at Moody's prior review. Moody's net
cash flow reflects a weighted average haircut of 14% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.3%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.49X and 1.33X, respectively, compared to
1.52X and 1.30X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with an investment grade credit estimate is
the Mall at Millenia Loan ($64.3 million -- 8.7% of the pool),
which represents a 34.6% pari passu interest in a first mortgage
loan. The loan is secured by a 1.1 million square foot (SF) mall
located in Orlando, Florida. The property is also encumbered by a
$15.0 million non-pooled junior loan. The mall is anchored by
Bloomingdale's, Macy's and Neiman Marcus (all not part of the
collateral). Property performance has improved due to an increase
in base and percentage rents. Moody's credit estimate and stressed
DSCR are Baa1 and 1.53X, respectively, compared to Baa1 and 1.46X
at last review.

The second loan with a credit estimate is the AFR Portfolio Loan
($56.1 million -- 7.6% of the pool), which represents a 29.4% pari
passu interest in a first mortgage loan secured by 114 properties
located in various states. The properties consist of office,
operation centers and retail bank branches. As of December 2010,
the portfolio was 91% leased compared to 86% at last review. Six
properties have been released from the pool and 32 properties,
representing 25% of the loan balance, have defeased since
securitization. Due to property releases, defeasance and loan
amortization, the loan balance has decreased by approximately
44% since securitization. The portfolio is also encumbered by a
$77.1 million B Note, which is held within the trust and is the
security for Classes S-AFR1, S-AFR2, S-AFR3 and S-AFR4. Moody's
credit estimate and stressed DSCR for the pari passu interest
are A1 and 1.91X, respectively, compared to A1 and 1.68X at last
review. Moody's credit estimate for Classes S-AFR1, S-AFR2, S-AFR3
and S-AFR4 are A3, Baa1, Baa2 and Baa3, respectively, the same as
last review.

The top three performing conduit loans represent 21% of the
pool balance. The largest loan is the 609 Fifth Avenue Loan
($59.7 million -- 8.1% of the pool), which represents a 62.7% pari
passu interest in a first mortgage loan. The loan is secured by a
148,000 SF office building located on Fifth Avenue in Midtown
Manhattan. The property includes 99,500 SF of office space, 46,000
SF of retail space, and 2,500 SF of storage space. Major tenants
include American Girl Place Inc. (34% of the net rentable area
(NRA); lease expiration March 2018) and DZ Bank (30% of the NRA;
lease expiration March 2017). Moody's LTV and stressed DSCR are
97% and 0.95X, respectively, compared to 96% and 0.96X at last
review.

The second largest loan is the Union Center Plaza V Loan
($56.5 million -- 7.6% of the pool), which is secured by a
250,000 SF Class A office building located in the Capitol Hill
submarket of Washington, D.C. The property is 100% leased to Group
Hospitalization Medical Services through August 2013. Performance
is stable. Moody's LTV and stressed DSCR are 82% and 1.15X,
respectively, compared to 85% and 1.12X at last review.

The third largest loan is the Town Center at Virginia Beach Loan
($40.2 million -- 5.4% of the pool), which is secured by a 324,000
SF mixed-use office and retail building located in Westlake, Ohio.
The office component of the building represents over 75% of the
NRA. The property was 94% leased as of June 2011 compared to 93%
as of December 2010 and 100% as of December 2009. Moody's LTV and
stressed DSCR are 78% and 1.25X, respectively, compared to 76% and
1.28X at last review.


GOLUB CAPITAL: Moody's Upgrades Rating of Class E Notes to 'Ba2'
----------------------------------------------------------------
Moody's Investors Service has upgraded and confirmed the ratings
of these notes issued by Golub Capital Management CLO 2007-1,
Ltd.:

US$32,000,000 Class C Deferrable Mezzanine Notes Due 2021,
Upgraded to A3 (sf); previously on June 22, 2011 Baa2 (sf) Placed
Under Review for Possible Upgrade;

US$19,750,000 Class D Deferrable Mezzanine Notes Due 2021,
Upgraded to Baa3 (sf); previously on June 22, 2011 Ba2 (sf) Placed
Under Review for Possible Upgrade;

US$20,250,000 Class E Deferrable Mezzanine Notes Due 2021,
Upgraded to Ba2 (sf); previously on June 22, 2011 B2 (sf) Placed
Under Review for Possible Upgrade.

In addition, Moody's confirmed the rating of the following notes:

US$28,000,000 Class B Senior Notes Due 2021, Confirmed at Aa3
(sf); previously on June 22, 2011 Aa3 (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 $496 million,
defaulted par of $3.8 million, a weighted average default
probability of 24.95% (implying a WARF of 2963), a weighted
average recovery rate upon default of 50.8%, 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.

Golub Capital Management CLO 2007-1 Ltd., issued in July 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 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 levels higher than the covenant levels due to the large
difference between the reported and covenant levels.

3) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates.


GRAMERCY REAL: S&P Affirms 'CCC-' Ratings on 2 Classes
------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes from Gramercy Real Estate CDO 2006-1 Ltd. (Gramercy 2006-
1), a U.S. commercial real estate collateralized debt obligation
(CRE CDO) transaction. "At the same time, we affirmed our ratings
on six other classes from the same transaction," S&P related.

"The downgrades and affirmations 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
rating actions also reflect the transaction's exposure to
downgraded underlying commercial mortgage-backed securities
(CMBS) collateral ($42.3 million, 4.0% of the total asset
balance)," S&P said.

As noted in the Sept. 30, 2011 trustee report, classes C, D, E, F,
and G all had partial note cancellations without repayment (see
table).

Notes Cancelled Without Payments
Class        Original par amount of
                cancelled notes ($)
C                         2,958,000
D                         1,667,000
E                         2,500,000
F                         1,000,000
G                         1,333,000

"In addition, our analysis of the transaction follows our rating
actions on the underlying CMBS collateral. Standard & Poor's has
downgraded five securities from four transactions totaling
$42.3 million (4.0% of the total asset balance)," S&P related.
Gramercy 2006-1 has exposure to the securities that Standard &
Poor's has downgraded:

    Greenwich Capital Commercial Funding Corp. series 2005-GG5
    (class D; $15.0 million, 1.4%);

    GS Mortgage Securities Trust series 2007-GKK1 (classes J and
    K; $14.9 million, 1.4%);

    JPMorgan Chase Commercial Mortgage Securities Trust series
    2007-LDP11 (class A-J; $11.0 million, 1.0%); and

    LB-UBS Commercial Mortgage Trust 2007-C-2 series (class A-M;
    $1.4 million, 0.1%).

"In our assessment of the transaction and downgraded underlying
CMBS collateral, we analyzed the transaction for increased risks
and credit stability considerations due to the subordinate note
cancellations," S&P related. To assess these risks, S&P applied
the following stresses it deemed appropriate:

    "We 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 balance of the senior notes in the
    calculation of any interest or principal diversion
    mechanisms," S&P said.

    "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.

According to the Sept. 30, 2011 trustee report, the transaction's
current assets included:

    29 whole loans and senior participations ($702.0 million,
    66.5%);

    16 CMBS tranches ($153.0 million, 14.5%);

    Seven mezzanine loans ($92.0 million, 8.7%)

    Three preferred equity notes ($44.8 million, 4.2%);

    Three CDO tranches ($20.0 million, 1.9%); and

    Cash ($44.2 million, 4.2%)

The aggregate principal balance of the assets totaled
$1.056 billion, including cash and defaulted securities, while
the transaction liabilities totaled $989.3 million. The trustee
report noted five defaulted loans ($108.2 million, 10.2%) in
the pool and four defaulted securities ($39.7 million, 3.8%).
Standard & Poor's estimated specific recovery rates for the
defaulted loans with a weighted average recovery rate of 31%.
"We based the recovery rates on information from the collateral
manager, special servicer, and third-party data providers," S&P
said. The defaulted loan assets are:

    Las Vegas Hilton whole loan ($43.5 million, 4.1%);

    Fiesta De Vida whole loan ($31.7 million, 3.0%);

    Coral Cove whole loan ($13.5 million, 1.3%);

    Jameson Mezzanine III mezzanine loan ($14.6 million, 1.4%);
    and

    Jameson Mezzanine IV mezzanine loan ($4.9 million, 0.5%)

According to the trustee report, the deal is passing all three par
value tests and interest coverage tests and has just entered its
amortization period.

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

Ratings Lowered

Gramercy Real Estate CDO 2006-1 Ltd.
                  Rating
Class     To                   From
B         BB- (sf)             BB (sf)
E         B- (sf)              B (sf)
F         CCC+ (sf)            B- (sf)
G         CCC (sf)             CCC+ (sf)
H         CCC- (sf)            CCC+ (sf)

Ratings Affirmed

Gramercy Real Estate CDO 2006-1 Ltd.

Class     Rating
A-1       BBB+ (sf)
A-2       BB+ (sf)
C         B+ (sf)
D         B (sf)
J         CCC- (sf)
K         CCC- (sf)


GULF COUNTY: Fitch Ups Rating on $3.5MM Bonds to 'BBB-' From 'BB'
-----------------------------------------------------------------
Fitch Ratings takes these rating actions on Gulf County, Florida's
revenue bonds as part of its continuous surveillance efforts:

  -- $3.5 million limited ad valorem revenue bonds upgraded to
     'BBB-' from 'BB';
  -- $13.3 million gas tax revenue bonds affirmed at 'A'.

The Rating Outlook is Stable.

The limited ad valorem revenue bonds are secured by a pledge of
the ad valorem taxing power of the county within both the Gulfside
and the Interior municipal service taxing units (MSTU), not to
exceed 6 mills and 4 mills, respectively.  The bonds are
additionally secured by a standard debt service reserve fund
(DSRF), of which 50% is funded with cash and 50% is funded with a
reserve account surety policy from Assured Guaranty (not rated by
Fitch).

The gas tax revenue bonds are secured by a lien and pledge of the
local option gas tax, the county gas tax, and the constitutional
gas tax received by the county.  The bonds are additionally
secured by a standard DSRF funded with a reserve account surety
policy from MBIA (not rated by Fitch).  The rating downgrade of
MBIA has required the county to cash fund the DSRF over a five-
year period beginning in 2010.

LIMITED AD VALOREM UPGRADE: The upgrade reflects the county's
demonstrated commitment to levy sufficient revenues from a
combination of pledged and non-pledged sources to meet debt
service. Fitch expects that the county will continue to do so for
the next two fiscal years, at which time the bonds will mature.

NARROW GAS TAX COVERAGE: Fiscal 2010 gas tax estimates showed
signs of stabilization, though coverage remains slim at 1.32 times
(x) maximum annual debt service (MADS).  Pledged revenues are
somewhat economically sensitive and may be negatively impacted by
rising fuel costs, although Fitch believes that the essential
nature of fuel as a commodity mitigates this risk.

BELOW AVERAGE ECONOMIC PROFILE: Gulf County's economy is narrowly
focused, income levels are low, and unemployment remains high.

SOUND FINANCIAL PERFORMANCE: A history of surplus results in the
county operating funds has contributed to very solid reserve
levels and liquidity.  Financial pressure is driven by notable
declines in property values and resulting property tax revenue
loss.

LOW DEBT LEVELS: Debt levels are low and are expected to remain so
given the county's manageable capital needs. Pension and OPEB
obligations do not represent large cost pressures.

PLEDGED AND NON-PLEDGED REVENUE COVERAGE ON LIMITED AD VALOREM
BONDS:

The limited ad valorem bonds were approved by voters of the
Gulfside MSTU and the Interior MSTU, to fund the cost of beach
reconstruction at Cape San Blas.  The peninsula, approximately 18
miles long and less than a mile wide, is recognized as one of the
premier beaches in Florida.  Cape San Blas contains only 1,300
mostly residential parcels owned by approximately 1,200 taxpayers.
The tax base is small, which presents a risk should the entire
peninsula be affected by a severe storm.

The MSTUs's residential parcels appreciated significantly during
the housing market run-up, preceding the sale of the bonds.  The
assessed valuation (AV) of each MSTU has declined over 70% from
peak valuation in fiscal 2007 with a decline of over 30% from
fiscal 2010 to fiscal 2012.  As a result, coverage provided by
pledged revenues has weakened dramatically to 0.67x in fiscal 2011
from 1.4x in fiscal 2007.

Florida counties are authorized to levy up to 10 mills within the
unincorporated areas of any MSTU for operations, in addition to
the countywide operating millage.  In fiscal 2010 and 2011, the
county adopted millage rates for each of the MSTUs that exceeded
the amount pledged to bondholders; this ensured the availability
of sufficient ad valorem revenue combined with carry forward
balances in the MSTU funds to meet debt service obligations.  The
county plans to continue to do so for the next two fiscal years,
after which time the bonds will mature.

The adopted millage rate for the Gulfside MSTU and Interior MSTU
for fiscal 2011 was 9.57 mills and 4.30 mills, respectively.  The
county will increase both millage rates in fiscal 2012 with a
maximum rate of 10.0 mill for the Gulfside MSTU and 4.84 mills for
the Interior MSTU.  Assuming the maximum rate of 10 mills for each
MSTU, Fitch calculates that AV can decline an additional 25%
before MSTU ad valorem revenue fails to cover the $1.85 million
annual debt service payment on the bonds, and by nearly 50%
including cash held in the DSRF.  The county is forecasting a 6.9%
fall in AV for fiscal 2012.

Fitch believes the capacity for payment of debt service on the
bonds is adequate, based on its projection of available ad valorem
revenue and cash in the DSRF.  Further enhancing this view is the
county's strong liquidity with more than $10 million in cash and
investments recorded in its operating funds at the close of fiscal
2010.

NARROW COVERAGE ON GAS TAX BONDS:

Fiscal 2010 gas tax revenues showed signs of stabilization with
3.7% growth after experiencing declines in fiscal 2008 and fiscal
2009. Coverage increased marginally from 1.27x maximum annual debt
service (MADS) in fiscal 2009 to 1.32x in fiscal 2010.  The bonds
have a level debt service with MADS occurring in fiscal 2015.
Fiscal 2011 revenue estimates project maintenance of MADS coverage
at 1.32x.  While fuel tax revenues are prone to some fluctuation
relative to economic factors and the price of fuel, the essential
nature of the commodity in large part mitigates this concern.

The county was required to cash fund the DSRF to MADS ($995,544)
in equal installments over five years following a downgrade of its
surety provider.  The county made its first payment ($199,109) in
fiscal 2010.  The obligation to pay debt service is senior to the
obligation to replenish the reserve fund. While the county is able
to use any legally available revenue to make the payment, it has
been using residual gas tax revenues.

STRONG RESERVE LEVELS AND SOUND FINANCIAL OPERATIONS:

The county's operating funds (general fund, fines and forfeitures
fund) continue to perform well, despite a challenging revenue
environment, due to the county's conservative expenditure
budgeting.  Actual spending has been under budget by 10% to 20% in
each of the prior three fiscal periods.  In fiscal 2010, the
county posted a net surplus equal to $1.9 million or 10.5% of
total spending, outperforming expectations reported at the time of
the last Fitch rating in November 2010.  The unreserved fund
balance increased to $9.97 million or a robust 55% of total
spending.  Liquidity is very strong with $10.1 million in cash and
investments -- the equivalent of 7.2x total liabilities or nearly
seven months of operating expenses.

County management expects fiscal 2011 to end with a net surplus of
$1 million or 6% of spending for an unreserved fund balance of
$10.9 million or a strong 61% of spending.  The county did not
raise the millage rate in fiscal 2011 after increases of 6.7% and
17.8% in fiscal 2009 and 2010, respectively.  Declining property
valuations in fiscal 2011 resulted in the loss of more than $2.4
million in property tax revenue.  Spending was lowered by 10% from
the year prior with the sharpest cut coming from infrastructure
and physical environment spending.  Though the county had
anticipated use of $2.7 million in reserves, the county achieved a
net surplus through its positive actual-to-budget variance for
expenditures and its receipt of several unanticipated grants.

The fiscal 2012 budget relies on the use of approximately $2
million in existing reserves to balance the budget.  The
structural imbalance stems from the loss of more than $615,000 in
property tax revenue and $1.2 million in state grants.  As in
fiscal 2011, the county board chose not to raise the millage rate
to offset declining property tax values. The county does not have
a formal fund balance policy or target, nor does it perform multi-
year forecasts.

WEAKENED TAX BASE AND LIMITED LOCAL ECONOMY:

Gulf County is located on the Gulf of Mexico in Florida's
Panhandle, approximately 35 miles southeast of Panama City and 100
miles southwest of Tallahassee.  The county is mostly rural and
sparsely populated with a 2010 population of 15,863.  The county
has experienced nominal population growth over the past decade,
and expectations for future growth are low.

The local economy remains very limited with a good deal of
employment concentration in the Gulf Correctional Institution
(GCI). The GCI, designated a 'major facility' within the Florida
Department of Corrections, has served as a major employer since
the 1990s. More recent developments include the opening of Sacred
Heart Hospital in March 2010, expanding the county's health care
presence.

The county's employment base has contracted nearly 2% from August
2010 to August 2011, erasing gains posted during the first half of
2010.  The August 2011 unemployment rate of 10.2% is lower than
the state (11%) but higher than the nation (9.5%).  Wealth levels
are very low, and an above-average number of residents live below
the poverty level.

AFFORDABLE DEBT LEVELS AND OTHER LONG-TERM LIABILITIES:

The county is rural in nature with a high percentage of its
undeveloped land designated as wetlands. As such, its capital
needs are minimal.  Over 80% of planned capital spending in the
FY11-15 CIP, totaling $73 million will finance road and
transportation improvements throughout the county.  Funding for a
significant portion of the CIP relies on expected grants that have
not been secured to date.  Other funding sources include pay-as-
you go funding derived from impact fees and general fund revenue.

The county had low debt levels of $1,072 per capita and 1.1% of
TAV as of fiscal 2010. Debt levels are expected to remain low
given the county's small capital needs and lack of future debt
plans.  Debt service as a percentage of spending is above average
at 14%.  Outstanding debt obligations consist of limited ad
valorem tax bonds ($3.4 million) and gas tax revenue bonds ($13.3
million), both rated by Fitch.  The county also has approximately
$240,000 in notes payable.  Amortization of outstanding principal
is average with 56% retired in ten years.

The county's pension and OPEB liabilities are relatively small.
County employees participate in the Florida Retirement System
(FRS), a cost-sharing multiple-employer public employee retirement
system.  For OPEB, the county offers an implicit subsidy for
retirees, as required by Florida statute.  Aggregate pension and
OPEB contributions for fiscal 2010 equaled 0.66% of spending.


HEWETT'S ISLAND: S&P Raises Rating on Class D Notes to 'CCC-'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on eight
classes of notes issued by Hewett's Island CLO II Ltd., a
collateralized loan obligation (CLO) transaction managed by
CypressTree Investment Management Co. Inc. "At the same time,
we removed seven of them from CreditWatch with positive
implications," S&P said.

"The upgrades reflect improved performance we have observed in the
deal's underlying asset portfolio since we reviewed the
transaction in April 2010," S&P related.

According to the Sept. 30, 2011 trustee report, the transaction
has paid down $109.07 million of the class A-1 notes and
$2.00 million of the class B-1 notes (which includes classes
B-1A and B-1B) since the March 5, 2010, trustee report, which we
used in our April 2010 analysis. The paydowns benefited the
overcollateralization (O/C) ratios for all classes: The class
senior note O/C ratio is 126.09%, up from 114.04% in March 2010;
the class B-2 O/C ratio is 117.42%, up from 109.37% in March 2010;
the class C O/C ratio is 109.86% in March 2010, up from 105.00%;
and the class D O/C ratio is 104.16%, up from 101.12% in March
2010.

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

Rating And CreditWatch Actions

Hewett's Island CLO II Ltd.
                 Rating
Class       To          From
A-1         AAA (sf)    A+ (sf)/Watch Pos
A-2A        AA+ (sf)    BBB+ (sf)/Watch Pos
A-2B        AA+ (sf)    BBB+ (sf)/Watch Pos
B-1A        AA (sf)     BBB (sf)/Watch Pos
B-1B        AA (sf)     BBB (sf)/Watch Pos
B-2         A+ (sf)     B+ (sf)/Watch Pos
C           BB+ (sf)    CCC- (sf)/Watch Pos
D           CCC- (sf)   CC


HIGHLAND CREDIT: S&P Puts 'BB' Rating on Class C 2006 on Watch Neg
------------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on four
classes of notes from Highland Credit Opportunities CDO Ltd. and
three classes of notes from McDonnell Loan Opportunity Ltd. on
CreditWatch with negative implications. Both transactions are U.S.
market value collateralized debt obligation (CDO) transactions.
"At the same time, we affirmed our ratings on 10 other classes
from McDonnell Loan Opportunity Ltd.," S&P said.

The classes' overcollateralization (O/C) ratios have decreased
since July 2011 due to decreases in loan prices. According to the
Sept. 30, 2011, trustee report for Highland Credit Opportunities
CDO Ltd., the class A O/C ratio was 91.69%, down from 104.26% in
July 2011; the class B O/C ratio was 93.23%, down from 106.26% in
July 2011; and the mezzanine O/C ratio was 93.07%, down from
104.90%. According to the Sept. 30, 2011, trustee report for
McDonnell Loan Opportunity Ltd., the second senior O/C ratio was
104.85%, down from 110.95% in July 2011. "According to our
preliminary analysis, the transaction is able to support the
current ratings on the other 10 tranches under our current
criteria for rating market value transactions," S&P said.

On Aug. 31, 2010, Standard & Poor's published a request for
comment asking for feedback on changes it is proposing to its
methodology and assumptions for rating market value securities
(see "Request for Comment: Methodology And Assumptions For Market
Value Securities"). "If we adopt the proposed changes,
it is likely that the final criteria would have a significant
negative impact on the ratings assigned to market value
transactions," S&P said.

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

Rating And CreditWatch Actions

Highland Credit Opportunities CDO Ltd.
                    Rating
Class         To                   From
A-1 2006      A (sf)/Watch Neg     A (sf)
A-2 2006      A (sf)/Watch Neg     A (sf)
B 2006        BBB (sf)/Watch Neg   BBB (sf)
C 2006        BB (sf)/Watch Neg    BB (sf)

McDonnell Loan Opportunity Ltd.
                      Rating
Class         To                   From
B-1 2006-2    AA (sf)/Watch Neg    AA (sf)
2SrTmL06-1    AA (sf)/Watch Neg    AA (sf)
2dSrLn06-2    AA (sf)/Watch Neg    AA (sf)

Ratings Affirmed

McDonnell Loan Opportunity Ltd.

Class          Rating
A-1 2006-1     AAA (sf)
A-2 2006-1     AAA (sf)
A-3 2006-1     AAA (sf)
A-5 2006-2     AAA (sf)
A-6 2006-2     AAA (sf)
A-7 2006-2     AAA (sf)
C-1 2006-1     A (sf)
C-2 2006-2     A (sf)
MzTmLn06-1     A (sf)
MzTmLn06-2     A (sf)


JEFFERIES RESECURITIZATION: S&P Cuts Ratings on 5 Classes to 'CC'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes from Jefferies Resecuritization Trust 2009-R4 and removed
them from CreditWatch with negative implications. "In addition,
we affirmed our ratings on two classes from the same transaction
and removed one of them from CreditWatch negative. Jefferies
Resecuritization Trust 2009-R4 is a residential mortgage-backed
securities (RMBS) resecuritized real estate mortgage investment
conduit (re-REMIC) transaction that pays interest pro rata within
each of its groups," S&P related.

"On Dec. 15, 2010, we placed our ratings on nine classes from
this transaction on CreditWatch negative, along with ratings
from a group of other RMBS re-REMIC securities (for more
information, see 'S&P Corrects: 1,196 Ratings On 129 U.S.
RMBS Re-REMIC Transactions Placed On CreditWatch Negative').
Additionally, on April 1, 2011, we provided an update on the
CreditWatch placements and provided clarification regarding
our analysis of interest payment amounts within re-REMIC
transactions (see 'Standard & Poor's Provides An Update On
Outstanding RMBS Re-REMIC CreditWatch Placements And Outlines
Their Resolution')," S&P said.

"Our ratings on the re-REMIC classes address the timely payment
of interest and the full payment of principal. We reviewed the
interest and principal amounts due on the underlying securities,
which are then passed through to the applicable re-REMIC classes.
When performing this analysis, we applied our loss projections,
incorporating, where applicable, our recently revised loss
assumptions to the underlying collateral to identify the principal
and interest amounts that could be passed through from the
underlying securities under our rating scenario stresses. We
stressed our loss projections at various rating categories to
assess whether the re-REMIC classes could withstand the stressed
losses associated with their ratings while receiving timely
payment of interest and principal consistent with our criteria,"
S&P related.

"As we noted, in applying our loss projections we incorporated,
where applicable, our recently revised loss assumptions as
outlined in 'Revised Lifetime Loss Projections For Prime,
Subprime, And Alt-A U.S. RMBS Issued In 2005-2007,' published on
March 25, 2011, into our review. Such updates pertain to the 2005-
2007 vintage prime, subprime, and Alternative-A (Alt-A)
transactions; some of which are associated with the re-REMICs we
reviewed (see tables 1 and 2 for the overall prior and revised
vintage- and product-specific lifetime loss projections as
percentages of the original structure balance)," S&P said.

Table 1
Lifetime Loss Projections For Prime And Subprime RMBS
(Percent of original balance)
           Prime RMBS      Subprime RMBS
            aggregate        aggregate
Vintage  Updated  Prior    Updated  Prior
2005         5.5   4.00      18.25  15.40
2006        9.25   6.60      38.25  35.00
2007       11.75   9.75      48.50  43.20

Table 2
Lifetime Loss Projections For Alternative-A RMBS
(Percent of original balance)
                            Fixed/
          Aggregate       long-reset
Vintage Updated  Prior  Updated  Prior
2005      13.75  11.25    12.75   9.60
2006      29.50  26.25    25.25  25.00
2007      36.00  31.25    31.75  26.25
         Short-reset
            hybrid        Option ARM
Vintage Updated  Prior  Updated  Prior
2005      13.25  14.75    15.50  13.25
2006      30.00  30.50    34.75  26.75
2007      41.00  40.75    43.50  37.50

"We based our downgrades on our projections of principal loss
amounts and/or interest shortfalls from the underlying securities
that would impair the re-REMIC classes under the applicable
ratings stress scenarios," S&P related.

"Five of the classes we downgraded to 'CC (sf)' experienced
accumulated interest shortfalls. We may lower the ratings on these
classes further in accordance with our interest shortfall
criteria," S&P said.

"The affirmations reflect our assessment of the likelihood that
the re-REMIC classes will receive timely payment of interest and
full payment of principal under the applicable stressed
assumptions," S&P said.

Rating Actions

Jefferies Resecuritization Trust 2009-R4
Series 2009-R4
                               Rating
Class      CUSIP       To                   From
32-A2      47232VGJ5   CCC (sf)             A (sf)/Watch Neg
11-A5      47232VCK6   CC (sf)              B (sf)/Watch Neg
32-A1      47232VGH9   AAA (sf)             AAA (sf)/Watch Neg
11-A1      47232VCF7   CC (sf)              AAA (sf)/Watch Neg
11-A3      47232VCH3   CC (sf)              BBB (sf)/Watch Neg
11-A4      47232VCJ9   CC (sf)              BB (sf)/Watch Neg
32-A3      47232VGK2   CCC (sf)             BBB (sf)/Watch Neg
11-A2      47232VCG5   CC (sf)              A (sf)/Watch Neg
32-A4      47232VGL0   CCC (sf)             B (sf)/Watch Neg

Ratings Affirmed

Jefferies Resecuritization Trust 2009-R4
Series 2009-R4
Class      CUSIP       Rating
32-A5      47232VGM8   CCC (sf)


JFIN CLO: S&P Removes 'BB+' Rating on Class D Notes From Watch Pos
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
C notes from JFIN CLO 2007 Ltd., a U.S. collateralized loan
obligation (CLO) transaction managed by Jefferies Finance LLC. "We
also affirmed our ratings on classes A-1A, A-1B, A-2, B, and D
notes. We removed the ratings on the class C and D notes from
CreditWatch, where we placed them with positive implications on
Aug. 2, 2011," S&P related.

"The upgrade reflects the improved performance we have observed in
the deal's underlying asset portfolio since we downgraded the
notes on Jan. 21, 2010. As of the Oct. 7, 2011, trustee report,
the transaction had $6.99 million in defaulted assets, compared
with the $13.81 million noted in the Dec. 10, 2009, trustee
report, which we referenced for our January 2010 rating actions.
The affirmations reflect the availability of credit support for
the notes at the current rating levels," S&P related.

The transaction has also benefited from an increase in
overcollateralization (O/C) available to support the rated notes.
The trustee reported the O/C ratio in the Oct. 7, 2011, monthly
report:

    The A/B O/C ratio was 132.05%, compared with a reported ratio
    of 124.18% in December 2009;

    The C O/C ratio was 118.43%, compared with a reported ratio of
    111.37% in December 2009; and

    The D O/C ratio was 109.37%, compared with a reported ratio of
    102.85% in December 2009.

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

Ratings And CreditWatch Actions

JFIN CLO 2007 Ltd.
                      Rating
Class             To          From
C                 A- (sf)     BBB+ (sf)/Watch Pos
D                 BB+ (sf)    BB+ (sf)/Watch Pos

Ratings Affirmed

JFIN CLO 2007 Ltd.
Class        Rating
A-1A         AAA (sf)
A-1B         AA+ (sf)
A-2          AA+ (sf)
B            AA (sf)

Transaction Information

Issuer:               JFIN CLO 2007 Ltd.
Coissuer:             JFIN CLO 2007 LLC
Collateral manager:   Jefferies Finance LLC
Trustee:              State Street Bank and Trust Co.
Transaction type:     Cash flow CLO


JPMCC 2005-LDP2: Moody's Affirms Ratings of 22 CMBS Classes
-----------------------------------------------------------
Moody's Investors Service (Moody's) affirmed 22 classes of CMBS
classes of J.P. Morgan Chase Commercial Mortgage Securities Corp.,
Commercial Mortgage Pass-Through Certificates, Series 2005-LDP2:

Cl. A-3, Affirmed at Aaa (sf); previously on July 5, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-3A, Affirmed at Aaa (sf); previously on July 5, 2005
Assigned Aaa (sf)

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

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

Cl. A-1A, Affirmed at Aaa (sf); previously on July 5, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aa2 (sf); previously on December 2, 2010
Downgraded to Aa2 (sf)

Cl. A-MFL, Affirmed at Aa2 (sf); previously on December 2, 2010
Downgraded to Aa2 (sf)

Cl. A-J, Affirmed at A3 (sf); previously on December 2, 2010
Downgraded to A3 (sf)

Cl. B, Affirmed at Baa1 (sf); previously on December 2, 2010
Downgraded to Baa1 (sf)

Cl. C, Affirmed at Baa2 (sf); previously on December 2, 2010
Downgraded to Baa2 (sf)

Cl. D, Affirmed at Ba2 (sf); previously on December 2, 2010
Downgraded to Ba2 (sf)

Cl. E, Affirmed at B1 (sf); previously on December 2, 2010
Downgraded to B1 (sf)

Cl. F, Affirmed at B2 (sf); previously on December 2, 2010
Downgraded to B2 (sf)

Cl. G, Affirmed at B3 (sf); previously on December 2, 2010
Downgraded to B3 (sf)

Cl. H, Affirmed at Caa1 (sf); previously on December 2, 2010
Downgraded to Caa1 (sf)

Cl. J, Affirmed at Ca (sf); previously on December 2, 2010
Downgraded to Ca (sf)

Cl. K, Affirmed at C (sf); previously on December 2, 2010
Downgraded to C (sf)

Cl. L, Affirmed at C (sf); previously on December 2, 2010
Downgraded to C (sf)

Cl. M, Affirmed at C (sf); previously on December 2, 2010
Downgraded to C (sf)

Cl. N, Affirmed at C (sf); previously on December 2, 2010
Downgraded to C (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on July 5, 2005
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on July 5, 2005
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss
of 7.3% of the current balance. At last full review, Moody's
cumulative base expected loss was 10.7%. Moody's stressed scenario
loss is 17.8% of the current balance.  Depending on the timing of
loan payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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 U.S. CMBS Conduit Transactions" published in
September 2000.

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 74, compared to 81 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 December 2, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the
transaction's aggregate certificate balance has decreased by 21%
to $2.36 billion from $2.98 billion at securitization. The
Certificates are collateralized by 253 mortgage loans ranging in
size from less than 1% to 5% of the pool, with the top ten loans
representing 27% of the pool. Nine loans, representing 2% of the
pool, have defeased and are collateralized with U.S. Government
securities.

Fifty-three loans, representing 17% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Twenty-five loans have been liquidated from the pool since
securitization, resulting in an aggregate of $63.8 million (33%
loss severity). Currently 17 loans, representing 9% of the pool,
are in special servicing. The master servicer has recognized
appraisal reductions totaling $80.8 million for the specially
serviced loans. Moody's has estimated an aggregate $91.9 million
loss (42% expected loss on average) for the specially serviced
loans.

Moody's has assumed a high default probability for 20 poorly
performing loans representing 7% of the pool. Moody's has
estimated a $25.7 million loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 95% and 87%, respectively, of the performing
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV for the conduit component is 101% compared to
105% at Moody's prior 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 for the conduit component are 1.40X and 1.06X,
respectively, compared 1.41X and 1.04X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three performing conduit loans represent 12% of the
pool. The largest loan is the CityPlace Corporate Center Loan
($117.0 million -- 5.0% of the pool), which is secured by five
office buildings totaling 789,000 square foot (SF), a 50,000 SF
mixed use property and a 28,000 SF retail building. All of the
properties are located in Creve Coeur, Missouri. The portfolio's
weighted average occupancy as of July 2011 was 92% compared to 93%
at last review. Moody's LTV and stressed DSCR are 106% and 0.95X,
respectively, compared to 107% and 0.95X at last review.

The second largest loan is the Shops at Canal Place Loan
($90.0 million -- 3.8% of the pool), which is secured by a 215,000
SF retail center located in New Orleans, Louisiana. The property
was severely damaged by fire and looting immediately following
Hurricane Katrina and was closed until February 2006. The property
was 94% leased as of March 2011 compared to 87% at last review.
The property is stable but operating below original projections.
Moody's LTV and stressed DSCR are 135% and 0.68X, respectively,
compared to 143% and 0.64X at last review.

The third largest loan is the Hutchinson Metro Center Loan
($84.8 million -- 3.6% of the pool), which is secured by a 424,000
SF office building located in the Bronx, New York. The property
was 100% leased as of year-end 2010, essentially the same as at
last review. Moody's LTV and stressed DSCR are 103% and 0.95X,
respectively, compared to 106% and 0.91X at last review.


JPMCC 2007-CIBC20: Moody's Affirms Ratings of 19 CMBS Classes
-------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed these ratings of 19
classes of J.P. Morgan Chase Commercial Mortgage Securities Corp.
Commercial Mortgage Pass-Through Certificates, Series 2007-CIBC20:

Cl. A-2, Affirmed at Aaa (sf); previously on Oct 3, 2007
Definitive Rating Assigned Aaa (sf)

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

Cl. A-4, Affirmed at Aaa (sf); previously on Nov 11, 2010
Confirmed at Aaa (sf)

Cl. A-SB, Affirmed at Aaa (sf); previously on Nov 11, 2010
Confirmed at Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Nov 11, 2010
Confirmed at Aaa (sf)

Cl. A-M, Affirmed at A1 (sf); previously on Nov 11, 2010
Downgraded to A1 (sf)

Cl. A-MFL, Affirmed at A1 (sf); previously on Nov 11, 2010
Downgraded to A1 (sf)

Cl. A-J, Affirmed at Ba2 (sf); previously on Nov 11, 2010
Downgraded to Ba2 (sf)

Cl. B, Affirmed at B1 (sf); previously on Nov 11, 2010 Downgraded
to B1 (sf)

Cl. C, Affirmed at B2 (sf); previously on Nov 11, 2010 Downgraded
to B2 (sf)

Cl. D, Affirmed at B3 (sf); previously on Nov 11, 2010 Downgraded
to B3 (sf)

Cl. E, Affirmed at Caa1 (sf); previously on Nov 11, 2010
Downgraded to Caa1 (sf)

Cl. F, Affirmed at Caa2 (sf); previously on Nov 11, 2010
Downgraded to Caa2 (sf)

Cl. G, Affirmed at Caa3 (sf); previously on Nov 11, 2010
Downgraded to Caa3 (sf)

Cl. H, Affirmed at Ca (sf); previously on Nov 11, 2010 Downgraded
to Ca (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. X-1, Affirmed at Aaa (sf); previously on Oct 3, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on Oct 3, 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
9.2% of the current balance. At last review, Moody's cumulative
base expected loss was 10.6%. Moody's stressed scenario loss is
24.3% of the current balance.  Depending on the timing of loan
payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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 of 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, 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 U.S. CMBS Fusion 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 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 26, the same as at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST (R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated November 11, 2010.

DEAL PERFORMANCE

As of the October 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 4% to $2.44 billion
from $2.54 billion at securitization. The Certificates are
collateralized by 125 mortgage loans ranging in size from less
than 1% to 12% of the pool, with the top ten loans representing
47% of the pool. The pool contains one loan with an investment
grade credit estimate, representing 0.8% of the pool.

Forty-four loans, representing 27% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (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.

Thirteen loans have been liquidated from the pool, resulting in
a realized loss of $45.1 million (46.4% loss severity). Currently
11 loans, representing 8% of the pool, are in special servicing.
The largest specially serviced loan is the STF Portfolio Loan
($49 million -- 2% of the pool), which is secured by 19 industrial
properties located in New Mexico and south Texas. The loan was
transferred to special servicing in August 2010 due to monetary
default.

The remaining ten specially serviced properties are secured
by a mix of property types. Moody's estimates an aggregate
$87.5 million loss for the specially serviced loans (43%
expected loss on average).

Moody's has assumed a high default probability for 26 poorly
performing loans representing 12% of the pool and has estimated an
aggregate $43.9 million loss (15% expected loss based on a 30%
probability default) from these troubled loans

Moody's was provided with full year 2010 operating results for 93%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 116% compared to 117% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 9.9% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.25X and 0.92X, respectively, compared to
1.18X and 0.89X 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 loan with a credit estimate is the 1564 Broadway Loan
($18.8 million -- 0.8%), which is secured by a 52,657 square
foot office property located in New York, New York. Moody's
current credit estimate and stressed DSCR are Baa2 and 1.52X,
respectively, compared to Baa2 and 1.53X at last review.

The top three performing conduit loans represent 28% of the pool
balance. The largest loan is the Retail Portfolio I Loan (formerly
Centro - New Plan Pool 1; $300 million -- 12.2%), which is secured
by a portfolio of 18 retail properties that are cross-
collateralized and cross-defaulted and total 3.1 million square
feet. The properties are located in 12 states, with the largest
concentrations in Georgia (20%), Florida (14%) and Texas (13%).
The portfolio was 92% leased as of December 2010 compared to 94%
at last review. The loan has 11 months remaining in a 60-month
interest only period and will amortize on a 360-month schedule
maturing in September 2017. The portfolio was recently purchased
by BRE Holdings, which is an affiliate of Blackstone Realty.
Moody's LTV and stressed DSCR are 117% and 0.83X, respectively,
compared to 124% and 0.78X at last review.

The second largest loan is the Gurnee Mills Loan ($246.0 million -
- 10%), which is a pari-passu interest in a $321.0 million first
mortgage loan. The loan is secured by the borrower's interest in a
1.8 million square foot regional mall located in Gurnee, Illinois.
The mall's major tenants include Sears, Bass Pro Shops Outdoor
World and Kohl's. The property was 84% leased as of March 2011,
compared to 91% at last review. Despite decreased occupancy,
property performance has improved since last review. The loan is
interest-only for its entire ten-year term maturing in July 2017.
Moody's LTV and stressed DSCR are 125% and 0.74X, respectively,
compared to 141% and 0.73X at last review.

The third largest loan is the North Hills Mall Loan
($141.2 million -- 5.7% of the pool), which is secured by the
borrower's interest in a 746,000 square foot mall located in
Raleigh, North Carolina. The property is situated within a mixed-
use development that includes residential condominiums, commercial
and hotel properties, a retirement community and recreational
amenities. The mall's major tenants include J.C. Penney, Target
(not part of the collateral) and Regal Entertainment Group. The
property also includes a 100,000 square foot office component. The
collateral was 96% leased as of December 2010, the same as at last
review. The loan is on the master servicer's watch list due to low
DSCR. The loan is interest-only for its entire ten-year term
maturing in July 2017. Moody's LTV and stressed DSCR are 144% and
0.66X, respectively, compared to 147% and 0.59X at last review.


KATONAH IV: S&P Raises Ratings on 2 Classes of Notes From 'BB+'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B, C, D-1, and D-2 notes from Katonah IV Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
Sankaty Advisors LLC. "At the same time, we removed our ratings
on the class B, C, D-1, and D-2 notes from CreditWatch, where we
placed them with positive implications on Aug. 2, 2011. We also
affirmed our 'AAA (sf)' rating on the class A notes," S&P related.

"The upgrades reflect a paydown to the class A notes and the
improved performance we have observed in the deal's underlying
asset portfolio since our November 2010 rating actions. Since
that time, the transaction has paid down the class A notes by
approximately $94 million, reducing the balance to about 10% of
the original balance. According to the Sept. 20, 2011, trustee
report, the transaction's asset portfolio held $2.6 million in
defaulted assets, down from the $9 million noted in the September
2010 trustee report," S&P said.

"We affirmed our rating on the class A notes to reflect the
sufficient credit support available at the current rating level,"
S&P related.

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

Rating And CreditWatch Actions

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

Rating Affirmed

Katonah IV Ltd.
Class                Rating
A                    AAA (sf)


KEYCORP STUDENT: Fitch Holds Junk Rating on Class II-C Notes
------------------------------------------------------------
Fitch Ratings affirms the ratings on all student loan notes by
KeyCorp Student Loan Trust 2006-A (Group II).  A Stable Outlook is
assigned to the senior notes and the Negative Outlook is
maintained on the subordinate notes.  Fitch's 'U.S. Private SL ABS
Criteria' and' Global Structured Finance Rating Criteria' were
used to review the ratings.  The rating actions are detailed at
the end of this press release.

The affirmation on all the student loan notes are based on loss
coverage multiples commensurate with the ratings.  A Stable
Outlook is assigned to the senior notes to account for the steady
increase in their parity.  Fitch will continue to monitor the
trust's performance to see if an upgrade is warranted for the
senior notes.  The Negative Outlook is maintained on the
subordinate notes due to the decline in parities.  As of September
2011, reported parity for the senior, subordinate, and junior
subordinate notes are at 135.69%, 107.08%, and 97.45%,
respectively.  Given the current cash release level is 104.5%, no
cash has been released from the trust.  Review of KeyCorp Student
Loan Trust 2006-A (Group II) is based on collateral performance
data as of September 2011.

Loss Coverage multiples were determined by comparing the projected
net loss amount to available credit enhancement for the rating
categories of KeyCorp Student Loan Trust 2006-A (Group II).  Fitch
used both data provided by KeyCorp and proxy data from other
issuers to form a loss timing curve representative of each pool
depending on loan composition.  After giving credit to the
seasoning of loans in repayment, Fitch applied the trust's current
cumulative gross level to the loss timing curve to derive the
expected gross losses over the projected remaining life.  A
recovery rate of 15% was applied, which was the level was assumed
during at the trust's initial review.

Credit enhancement consists of excess spread,
overcollateralization, and a reserve account for the senior and
subordinate notes.  The junior subordinate notes benefit from
excess spread and the reserve account.  Fitch assumed excess
spread to be the lesser of the current annualized excess spread;
the average historical excess spread; and the most recent 12-month
average spread, and applied that same rate over the remaining
life.

The private student loan collateral consists primarily of Key
Alternative Loans originated to undergraduate students.  The
trusts also include a combination of graduate student loans,
career loans, consolidation loans, and CampusDoor loans marketed
through the direct to consumer channel.

KeyCorp Student Loan Trust 2006-A (Group II):

  -- Class II-A-2 affirmed at 'A-sf'; Outlook Stable from Outlook
     Negative;

  -- Class II-A-3 affirmed at 'A-sf'; Outlook Stable from Outlook
     Negative;

  -- Class II-A-4 affirmed at 'A-sf'; Outlook Stable from Outlook
     Negative;

  -- Class II-B affirmed at 'B+sf'; Outlook Negative;

  -- Class II-C affirmed at 'CCsf'.


KIMBERLITE CDO: Moody's Downgrades Cl. A Notes Rating to 'C'
------------------------------------------------------------
Moody's has downgraded the rating of two classes and affirmed the
ratings of six classes of Notes issued by Kimberlite CDO I, Ltd.
due to increase in defaulted assets and deterioration of par value
ratios since last review. The affirmations are due to the key
transaction parameters performing within levels commensurate with
the existing ratings levels. The rating action is the result of
Moody's on-going surveillance of commercial real estate
collateralized debt obligation (CRE CDO Synthetic) transactions.

Cl. A, Downgraded to C (sf); previously on Dec 9, 2010 Downgraded
to Ca (sf)

Cl. B, Downgraded to C (sf); previously on Dec 17, 2009 Downgraded
to Ca (sf)

Cl. C, Affirmed at C (sf); previously on Dec 17, 2009 Downgraded
to C (sf)

Cl. D, Affirmed at C (sf); previously on Dec 17, 2009 Downgraded
to C (sf)

Cl. E, Affirmed at C (sf); previously on Dec 17, 2009 Downgraded
to C (sf)

Cl. F, Affirmed at C (sf); previously on Dec 17, 2009 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Dec 17, 2009 Downgraded
to C (sf)

Cl. H, Affirmed at C (sf); previously on Dec 17, 2009 Downgraded
to C (sf)

RATINGS RATIONALE

Kimberlite CDO I, Ltd., is a hybrid CRE CDO transaction backed by
a portfolio of credit default swaps (87.4% of the pool balance)
and cash collateral (12.6%). The reference obligation pool
comprises of commercial mortgage backed securities (CMBS) (94.2%
of the current pool balance) and CRE CDO (5.8%). As of the
September 22, 2011 Trustee report, the aggregate issued Note
balance of the transaction, including preferred shares, increased
to $254.1 million from $250.0 million at issuance due to
accumulated deferred interest as a result of failing the par value
tests.

There are 51 assets with a par balance of $303.5 million (44.6% of
the current pool balance) that are considered Defaulted Securities
as of the September 22, 2011 Trustee report. While there have been
limited realized losses on the underlying reference obligations,
Moody's does expect significant losses to occur once they are
realized.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: weighted average
rating factor (WARF), weighted average life (WAL), weighted
average recovery rate (WARR), and Moody's asset correlation (MAC).
These parameters are typically modeled as actual parameters for
static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated reference obligations and cash collateral. The bottom-dollar
WARF is a measure of the default probability within a collateral
pool. Moody's modeled a bottom-dollar WARF of 7,920 compared to
7,171 at last review. The distribution of current ratings and
credit estimates is as follows: Baa1-Baa3 (7.3% compared to 8.7%
at last review), Ba1-Ba3 (3.7% compared to 5.4% at last review),
B1-B3 (6.5% compared to 15.3% at last review), and Caa1-C (82.5%
compared to 70.6% at last review).

WAL acts to adjust the probability of default of the reference
obligations and cash collateral in the pool for time. Moody's
modeled to a WAL of 5.1 years compared to 5.5 years at last
review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations and cash collateral in the pool. Moody's
modeled a variable WARR with a mean of 2.2% compared to 3.5% at
last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the reference obligation and cash collateral pool (i.e. the
measure of diversity). Moody's modeled a MAC of 0% compared to
100.0% at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. In general, the rated Notes are particularly
sensitive to rating changes within the reference obligation and
cash collateral pool. However, in light of the performance
indicators noted above, Moody's believes that it is unlikely that
the ratings announced are sensitive to further change.

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 SF CDOs" published in November 2010.


LB-UBS 2004-C7: S&P Lowers Ratings on 6 Classes of Certs. to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage pass-through certificates from LB-
UBS Commercial Mortgage Trust 2004-C7, a U.S. commercial
mortgage-backed securities (CMBS) transaction.

"The downgrades reflect current and potential interest shortfalls.
We lowered our ratings on six of these classes to 'D (sf)' because
we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. The six classes that we
downgraded to 'D (sf)' have had accumulated interest shortfalls
outstanding for five 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 loans;

    The lack of servicer advancing for loans where the servicer
    has made nonrecoverable advance declarations;

    Special servicing fees; and

    Interest rate reductions or deferrals due to 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 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 a loan is 60 days past
due and an appraisal, or other valuation, is not available within
a specified timeframe. "We primarily considered ASER amounts based
on ARAs calculated from MAI appraisals when deciding which classes
from the affected transactions to downgrade to 'D (sf)' because
ARAs based on a principal balance haircut are highly subject to
change, or even reversal, once the special servicer obtains the
MAI appraisals," S&P related.

Servicer nonrecoverable advance declarations can prompt shortfalls
due to a lack of debt service advancing, the recovery of
previously made advances deemed nonrecoverable, or the failure to
advance trust expenses when nonrecoverable declarations have been
determined. "Trust expenses may include, but are not limited to,
property operating expenses, property taxes, insurance
payments, and legal expenses," S&P said.

"We lowered our ratings on the class J, K, L, M, N, P, Q, and S
certificates. We lowered our ratings to 'D (sf)' on the class L,
M, N, P, Q, and S certificates to reflect accumulated interest
shortfalls outstanding for five months, primarily due to interest
reduction due to rate modification ($94,124) on the North DeKalb
Mall loan, special servicing fees ($8,380), and an ASER
amount related to one ($2.9 million, 0.3%) of the six assets
($34.9 million, 4.1%) that are currently with the special
servicer, CWCapital Asset Management LLC. The master servicer,
Wells Fargo Bank N.A. (Wells Fargo), made a nonrecoverability
determination on one of the other specially serviced assets
and therefore, did not advance interest totaling $6,613 on this
asset. We lowered our ratings on classes J and K 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 Oct. 17,
2011, trustee remittance report, ARAs totaling $17.8 million were
in effect for five assets and the total reported monthly ASER
amount on these assets was $11,910, which was offset by an ASER
recovery of $724. The reported monthly interest shortfalls totaled
$120,302, and the shortfalls have affected all of the classes
subordinate to and including class K," S&P related.

Ratings Lowered

LB-UBS Commercial Mortgage Trust 2004-C7
Commercial mortgage pass-through certificates

                             Credit         Reported
             Rating      enhancement   interest shortfalls ($)
Class     To        From        (%)       Current  Accumulated
J         BB (sf)   BBB (sf)   5.53       (6,734)            0
K         CCC- (sf) BB+ (sf)   3.44        16,774      351,703
L         D (sf)    BB (sf)    3.02        13,385       66,927
M         D (sf)    BB- (sf)   2.40        20,078      100,391
N         D (sf)    B+ (sf)    1.98        13,385       66,927
P         D (sf)    B (sf)     1.77         6,693       33,464
Q         D (sf)    CCC+ (sf)  1.35        13,385       66,927
S         D (sf)    CCC (sf)   0.93        13,385       66,927


LBUBS 2006-C4: Moody's Affirms Ratings of 30 CMBS Classes
---------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 30
classes of LBUBS Commercial Mortgage Trust, Commercial Mortgage
Pass-Through Certificates, Series 2006-C4:

Cl. A-2, Affirmed at Aaa (sf); previously on Jun 29, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jun 29, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Jun 29, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Dec 17, 2010
Confirmed at Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Dec 17, 2010
Confirmed at Aaa (sf)

Cl. A-M, Affirmed at Aa3 (sf); previously on Dec 17, 2010
Downgraded to Aa3 (sf)

Cl. A-J, Affirmed at Baa2 (sf); previously on Dec 17, 2010
Downgraded to Baa2 (sf)

Cl. B, Affirmed at Baa3 (sf); previously on Dec 17, 2010
Downgraded to Baa3 (sf)

Cl. C, Affirmed at Ba2 (sf); previously on Dec 17, 2010 Downgraded
to Ba2 (sf)

Cl. D, Affirmed at B1 (sf); previously on Dec 17, 2010 Downgraded
to B1 (sf)

Cl. E, Affirmed at B3 (sf); previously on Dec 17, 2010 Downgraded
to B3 (sf)

Cl. F, Affirmed at Caa1 (sf); previously on Dec 17, 2010
Downgraded to Caa1 (sf)

Cl. G, Affirmed at Caa2 (sf); previously on Dec 17, 2010
Downgraded to Caa2 (sf)

Cl. H, Affirmed at Ca (sf); previously on Dec 17, 2010 Downgraded
to Ca (sf)

Cl. J, Affirmed at Ca (sf); previously on Dec 17, 2010 Downgraded
to Ca (sf)

Cl. K, Affirmed at C (sf); previously on Dec 17, 2010 Downgraded
to C (sf)

Cl. L, Affirmed at C (sf); previously on Dec 17, 2010 Downgraded
to C (sf)

Cl. M, Affirmed at C (sf); previously on Dec 17, 2010 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Dec 17, 2010 Downgraded
to C (sf)

Cl. HAF-1, Affirmed at Baa1 (sf); previously on Dec 17, 2010
Confirmed at Baa1 (sf)

Cl. HAF-2, Affirmed at Baa2 (sf); previously on Dec 17, 2010
Confirmed at Baa2 (sf)

Cl. HAF-3, Affirmed at Baa3 (sf); previously on Dec 17, 2010
Confirmed at Baa3 (sf)

Cl. HAF-4, Affirmed at Ba1 (sf); previously on Dec 17, 2010
Confirmed at Ba1 (sf)

Cl. HAF-5, Affirmed at Ba2 (sf); previously on Dec 17, 2010
Confirmed at Ba2 (sf)

Cl. HAF-6, Affirmed at Ba3 (sf); previously on Dec 17, 2010
Confirmed at Ba3 (sf)

Cl. HAF-7, Affirmed at B2 (sf); previously on Dec 17, 2010
Downgraded to B2 (sf)

Cl. HAF-8, Affirmed at Caa1 (sf); previously on Dec 17, 2010
Downgraded to Caa1 (sf)

Cl. HAF-9, Affirmed at Ca (sf); previously on Dec 17, 2010
Downgraded to Ca (sf)

Cl. HAF-10, Affirmed at C (sf); previously on Dec 17, 2010
Downgraded to C (sf)

Cl. X, Affirmed at Aaa (sf); previously on Jun 29, 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.

Moody's rating action reflects a cumulative base expected loss of
9.0% of the current lower pool balance compared to 9.8% at last
review. Moody's stressed scenario loss is 19.0% of the current
balance compared to 21.4% at last review.  Depending on the
timing of loan payoffs and the severity and timing of losses
from specially serviced loans, the credit enhancement level for
investment grade classes could decline below the current levels.
If future performance materially declines, the expected level of
credit enhancement and the priority in the cash flow waterfall may
be insufficient for the current ratings of these classes.

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
the 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 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 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 19 compared to 21 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 December 17, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the
transaction's aggregate certificate balance has decreased
by 12% to $1.744 billion from $1.982 billion at securitization and
5% since Moody's prior review in December 2010. The Certificates
are collateralized by 136 mortgage loans ranging in size from less
than 1% to 15% of the pool, with the top ten loans representing
56% of the pool. There are two loans with credit estimates
representing 5% of the pool.

Non-pooled Classes HAF-1, HAF-2, HAF-3, HAF-4, HAF-5, HAF-6, HAF-
7, HAF-8, HAF- 9, HAF-10 and HAF-11 are collateralized by the
junior non-pooled components of the 70 Hudson Street Loan, The
AMLI North Dallas Loan and the Fountains of Miramar Loan.

Twenty-nine loans, representing 31% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (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.

One loan has been liquidated from the pool, resulting in a
realized loss of $1.8 million (77% loss severity), the same as at
last review. Twenty-seven loans, representing 14% of the pool, are
currently in special servicing. The largest loan in special
servicing is the Rivergate Plaza Loan ($58.5 million -- 3.4% of
the pool), which is secured by two office buildings totaling
302,058 square feet (SF) and located in Miami, Florida. The loan
was transferred to special servicing in September 2009 due to
payment default, foreclosed in July 2010 and is currently real
estate owned (REO). The second largest loan in special servicing
is the Belmont at Cowan Place Loan ($32.8 million -- 1.9% of the
pool), which is secured by a 300-unit multifamily property in
Fredericksburg, Virginia. The loan was transferred to special
servicing in July 2009 and was foreclosed December 2009. Moody's
has estimated an aggregate $93.4 million loss (44% expected loss
on average) for all of the specially serviced loans.

Moody's has assumed a high default probability for fourteen poorly
performing loans representing 10% of the pool and has estimated a
$24.4 million loss (14% expected loss based on a 50% probability
default) from these troubled loans.

Excluding specially serviced and defeased loans, Moody's was
provided with partial year 2011 operating results for 89% of the
pool and full year 2010 operating results for 96% of the pool.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 98% compared to 100% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 7.8%
to the most recently available net operating income. Moody's value
reflects a weighted average capitalization rate of 8.9%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.38X and 1.03X, respectively, compared to
1.81X and 1.26X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the 70 Hudson Street
Loan ($72.6 million -- 4.2% of the pool), which is secured by a
409,272 SF Class A office building located in Jersey City, New
Jersey. The property is 100% leased to Barclay's Capital through
January 2016. The lease expires three months prior to the loan
maturity date. Moody's credit estimate and stressed DSCR are A2
and 1.56X, respectively, compared to A2 and 1.52X at last review.

The second loan with a credit estimate is the Fountains of Miramar
Loan ($12.3 million -- 0.7% of the pool), which is secured by a
139,380 SF anchored retail center in Miramar, Florida. The junior
non-pooled component of the loan is a part of the collateral for
the multi-loan HAF class rake bonds. The loan has a credit
estimate of A3 and stressed DSCR of 1.73X, the same as at last
review.

The top three performing conduit loans represent 34% of the
pool balance. The largest conduit loan is the One Federal Street
Loan ($262 million -- 15.0% of the pool), which is secured by an
1.1 million SF Class A office tower located in the Financial
District of Boston, Massachusetts. Occupancy at the property has
declined since last review and was reported at 64% as of June 2011
versus 97% as of June 2010. Financial performance has declined in
concert with the occupancy decline. The loan is interest-only
throughout the term and matures in June 2016. Moody's LTV and
stressed DSCR are 78% and 1.18X, respectively, compared to 77%
and 1.19X at last review.

The second largest loan is the One New York Plaza Loan
($190.1 million -- 10.9% of the pool), which is secured by a 50%
pari-passu interest in a $380.2 million loan. The loan is secured
by a 2.4 million SF Class A office property located in Lower
Manhattan. The property's largest tenant is Wachovia Securities
(54% of net rentable area; lease expiration December 2014). The
property was 73% leased as of June 2011 compared to 99% at last
review following the departure of Goldman Sachs as of December
2010. The loan has amortized 2.0% since last review. Moody's LTV
and stressed DSCR are 71% and 1.3X, respectively, compared to 85%
and 1.08X at last review.

The third largest loan is the 215 Fremont Street Loan ($141.4
million -- 8.1% of the pool), which is secured by a 373,470 SF
Class A office building located in the Financial District of San
Francisco, California. Charles Schwab leases the entire building
as its headquarters (Moody's senior unsecured rating of A2, stable
outlook) through 2024. The loan is interest-only for the entire
term and matures in May 2016 -- eight years prior to lease
expiration. Moody's LTV and stressed DSCR are 119% and 0.73X,
respectively, compared to 126% and 0.73X at last review.




LBUBS 2006-C6: Moody's Affirms Ratings of 21 CMBS Classes
---------------------------------------------------------
Moody's Investors Service (Moody's) affirmed these ratings of 21
classes of LB-UBS Commercial Mortgage Securities Trust, Commercial
Mortgage Pass-Through Certificates, Series 2006-C6:

Cl. A-2, Affirmed at Aaa (sf); previously on Oct 6, 2006 Assigned
Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Oct 6, 2006 Assigned
Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Oct 6, 2006 Assigned
Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Oct 6, 2006 Assigned
Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Oct 6, 2006 Assigned
Aaa (sf)

Cl. A-M, Affirmed at Aa1 (sf); previously on Nov 17, 2010
Downgraded to Aa1 (sf)

Cl. A-J, Affirmed at Baa2 (sf); previously on Nov 17, 2010
Downgraded to Baa2 (sf)

Cl. B, Affirmed at Baa3 (sf); previously on Nov 17, 2010
Downgraded to Baa3 (sf)

Cl. C, Affirmed at Ba2 (sf); previously on Nov 17, 2010 Downgraded
to Ba2 (sf)

Cl. D, Affirmed at B1 (sf); previously on Nov 17, 2010 Downgraded
to B1 (sf)

Cl. E, Affirmed at B2 (sf); previously on Nov 17, 2010 Downgraded
to B2 (sf)

Cl. F, Affirmed at Caa1 (sf); previously on Nov 17, 2010
Downgraded to Caa1 (sf)

Cl. G, Affirmed at Caa2 (sf); previously on Nov 17, 2010
Downgraded to Caa2 (sf)

Cl. H, Affirmed at Caa3 (sf); previously on Nov 17, 2010
Downgraded to Caa3 (sf)

Cl. J, Affirmed at Ca (sf); previously on Nov 17, 2010 Downgraded
to Ca (sf)

Cl. K, Affirmed at Ca (sf); previously on Nov 17, 2010 Downgraded
to Ca (sf)

Cl. L, Affirmed at C (sf); previously on Nov 17, 2010 Downgraded
to C (sf)

Cl. M, Affirmed at C (sf); previously on Nov 17, 2010 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Nov 17, 2010 Downgraded
to C (sf)

Cl. X-CL, Affirmed at Aaa (sf); previously on Oct 6, 2006 Assigned
Aaa (sf)

Cl. X-CP, Affirmed at Aaa (sf); previously on Oct 6, 2006 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
7.8% of the current balance. At last review, Moody's cumulative
base expected loss was 7.9%. Moody's stressed scenario loss is 17%
of the current balance.  Depending on the timing of loan payoffs
and the severity and timing of losses from specially serviced
loans, the credit enhancement level for investment grade classes
could decline below the current levels. If future performance
materially declines, the expected level of credit enhancement and
the priority in the cash flow waterfall may be insufficient for
the current ratings of these classes.

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 of 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, 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 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
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 20 compared to 21 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 17, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 11% to $2.7 billion
from $3 billion at securitization. The Certificates are
collateralized by 145 mortgage loans ranging in size from less
than 1% to 15% of the pool, with the top ten non-defeased loans
representing 57.5% of the pool.

Fourty-four loans, representing 23% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Nine loans have been liquidated from the pool, resulting in a
realized loss of $28.5 million (31% loss severity). Currently 12
loans, representing 7% of the pool, are in special servicing. The
largest specially serviced loan is the LeCraw Portfolio Loan
($73.7 million -- 3% of the pool), which is secured by five
apartment properties located in Georgia. The loan was transferred
to special servicing in Juanuary 2010 due to monetary default. As
of December 2010, the property was 92% occupied. A foreclosure
sale is anticipated to commence within the next month. Moody's has
estimated an aggregate loss of $93.7 million (50% loss severity
based on a 100% probability of default) for all of the specially
serviced loans.

Moody's has assumed a high default probability for 22 poorly
performing loans representing 10% of the pool and has estimated a
$46.3 million aggregate loss (15% expected loss based on a 50%
probability of default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 97%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 105% compared to 110% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 10.8% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.32X and 0.96X, respectively, compared to
1.28X and 0.94X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the 1211 Avenue of the
Americas Loan ($400.0 million -- 15%), which is a pari-passu
interest in a $675.0 million first mortgage loan. The loan is
secured by 1.9 million square foot office property built in 1973,
renovated in 2006 and located in midtown Manhattan, New York. The
largest tenants are News America Publishing Inc (55% of the net
rentable area (NRA); lease expiration November 2020) and Ropes &
Gray LLP (14% of the NRA; lease expiration March 2027). The
building was 88% leased as of December 2010 compared to 95% at
last review and 99% at securitization. Despite decreased
occupancy, property performance has been stable. The loan is
interest-only during its entire 10-year term maturing in September
2016. Moody's current credit estimate and stressed DSCR are Baa3
and 1.17X, respectively, compared to Baa3 and 1.15X at last
review.

The remaining three loans with credit estimates comprise 3% of the
pool. The Park Square Building Loan ($71.2 million -- 2.7%) is
secured by a 495,708 square foot office building located in
downtown Boston's Back Bay submarket. Its credit estimate is Baa3,
the same as at last review and securitization. The Naples Walk I,
II, & III Loan ($9.5 million -- 0.4%) is secured by a 126,490
square foot retail anchored property located in Naples. Florida.
Its credit estimate is A3, the same as at last review and
securitization. The 1155 Avenue of the Americas Loan ($6.2 million
-- 0.3%) is a pari-passu interest in a $56.7 million first
mortgage loan secured by a 739,261 square foot office property
located in New York, New York. Its credit estimate is Aa2, the
same as at last review and securitization.

The top three performing conduit loans represent 25% of the
pool balance. The largest loan is the 125 High Street Loan
($340.0 million -- 12.8%), which is secured by a 1.5 million
square foot office property located in downtown Boston,
Massachusetts. The property was 81% leased as of June 2011
compared to 84% at last review. The loan is interest only
throughout its entire 10-year term maturing in August 2016.
Performance has declined since last review due to the decline
in base rents and expense reimbursements attributed to the
decline in occupancy. Moody's LTV and stressed DSCR are 87% and
1.02X, respectively, compared to 80% and 1.11X at securitization.

The second largest loan is The Shops at Las Americas Loan
($180.0 million -- 6.7%), which is secured by a 561,426 square
foot outlet mall located in San Diego, California. The mall's
major tenants include Last Call by Neiman Marcus, Nike Factory
Store and Old Navy. The property was 96% leased as of December
2010 compared to 98% at last review. Property performance has
increased due to increased base rents and expense reimbursements.
The loan has 19 months remaining in an 84-month interest-only
period before amortizing on a 360-month schedule maturing in
June 2016. Moody's LTV and stressed DSCR are 108% and 0.87X,
respectively, compared to 137% and 0.69X at last review.

The third largest loan is the Westfield Chesterfield Loan
($140 million -- 5.2% of the pool), which is secured 1.3 million
square foot regional mall located in Chesterfield Missouri, about
25 miles west of St. Louis. The loan is interest only throughout
its entire 10-year term maturing in September 2016. The occupancy
as of March 2011 was 91%, which is down from 95% at last review.
Moody's LTV and stressed DSCR are 90% and 1.05X, respectively,
compared to 87% and 1.09X at last review.


LCM II: S&P Hikes Ratings on 2 Classes of Notes From 'B+' to 'BB+'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised and removed from
CreditWatch positive its ratings on the class A, B, C, E1, and E2
notes from LCM II L.P., a U.S. collateralized loan obligation
(CLO) transaction managed by LCM Asset Management LLC. "At the
same time, we raised our rating on the class B-2-A note from
Liston Funding 2009-1 Ltd., a retranching of the class A notes
issued by LCM II L.P. We also affirmed and removed from
CreditWatch positive our rating on the class D note from LCM II
L.P.," S&P related.

"The upgrades on LCM II L.P. reflect improvements in the
overcollateralization (O/C) available to support the rated notes
and in the credit quality of the transaction's underlying asset
portfolio since we lowered our ratings on the transaction in
January 2010. As of the September 2011 trustee report, the class
A/B OC ratio increased to 132.44% from 120.38% in January 2010,
while the defaulted balance decreased to $0.0 million from
$5.8 million. The class A notes have paid down over $98.5 million
during the same period," S&P related.

"We upgraded the class B-2-A note from Liston Funding 2009-1 Ltd.
to reflect the same factors that have positively affected the
credit enhancement available to the class A note from LCM II
L.P.," S&P said

The affirmation of the rating on class D from LCM II L.P. reflects
the availability of sufficient credit support at the class'
current rating level.

"We will continue to review our ratings on the notes and assess
whether, in our view, the ratings remain consistent with the
credit enhancement available," S&P said.

Rating Actions

LCM II L.P.

                  Rating
Class        To            From
A            AAA (sf)      AA+ (sf)/Watch Pos
B            AA+ (sf)      AA- (sf)/Watch Pos
C            AA- (sf)      A (sf)/Watch Pos
E1           BB+ (sf)      B+ (sf)/Watch Pos
E2           BB+ (sf)      B+ (sf)/Watch Pos

Liston Funding 2009-1 Ltd.

                  Rating
Class        To            From
B-2-A        AAA (sf)      AA+ (sf)


RATING AFFIRMED AND REMOVED FROM CREDITWATCH POSITIVE

LCM II L.P.

                  Rating
Class        To             From
D            BBB- (sf)      BBB- (sf)/Watch Pos


LEAF CAPITAL: Moody's Gives 'Ba1' Rating to Class E-1 Notes
-----------------------------------------------------------
Moody's has assigned definitive ratings to the notes issued
by LEAF Receivables Funding 7, LLC -- Equipment Contract
Backed Notes, Series 2011-2 (LEAF 2011-2). The transaction
is a securitization of small ticket equipment loans and leases
sponsored by LEAF Capital Funding, LLC (LEAF), a wholly owned
subsidiary of LEAF Commercial Capital, Inc. The loans and
leases are backed by various equipment including primarily
office equipment such as copiers, as well as technology,
telecommunications and industrial equipment. The complete
rating action is:

Issuer: LEAF Receivables Funding 7, LLC -- Equipment Contract
Backed Notes, Series 2011-2

Class A-1 Notes, rated Prime-1 (sf)

Class A-2 Notes, rated Aaa (sf)

Class B Notes, rated Aa2 (sf)

Class C Notes, rated A2 (sf)

Class D Notes, rated Baa2 (sf)

Class E-1 Notes, rated Ba1 (sf)

Class E-2 Notes, rated B1 (sf)

RATINGS RATIONALE

The ratings are based primarily on an analysis of the credit
quality of the collateral, the historical performance of similar
collateral, the ability of LEAF Commercial Capital, Inc. as
servicer, the ability of U.S. Bank National Association as back-up
servicer, the ability of financial guarantor Assured Guaranty
Corp. (Assured) as financial guarantor for the Class A Notes and
control party, and the level of credit enhancement available under
the proposed capital structure. Credit enhancement includes
overcollateralization which is initially 5.75%, a non-declining
reserve account that is funded at 1.5% of original collateral
balance, subordination in the case of the Class A , Class B, Class
C, Class D, and Class E-1 notes, and excess spread. This deal
utilizes a sequential pay structure where each class of notes will
receive all principal collections until it is paid in full,
beginning with the Class A-1 notes. Credit enhancement has been
sized without regard to the financial guarantee policy.

Moody's median cumulative net loss expectation for the collateral
pool securitized in LEAF 2011-2 is 4.25%. Moody's Aaa Volatility
Proxy for the deal is 26.00%. The expected loss is based primarily
on an analysis of the collateral's historical performance --
including securitization performance, static pool performance for
annual originations and managed portfolio performance -- adjusted
to reflect differences between the economic conditions underlying
the historical performance and Moody's expectation of future
economic conditions.

The collateral securitized in this deal was originated by LEAF
Capital Funding, LLC (LEAF). It consists primarily of loans and
leases extended to small to mid-sized obligors and secured by
various types of equipment including office equipment (67.92%),
communications (9.09%), and computer equipment (4.61%). The office
equipment category is largely comprised of copiers.

The collateral pool backing the notes consist of 6,789 equipment
loans with an initial balance of $106,406,097. The weighted
average contract balance is $15,673. The weighted average
original and remaining terms to maturity are 51 and 46 months,
respectively. All of the loans in this deal are fixed interest
rate contracts and nearly all are monthly pay contracts.

The Class A-1 and A-2 are covered by a financial guarantee
insurance policy provided by Assured Guaranty Corp. (Assured)
which covers interest and principal. Under Moody's Global
Structured Finance Operational Risk Guidelines, transactions
from sponsor/servicers that are not rated or not assessed as
investment grade require mitigants (such as a backup servicer)
in order to achieve Moody's highest ratings. Transactions from
sponsor/servicers rated or assessed at the low end of non-
investment grade may require further mitigants such as a master
servicer. In some cases, the highest ratings may not be able to
achieved at all. The presence of a highly-rated guarantor provides
a strong form of support in the form of oversight that in Moody's
view goes beyond the actual financial guarantee policy. This
oversight mitigates operational risk in a highly effective way
that is not directly linked to the financial strength rating of
the guarantor. As long as the guarantor remains viable, it will be
motivated to carefully monitor the transaction and to use every
available tool to act to address operational or performance
problems should they arise. As a result, the ratings of the Notes,
including the Class A Notes, would likely be unaffected by even a
multi-notch downgrade of the guarantor. Should however the policy
be terminated or the guarantor be downgraded to below investment
grade, Moody's revisits the role played by the guarantor in
mitigating operational risk as it relates to Moody's rating of the
Notes.

The V Score for this transaction is Medium, which is somewhat
stronger than the score assigned to the U.S. Small Issuer
Equipment Lease and Loan ABS sector. The V Score indicates
"medium" uncertainty about critical assumptions. Moody's V Scores
provide a relative assessment of the quality of available credit
information and the potential variability around the various
inputs to a rating determination. The V Score ranks transactions
by the potential for significant rating changes owing to
uncertainty around the assumptions due to data quality, historical
performance, the level of disclosure, transaction complexity, the
modeling and the transaction governance that underlie the ratings.
V Scores apply to the entire transaction (rather than individual
tranches). While the overall score is medium, significant
deviations from the sector within the individual categories
include the following: Issuer/Sponsor/Originator's historical
Performance Variability which is medium versus medium/high due to
the relatively stable performance of the issuer's collateral;
market value sensitivity is medium rather than low/medium due to
the exposure to residuals; experience and oversight of transaction
parties is low/medium versus medium due to the significant
securitization experience of transaction parties with an oversight
role; and back-up servicer arrangement is low/medium versus medium
due to the back-up servicer arrangement with U.S Bank National
Association and the oversight role of Assured.

Moody's Parameter Sensitivities: If the expected cumulative net
loss used in determining the initial rating were changed to 5.25%,
7.15%, or 8.95% the initial model-indicated rating for the Class A
notes might change from Aaa to Aa1, Aa3, and A2, respectively. If
the expected cumulative net loss used in determining the initial
rating were changed to 4.35%, 5.25%, or 6.05%, the initial model-
indicated rating for the Class B notes might change from Aa2 to
Aa3, A2, and Baa1, respectively. If the expected cumulative net
loss used in determining the initial rating were changed to 4.40%,
5.00%, or 5.95%, the initial model-indicated rating for the Class
C notes might change from A2 to A3, Baa2, and Ba1, respectively.
If the expected cumulative net loss used in determining the
initial rating were changed to 4.35%, 5.15%, or 5.95%, the initial
model-indicated rating for the Class D notes might change from
Baa2 to Baa3, Ba2, and B1, respectively. If the expected
cumulative net loss used in determining the initial rating were
changed to 4.45%, 5.15%, or 5.85%, the initial model-indicated
rating for the Class E-1 notes might change from Ba1 to Ba2, B1,
and B3, respectively. If the expected cumulative net loss used in
determining the initial rating were changed to 4.45%, 4.80%, or
5.50%, the initial model-indicated rating for the Class E-2 notes
might change from B1 to B2, B3, and lower than B3, respectively.

Parameter Sensitivities are not intended to measure how the rating
of the security might migrate over time, rather they are designed
to provide a quantitative calculation of how the initial rating
might change if key input parameters used in the initial rating
process differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.

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

PRINCIPAL METHODOLOGY

The principal methodology used in this rating was "Moody's
Approach to Rating Securities Backed by Equipment Leases and
Loans," March 2007.


LEGG MASON: Moody's Affirms Rating of Class C Notes at 'Ba2'
------------------------------------------------------------
Moody's has affirmed the ratings of all classes of Notes issued
by Legg Mason Real Estate CDO I, Ltd., due to key transaction
parameters performing within levels commensurate with the existing
ratings levels. The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation and collateralized loan obligation (CRE CDO CLO)
transactions.

Cl. A1-R, Affirmed at Aaa (sf); previously on Apr 21, 2009
Confirmed at Aaa (sf)

Cl. A1-T, Affirmed at Aaa (sf); previously on Apr 21, 2009
Confirmed at Aaa (sf)

Cl. A2, Affirmed at A1 (sf); previously on Nov 3, 2010 Downgraded
to A1 (sf)

Cl. B, Affirmed at Baa3 (sf); previously on Nov 3, 2010 Downgraded
to Baa3 (sf)

Cl. C, Affirmed at Ba2 (sf); previously on Nov 3, 2010 Downgraded
to Ba2 (sf)

Cl. D, Affirmed at B1 (sf); previously on Nov 3, 2010 Downgraded
to B1 (sf)

Cl. E, Affirmed at B2 (sf); previously on Nov 3, 2010 Downgraded
to B2 (sf)

Cl. F-1, Affirmed at Caa1 (sf); previously on Nov 3, 2010
Downgraded to Caa1 (sf)

Cl. F-2, Affirmed at Caa1 (sf); previously on Nov 3, 2010
Downgraded to Caa1 (sf)

Cl. G, Affirmed at Caa3 (sf); previously on Nov 3, 2010 Downgraded
to Caa3 (sf)

RATINGS RATIONALE

Legg Mason Real Estate CDO I, Ltd., is a static (the reinvestment
period ended in April 2011) CRE CDO CLO. As of the September 26,
2011 Trustee report, the transaction is backed by a portfolio of
whole loans (91.2% of the pool balance), commercial mortgage
backed securities (CMBS) (3.9%), B-Notes (3.5%), and mezzanine
loans (1.4%). The aggregate Note balance of the transaction,
including Income Notes, has decreased to $529.2 million from
$532.0 million at issuance, due to approximately $2.8 million in
full amortization to the Class A1-R and A1-T Notes. There are no
losses in the collateral pool to date. Currently, the transaction
is passing all its ratio tests.

There are four assets with a par balance of $49.5 million (9.3% of
the current pool balance) that are considered Defaulted Securities
as of the September 26, 2011 Trustee report, compared to seven
assets with 13.3% of the pool balance at last review.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: weighted average
rating factor (WARF), weighted average life (WAL), weighted
average recovery rate (WARR), and Moody's asset correlation (MAC).
These parameters are typically modeled as actual parameters for
static deals and as covenants for managed deals.

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has updated credit estimates for the non-Moody's rated
collateral. The bottom-dollar WARF is a measure of the default
probability within a collateral pool. Moody's modeled a bottom-
dollar WARF of 7,286 compared to 7,927 at last review. The
distribution of current ratings and credit estimates is as
follows: A1-A3 (0.1% compared to 3.6% at last review), Baa1-Baa3
(3.9% compared to 0.1% at last review), Ba1-Ba3 (0.6% compared to
0.0% at last review), B1-B3 (11.8% compared to 1.8% at last
review), and Caa1-C (83.6% compared to 94.5% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 2.7 years compared
to 2.3 at last review. Moody's is modeling the actual remaining
WAL of the collateral pool, including extensions for loans, in the
current review

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
53.4% compared to 53.8% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 100%, the same as that at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

The cash flow model, CDOEdge(R) v3.2.1.0, was used to analyze the
cash flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
53.4% to 43.4% or up to 63.4% would result in average rating
movement on the rated tranches of 0 to 6 notches downward and 0 to
9 notches upward, respectively.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected
range will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of assumption uncertainty
are the current sluggish macroeconomic environment and 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 methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in November 2010, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


LEHMAN MANUFACTURED: Fitch Affirms Rating on Two Notes at 'Dsf'
---------------------------------------------------------------
Fitch Ratings has affirmed five classes and withdrawn two classes
from two U.S. RMBS Manufactured Housing (MH) Resecuritization
Trusts (RE-REMICs).  These Re-REMICs are collateralized with
underlying MH transactions from the 1995-2000 vintages.
Fitch's rating actions are as follows:

Asset-Backed Securities Corp. 2004-CNF1

  -- A-1 (00081WAG6) affirmed at 'Asf'; Outlook Stable;
  -- A-2 (00081WAH4) affirmed at 'Csf/RR1'.

Lehman Manufactured Housing Asset-Backed Trust 1998-1

  -- I-A1 (525170BB1) affirmed at 'Asf'; Outlook Positive;
  -- I-IO (525170BC9) withdrawn;
  -- II-A1 (525170BD7) affirmed at 'Dsf/RR2';
  -- II-A2 (525170BE5) affirmed at 'Dsf/RR2';
  -- II-IO (525170BF2) withdrawn.

The Re-REMIC rating actions reflect the recently completed MH
sector rating review. Additional information regarding the MH
rating actions is available in Fitch's Oct. 21, 2011 press release
titled 'Fitch Takes Various Actions on 143 U.S. Manufactured
Housing RMBS Deals'.

To analyze the Re-REMIC classes for Asset-Backed Securities Corp.
2004-CNF1, Fitch first determines the underlying collateral pool's
projected base-case and rating-stressed loss assumptions.  These
assumptions are derived using the pool's 12-month average
prepayment speed, default frequency, loss severity, and
delinquency trend.  After determining the underlying pool's loss
assumptions, Fitch performs cash flow analysis on the Re-REMIC
classes.

The ratings on Lehman Manufactured Housing Asset-Backed Trust
1998-1 directly reflect the ratings on the underlying classes.
This Re-REMIC is a direct pass-through structure and does not
provide additional enhancement to the Re-REMIC classes.  Two
interest only classes were withdrawn since their notional balance
is derived from the collateral balance.

These actions were reviewed by a committee of Fitch analysts.


MAC CAPITAL: Moody's Raises Rating of Class B-1F Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by MAC Capital, Ltd.:

US$203,000,000 Class A-1L Floating Rate Notes Due July 2023
(current outstanding balance of $185,712,925), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review for
Possible Upgrade;

US$75,000,000 Class A-1LV Floating Rate Revolving Notes Due July
2023 (current outstanding balance of USD 49,743,373, EUR6,169,488,
and AUD 9,264,160), Upgraded to Aaa (sf); previously on June 22,
2011 Aa3 (sf) Placed Under Review for Possible Upgrade;

US$49,000,000 Class A-2L Floating Rate Notes Due July 2023,
Upgraded to Aa3 (sf); previously on June 22, 2011 Baa1 (sf) Placed
Under Review for Possible Upgrade;

US$35,000,000 Class A-3L Floating Rate Notes Due July 2023,
Upgraded to Baa1 (sf); previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$16,600,000 Class B-1F Fixed Rate Notes Due July 2023, Upgraded
to Ba1 (sf); previously on June 22, 2011 Caa1 (sf) Placed Under
Review for Possible Upgrade;

US$4,400,000 Class B-1L Floating Rate Notes Due July 2023,
Upgraded to Ba1 (sf); previously on June 22, 2011 Caa1 (sf) Placed
Under Review for Possible Upgrade;

US$5,000,000 Class B-2F Fixed Rate Notes Due July 2023, Upgraded
to Ba3 (sf); previously on June 22, 2011 Caa3 (sf) Placed Under
Review for Possible Upgrade;

US$14,000,000 Class B-2L Floating Rate Notes Due July 2023,
Upgraded to Ba3 (sf); previously on June 22, 2011 Caa3 (sf) Placed
Under Review for Possible Upgrade;

US$27,700,000 Class C-1 Combination Securities due July 2023
(current outstanding rated balance of $20,289,517), Upgraded to
Ba1 (sf); previously on June 22, 2011 Caa3 (sf) Placed Under
Review for Possible Upgrade;

US$4,000,000 Class C-2 Combination Securities due July 2023
(current outstanding rated balance of $3,264,914), Upgraded to Ba3
(sf); previously on June 22, 2011 Caa3 (sf) Placed Under Review
for Possible Upgrade;

US$12,500,000 Class C-3 Combination Securities due July 2023
(current outstanding rated balance of $8,691,636), Upgraded to B1
(sf); previously on June 22, 2011 Ca (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 September
2009. In particular, as of the trustee report dated September
2011, the weighted average rating factor is currently 2959
compared to 3401 in the August 2009 report. The Senior Class A,
Class A, Class B-1, and Class B-2 overcollateralization ratios are
reported at 136.31%, 122.17%, 115.01%, and 109.22%, respectively,
versus August 2009 levels of 133.94%, 120.35%, 113.44%, and
105.97%, 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 balance, including principal proceeds, of
$410 million, defaulted par of $7.9 million, a weighted average
default probability of 28.0% (implying a WARF of 3248), a weighted
average recovery rate upon default of 43.1%, and a diversity score
of 50. These default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends, and collateral manager
latitude for trading the collateral are also factors.

MAC Capital, Ltd., issued in May 2007, is a collateralized loan
obligation backed primarily by a portfolio of U.S. dollar-
denominated senior secured loans and high yield bonds.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011. In addition the methodology "Using the Structured Note
Methodology to Rate CDO Combo-Notes" published in February 2004
was also use in this rating.

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.

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 selling defaulted
assets create additional uncertainties. Moody's analyzed defaulted
recoveries assuming the lower of the market price and the recovery
rate in order to account for potential volatility in market
prices.

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

3. Other collateral quality metrics: The deal is allowed to
reinvest and the manager has the ability to deteriorate the
collateral quality metrics' existing cushions against the covenant
levels. Moody's analyzed the impact of assuming 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 spread levels higher than the covenant levels due
to the large difference between the reported and covenant levels.


MAPS CLO: Moody's Upgrades Rating of Class C Notes to 'Ba1'
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by MAPS CLO Fund II Ltd.:

US$186,250,000 Class A-1 Senior Secured Floating Rate Notes Due
July 20, 2022, Upgraded to Aa1 (sf); previously on June 22, 2011
Aa2 (sf) Placed Under Review for Possible Upgrade;

US$18,750,000 Class A-1J Senior Secured Floating Rate Notes Due
July 20, 2022, Upgraded to Aa1 (sf); previously on June 22, 2011
Aa3 (sf) Placed Under Review for Possible Upgrade;

US$18,000,000 Class A-2 Senior Secured Floating Rate Notes Due
July 20, 2022, Upgraded to Aa3 (sf); previously on June 22, 2011
A3 (sf) Placed Under Review for Possible Upgrade;

US$26,000,000 Class B Senior Secured Deferrable Floating Rate
Notes Due July 20, 2022, Upgraded to A3 (sf); previously on
June 22, 2011 Ba1 (sf) Placed Under Review for Possible Upgrade;

US$22,000,000 Class C Senior Secured Deferrable Floating Rate
Notes Due July 20, 2022, Upgraded to Ba1 (sf); previously on
June 22, 2011 B1 (sf) Placed Under Review for Possible Upgrade;

US$16,000,000 Class D Secured Deferrable Floating Rate Notes Due
July 20, 2022, Upgraded to Ba3 (sf); previously on June 22, 2011
Caa3 (sf) Placed Under Review for Possible Upgrade;

US$3,000,000 Composite Notes Due July 20, 2022 (current Rated
Balance of $2,379,843), Upgraded to Baa3 (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.

Moody's also notes that the deal has benefited from improvement in
the credit quality of the underlying portfolio and an increase in
the transaction's overcollateralization ratios since the rating
action in August 2009. Based on the September 2011 trustee report,
the weighted average rating factor is currently 2729 compared to
3181 in July 2009. The Class A, Class B, Class C and Class D
overcollateralization ratios are reported at 129.05%, 118.70%,
111.15% and 106.24%, respectively, versus July 2009 levels of
126.2%, 116.13%, 108.75% and 103.94%, 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 and principal proceeds balance of $383.2 million,
defaulted par of $4.3 million, a weighted average default
probability of 26.23% (implying a WARF of 3274), a weighted
average recovery rate upon default of 49.29%, 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.

MAPS CLO Fund II Ltd., issued in June 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. In addition, the methodology "Using the Structured Note
Methodology to Rate CDO Combo-Notes" published in February 2004
was also used.

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 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 spread and
diversity score. However, as part of the base case, Moody's
considered a coupon level higher than the covenant level and a
weighted average rating factor lower than the covenant level due
to the large difference between the reported and covenant levels.

4) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates.


MERRILL LYNCH: S&P Lowers Ratings on 2 Classes of Certs. to 'D'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage pass-through certificates from
Merrill Lynch Mortgage Trust 2006-C1, a U.S. commercial mortgage-
backed securities (CMBS) transaction. "Concurrently, we affirmed
our 'AAA (sf)' ratings on seven other classes from the same
transaction," S&P related.

"Our rating actions primarily reflect our analysis of the
transaction using our U.S. CMBS conduit/fusion criteria. Our
analysis included a review of the credit characteristics of the
remaining assets in the pool, the transaction structure, and the
liquidity available to the trust. The downgrades reflect credit
support erosion that we anticipate will occur upon the eventual
resolution of 21 ($189.3 million, 8.6%) of the transaction's 24
($201.7 million, 9.1%) assets that are with the special servicer
and three loans ($40.3 million, 1.8%) that we determined to be
credit-impaired. We also considered the monthly interest
shortfalls that are affecting the trust. We lowered our ratings
on classes F and G to 'D (sf)' because we expect the interest
shortfalls to continue and believe the accumulated interest
shortfalls will remain outstanding for the foreseeable future,"
S&P said.

The affirmed ratings on the principal and interest certificates
reflect subordination and liquidity support levels that are
consistent with the outstanding ratings. "We affirmed our 'AAA
(sf)' rating on the class X interest-only (IO) certificate based
on our current criteria," S&P related.

"Using servicer-provided financial information, we calculated an
adjusted debt service coverage (DSC) of 1.51x and a loan-to-value
(LTV) ratio of 97.0% for the pool. We further stressed the loans'
cash flows under our 'AAA' scenario to yield a weighted average
DSC of 0.99x and a LTV ratio of 133.2%. The implied defaults and
loss severity under the 'AAA' scenario were 69.8% and 42.0%,
respectively. The DSC and LTV calculations noted exclude 21
($189.3 million, 8.6%) of the transaction's 24 ($201.7 million,
9.1%) specially serviced assets and three loans ($40.3 million,
1.8%) that we determined to be credit-impaired. We separately
estimated losses for these assets and included them in our 'AAA'
scenario implied default and loss severity figures," S&P said.

As of the Oct. 12, 2011 trustee remittance report, the trust
experienced monthly interest shortfalls totaling $497,182,
primarily related to appraisal subordinate entitlement reduction
(ASER) amounts totaling $428,074, special servicing fees of
$40,765, and interest reduction of $32,241 due to a rate
modification. "The interest shortfalls have affected all classes
subordinate to and including class F. Classes F and G have had
accumulated interest shortfalls outstanding for two consecutive
months, and we expect these interest shortfalls to continue in the
near term. Consequently, we lowered our ratings on classes F and G
to 'D (sf)'," S&P related.

                       Credit Considerations

As of the Oct. 12, 2011, trustee remittance report, 24
($201.7 million, 9.1%) assets in the pool were with the
special servicer, CWCapital Asset Management LLC (CWCapital).
The reported payment status of the specially serviced assets
as of the October 2011 trustee remittance report is: 12 are
real estate owned (REO; $129.3 million, 5.8%), one ($2.4 million,
0.1%) is in foreclosure, nine ($61.2 million, 2.8%) are 90-plus
days delinquent, one ($4.0 million, 0.2%) is in its grace period,
and one ($4.8 million, 0.2%) is current. Appraisal reduction
amounts (ARAs) totaling $101.9 million are in effect for 20 of the
specially serviced assets. Details of the three largest specially
serviced assets, one of which is a top 10 asset, are:

The Raintree Corporate Center 1 and 2 asset ($56.1 million 2.5%),
the seventh-largest asset in the pool, consists of two office
buildings totaling 298,865 sq. ft. in Scottsdale, Ariz. The asset
was transferred to the special servicer on Oct. 1, 2009, due
to imminent monetary default and became REO on Aug. 10, 2011.
According to CWCapital, occupancy as of September 2011 was 57.0%,
and CWCapital is currently continuing its leasing efforts at the
property. An ARA of $32.9 million is in effect against the asset.
"We expect a significant loss upon the eventual resolution of this
asset," S&P said.

The Suites at Mainsail Village loan ($26.3 million, 1.2%), the
second-largest asset with CWCapital, is secured by a 360-room
independent hotel in Tampa, Fla. The loan, which has a reported
90-plus days delinquent payment status, was transferred to
CWCapital on Nov. 16, 2010, due to monetary default. According to
CWCapital, it is working with the borrower on a loan modification
while pursuing foreclosure. No updated 2010 financial data is
available. An ARA of $17.4 million is in effect against the loan.
We expect a significant loss upon the eventual resolution of this
loan," S&P related.

The Fourth & Walnut asset ($23.4 million, 1.1%), the third-largest
asset with CWCapital, is a 356,061 sq.-ft. office building in
Cincinnati, Ohio. The asset was transferred to the special
servicer on June 27, 2008, due to imminent monetary default and
became REO on March 11, 2010. According to CWCapital, the current
occupancy is 70.3%, and CWCapital is continuing its leasing
efforts at the property. An ARA of $11.5 million is in effect
against the asset. "We expect a significant loss upon the eventual
resolution of this asset," S&P said.

The remaining 21 specially serviced assets have balances that
individually represent less than 0.5% of the total pool balance.
ARAs totaling $40.1 million are in effect against 17 of these
assets. "We estimated losses for 18 of them, arriving at a
weighted average loss severity of 51.5%. The special servicer has
conveyed to us that the remaining three loans have been modified
and are expected to be returned to the respective master servicers
in the near term," S&P related.

"In addition to the specially serviced assets, we determined three
loans ($40.3 million, 1.8%) to be credit-impaired due to low
reported DSCs. The Central Florida Research Park Portfolio loan
($24.9 million, 1.1%), with a reported in grace payment status, is
secured by a portfolio of three industrial properties totaling
197,544 sq. ft. in Orlando, Fla. The reported DSC for this loan
was 0.75x as of year-end 2010, and according to the master
servicer, the borrower stated that it may not be able to make
future debt service payments. The second loan, the South Rainbow
Business Park ($9.9 million, 0.5%), with a reported in grace
payment status, is secured by a 43,614-sq.-ft. office building in
Las Vegas, Nev. The loan was recently transferred back to master
servicing, but it is our understanding from the special servicer
that the borrower has a history of being delinquent on its debt
service payments. The borrower has not provided current reported
financial data for this loan. The remaining loan, the Elk Park
Retail loan ($5.5 million, 0.2%), with a reported less than 30
days delinquent payment status, is secured by a 44,632-sq.-ft.
retail property in Jonesboro, Ark. The loan reported a DSC of
0.87x and 74.0% occupancy for year-end 2010. Consequently, we view
these three loans to be at an increased risk of default and loss,"
S&P said.

Seven loans totaling ($69.2 million (3.1%) were previously with
the special servicer and have been returned to the master
servicer. Pursuant to the transaction documents, the special
servicer is entitled to a workout fee that equals 1% of future
principal and interest payments if the loans perform and
remain with the master servicer. According to both master
servicers, the workout fee will be collected on these seven
loans.

                        Transaction Summary

As of the Oct. 12, 2011 trustee remittance report, the pool
balance was $2.21 billion, which is 88.8% of the pool balance at
issuance. The pool includes 213 loans and 12 REO assets, down from
244 loans at issuance. The master servicers, Midland Loan Services
(Midland) and Wells Fargo Bank N.A. (Wells Fargo), provided
financial information for 91.9% of the assets in the pool, 87.3%
of which was full-year 2010 data.

"We calculated a weighted average DSC of 1.56x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.51x and 97.0%. Our adjusted DSC and LTV
figures exclude 21 ($189.3 million, 8.6%) of the transaction's 24
($201.7 million, 9.1%) specially serviced assets and three loans
($40.3 million, 1.8%) that we determined to be credit-impaired. To
date, the transaction has experienced $22.1 million in principal
losses from six assets. Fifty-four loans ($360.6 million, 16.3%)
in the pool are on the master servicers' combined watchlist.
Fifty-eight loans ($361.9 million, 16.4%) have a reported DSC of
less than 1.10x, 46 of which ($284.7 million, 12.9%) have a
reported DSC of less than 1.00x," S&P related.

                    Summary of Top 10 Assets

The top 10 assets have an aggregate outstanding balance of
$848.1 million (38.4%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.85x for nine of the top 10
assets. The remaining asset, the Raintree Corporate Center 1 and 2
($56.1 million, 2.5%), is with the special servicer. "Our adjusted
DSC and LTV ratio for nine of the top 10 assets were 1.70x and
90.9%. The fourth-largest asset, the Galileo NXL Retail Portfolio
4 loan ($102.0 million, 4.6%) is scheduled to mature in 2012.
Details of this loan and the largest asset in the pool are set
forth," S&P said.

The North Point Mall loan, the largest asset in the pool, has a
trust balance of $148.8 million (6.7%) and a whole-loan balance
of $211.8 million. The loan is secured by a 1.0 million-sq.-ft.
regional mall in Alpharetta, Ga. Midland indicated that the
maturity of the loan was recently extended from March 1, 2011,
to March 1, 2014. The reported DSC was 1.14x for year-end 2010,
and based on the March 2011 rent roll, occupancy was 82.0%.

The Galileo NXL Retail Portfolio 4 loan ($102.0 million, 4.6%)
is secured by a portfolio of 10 retail properties totaling
1.4 million sq. ft. in Florida, Texas, New York, Pennsylvania,
and Colorado. The loan is scheduled to mature on Aug. 31, 2012.
Wells Fargo reported a combined DSC of 1.67x for year-end 2010,
and according to the May 2011 rent rolls, the combined occupancy
was 91.35%.

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

Ratings Lowered

Merrill Lynch Mortgage Trust 2006-C1
Commercial mortgage pass-through certificates

                Rating
Class      To           From       Credit enhancement (%)
AM         A (sf)       AA- (sf)                    21.52
AJ         BB (sf)      BBB (sf)                    11.67
B          B (sf)       BB+ (sf)                     9.14
C          B- (sf)      BB (sf)                      7.87
D          CCC (sf)     BB- (sf)                     6.46
E          CCC- (sf)    B+ (sf)                      5.62
F          D (sf)       B- (sf)                      4.35
G          D (sf)       CCC (sf)                     3.37

Ratings Affirmed

Merrill Lynch Mortgage Trust 2006-C1
Commercial mortgage pass-through certificates

Class    Rating                      Credit enhancement (%)
A-2      AAA (sf)                                     32.79
A-3      AAA (sf)                                     32.79
A-3B     AAA (sf)                                     32.79
A-SB     AAA (sf)                                     32.79
A-4      AAA (sf)                                     32.79
A-1A     AAA (sf)                                     32.79
X        AAA (sf)                                       N/A

N/A -- Not applicable.


MORGAN STANLEY: DBRS Downgrades Class Q Rating to 'D'
-----------------------------------------------------
DBRS has downgraded the Commercial Mortgage Pass-Through
Certificates, Series 2005-HQ6, Class Q (the Class Q) rating of
Morgan Stanley Capital I Trust 2005-HQ6 (the Trust) to D (sf) from
C (sf).  The downgrade is the consequence of realized losses to
the Trust as a result of the liquidation of three loans out of the
Trust.

Prospectus ID#136 (Ferndale Retail Center), Prospectus ID#79
(Suburban Extended Stay Portfolio-Daytona) and Prospectus
ID#144 (Rogers Retail Center) were liquidated at a total loss
of $6.32 million to the Trust as of the October 2011 remittance
report.  The weighted-average loss severity of 66.9% is in line
with projections by DBRS for these loans at the time of its most
recent full review of the transaction, conducted in July 2011.
As a result of these losses, the original balance of the Class
Q certificates has been reduced by approximately 56% to
$5.76 million as of the October 2011 remittance report.


MORGAN STANLEY: S&P Lowers Rating on Class F Certs. to 'CCC+'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage pass-through certificates from
Morgan Stanley Capital I Trust 2007-TOP27, a U.S. commercial
mortgage-backed securities (CMBS) transaction. "Concurrently, we
affirmed our 'AAA (sf)' ratings on nine other classes from the
same transaction," S&P related.

"Our rating actions follow our analysis of the transaction
primarily using our U.S. conduit/fusion CMBS criteria, the deal
structure, and the liquidity available to the trust. The
downgrades reflect credit support erosion that we anticipate will
occur upon the resolution of 10 ($120.9 million, 4.5%) of the
11 loans ($124.6 million, 4.6%) that are currently with the
special servicer and four additional loans ($34.6 million, 1.3%)
that we determined to be credit-impaired. We also considered the
monthly interest shortfalls affecting the trust and the potential
for additional interest shortfalls associated with loan
modifications and/or revised appraisal reduction amounts (ARAs) on
the specially serviced assets," S&P said.

"The rating affirmations on the principal and interest
certificates reflect subordination and liquidity support levels
that we consider to be consistent with our outstanding ratings on
these classes. We affirmed our 'AAA (sf)' rating on the class X
interest-only (IO) certificate based on our current criteria," S&P
stated.

"The affirmed 'AAA (sf)' rating on the AW34 raked certificate
class reflects our analysis of the credit characteristics of the
330 West 34th Street loan, which is the sole source of cash flow
for the certificate. This loan is secured by the leased fee
interest in the land beneath a 638,982-sq.-ft. office and retail
building located at 330 West 34th Street in Manhattan. The
pool balances and statistics do not include this loan," S&P said.

"Our analysis included a review of the credit characteristics of
the remaining loans in the pool. Using servicer-provided financial
information, we calculated an adjusted debt service coverage (DSC)
of 1.66x and a loan-to-value (LTV) ratio of 97.9%. We further
stressed the loans' cash flows under our 'AAA' scenario to yield a
weighted-average DSC of 1.00x and an LTV ratio of 134.0%. The
implied defaults and loss severity under the 'AAA' scenario were
84.7% and 32.9%, respectively. The DSC and LTV calculations
noted above exclude 10 ($120.9 million, 4.5%) of the 11 loans
($124.6 million, 4.6%) that are currently with the special
servicer and four ($34.6 million, 1.3%) loans that we determined
to be credit-impaired. We separately estimated losses for the
excluded specially serviced and credit-impaired loans and
included them in our 'AAA' scenario implied default and loss
severity figures," S&P said.

As of the Oct. 14, 2011, trustee remittance report, the trust had
experienced monthly interest shortfalls totaling $327,060. The
interest shortfalls were primarily due to appraisal subordinate
entitlement reduction (ASER) amounts totaling $213,482 and special
servicing fees of $18,356. In addition, the trust experienced a
reduction in interest of $95,221 related to nonrecoverability
determinations on two loans. The class G certificates experienced
a partial interest shortfall for the current reporting period.

"The class H, J, K, L, M, N, and O certificates, which we
previously downgraded to 'D (sf)', have experienced cumulative
interest shortfalls for periods ranging from 13 to 16 consecutive
months and we expect the shortfalls to remain outstanding for the
foreseeable future," S&P said.

                    Credit Considerations

As of the Oct. 14, 2011, trustee remittance report, 10 assets
($88.1 million, 3.3%) in the pool were with the special servicer,
C-III Asset Management LLC (C-III). The reported payment status of
the specially serviced assets is: six are real estate owned (REO;
$64.3 million, 2.43%); one loan is in foreclosure ($14.4 million,
0.5%); two loans are 90-plus-days delinquent ($5.8 million, 0.2%);
and one loan is 30-plus-days delinquent ($3.7 million, 0.1%). On
Oct. 21, 2011, the Springfield Hotel Portfolio ($36.5 million,
1.4%) loan was transferred to C-III due to imminent default. The
payment status of the recently transferred loan is current. As of
the reporting date, appraisal reduction amounts (ARAs) totaling
$59.2 million were in effect against nine of the 10 specially
serviced loans. Details on the four largest loans with the
special servicer are:

The Springfield Hotel Portfolio loan ($36.5 million, 1.4%) is now
the largest loan with the special servicer. The loan is secured by
two hotels: a 288-room Crowne Plaza hotel and a 140-room Holiday
Inn Express, which are adjacent to one other and located in
Springfield, Ill. The loan's payment status is current. According
to the master servicer, the borrower has indicated its
inability to refinance the loan prior to the April 1, 2012,
maturity date. As of Dec. 31, 2010, DSC was reported as 1.37x. "We
anticipate a moderate loss upon the eventual resolution of this
loan," S&P related.

The Comfort Suites BWI Airport asset ($14.9 million, 0.6%) is the
second-largest specially serviced loan. This loan was transferred
to C-III on Jan. 22, 2010, due to payment default, and became REO
on June 16, 2011. The asset is a 137-room limited-service hotel in
Linthicum Heights, Md. C-III is in the process of marketing the
asset for sale. The total exposure including servicer advances is
$16.9 million. "An ARA of $7.1 million is in effect, and we
anticipate a significant loss upon the eventual resolution of this
asset," S&P related.

The Empire Towers loan ($14.4 million, 0.5%) is the third-largest
loan with the special servicer. The loan was transferred to C-III
on May 7, 2009, due to payment default, and the reported payment
status is in foreclosure. The loan is secured by an office and
retail property totaling 141,667 sq. ft. in Glen Burnie, Md. The
total exposure, including servicer advances, is $16.6 million. An
ARA of $10.0 million is in effect against this loan, and we
anticipate a significant loss upon the eventual resolution of this
asset," S&P stated.

The Grand Mart Chicago asset ($14.1 million, 0.5%) is the fourth-
largest asset with the special servicer. The asset was transferred
to C-III on March 3, 2009, due to payment default, and became REO
on Dec. 21, 2010. The asset consists of a portfolio of three
retail properties totaling 193,566 sq. ft. in Illinois. "According
to C-III, one of the three properties is going into contract of
sale. An ARA of $11.3 million is in effect, and we anticipate a
significant loss upon the eventual resolution of this asset," S&P
said.

The remaining seven specially serviced assets have individual
exposures that represent less than 0.5% of the total pool balance.
ARAs totaling $30.8 million were in effect against six of these
seven remaining specially serviced loans. "Standard & Poor's
estimated losses for these six specially serviced loans represent
a 74.3% weighted-average loss severity," S&P stated.

"In addition to the specially serviced loans, we determined four
loans in the pool to be credit-impaired," S&P said.

The Reston Sunrise I & II loan ($22.0 million, 0.8%) is secured by
two office buildings totaling 136,825 sq. ft. in Reston, Va. The
loan appears on the master servicer's watchlist due to a decline
in DSC. The loan's reported payment status is current. "As of June
30, 2011, the reported DSC was 0.40x. Given the reported
performance, we consider this loan to be at an increased
risk of default and loss," S&P said.

The Country Inn & Suites loan ($7.7 million, 0.3%) is secured by a
122-room hotel in Chanhassen, Minn., which is within the
Minneapolis metropolitan area. The loan is on the master
servicer's watchlist due to a decline in DSC. The loan's reported
payment status is current. As of June 30, 2011, the reported
DSC and occupancy were 0.66x and 52%. "Given the reported
performance, we consider this loan to be at an increased risk of
default and loss," S&P said.

The 3334 Richmond Avenue loan ($2.6 million, 0.1%) is secured by a
26,769-sq.-ft. office building in Houston, Texas. The loan is on
the master servicer's watchlist due to a decline in DSC. The
loan's reported payment status is current. The debt service for
this loan converted from interest only to principal and interest
in March 2010. "As of Dec. 31, 2010, the reported DSC was 0.51x.
Given the reported performance, we consider this loan to be at an
increased risk of default and loss," S&P said.

The Pinebrook Estates loan ($2.3 million, 0.1%) is secured by a
mobile home park with 147 spaces located in Douglasville, Ga.,
which is  about 20 miles west of Atlanta. The loan is on the
master servicer's watchlist due to a decline in DSC. The loan's
reported payment status is current. As of June 30, 2011, the
reported DSC and occupancy were 0.49x and 60%. "Given
the reported performance, we consider this loan to be at an
increased risk of default and loss," S&P related.

                      Transaction Summary

As of the Oct. 14, 2011, trustee remittance report, the collateral
pool balance was $2.6 billion, or 95.3% of the balance at
issuance. The pool includes 214 loans and six REO assets, down
from 226 loans at issuance. The master servicer, Wells Fargo Bank
N.A., provided financial information for 96.9% of the loan
balance, 90.3% of which was interim- or full-year 2010 data,
and the remainder reflected full-year 2009 or interim-2011 data.

"We calculated a weighted average DSC of 1.66x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.66x and 97.9%. Our adjusted DSC and LTV
figures exclude 10 of the 11 specially serviced loans and four
loans that we determined to be credit-impaired. Six loans have
experienced $12.7 million in principal losses to date. Fifty loans
($410.7 million, 15.2%) in the pool are on the master servicer's
watchlist. Twenty-seven loans ($230.9 million, 8.6%) have a
reported DSC of less than 1.10x, 21 of which ($153.8 million,
5.7%) have reported a DSC below 1.00x," S&P said.

                    Summary of The Top 10 Loans

The top 10 loans have an aggregate outstanding balance of
$788.6 million (29.3%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.72x for the top 10
loans. None of the top 10 loans appear on the master servicer's
watchlist. "Our adjusted DSC and LTV ratio for the top 10 loans
were 1.66x and 93.5%," S&P said.

The 360 Park Avenue South loan ($220.0 million, 8.2%) is the
largest loan in the pool and is secured by a 451,800-sq.-ft.
office building located in the Midtown South submarket of
Manhattan in New York City. The building is fully leased to Reed
Elsevier Inc. ('BBB+'), a publisher of science and health
information. As of Dec. 31, 2010, the servicer-reported DSC was
1.64x and occupancy was 100.0%.

Two of the top 10 loans have inherent refinance risk because they
mature on March 1, 2012.

The Maple Tree Place loan ($63.4 million, 2.4%) is the sixth-
largest loan in the pool, and is secured by a 488,915-sq.-ft.
retail shopping center in Williston, Vt., just outside Burlington.
As of Dec. 31, 2010, the servicer-reported DSC was 1.62x.
Occupancy was 84.0% as of Sept. 30, 2010.

The NY Inland Portfolio loan ($52.3 million, 1.9%) is the eighth-
largest loan in the pool, and is secured by two retail shopping
centers in New York totaling 673,696sq. ft.: one is in
Poughkeepsie and one is in Saratoga Springs. As of Dec. 31, 2010,
the servicer-reported DSC and occupancy were 1.93x and 90.9%.

Standard & Poor's stressed the loans in the pool according to its
current criteria. "The resultant credit enhancement levels are
consistent with our rating actions," S&P said.

Ratings Lowered - Pooled Certificates

Morgan Stanley Capital I Trust 2007-TOP27
Commercial mortgage pass-through certificates

               Rating
Class        To          From       Credit enhancement (%)
A-M         A- (sf)     A (sf)                       17.03
A-MFL       A- (sf)     A (sf)                       17.03
A-J         BB (sf)     BBB (sf)                      9.82
B           BB- (sf)    BBB- (sf)                     7.76
C           B+ (sf)     BB+ (sf)                      6.60
D           B (sf)      BB (sf)                       5.44
E           B- (sf)     BB- (sf)                      4.54
F           CCC+ (sf)   B+ (sf)                       3.64

Ratings Affirmed - Pooled Certificates

Morgan Stanley Capital I Trust 2007-TOP27
Commercial mortgage pass-through certificates

Class       Rating              Credit enhancement (%)
A-1         AAA (sf)                             27.32
A-2         AAA (sf)                             27.32
A-3         AAA (sf)                             27.32
A-AB        AAA (sf)                             27.32
A-4         AAA (sf)                             27.32
A-1A        AAA (sf)                             27.32
G           CCC- (sf)                             2.48
X           AAA (sf)                               N/A

Rating Affirmed - Nonpooled Certificates

Morgan Stanley Capital I Trust 2007-TOP27

Class      Rating
AW34       AAA

N/A -- Not applicable.


MORGAN STANLEY: S&P Lowers Ratings on 3 Classes of Certs. to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 13
classes of commercial mortgage pass-through certificates from
Morgan Stanley Capital I Trust 2006-HQ8, a U.S. commercial
mortgage-backed securities (CMBS) transaction. "Concurrently, we
affirmed our 'AAA (sf)' ratings on five other classes from the
same transaction," S&P related.

"Our rating actions primarily reflect our analysis of the
transaction using our U.S. CMBS conduit/fusion criteria. Our
analysis included a review of the credit characteristics of all of
the remaining assets in the pool, the transaction structure, and
the liquidity available to the trust. The downgrades reflect
credit support erosion that we anticipate will occur upon
the eventual resolution of 28 ($303.3 million, 13.0%) of the 29
($307.2 million, 13.2%) assets that are with the special servicer
and two loans ($22.2 million, 1.0%) that we determined to be
credit-impaired. We also considered the monthly interest
shortfalls that are affecting the trust and the potential
additional interest shortfalls associated with the specially
serviced assets. We lowered our ratings on classes K, L, and M to
'D (sf)' because we expect interest shortfalls to continue and
believe the accumulated interest shortfalls will remain
outstanding for the foreseeable future," S&P said.

The affirmed ratings on the principal and interest certificates
reflect subordination and liquidity support levels that are
consistent with the outstanding ratings. "We affirmed our 'AAA
(sf)' rating on the class X interest-only (IO) certificate based
on our current criteria," S&P related.

"Using servicer-provided financial information, we calculated
an adjusted debt service coverage (DSC) of 1.31x and a loan-to-
value (LTV) ratio of 105.6%. We further stressed the loans' cash
flows under our 'AAA' scenario to yield a weighted average DSC
of 0.90x and an LTV ratio of 143.0%. The implied defaults and
loss severity under the 'AAA' scenario were 84.2% and 37.7%.
The DSC and LTV calculations noted above exclude four defeased
loans ($9.9 million, 0.4%), 28 ($303.3 million, 13.0%) of the
transaction's 29 ($307.2 million, 13.2%) assets with the special
servicer and two loans ($22.2 million, 1.0%) that we determined
to be credit-impaired. We separately estimated losses for these
specially serviced and credit-impaired assets and included them in
our 'AAA' scenario implied default and loss severity figures," S&P
said.

As of the Oct. 17, 2011 trustee remittance report, the trust
experienced monthly interest shortfalls totaling $232,983
primarily related to appraisal subordinate entitlement reduction
(ASER) amounts of $351,117, special servicing fees of $47,965, and
interest not advanced due to a nonrecoverable determination of
$21,765. The monthly interest shortfalls were offset this period
by ASER recoveries totaling $189,608. "The interest shortfalls
affected all classes subordinate to and including class L. Classes
K, L, and M has had accumulated interest shortfalls outstanding
between three and four months, and we expect the accumulated
interest shortfalls to remain outstanding in the near term.
Consequently, we lowered our ratings on these classes to 'D
(sf)'," S&P related.

                     Credit Considerations

As of the Oct. 17, 2011, trustee remittance report, 29
($307.2 million, 13.2%) assets in the pool were with the
special servicer, C-III Asset Management LLC (C-III). The
reported payment status of the specially serviced assets as
of the October 2011 trustee remittance report was: five are real
estate owned (REO; $34.8 million, 1.5%), seven ($86.0 million,
3.7%) are in foreclosure, 12 ($57.8 million, 2.5%) are 90-plus-
days delinquent, one is 60 days delinquent ($5.5 million, 0.2%),
three ($61.9 million, 2.7%) are 30 days delinquent, and one
($61.2 million, 2.6%) is less than 30 days delinquent. Appraisal
reduction amounts (ARAs) totaling $84.8 million are in effect for
19 of the specially serviced assets. Details of the three largest
specially serviced assets, two of which are top 10 assets, are:

The Marketplace at Northglenn loan ($61.2 million, 2.6%) is the
fifth-largest asset in the pool and the largest asset with the
special servicer. The total reported exposure for this loan is
$61.5 million. The loan is secured by a retail shopping center
totaling 439,273 sq. ft. in Northglenn, Colo. The loan was
transferred to C-III on Aug. 31, 2011, due to imminent default.
The reported payment status of the loan is less than 30 days
delinquent.

According to C-III, the borrower proposed a deed-in-lieu of
foreclosure to avoid further funding of debt service shortfalls.
The reported DSC as of year-end 2010 was 1.0x, and occupancy was
91.0% according to the May 2011 rent roll. "We expect a moderate
loss upon the eventual resolution of this loan," S&P related.

The Roseville Portfolio - Roll-Up loan ($42.2 million, 1.8%) is
the seventh-largest asset in the pool and the second-largest asset
with the special servicer. The loan consists of three cross-
collateralized and cross-defaulted loans with a total reported
exposure of $50.0 million. The loan is secured by an 110,381-sq.-
ft. office building and two retail properties totaling 101,612 sq.
ft. in Roseville, Calif. The loan was transferred to C-III on Dec.
29, 2008, due to payment default. The reported payment status of
the loan is in foreclosure. According to C-III, the borrower
is in bankruptcy and has requested a deed-in-lieu of foreclosure.
No recent financial data is available for this loan. An ARA of
$26.4 million is in effect against this loan. Based on the most
recent appraisal, we expect a significant loss upon the eventual
resolution of this loan," S&P said.

The Centre Properties Portfolio - Roll-up loan ($35.2 million,
1.5%) is the 11th-largest asset in the pool and the third-largest
asset with the special servicer. The loan consists of five cross-
collateralized and cross-defaulted loans with a total reported
exposure of $35.6 million. The loan is secured by a portfolio of
five retail properties totaling 244,983 sq. ft. in Indianapolis,
Ind. The asset was transferred to C-III on June 1, 2011, due to
payment default. The reported payment status of the loan is 30
days delinquent. C-III indicated that the borrower is currently
revising a loan modification proposal. The reported DSC as of
year-end 2010 was 0.81x. "Based on the most recent appraisal and
broker's opinion of value, we expect a significant loss upon the
eventual resolution of this loan," S&P stated.

The remaining 26 specially serviced assets have balances that
individually represent less than 1.1% of the total pool balance.
ARAs totaling $58.4 million are in effect against 18 of these
assets. "We estimated losses for 25 of these assets, arriving at a
weighted-average loss severity of 52.4%. The remaining loan was
recently transferred to C-III, which stated that it is
currently evaluating various workout strategies," S&P stated.

"In addition to the specially serviced assets, we determined
two loans ($22.2 million, 1.0%) to be credit-impaired due
primarily to low reported DSCs; they also have payment statuses
of  less-than-30 days delinquent. The Hanover Portfolio - Roll-up
loan ($15.5 million, 0.7%) consists of three cross-collateralized
and cross-defaulted loans. The loan is secured by two retail
properties totaling 92,961 sq. ft. and a 42,550-sq.-ft. office
building in Hanover, Mass. The loan, which has reported less
than 30 days delinquent status, appears on the master servicer's
watchlist due to a low reported combined DSC, which was 0.85x as
of year-end 2010. The other loan, the Alum Rock Self Storage loan
($6.7 million, 0.3%), is secured by a 59,140-sq.-ft. self-storage
property in San Jose, Calif. The loan is on the master servicer's
watchlist because the borrower has not provided correct financial
data for 2009 and 2010. As a result, we view both loans to be at
an increased risk of default and loss," S&P said.

                         Transaction Summary

As of the Oct. 17, 2011 trustee remittance report, the total pool
balance was $2.3 billion, which is 85.1% of the pool balance at
issuance. The pool includes 242 loans and five REO assets, down
from 268 loans at issuance. The master servicer, Wells Fargo Bank
N.A. (Wells Fargo), provided financial information for 94.6% of
the assets in the pool, the majority of which was full-year 2010
data (92.1%), with the remainder reflecting partial- or
full-year 2009, 2010, or 2011 data.

"We calculated a weighted average DSC of 1.26x for the assets in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.31x and 105.6%. Our adjusted DSC and LTV
figures excluded four defeased loans ($9.9 million, 0.4%), 28
($303.3 million, 13.0%) of the transaction's 29 ($307.2 million,
13.2%) specially serviced assets, and two loans ($22.2 million,
1.0%) that we determined to be credit-impaired. We separately
estimated losses for the specially serviced and credit-impaired
assets and included them in our 'AAA' scenario implied default
and loss severity figures. If we include the specially serviced
assets in our calculation, our adjusted DSC and LTV ratio would
have been 1.29x and 108.1%. The transaction has experienced
$22.1 million in principal losses from eight assets. Eighty-
eight loans ($604.7 million, 26.0%) in the pool are on the
master servicer's watchlist. Fifty-five loans ($720.0 million,
31.0%) have a reported DSC of less than 1.10x, 34 of which
($445.7 million, 19.2%) have a reported DSC of less than 1.00x,"
S&P related.

                    Summary of Top 10 Assets

The top 10 assets have an aggregate outstanding balance of
$721.0 million (31.0%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.05x for eight of the top 10
assets. The two remaining top 10 assets ($103.4 million, 4.4%) are
with the special servicer. "Our adjusted DSC and LTV ratio for
eight of the top 10 assets were 1.15x and 120.0%. Two of the top
10 assets ($134.4 million, 5.8%) are on the master servicer's
watchlist," S&P related. Details of the two loans on the master
servicer's watchlist and two other top 10 assets ($242.5 million,
10.4%) that have a reported DSC below 1.0x are:

The Ritz-Carlton Portfolio - Roll-up loan ($172.8 million, 7.4%)
is the largest asset in the pool. The loan currently consists of
four cross-collateralized and cross-defaulted loans and is secured
by four full-service hotel properties totaling 945 rooms in New
York City and Washington, D.C. The reported combined DSC and
occupancy for year-end 2010 were 0.57x and 71.7%.

The Flournoy Portfolio - Roll-up loan ($94.2 million, 4.1%),
the third-largest asset in the pool, consists of four cross-
collateralized and cross-defaulted loans. The loan is secured by
four garden-style apartment complexes totaling 1,397 units in
Texas, Kansas, and Tennessee. Three of the four loans, totaling
$73.8 million (3.2%), are on Wells Fargo's watchlist due to a low
reported DSC. The reported combined DSC and occupancy were 1.06x
and 92.6% for year-end 2010.

The Crossroads Logistics Portfolio - Roll-up loan ($69.7 million,
3.0%), the fourth-largest asset in the pool and consists of four
cross-collateralized and cross-defaulted loans. The loan is
secured by four industrial/warehouse properties totaling
2.6 million sq. ft. in various cities in Indiana. The reported
combined DSC and occupancy for the four properties were 0.52x
and 65.8% for year-end 2010.

The Allstate Charlotte & Roanoke - Roll-up loan ($40.2 million,
1.7%), the eighth-largest asset in the pool, consists of two
cross-collateralized and cross-defaulted loans. The loan is
secured by two suburban office properties totaling 357,489 sq.
ft. in Roanoke, Va., and Charlotte, N.C. The loan appears on the
master servicer's watchlist due to deferred maintenance items
noted for the property in Roanoke. The reported combined DSC and
occupancy for the two properties were 1.28x and 100% for year-end
2010.

Standard & Poor's stressed the assets in the pool according to its
current criteria. "The resultant credit enhancement levels are
consistent with our lowered and affirmed ratings," S&P related.

Ratings Lowered

Morgan Stanley Capital I Trust 2006-HQ8
Commercial mortgage pass-through certificates

                Rating
Class      To           From        Credit enhancement (%)
A-M        A (sf)       A+ (sf)                      22.28
A-J        BB+ (sf)     BBB+ (sf)                    13.76
B          BB (sf)      BBB (sf)                     13.02
C          B+ (sf)      BBB- (sf)                    11.26
D          B (sf)       BB+ (sf)                      9.79
E          B- (sf)      BB (sf)                       9.21
F          CCC+ (sf)    BB- (sf)                      8.18
G          CCC (sf)     B+ (sf)                       7.00
H          CCC (sf)     B+ (sf)                       5.39
J          CCC- (sf)    B (sf)                        4.21
K         D (sf)        CCC+ (sf)                     3.04
L         D (sf)        CCC- (sf)                     2.45
M         D (sf)        CCC- (sf)                     2.01

Ratings Affirmed

Morgan Stanley Capital I Trust 2006-HQ8
Commercial mortgage pass-through certificates

Class    Rating                      Credit enhancement (%)
A-3      AAA (sf)                                    34.02
A-AB     AAA (sf)                                    34.02
A-4      AAA (sf)                                    34.02
A-1A     AAA (sf)                                    34.02
X        AAA (sf)                                      N/A

N/A -- Not applicable.


MSC 2006-HQ10: Moody's Affirms Ratings of 18 CMBS Classes
---------------------------------------------------------
Moody's Investors Service (Moody's) affirmed these ratings of 18
classes of Morgan Stanley I Trust 2006-HQ10 Commercial Mortgage
Pass-Through Certificates, Series 2006-HQ10:

Cl. A-2, Affirmed at Aaa (sf); previously on November 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on November 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on November 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4FL, Affirmed at Aaa (sf); previously on November 30, 2006
Assigned Aaa (sf)

Cl. A-4FX, Affirmed at Aaa (sf); previously on March 31, 2010
Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on November 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aa2 (sf); previously on December 17, 2010
Downgraded to Aa2 (sf)

Cl. A-J, Affirmed at Baa3 (sf); previously on December 17, 2010
Downgraded to Baa3 (sf)

Cl. B, Affirmed at Ba3 (sf); previously on December 17, 2010
Downgraded to Ba3 (sf)

Cl. C, Affirmed at B3 (sf); previously on December 17, 2010
Downgraded to B3 (sf)

Cl. D, Affirmed at Caa2 (sf); previously on December 17, 2010
Downgraded to Caa2 (sf)

Cl. E, Affirmed at Caa3 (sf); previously on December 17, 2010
Downgraded to Caa3 (sf)

Cl. F, Affirmed at Ca (sf); previously on December 17, 2010
Downgraded to Ca (sf)

Cl. G, Affirmed at C (sf); previously on December 17, 2010
Downgraded to C (sf)

Cl. H, Affirmed at C (sf); previously on December 17, 2010
Downgraded to C (sf)

Cl. J, Affirmed at C (sf); previously on December 17, 2010
Downgraded to C (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on November 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on November 30, 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.

Moody's rating action reflects a cumulative base expected loss of
8.1% of the current balance. At last review, Moody's cumulative
base expected loss was 9.9%. Moody's stressed scenario loss is
18.0% of the current balance. At last review, Moody's cumulative
base expected loss plus realized losses was10.2% compared to 10.6%
at this review. Depending on the timing of loan payoffs and the
severity and timing of losses from specially serviced loans, the
credit enhancement level for investment grade classes could
decline below the current levels. If future performance materially
declines, the expected level of credit enhancement and the
priority in the cash flow waterfall may be insufficient for the
current ratings of these classes.

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 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
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 30 compared to 33 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 December 17, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 12% to $1.31
billion from $1.49 billion at securitization. The Certificates are
collateralized by 118 mortgage loans ranging in size from less
than 1% to 9% of the pool, with the top ten non-defeased loans
representing 45% of the pool. One loan, representing 5% of the
pool, has defeased and is secured by a U.S. Government security.
Defeasance at last review represented 0% of the pool. The pool
contains three loans with investment grade credit estimates,
representing 15% of the pool.

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

Ten loans have been liquidated from the pool, resulting in a
realized loss of $37.5 million (59% loss severity on average).
Currently thirteen loans, representing 12% of the pool, are in
special servicing. The largest specially serviced loan is the
Kings Crossing Shopping Centre Loan ($36.5 million -- 2.8% of the
pool), which is secured by a 272,136 square foot retail center
located in Shreveport, Louisiana. The loan was transferred to
special servicing in September 2009 due to imminent payment
default. Foreclosure was filed in December 2009 and a receiver was
appointed in July 2010. Discussions with the borrower are ongoing.
The master servicer has recognized a $12.8 million appraisal
reduction for this property.

The remaining twelve specially serviced properties are secured by
a mix of property types. Moody's estimates an aggregate $43.6
million loss for the specially serviced loans (36% expected loss
on average).

Moody's has assumed a high default probability for 16 poorly
performing loans representing 14% of the pool and has estimated an
aggregate $32.1 million loss (18% expected loss based on a 38%
probability default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 99%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 110% compared to 113% at Moody's
prior 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 9.2%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.23X and 0.96X, respectively, compared to
1.25X and 0.95X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the Waterside Shops
Loan ($120 million -- 9.2% of the pool), which is secured by a
265,664 square foot regional mall located in Naples, Florida. The
center is anchored by Nordstrom, Saks Fifth Avenue, and Barnes &
Noble. As of July 2011, the property was 99% leased; the same as
at the prior review and securitization. Inline sales as of June
2011 were $678 psf compared to $635 at last review and $658 at
securitization. The most recent reported NOI has decreased since
the prior review due to an increase in repairs and maintenance
expenses and ongoing legal fees associated with renovations at the
property in 2006. Overall, the property is stable and Moody's
credit estimate and stressed DSCR are Baa3 and 1.08X,
respectively, compared to Baa3 and 1.14X at last review.

The second loan with a credit estimate is the Sony Pictures Plaza
Loan ($48.7 million -- 3.7% of the pool), which is secured by a
328,847 square foot office building located in Culver City,
California. The property is 100% leased to Sony Pictures
Entertainment through 2027. The loan is stable and has benefitted
from amortization. Moody's credit estimate and stressed DSCR are
Baa1 and 1.70X, respectively, compared to Baa2 and 1.67X at last
review.

The third loan with a credit estimate is the Cherry Creek Shopping
Center Loan ($30 million -- 2.3% of the pool), which is a 11%
pari-passu interest in a first mortgage loan secured by the
borrower's interest in a 547,457 square foot regional mall located
in Denver, Colorado. The property is anchored by Neiman Marcus,
Saks Fifth Avenue, Macy's and Nordstrom. The property was 94%
leased as of December 2010 compared to 92% at last review and 97%
at securitization. Moody's credit estimate and stressed DSCR are
Baa2 and 1.20X, respectively, compared to Baa2 and 1.22X at last
review.

The top three performing conduit loans represent 19% of the pool
balance. The largest loan is the PPG Portfolio Loan ($104 million
-- 7.9% of the pool), which is secured by seven cross-
collateralized and cross-defaulted office properties located in
Arizona, Colorado, and Indiana. As of December 2010, the portfolio
was 87% leased; the same as at last review. Portfolio performance
has improved due to rent bumps from existing tenants. Moody's LTV
and stressed DSCR are 116% and 0.84X, respectively, compared to
134% and 0.77X at securitization.

The second largest loan is the AZ Office/Retail Portfolio Loan
($72 million -- 5.5% of the pool), which is secured by three
mixed use (retail and office) properties located in Scottsdale,
Arizona. As of June 2011, the properties were 80% leased compared
to 77% at last review and 84% at securitization. The borrower
has successfully signed multiple leases since the prior review.
Moody's has assumed a high default probability for this loan.
Moody's LTV and stressed DSCR are 183% and 0.59X, respectively,
compared to 188% and 0.58X at securitization.

The third largest loan is the Shops at Briargate Loan
($71.4 million -- 5.4% of the pool), which is secured by a
225,922 luxury lifestyle center located in Colorado Springs,
Colorado. The property was 95% leased as of March 2011 compared
to 96% at securitization. The loan is on the watchlist due low
DSCR caused by the borrower providing a rental credit to many
of the poorly performing tenants. The rental credit negatively
impacted NOI at the property but the issue has been remedied
ever since. Moody's LTV and stressed DSCR are 140% and 0.69X,
respectively, compared to 125% and 0.78X at securitization.


MSC 2007-TOP25: Moody's Reviews Ratings for Possible Downgrade
--------------------------------------------------------------
Moody's Investors Service (Moody's) placed seven classes of
Morgan Stanley Capital I Trust, Commercial Mortgage Pass-Through
Certificates, Series 2007-TOP25 on review for possible downgrade:

Cl. A-M, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Nov 18, 2010 Downgraded to Aa1 (sf)

Cl. A-J, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Nov 18, 2010 Downgraded to Baa3 (sf)

Cl. B, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Nov 18, 2010 Downgraded to B2 (sf)

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

Cl. D, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Nov 18, 2010 Downgraded to Caa3 (sf)

Cl. E, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Nov 18, 2010 Downgraded to Ca (sf)

Cl. F, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Nov 18, 2010 Downgraded to Ca (sf)

RATINGS RATIONALE

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (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

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

DEAL PERFORMANCE AND SUMMARY

As of the October 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 4.6% to
$1.48 billion from $1.55 billion at securitization. The
Certificates are collateralized by 197 mortgage loans ranging
in size from less than 1% to 6% of the pool, with the top ten
non-defeased loans representing 28% of the pool.

Fifty-four loans, representing 26% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (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.

Four loans have been liquidated from the pool, resulting in a
realized loss of $10.5 million (75.8% loss severity). Currently
six loans, representing 5.5% of the pool, are in special
servicing. The largest specially serviced loan is the Village
Square Loan ($59.6 million -- 4% of the pool), which is secured by
a 238,000 square foot (SF) mixed use office and retail property,
located in Las Vegas Nevada. The loan was transferred to special
servicing in February 2009 due to payment default. The property"s
performance has been hurt by the increased vacancy as well as a
decline in rental achievement. The loan is currently real estate
owned (REO) and is currently under contract with an anticipated
sale in mid November.

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


NATIONAL COLLEGIATE: Fitch Holds Rating on Subor. Notes at 'CCsf'
-----------------------------------------------------------------
Fitch Ratings affirms the ratings on the National Collegiate Trust
2006-A student loan asset-backed notes (NCT 2006-A).  The Rating
Outlook has been revised to Stable from Negative for the senior
notes.  Fitch's Global Structured Finance Rating Criteria and
Private Student Loan Asset-Backed Securities (ABS) Criteria were
used to review the transaction.  The rating action is detailed at
the end of this press release.

The calculated loss coverage multiple for the NCT 2006-A notes is
sufficient to support a 'A-sf' rating on the senior notes and
'CCsf' rating on the subordinate notes, which was calculated using
collateral performance data as of Sept. 30, 2011.  The collateral
performance data reported senior parity to be 121.83% and total
parity 95.03%. T he Rating Outlook for the senior notes has been
revised to Stable as senior parity continues to rise and excess
spread is positive.

A loss coverage multiple was determined by comparing a projected
net loss amount to available credit enhancement.  Fitch used
historical vintage loss data provided by First Marblehead
Corporation to form a loss timing curve.  After giving credit for
seasoning of loans in repayment, Fitch applied the trust's current
cumulative gross loss level to this loss timing curve to derive
the expected gross losses over the projected remaining life.  A
recovery rate was applied, which was determined to be appropriate
based on the latest data provided by the issuer.  Credit
enhancement consists of excess spread and a general reserve
account, while the senior notes benefit from subordination
provided by the class B notes.  Fitch derived excess spread from
the most recent information provided by First Marblehead
Corporation and applied that same rate over the stressed
projection of remaining life.

The collateral supporting NCT 2006-A notes consists entirely of
private student loans originated by First Marblehead Corporation,
which is not rated by Fitch.  The private student loans are
serviced by Pennsylvania Higher Education Assistance Agency
(PHEAA), Great Lakes Education Loan Services, Inc., ACS Education
Services, Inc., and FirstMark Loan Services, Inc, all of which are
not rated by Fitch.  Although Fitch does not explicitly rate the
above-referenced servicers, Fitch considers their servicing
ability to be satisfactory.  Loan proceeds are used by students to
assist in financing the cost of attending undergraduate, law
school, business school, medical school, dental school, and other
graduate programs.

Fitch has taken these rating actions:

National Collegiate Trust 2006-A Student Loan Asset-Backed Notes:

  -- Senior class A-2 affirmed at 'A-sf'; Outlook revised to
     Stable from Negative;

  -- Subordinate class B affirmed at 'CCsf'.


NAVIGATOR CDO: S&P Raises Ratings on 2 Classes of Notes to 'B+'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1A, A-1B, A-2, B-1, B-2, C-1, and C-2 notes from Navigator CDO
2005 Ltd. "At the same time, we withdrew our rating on the class
Q-7 notes. Navigator CDO 2005 Ltd. is a collateralized
loan obligation (CLO) transaction managed by GE Capital Debt
Advisors LLC," S&P related.

"The upgrades reflect the improved performance we have observed
in the deal since our last rating action in March 2010. According
to the Sept. 3, 2011, trustee report, the transaction held
$13.2 million in defaulted assets and $32.7 million in assets
rated 'CCC', down from $27.9 million in defaulted assets and
$62.5 million in assets rated 'CCC' as of the Jan. 8, 2010,
trustee report," S&P related.

The transaction has also benefited from an increase in
overcollateralization (O/C) available to support the rated
notes. The trustee reported these principal coverage tests in
the Sept. 3, 2011 trustee report:

    The class A test was 126.66%, compared with a reported test of
    120.14% in January 2010;

    The class B test was 115.59%, compared with a reported test of
    110.62% in January 2010; and

    The class C test was 109.24%, compared with a reported test of
    104.33% in January 2010.

"We withdrew the ratings on the class Q-7 notes following the
class' full repayment," S&P said.

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

Rating Actions

Navigator CDO 2005 Ltd.
                       Rating
Class               To           From
A-1A                AAA (sf)     AA+ (sf)
A-1B                AAA (sf)     AA+ (sf)
A-2                 AA+ (sf)     A+ (sf)/Watch Pos
B-1                 BBB (sf)     BB+ (sf)/Watch Pos
B-2                 BBB (sf)     BB+ (sf)/Watch Pos
C-1                 B+ (sf)      CCC- (sf)/Watch Pos
C-2                 B+ (sf)      CCC- (sf)/Watch Pos
Q-7                 NR (sf)      CCC- (sf)/Watch Pos


NYCTL 2011-A: Moody's Assigns Provisional Rating to Bonds
---------------------------------------------------------
Moody's Investors Service has assigned a provisional rating of
(P)Aaa (sf) to the Class A tax lien collateralized bonds to be
issued by NYCTL 2011-ATrust, sponsored by The City of New York
(Aa2). The transaction is collateralized by first priority liens
on residential and commercial properties located in the five
boroughs of New York City arising out of delinquent property
taxes, water and sewer charges and other municipal charges. The
creation and sale of these assets is governed by legislation (the
New York City Administrative Code) under which The City of New
York has the ability to create and sell tax liens, which liens
generally speaking prime mortgage liens and judgment liens.

The complete rating action is:

Issuer: NYCTL 2011-A Trust

$69,748,,000 of Fixed Rate Class A Tax Lien Collateralized Bonds
maturing on December 10, 2024, and rated (P)Aaa (sf)

RATING RATIONALE

The provisional rating of (P)Aaa is based primarily on (1) the
credit quality of the underlying collateral with weighted average
lien-to-value ratio of 18.68% with 42.54% of the pool carrying
lien to values of greater than 10.00% (Lien to value is defined as
the sum of the tax lien redemptive value plus any subsequent tax
liens and any parri passu tax liens, divided by the full value of
the property as estimated by and reflected on the records of the
Department of Finance of the City of New York as of January 1,
2011.), (2) the historical performance of New York City tax lien
collateral securitized in the past with stable redemption patterns
and low frequency of charge-offs, (3) the level of credit support
provided by overcollateralization totaling 38% (as a % of the pool
of securitized liens) plus excess spread, (4) the ability of New
York City as seller of the collateral to honor its representations
and warranties including the obligation to repurchase defective
liens; (5) the full turbo structural feature permitting no cash
outflow to the residual holder until the rated bonds are fully
paid off, (6) the level of liquidity support provided by the
Interest Reserve Fund and the Working Capital Reserve Fund, as
supplemented by limited advancing by the Indenture Trustee, (7)
the expertise and experience of Plymouth Park Tax Services, LLC
(dba "Xspand," a wholly-owned subsidiary of JPMorgan Chase) and
MTAG Services, LLC, as servicers, to foreclose, manage and
liquidate the underlying real estate properties including
distressed and bankrupt properties, (8) the responsibility of the
Indenture Trustee to act as the successor servicer, and (9) the
integrity of the transaction's legal structure which reduces the
probability of a bankruptcy proceeding by or against the issuing
entity and thus provides comfort that the underlying collateral
will be readily available to support debt repayment.

COLLATERAL SUMMARY

The tax liens arise out of delinquent property taxes, water and
sewer charges and other municipal charges of The City of New York,
and these liens generally prime mortgage and judgment liens. The
collateral pool backing this transaction is moderately weaker than
the most recently closed transaction (i.e. NYCTL 2010-A Trust).
The weighted average lien-to-value for this asset pool is 18.68%
with only 42.54% of the pool having lien to values of greater than
10.00% and 6.09% of the pool having lien-to-values of greater than
50.00%. This compares unfavorably to the last transaction which
had a weighted average lien-to-value of 8.17% and 28.78% of the
pool with lien-to-values of greater than 10.00%, and 0.54% of the
pool with lien-to-values greater than 50.00%. The geographic
distribution of the assets in this deal compares slightly less
favorably relative to the last transaction. There are less tax
liens relating to real estate in Manhattan (approximately 16.81%
by dollar balance vs. 19.87% for 2010-A) and more tax liens
relating to real estate in Bronx (approximately 15.04% vs. 13.86%
for 2010-A); The distribution of this asset pool along the
property types is also slightly weaker than that in the most
recent transaction, primarily as a result of more vacant land
properties (approximately 11.42% vs. 6.60% for 2010-A), which
tends to perform worse than other types properties based on
historical data. The 2011-A pool has similar concentration (44%)
in tax liens secured by commercial properties may have somewhat
greater risk as a result of longer potential liquidation
timelines, greater potential for environmental risk exposure and
higher likelihood of property owners seeking bankruptcy
protection, which can further lengthen asset liquidation timing as
well as possibly result in adjustments to the amount owed by the
property owner under the tax lien obligation.

The value of the property as reflected on the records of the
Department of Finance of the City of New York (DFNYC) is used for
all lien-to-value computations. This creates exposure to the
sponsor since these are not necessarily as accurate or reliable
as, 3rd party appraised values. However in Moody's view the DFNYC
has developed a thorough system for determining and periodically
updating property values. The system relies on a combination of
comparables, models, property specific data and site visits.

CREDIT ENHANCEMENTS

Credit enhancement is in the form of 38% of overcollateralization
and excess spread. The transaction also benefits from available
liquidity support provided by an interest reserve fund cash-funded
at closing with a required balance equal to the lesser of three
months of interest on the initial bond balance or six months of
interest on the current bond balance, a working capital reserve
fund cash-funded at closing with a required balance of $5.25
million, and advancing by The Bank of New York Mellon(Aaa) as the
Indenture Trustee with a cap at any time of not to exceed the
lesser of $9 million or 10% of the then current aggregate tax lien
principal balance.

PRINCIPAL RATING METHODOLOGY

Moody's believes that lien-to-value is the primary indicator of
the property owner's willingness to redeem the tax lien
certificate. In general, high lien-to-value properties are more
risky than low lien to value properties as recovery rates may be
higher for low lien to value properties, other things being the
same. Consistent with that view, in Moody's methodology, Moody's
first assumes that tax liens related to properties with a lien-to-
value in excess of the threshold of 10% provide a proxy for the
amount of unredeemable collateral under scenarios commensurate
with the Aaa desired rating level. Therefore the portion of the
liens with lien to value greater than 10% is the initial basis for
being indicative of the appropriate credit support level for the
desired (P)Aaa (sf) rating. Judgmental adjustment factors are then
applied to determine the final enhancement level based on other
important collateral performance characteristics. These judgmental
adjustment factors include the following: current and expected
trends in real estate values; exposure to the repurchase
obligations of the sponsor for defective tax liens and the history
of repurchase volumes in prior deals; tax lien pool composition as
compared to prior pools; exposure to uncertain recovery expenses
and the history of recovery expenses in prior deals; and expected
excess interest vs. the uncertainty of the time when a tax lien
will be redeemed post closing. Moody's also considers the
redemption curves for past securitizations provided to us. In
particular, an average monthly redemption curve is derived based
on all those transactions and then a cumulative redemption curve
based on the monthly average monthly redemption curve is derived.
The cumulative average redemption curve provides an estimate of
the percentage of the pool that will be redeemed within a 7-10
year horizon. For the remaining balance yet to be redeemed,
Moody's applies a haircut and use this result as a proxy for
expected loss on the pool. The expected loss on the pool is
considered when estimating the total credit enhancement for the
target rating taking into consideration the volatility in the
losses. As an additional check, Moody's uses an alternative
approach to determining credit support for the desired rating.
Moody's applies certain property-specific haircuts by property
type (ranging between 45% and 65%) to the property values provided
to Moody's by the deal's sponsor. This results in a Moody's
adjusted lien-to-value for the assets, with the percentage of
assets below certain threshold translating into an indicative
credit support level given the desired rating.

The ratings on the securities are modestly exposed to the rating
of The City of New York primarily due to their liability to
repurchase of defective assets. Due to matters ranging from
administrative error to tax payer litigation, the sponsor
historically has repurchased pursuant to requirements, amounts
ranging up to 7% of the transaction balance. The enhancement level
incorporates this exposure but does not completely eliminate the
risk of sponsor repurchase default. Other methodologies and
factors that may have been considered in the process of rating
this issue can also be found in the Rating Methodologies sub-
directory on Moody's website.

MOODY'S V-SCORES & PARAMETER SENSITIVITIES

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

Moody's Parameter Sensitivities: If the property value underlying
the determination of the initial rating were changed by 25.0%,
40.0%, or 65.0%, the initial model-indicated rating for the Class
A notes might change from Aaa to Aa1, Aa3, and B2, respectively.

Parameter Sensitivities are not intended to measure how the rating
of the security might migrate over time, rather they are designed
to provide a quantitative calculation of how the initial rating
might change if key input parameters used in the initial rating
process differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.


OHA INTERPID: S&P Affirms 'BB' Rating on Class E Deferrable Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on OHA
Intrepid Leveraged Loan Fund Ltd./OHA Intrepid Leveraged Loan Fund
Inc.'s $364.0 million floating-rate notes following the
transaction's effective date as of Aug. 1, 2011.

Most U.S. cash flow collateralized debt obligations (CLOs) close
before purchasing the full amount of their targeted level of
portfolio collateral. On the closing date, the collateral manager
typically covenants to purchase the remaining collateral within
the guidelines specified in the transaction documents to reach the
target level of portfolio collateral. Typically, the CLO
transaction documents specify a date by which the targeted level
of portfolio collateral must be reached. The "effective date" for
a CLO transaction is usually the earlier of the date on which the
transaction acquires the target level of portfolio collateral, or
the date defined in the transaction documents. Most transaction
documents contain provisions directing the trustee to request the
rating agencies that have issued ratings upon closing to affirm
the ratings issued on the closing date after reviewing the
effective date portfolio (typically referred to as an "effective
date rating affirmation").

"An effective date rating affirmation reflects our opinion that
the portfolio collateral purchased by the issuer, as reported to
us by the trustee and collateral manager, in combination with the
transaction's structure, provides sufficient credit support to
maintain the ratings that we assigned on the transaction's closing
date. The effective date reports provide a summary of certain
information that we used in our analysis and the results of our
review based on the information presented to us," S&P related.

"We believe the transaction may see some benefit from allowing a
window of time after the closing date for the collateral manager
to acquire the remaining assets for a CLO transaction. This window
of time is typically referred to as a 'ramp-up period.' Because
some CLO transactions may acquire most of their assets from the
new issue leveraged loan market, the ramp-up period may give
collateral managers the flexibility to acquire a more diverse
portfolio of assets," S&P said.

"For a CLO that has not purchased its full target level of
portfolio collateral by the closing date, our ratings on the
closing date and prior to our effective date review are generally
based on the application of our criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to us by the
collateral manager, and may also reflect our assumptions about the
transaction's investment guidelines. This is because not all
assets in the portfolio have been purchased," S&P related.

"When we receive a request to issue an effective date rating
affirmation, we perform quantitative and qualitative analysis of
the transaction in accordance with our criteria to assess whether
the initial ratings remain consistent with the credit enhancement
based on the effective date collateral portfolio. Our analysis
relies on the use of CDO Evaluator to estimate a scenario default
rate at each rating level based on the effective date portfolio,
full cash flow modeling to determine the appropriate percentile
break-even default rate at each rating level, the application of
our supplemental tests, and the analytical judgment of a rating
committee. (For more information on our criteria and our
analytical tools, see 'Update To Global Methodologies And
Assumptions For Corporate Cash Flow And Synthetic CDOs,' published
Sept. 17, 2009.)," S&P said

"In our published effective date report, we discuss our analysis
of the information provided by the transaction's trustee and
collateral manager in support of their request for effective date
rating affirmation. In most instances, we intend to publish an
effective date report each time we issue an effective date rating
affirmation on a publicly rated U.S. cash flow CLO," S&P related.

"On an ongoing basis after we issue an effective date rating
affirmation, we will periodically review whether, in our view, the
current ratings on the notes remain consistent with the credit
quality of the assets, the credit enhancement available to support
the notes, and other factors, and take rating actions as we deem
necessary," S&P said.

Ratings Affirmed
OHA Intrepid Leveraged Loan Fund Ltd./OHA Intrepid Leveraged Loan
Fund Inc.

Class                Rating      Amount (mil. $)
A                    AAA (sf)             265.00
B                    AA (sf)               26.00
C (deferrable)       A (sf)                35.00
D (deferrable)       BBB (sf)              18.00
E (deferrable)       BB (sf)               20.00
Subordinated         NR                    49.00

NR -- Not rated.


PACIFIC SHORES: S&P Lowers Ratings on 2 Classes of Notes to 'CC'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
A, B-1, and B-2 notes from Pacific Shores CDO Ltd., a mezzanine
structured finance collateralized debt obligation (CDO) backed
predominately by residential mortgage-backed securities (RMBS)
and managed by Pacific Investment Management Co. LLC. "We removed
our rating on the class A notes from CreditWatch with negative
implications, and we affirmed our rating on class C notes," S&P
related.

"The rating actions reflect credit deterioration in the
transaction's underlying asset portfolio since we lowered the
ratings on the class B-1 and B-2 notes on Sept. 28, 2010," S&P
said.

"According to the Sept. 27, 2011, trustee report, the transaction
had $47.13 million in defaulted obligations. This was an increase
from the $40.73 million reported in the July 31, 2010, trustee
report, which we used for our September 2010 rating actions," S&P
said.

The transaction had paid the class A note balance down to $89.64
million as of September 2011 from $132.27 million as of July 2010.
Despite the reduced note balance, the coverage test ratios dropped
during the same time period. The trustee reported these
overcollateralization (O/C) ratios in the Sept. 27, 2011, monthly
report:

    The class A/B O/C ratio test was 90.10%, compared with a
    reported ratio of 93.68% in July 2010; and

    The class C O/C ratio test was 80.39%, compared with a
    reported ratio of 85.09% in July 2010.

"We affirmed our rating on the class C notes to reflect our belief
that the credit support available is commensurate with the current
rating," S&P related.

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

Rating Actions

Pacific Shores CDO Ltd.
             Rating
Class    To           From
A        BBB+ (sf)    AA- (sf)/Watch Neg
B-1      CC (sf)      CCC- (sf)
B-2      CC (sf)      CCC- (sf)

rating affirmed

Pacific Shores CDO Ltd.
Class    Rating
C        CC (sf)


PARCS-R MASTER: S&P Lowers Rating on Class Trust Unit to 'CC'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the two
classes from PARCS-R Master Trust's series 2007-15 and 2007-18.
Both are U.S. synthetic collateralized debt obligation (CDO)
retranche transactions.

"The rating on the trust unit from 2007-15 is directly linked to
the rating on the M-2 notes from RASC Series 2006-KS3 Trust (a
residential mortgage-backed securities {RMBS} subprime
transaction), which we lowered to 'CC (sf)' on Oct. 21, 2011. The
rating on the trust units from 2007-18 is directly linked to the
rating on the M-2 notes from Morgan Stanley ABS Capital I Inc.
Trust 2007-NC3 (a residential mortgage-backed securities {RMBS}
subprime transaction), which we lowered to 'D (sf)' on Oct. 21,
2011," S&P related.

Ratings Lowered

PARCS-R Master Trust Class 2007-15
                       Rating
Class            To         From
Trust unit       CC (sf)    CCC (sf)

PARCS-R Master Trust Class 2007-18
                       Rating
Class            To        From
Trust units      D (sf)    CCC (sf)


PIMA & TUCSON: Moody's Lowers Rating of Series 2007A-2 to Ba3
-------------------------------------------------------------
Moody's Investors Service has downgraded Pima and Tucson County,
AZ Industrial Development Authority Single Family Mortgage Revenue
Subordinate Bonds Series 2007A-2 from Ba1 to Ba3. The rating
action affects approximately $675,000 of outstanding debt and was
driven by poor loan portfolio performance and a review of cash
flows. The Ba3 rating remains under review for possible downgrade
while Moody's obtains and assess additional cash flow scenarios on
the program.

RATING RATIONALE

The bonds are being downgraded to Ba3 based on the poor
performance of the second mortgage loans which secure the bonds.
As of October 1, 2011, 11% of the loans originated have defaulted
and another 19% are delinquent. The performance of the loans has
deteriorated over the past year and the housing market in Pima and
Tucson remains weak.

The Ba3 rating remains under review for possible downgrade pending
assessment of additional cash flow scenarios which will measure
the impact of additional loan defaults on the financial
performance of the bonds. Moody's expects to complete its review
within 90 days.

The 2007 A-2 subordinate bonds were issued in conjunction with the
2007 A-1 senior bonds. The senior bonds are not affected by this
rating action and are rated Aaa.

STRENGTHS

* The subordinate bonds benefit from a fully funded debt service
reserve fund ($16,875) which is invested in a Transamerica (A1/P-
1) guaranteed investment contract, and eligible surplus funds from
both the senior and the subordinate bonds which, pursuant to the
Indenture, are directed to pay subordinate interest due and then
to redeem 2007A-2 bonds.

CHALLENGES

* Loan portfolio performance has deteriorated since 2010, as
evidenced by the portfolio's significant composition of delinquent
loans accompanied by an increase in defaults.

* Cash flows demonstrate a break-even loan loss of approximately
20% of current loans, or 40% of all outstanding loans, over a
three year period

WHAT COULD CHANGE THE RATING DOWN:

* High probability that projected loan losses will result in a
default on the bonds

* Debt service reserve fund is drawn down, or has a high
probability that it will be, in order to fulfill debt service
deficiencies

The principal methodology used in this rating was Moody's Rating
Approach For Single Family, Whole-Loan Housing Programs published
in May 1999.


PREFERREDPLUS TRUST: Moody's Raises Rating of 7.4% Certs to Ba2
---------------------------------------------------------------
Moody's Investors Service has upgraded the rating of these
certificates issued by PREFERREDPLUS Trust Series FRD-1:

PREFERREDPLUS 7.40% Trust Certificates, Upgraded to Ba2;
previously on October 10, 2011 Ba3 Placed on Review for Possible
Upgrade

RATINGS RATIONALE

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction. The rating action is a result of the change of the
rating of 7.40% Debentures due November 1, 2046 issued by Ford
Motor Company which were upgraded to Ba2 by Moody's on October 27,
2011.

The principal methodology used in this rating was "Moody's
Approach to Rating Repackaged Securities" published in April 2010.


PUBLIC STEERS: Moody's Raises Rating of $106.903-Mil. Notes to Ba2
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these
certificates issued by Public Steers Series 1998 F-Z4 Trust:

US$106,903,000 Initial Principal Amount Class A Trust
Certificates, Upgraded to Ba2; Previously on October 10, 2011 Ba3
Placed on Review for Possible Upgrade

US$125,000,000 Principal Amount at Maturity Class B Trust
Certificates, Upgraded to Ba2; Previously on October 10, 2011 Ba3
Placed on Review for Possible Upgrade

RATINGS RATIONALE

The transaction is a structured note whose ratings are based on
the rating of the Underlying Securities and the legal structure of
the transaction. The rating actions are a result of the change of
the rating of 7.70% Debentures due May 15, 2097 issued by Ford
Motor Company which were upgraded to Ba2 by Moody's on October 27,
2011.

The principal methodology used in this rating was "Moody's
Approach to Rating Repackaged Securities" published in April 2010.


RELATED CAPITAL: Moody's Lowers Rating of Series F Funds to 'B3'
----------------------------------------------------------------
Moody's Investors Service has downgraded the underlying ratings of
the Related Capital Guaranteed Corporate Partners II, LP- Series
B, Series D, and Series F Funds to B3 from B2 and affirmed Series
C Fund at B3. The rating outlook on all four funds remains
negative.

RATINGS RATIONALE

This rating action is primarily based on the continued weakness of
some individual properties within the funds, which are
underperforming, primarily due to low debt service coverage and
occupancy levels, exacerbated by the soft real estate in many
markets. The continued challenges in the multi-family real estate
market further strain the operating performance of the individual
assets.

What could make the rating go up:

  -- Significant improvements in debt service coverage at
     individual properties

  -- Significant improvement in occupancy at individual properties

  -- Significant improvements in the multi-family housing sector

What could make the rating go down:

  -- Further deterioration in debt service coverage and occupancy
     at individual properties

  -- Potential non-compliance or loss of tax credits for the
     underlying assets

PRINCIPAL METHODOLOGY

The principal methodology used in this rating was Moody's Approach
to Analyzing Pools of Multifamily Properties published in October
2001.


RUTLAND RATED: S&P Withdraws 'CCC-' Ratings on 2 Classes of Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on the
class A1B-$LCS, A3A-$LS, and A3-$FS notes issued by Rutland Rated
Investments' Dryden XII-IG Synthetic CDO 2006-1, a synthetic
corporate investment-grade collateralized debt obligation (CDO)
transaction.

"We withdrew our ratings on the class A1B-$LCS, A3A-$LS, and A3-
$FS notes following the termination of the notes," S&P said.

Ratings Withdrawn

Rutland Rated Investments
Dryden XII-IG Synthetic CDO 2006-1
             Rating
Class     To        From
A1B-$LCS  NR        B+ (sf)
A3A-$LS   NR        CCC-(sf)
A3-$FS    NR        CCC-(sf)

NR -- Not rated.


SCHOONER TRUST: DBRS Confirms Class K at 'B'
--------------------------------------------
DBRS has upgraded eight classes of Schooner Trust, Series 2004-CF2
and confirmed five classes. Concurrently, Class D through Class L
were removed from Under Review with Developing Implications, where
they were placed on July 27, 2011.  These actions have been taken.

DBRS has confirmed these classes:

  -- Class A-1 at AAA (sf)
  -- Class A-2 at AAA (sf)
  -- Class K at B (sf)
  -- Class L at B (low) (sf)
  -- Class X at AAA (sf)

DBRS has also upgraded these classes:

  -- Class B to AAA (sf) from AA (high) (sf)
  -- Class C to AA (sf) from A (high) (sf)
  -- Class D to A (high) (sf) from BBB (sf)
  -- Class E to A (sf) from BBB (low) (sf)
  -- Class F to BBB (sf) from BB (high) (sf)
  -- Class G to BBB (low) (sf) from BB (sf)
  -- Class H to BB (sf) from BB (low) (sf)
  -- Class J to BB (low) (sf) from B (high) (sf)

The trend for all classes is Stable.

The rating actions follow the maturity and successful refinancing
of DaimlerChrysler Building (Prospectus ID#3).  This loan was
secured by a 195,952 square foot (sf) Class A office building in
Windsor, Ontario, and was originally scheduled to mature on
September 1, 2011.  The loan was discharged in full on October 1,
2011, and had an outstanding balance of $25,915,168 at the time of
repayment.

Credit enhancement increased as a result of the payoff of the
DaimlerChrysler Building loan; that, coupled with healthy credit
metrics for the remaining loans in the transaction, merited the
upgrades of the above-noted classes.  The transaction is seasoned,
with observed improvement in the pool since issuance.  At
issuance, the weighted-average loan-to-value ratio (WALTV),
weighted-average debt service coverage ratio (WADSCR) and
weighted-average (WA) debt yield were 68.3%, 1.4 times (x) and
11.3%, respectively.  As of the October 2011 remittance, with 92%
of the deal reporting YE2010 financials, the WALTV, WADSCR and WA
debt yield are 58.9%, 1.6x and 14.8%, respectively.  In addition
to collateral reduction of 30.4% since issuance, the transaction
also benefits from 8.5% defeasance.

There are currently two loans on the servicer's watchlist, one of
moderate concern to DBRS.  Howard Johnson Hotel - London
(Prospectus ID#38, 0.75% of the current pool balance) has changed
its banner a number of times since issuance.  Originally an 87-key
Howard Johnson Hotel, the subject is now a 79-key Super 8.  The
property's flag was first changed to Knights Inn in 2009, which
was replaced by the Super 8 banner in June 2010.  The subject
experiences significant competition within the area from similar
properties.  Updated financial statements for the asset have not
been made available, and the last reported financials reflect
YE2008 and indicate a DSCR of 0.30x with an occupancy rate of 50%.
It has also been made known to the servicer that the real estate
taxes are in arrears.  The servicer awaits confirmation that the
borrower has paid all taxes in arrears.  The loan remains current
on mortgage payments.

The largest loan in the pool is PD Kanco Multifamily Portfolio
(Prospectus ID#1, 14.24% of the current pool balance).  This
portfolio consists of 736 units, which are primarily one- and two-
bedroom apartments, located in the Waterloo, Kitchener, Cambridge
and Guelph, Ontario, markets.  All of the properties are in good
locations, with proximity to high-traffic commercial centres,
highways and public transit within their respective communities.
With a DSCR of 1.29x and an occupancy rate of 99% as of YE2010,
the loan's performance has been stable since issuance.  This loan
is scheduled to mature in January 2014, with an estimated exit
debt yield of 11.29%.

DBRS continues to monitor this transaction on a monthly basis,
with ongoing information available in the Monthly CMBS
Surveillance Report.


SIERRA TIMESHARE: Fitch to Rate $25.2 Mil. Note Class at 'BBsf'
---------------------------------------------------------------
Fitch Ratings expects to rate Sierra Timeshare 2011-3 Receivables
Funding LLC (Sierra 2011-3) as follows:

  -- $186,170,000 class A notes 'Asf'; Outlook Stable;
  -- $38,570,000class B notes 'BBBsf'; Outlook Stable;
  -- $25,260,000class C notes 'BBsf'; Outlook Stable.

Fitch's stress and rating sensitivity analysis are discussed in
the presale report titled 'Sierra Timeshare 2011-3 Receivables
Funding LLC', dated Nov. 2, 2011.


SPRING ROAD: Moody's Raises Rating of Class E Notes to 'Ba2'
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Spring Road CLO 2007-1, Ltd.:

US$38,000,000 Class B Second Priority Senior Notes Due 2021,
Upgraded to Aa1 (sf); Previously on June 22, 2011 Aa2 (sf) Placed
Under Review for Possible Upgrade;

US$30,000,000 Class C Third Priority Subordinated Deferrable Notes
Due 2021, Upgraded to A2 (sf); Previously on June 22, 2011 A3 (sf)
Placed Under Review for Possible Upgrade;

US$21,000,000 Class D Fourth Priority Subordinated Deferrable
Notes Due 2021, Upgraded to Baa2 (sf); Previously on June 22, 2011
Baa3 (sf) Placed Under Review for Possible Upgrade;

US$23,000,000 Class E Fifth Priority Subordinated Deferrable Notes
Due 2021, Upgraded to Ba2 (sf); Previously on June 22, 2011 Ba3
(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 actions reflect key
changes to the modeling assumptions, which incorporate (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 from October 2011, the weighted
average rating factor is currently 2789 compared to 3078 in the
September 2009 report. Additionally, Moody's notes that the
portfolio composition has shifted materially away from middle
market loans to broadly syndicated loans since the last rating
action.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" 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 $407.4 million,
defaulted par of $13.2 million, a weighted average default
probability of 28.1% (implying a WARF of 3682), a weighted average
recovery rate upon default of 50.6%, and a diversity score of 56.
Moody's generally analyzes deals in their reinvestment period by
assuming the worse of reported and covenanted values for all
collateral quality tests. However, in this case Moody's analysis
reflects the benefit of assuming a higher likelihood that the
collateral pool characteristics will continue to maintain a
positive "cushion" relative to certain covenant requirements, as
seen in the actual collateral quality measurements. 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.

Spring Road CLO 2007-1, Ltd., issued in July 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, 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 the weighted average rating
factor. 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.

3) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates.


STARWOOD VACATION: Moody's Upgrades Rating of 2 Classes of Notes
----------------------------------------------------------------
Moody's Investors Service upgraded two classes of notes from SVO
2003-A VOI Mortgage Corp. Series 2003-A, which is sponsored by
Starwood Vacation Ownership Portfolio Services, Inc. (Starwood)
(Ba1/Stable). The underlying collateral consists of timeshare loan
receivables issued and serviced by Starwood.

RATINGS RATIONALE

The upgrades reflect the buildup in credit enhancement and
continued improvement in the performance of the underlying
collateral. The trust is currently at its overcollateralization
target of 10.5% of the outstanding pool balance. The non-declining
reserve remained at its floor of 0.5% of original pool balance,
increasing to 7.4% of outstanding pool balance as of the August
2011 report from 6.3% when the notes were placed on review in July
2011. The 6-month average monthly gross charge-off rate was
approximately 0.75%, which is 50% lower than the peak in 2009.
Furthermore, the monthly gross charge-off to liquidation rate
adjusted for loans substituted during the month has declined to
15-20%, which is consistent with the pre-crisis level. The 60-day
plus delinquency level continued to decrease, which indicates a
lower charge-off rate in the next a few months.

The principal methodology used in the rating action was "Moody's
Approach to Rating Vacation Timeshare Loan Securitizations",
published on September 19, 2011, which is available at
www.moodys.com in the Rating Methodologies sub-directory under the
Research & Ratings tab. Other methodologies and factors that may
have been considered in the process of rating this issue can also
be found in the Rating Methodologies sub-directory on Moody's
website.

Our expected lifetime net loss as a percentage of the original
pool balance plus cumulative substitutions for defaulted loans is
approximately 17.2%. The ratings of Class B and C could be
upgraded in the future if the lifetime expected net losses are 5%
lower, or downgraded if the lifetime expected net losses are 5%
higher than the levels indicated above, on a relative basis.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of uncertainty with
regard to expected losses are the weak economic environment, which
adversely impacts the income-generating ability of the borrowers.
Overall, Moody's expects overall a sluggish recovery in most of
the world largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

RATINGS

Issuer: SVO 2003-A VOI Mortgage Corp. Series 2003-A

Cl. B, Upgraded to Aa1 (sf); previously on Jul 19, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade

Cl. C, Upgraded to A1 (sf); previously on Jul 19, 2011 A2 (sf)
Placed Under Review for Possible Upgrade


SYMPHONY CLO: S&P Affirms 'BB' Rating on Class E Notes
------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Symphony CLO VII Ltd./Symphony CLO VII Inc.'s $487.0 million
floating-rate notes following the transaction's effective date
as of Aug. 9, 2011.

Most U.S. cash flow collateralized debt obligations (CLOs) close
before purchasing the full amount of their targeted level of
portfolio collateral. On the closing date, the collateral manager
typically covenants to purchase the remaining collateral within
the guidelines specified in the transaction documents to reach
the target level of portfolio collateral. Typically, the CLO
transaction documents specify a date by which the targeted level
of portfolio collateral must be reached. The "effective date" for
a CLO transaction is usually the earlier of the date on which the
transaction acquires the target level of portfolio collateral, or
the date defined in the transaction documents. Most transaction
documents contain provisions directing the trustee to request the
rating agencies that have issued ratings upon closing to affirm
the ratings issued on the closing date after reviewing the
effective date portfolio (typically referred to as an "effective
date rating affirmation").

"An effective date rating affirmation reflects our opinion that
the portfolio collateral purchased by the issuer, as reported to
us by the trustee and collateral manager, in combination with the
transaction's structure, provides sufficient credit support to
maintain the ratings that we assigned on the transaction's closing
date. The effective date reports provide a summary of certain
information that we used in our analysis and the results of our
review based on the information presented to us," S&P related.

"We believe the transaction may see some benefit from allowing a
window of time after the closing date for the collateral manager
to acquire the remaining assets for a CLO transaction. This window
of time is typically referred to as a 'ramp-up period.' Because
some CLO transactions may acquire most of their assets from the
new issue leveraged loan market, the ramp-up period may give
collateral managers the flexibility to acquire a more diverse
portfolio of assets," S&P said.

"For a CLO that has not purchased its full target level of
portfolio collateral by the closing date, our ratings on the
closing date and prior to our effective date review are generally
based on the application of our criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to us by the
collateral manager, and may also reflect our assumptions about the
transaction's investment guidelines. This is because not all
assets in the portfolio have been purchased," S&P related.

"When we receive a request to issue an effective date rating
affirmation, we perform quantitative and qualitative analysis of
the transaction in accordance with our criteria to assess whether
the initial ratings remain consistent with the credit enhancement
based on the effective date collateral portfolio. Our analysis
relies on the use of CDO Evaluator to estimate a scenario default
rate at each rating level based on the effective date portfolio,
full cash flow modeling to determine the appropriate percentile
break-even default rate at each rating level, the application of
our supplemental tests, and the analytical judgment of a rating
committee. (For more information on our criteria and our
analytical tools, see 'Update To Global Methodologies And
Assumptions For Corporate Cash Flow And Synthetic CDOs,' published
Sept. 17, 2009.)," S&P said.

"In our published effective date report, we discuss our analysis
of the information provided by the transaction's trustee and
collateral manager in support of their request for effective date
rating affirmation. In most instances, we intend to publish an
effective date report each time we issue an effective date rating
affirmation on a publicly rated U.S. cash flow CLO," S&P related.

"On an ongoing basis after we issue an effective date rating
affirmation, we will periodically review whether, in our view, the
current ratings on the notes remain consistent with the credit
quality of the assets, the credit enhancement available to support
the notes, and other factors, and take rating actions as we deem
necessary," S&P stated.

Ratings Affirmed
Symphony CLO VII Ltd./Symphony CLO VII Inc.

Class                Rating      Amount (mil. $)
A                    AAA (sf)             334.00
B                    AA (sf)               56.50
C (deferrable)       A (sf)                41.50
D (deferrable)       BBB (sf)              27.50
E (deferrable)       BB (sf)               27.50
F (deferrable)       NR                    22.00
Subordinated         NR                    49.00

NR -- Not rated.


TELOS CLO 2006-1: Moody's Upgrades Rating of Class D Notes to Ba1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Telos CLO 2006-1, Ltd.:

US$60,000,000 Class A-2 Second Priority Senior Secured Floating
Rate Notes Due 2021, Upgraded to Aa1 (sf); previously on June 22,
2011 Aa2 (sf) Placed Under Review for Possible Upgrade;

US$27,200,000 Class B Third Priority 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$22,000,000 Class C Fourth Priority Mezzanine Secured Floating
Rate Deferrable Interest Notes Due 2021, Upgraded to A3 (sf);
previously on June 22, 2011 Baa3 (sf) Placed Under Review for
Possible Upgrade;

US$22,000,000 Class D Fifth Priority Mezzanine Secured Floating
Rate Deferrable Interest Notes Due 2021, Upgraded to Ba1 (sf);
previously on June 22, 2011 Ba3 (sf) Placed Under Review for
Possible Upgrade;

US$16,000,000 Class E Sixth Priority Mezzanine Secured Floating
Rate Deferrable Interest 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 "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 $401.5 million,
defaulted par of $10.6 million, a weighted average default
probability of 29.13% (implying a WARF of 3761), a weighted
average recovery rate upon default of 48.23%, 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.

TELOS CLO 2006-1, issued in November of 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans of middle market issuers.

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.

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 levels higher than the covenant levels due to the large
difference between the reported and covenant levels.

3) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates.


TELOS CLO 2007-2: Moody's Raises Rating of Class D Notes to 'Ba1'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Telos CLO 2007-2, Ltd.:

US$40,000,000 Class A-2 Second Priority Senior Secured Floating
Rate Notes Due 2022, Upgraded to Aa1 (sf); previously on June 22,
2011 A1 (sf) Placed Under Review for Possible Upgrade;

US$27,500,000 Class B Third Priority Senior Secured Floating Rate
Notes Due 2022, Upgraded to A1 (sf); previously on June 22, 2011
A3 (sf) Placed Under Review for Possible Upgrade;

US$22,000,000 Class C Fourth Priority Mezzanine Secured Floating
Rate Deferrable Interest Notes Due 2022, Upgraded to Baa2 (sf);
previously on June 22, 2011 Baa3 (sf) Placed Under Review for
Possible Upgrade;

US$22,000,000 Class D Fifth Priority Mezzanine Secured Floating
Rate Deferrable Interest Notes Due 2022, Upgraded to Ba1 (sf);
previously on June 22, 2011 Ba3 (sf) Placed Under Review for
Possible Upgrade;

US$16,000,000 Class E Sixth Priority Mezzanine Secured Floating
Rate Deferrable Interest Notes Due 2022, 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 $406.1 million,
defaulted par of $10 million, a weighted average default
probability of 27.76% (implying a WARF of 3619), a weighted
average recovery rate upon default of 48.01%, 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.

Telos CLO 2007-2, Ltd., issued in June of 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans of middle market issuers.

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 levels higher than the covenant levels due to the large
difference between the reported and covenant levels.

3) Exposure to credit estimates: The deal is exposed to a large
number of securities whose default probabilities are assessed
through credit estimates. In the event that Moody's is not
provided the necessary information to update the credit estimates
in a timely fashion, the transaction may be impacted by any
default probability stresses Moody's may assume in lieu of updated
credit estimates.


TERRA CDO: S&P Withdraws 'CCC-' Rating on Class A1 Notes
--------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'CCC- (sf)' rating
on the class A1 notes from Terra CDO SPC Ltd.'s series 2007-3
segregated portfolio, a U.S. synthetic corporate investment-grade
collateralized debt obligation (CDO) transaction.

The rating withdrawal follows the noteholders' decision to
exercise the option to put the entire principal amount of the
notes outstanding to the issuer at a redemption amount of 'zero',
pursuant to section 8.07 of the indenture and section 10.01 of the
master terms.

Rating Withdrawn

Terra CDO SPC Ltd.
Series 2007-3
            Rating
Class    To      From
A1       NR      CCC-(sf)

NR -- Not rated.


TRUST CERTIFICATES: Moody's Raises Rating of $1.28MM Notes to Ba2
-----------------------------------------------------------------
Moody's Investors Service has upgraded the rating of these
certificates issued by Trust Certificates (TRUCs) Series 2002-1
Trust:

US$1,280,000 7.70% Class A-1 Certificates due 2097 Notes, Upgraded
to Ba2 (sf); previously on October 7, 2011 Ba3 (sf) Placed Under
Review for Possible Upgrade

RATINGS RATIONALE

The transaction is a structured note whose rating is based on the
rating of the Underlying Securities and the legal structure of the
transaction. The rating action is a result of the change of the
rating of 7.70% Debentures due 2097 issued by Ford Motor Company
which were upgraded to Ba2 by Moody's on October 27, 2011.

The principal methodology used in this rating was "Moody's
Approach to Rating Repackaged Securities" published in April 2010.


UBS 2007-FL1: Moody's Affirms Ratings of 14 CMBS Classes
--------------------------------------------------------
Moody's Investors Service (Moody's) upgraded one rake, or non-
pooled class, downgraded one rake class, and affirmed ratings of
14 classes of UBS Commercial Mortgage Trust Commercial Mortgage
Pass-Through Certificates, Series 2007-FL1. Moody's rating action
is as follows:

Cl. A-1 Certificate, Affirmed at Aaa (sf); previously on
January 15, 2008 Definitive Rating Assigned Aaa (sf)

Cl. A-2 Certificate, Affirmed at Baa2 (sf); previously on
December 2, 2010 Downgraded to Baa2 (sf)

Cl. B Certificate, Affirmed at Ba1 (sf); previously on December 2,
2010 Downgraded to Ba1 (sf)

Cl. C Certificate, Affirmed at Ba3 (sf); previously on December 2,
2010 Downgraded to Ba3 (sf)

Cl. D Certificate, Affirmed at B1 (sf); previously on December 2,
2010 Downgraded to B1 (sf)

Cl. E Certificate, Affirmed at B2 (sf); previously on December 2,
2010 Downgraded to B2 (sf)

Cl. F Certificate, Affirmed at B3 (sf); previously on December 2,
2010 Downgraded to B3 (sf)

Cl. G Certificate, Affirmed at Caa1 (sf); previously on
December 2, 2010 Downgraded to Caa1 (sf)

Cl. H Certificate, Affirmed at Caa2 (sf); previously on
December 2, 2010 Downgraded to Caa2 (sf)

Cl. J Certificate, Affirmed at Caa3 (sf); previously on
December 2, 2010 Downgraded to Caa3 (sf)

Cl. K Certificate, Affirmed at Ca (sf); previously on December 2,
2010 Downgraded to Ca (sf)

Cl. O-MD Certificate, Affirmed at B1 (sf); previously on
December 2, 2010 Downgraded to B1 (sf)

Cl. O-WC Certificate, Affirmed at Caa2 (sf); previously on
December 2, 2010 Downgraded to Caa2 (sf)

Cl. O-SA Certificate, Downgraded to C (sf); previously on
December 2, 2010 Downgraded to Caa3 (sf)

Cl. O-HA Certificate, Upgraded to Caa2 (sf); previously on
December 2, 2010 Downgraded to Ca (sf)

Cl. X Certificate, Affirmed at Aaa (sf); previously on January 15,
2008 Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrade of the rake, or non-pooled bond Class O-HA is due
to the better than expected property performance of the Hilton
Arlington, TX loan. The downgrade of the rake, or non-pooled bond
Class O-SA is due to longer than anticipated resolution timing and
potentially higher loss severity than what Moody's had assumed at
last review for the St. Anthony's Hotel loan. 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 8.2. 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 December 2, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased to $1.17 billion from
$1.52 billion at last review. The Certificates are collateralized
by 19 floating rate whole loans and senior interests in whole
loans. The loans range in size from 1% to 16% of the pooled
balance, with the top three loans representing approximately 39%
of the pooled balance.

Except for the Maui Prince Hotel & Resort Loan (now called Makena
Beach & Golf Resort), which was modified, all other loans have
additional debt in the form of a non-pooled or rake bond within
the trust, B note or mezzanine debt outside of the trust. The
current low interest rate environment coupled with low loan
spreads have helped the loans stay current through the last two
years, but high leverage continues to be a cause for concern,
especially as the majority of the loans mature in 2012.

There are currently four loans totaling 18% of pooled balance in
special servicing. However, Maui Prince Resort and 281 & 321
Summer Street loans (totaling 15% of pooled balance) have been
modified. Cumulated bond loss totals $30.2 million and affects
pooled Class L and rake bonds M-MP, N-MP, O-MP, O-HW and O-BH.
Interest shortfalls total $439,158 and affects pooled Classes H,
J, K and L as well as rake classes M-MP, N-MP, O-MP, O-WC, and
O-SA. In addition, as of the October 2011 distribution date,
outstanding P&I advances total $407,268, and outstanding servicing
advances total $796,291.

Moody's weighted average pooled LTV ratio is 95% compared to 97%
at last review, and Moody's weighted average pooled stressed DSCR
is 0.74X compared to 0.80X at last review.

The largest loan in the pool is secured by a fee interest in
Jumeirah Essex House ($186 million, or 16% of the pooled balance)
located in Midtown Manhattan on Central Park South. The sponsor
for the 515-room full-service hotel and 26 condominium units is
Dubai Investment Group Limited and Dubai Holdings LLC. This is a
flag ship property for the Jumeirah brand in the US. The final
maturity date including extension options is September 9, 2012.
There is an additional debt in the form of non-trust junior
component and mezzanine debt outside the trust.

During the first seven months in 2011, the Jumeirah Essex House
achieved 75.9% occupancy at $364.99 Average Daily Rate (ADR) for a
Revenue per Available Room (RevPAR) of $277.02. During the same
seven month period in 2010, occupancy was at 75.3% with an ADR of
$343.75 resulting in a RevPAR of $258.84. Net Operating Income
(NOI) for the first seven months of 2011 was $49,655 compared
to $40,092 achieved during the same period in 2010. During
the calendar year 2010, the hotel achieved 76.4% occupancy at
$388.25 ADR for a RevPAR of $296.71. The full year 2010 NOI was
$5.6 million. NOI comparison for the year-to-date through July
2011 over July 2010 shows very little movement despite improvement
in the top line revenue. Based on the trend of 2010, Moody's can
expect that 2011 full year NOI will be slightly higher than that
of calendar year 2010. Although the in-place cash flow is still
below normalized levels, the inherent value in the property, its
flag ship status in the chain, desirable location as well as
trophy status help to support Moody's value of $180 million.
Moody's current credit estimate for this loan is B3, the same as
last review.

The second largest loan is the Maui Prince Resort (now called
Makena Beach & Golf Resort) Loan ($150 million, or 11% of pooled
balance) which is currently in special servicing, and waiting
to be returned to master servicer post modification. The loan
is secured by fee simple interest in Maui Prince Resort (310
guestrooms), two18-hole golf course and 1,200 acres of undeveloped
land located in Makena (Maui), HI. The loan was transferred to
special servicing in June 2009, and foreclosed by the trust in
September 2009. The rake investor assumed the A note and converted
their interest in rake, or non-pooled bonds to equity as part
of the assumption. A note received a principal pay-down of
$12.5 million, and loan maturity has been extended by three
years with two one-year extension options.

The new sponsors for this loan are AREA Property Partners
(formerly known as Apollo Real Estate Advisors), Trinity
Investments, LLC, and Stanford Carr Development, LLC, a Honolulu
based residential development firm. Moody's did not rate the three
rake bonds associated with this loan (Classes M-MP, N-MP and O-MP)
which have been converted to equity. Total interest shortfalls
to these three rake classes total $334,849 as of the October
distribution date. Moody's value is $150 million, and Moody's
current credit estimate for this loan is B3, the same as last
review.

The third largest loan in the pool, the Magazine Multfamily
Portfolio Loan ($110 million or 10% of the pooled balance) is
secured by fee interest in seven multifamily property portfolio
located in Florida. The Magazine Multifamily Portfolio totals
2,120 units and was built between 1987 and 1992. The properties
are located in Palm Beach Gardens, Orlando, Sarasota and
Bradenton. The sponsors are Morgan Stanley Real Estate Fund V
U.S., LP and Onex Real Estate Partners LP. There is a $10 million
junior component and a $60 million mezzanine debt outside of the
trust. The final maturity date including extension options is July
9, 2012. The portfolio's NOI for 2010 was $10.5 million, and NOI
for the first eight months of 2011 was $7.2 million. Moody's value
is $117 million, and Moody's current credit estimate is B3, the
same as last review.


US COMMERCIAL: Fitch Lowers Ratings on 18 Bonds to 'D'
------------------------------------------------------
Fitch Ratings has downgraded 18 bonds in 12 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.

This 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 has downgraded the bonds to 'D' as
part of the ongoing surveillance process and will continue to
monitor these transactions for additional defaults.

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 Lowers Rating on 270 Distressed Bonds to 'Dsf'
-------------------------------------------------------------
Fitch Ratings has downgraded 270 distressed bonds in 171 U.S. RMBS
transactions to 'Dsf'.  The downgrades indicate that the bonds
have incurred a principal write-down.  Of the bonds downgraded to
'Dsf', 269 classes were previously rated 'Csf' (over 99%) and the
remaining bond was rated 'CCsf'.  All ratings below 'Bsf' indicate
a default is expected.  As part of this review, the Recovery
Ratings of the defaulted bonds were not revised.  Additionally,
the review only focused on the bonds which defaulted and did not
include any other bonds in the affected transactions.

Of the 270 classes affected by these downgrades, 118 are Alt-A, 91
are Prime and 53 are Subprime. The remaining transaction types are
other sectors.  The majority of the bonds (54%) have Recovery
Ratings of either 'RR5' or 'RR6' indicating that minimal recovery
is expected, while 45% have Recovery Ratings of either 'RR2' or
'RR3', which indicates anywhere from 50%-90% of the outstanding
balance is expected to be recovered.

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 BANK: Moody's Upgrades Rating of Two Classes of Notes
--------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of two
classes, affirmed seven classes, confirmed two classes, and
downgraded seven classes of Wachovia Bank Commercial Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series 2004-
C14:

Cl. A-3, Affirmed at Aaa (sf); previously on Sep 15, 2004 Assigned
Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Sep 15, 2004 Assigned
Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Sep 15, 2004
Assigned Aaa (sf)

Cl. B, Upgraded to Aa1 (sf); previously on Sep 15, 2004 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Upgraded to Aa2 (sf); previously on Sep 15, 2004 Definitive
Rating Assigned Aa3 (sf)

Cl. D, Affirmed at A2 (sf); previously on Sep 15, 2004 Definitive
Rating Assigned A2 (sf)

Cl. E, Affirmed at A3 (sf); previously on Sep 15, 2004 Definitive
Rating Assigned A3 (sf)

Cl. F, Confirmed at Baa1 (sf); previously on Aug 4, 2011 Baa1 (sf)
Placed Under Review for Possible Downgrade

Cl. G, Confirmed at Baa2 (sf); previously on Aug 4, 2011 Baa2 (sf)
Placed Under Review for Possible Downgrade

Cl. H, Downgraded to Ba2 (sf); previously on Aug 4, 2011 Baa3 (sf)
Placed Under Review for Possible Downgrade

Cl. J, Downgraded to Ba3 (sf); previously on Aug 4, 2011 Ba1 (sf)
Placed Under Review for Possible Downgrade

Cl. K, Downgraded to B1 (sf); previously on Aug 4, 2011 Ba2 (sf)
Placed Under Review for Possible Downgrade

Cl. L, Downgraded to B3 (sf); previously on Aug 4, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

Cl. M, Downgraded to Caa1 (sf); previously on Aug 4, 2011 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. N, Downgraded to Caa2 (sf); previously on Aug 4, 2011 Caa1
(sf) Placed Under Review for Possible Downgrade

Cl. O, Downgraded to Caa3 (sf); previously on Aug 4, 2011 Caa2
(sf) Placed Under Review for Possible Downgrade

Cl. X-C, Affirmed at Aaa (sf); previously on Sep 15, 2004
Definitive Rating Assigned Aaa (sf)

Cl. MAD, Affirmed at Aaa (sf); previously on May 4, 2007 Upgraded
to Aaa (sf)

RATINGS RATIONALE

The upgrades are due to an increase in subordination from
amortization and loan payoffs. The Park Place Mall Loan (A-note -
$134.15 million; 15.1% of the pool) in April 2011. The pool has
paid down 40% since securitization and 29% since last review. Six
loans, representing 17% of the pool, have been fully defeased and
are secured by U.S. Government securities compared to 12% at last
review.

The affirmations and confirmations 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 our current base
expected loss, the credit enhancement levels for the affirmed
classes are sufficient to maintain their current ratings.

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

On August 4, 2011 Moody's placed nine classes on review for
possible downgrade. This action concludes our review.

Moody's rating action reflects a cumulative base expected loss of
4.6% of the current balance. At last full review, Moody's
cumulative base expected loss was 2.6%. Moody's stressed scenario
loss is 11.0% of the current balance. Depending on the timing of
loan payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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

Primary sources of assumption uncertainty are the current
sluggish macroeconomic environment and varying performance in
the commercial real estate property markets. However, Moody's
expects to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011 The hotel
and multifamily sectors are continuing to show signs of recovery,
while recovery in the office and retail sectors will be tied to
recovery of the broader economy. The availability of debt capital
continues to improve with terms returning toward market norms.
Moody's central global macroeconomic scenario reflects an overall
sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

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

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (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 our 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 24 compared to 15 at Moody's prior full review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST (R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated March 9, 2011.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 40% to
$658.58 million from $1.1 billion at securitization. The
Certificates are collateralized by 59 mortgage loans ranging in
size from less than 1% to 12% of the pool, with the top ten loans
representing 43% of the pool. Six loans, representing 17% of the
pool, have defeased and are collateralized with U.S. Government
securities, compared to 12% at last review.

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

Three loans have been liquidated from the pool since
securitization, resulting in an aggregate $1.7 million loss (11%
loss severity on average). Currently two loans, representing 5% of
the pool, are in special servicing. The largest loan in special
servicing is the Bel Villaggio, Phases I & II Loan (16.2 million -
- 2.5% of the pool). The loan is secured by a 77,000 square foot
(SF) retail center located in Temecula, CA. The property has been
in foreclosure since June 2010 and is listed for sale. The second
specially serviced loan is the Summer View at Sherman Oaks
Apartments Loan (15.1 million -- 2.3% of the pool). This loan is
secured by a 169-unit apartment complex in Sherman Oaks,
California. The loan was transferred into special servicing in
February 2011 due to monetary default. The master servicer has
recognized an aggregate $7.1 million appraisal reduction for the
specially serviced loans. Moody's has estimated an aggregate loss
of $11.9 million (38% expected loss on average) for all of the
specially serviced loans.

Moody's has assumed a high default probability for three poorly
performing loans representing 2.4% of the pool and has estimated a
$2.3 million loss (25% expected loss based on a 50% probability
default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 89% and 68% of the performing pool,
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 96% compared to 92% at last full
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
9.0%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.27X and 1.23X, respectively, compared to
1.32X and 1.08X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing conduit loans represent 22% of the pool
balance. The largest loan is the 444 North Michigan Avenue Loan
($71.5 million -- 10.9% of the pool), which is secured by a
511,000 SF office property located in Chicago, Illinois. The
property was 72% leased as of December 2010 compared to 76% at
last review. The loan is currently on the master servicer's
watchlist due to a low DSCR. Performance has declined since last
review, however, Moody's expects the property to stabilize
resulting in an increase in near-term performance. The largest
tenant, Monster Worldwide Inc. (6% of NRA), renewed its lease
through 2020. Moody's LTV and stressed DSCR are 133% and 0.73X,
respectively, compared to 127% and 0.77X at last full review.

The second largest loan is the FBI Field Office Loan
($38.4 million -- 5.8% of the pool), which is secured by a
156,000 SF Class A office property located approximately seven
miles northwest of Baltimore in Woodlawn, Maryland. The property
is 100% occupied by the FBI through July 2014. The loan was
previously transferred into special servicing in February 2010 due
to the parent of the borrower filing for Chapter 11 but the loan
has been returned to the master servicer. Moody's value for this
loan reflects a lit/dark analysis. Moody's LTV and stressed DSCR
are 98% and 1.03X, respectively, compared to 88% and 1.14X at last
review.

The third largest loan is the Barneys New York -- Beverly Hills,
CA Loan ($33.2 million -- 5.0% of the pool), which is secured by a
115,000 SF single tenant retail property located in Beverly Hills,
California. The tenant is Barneys New York, Inc., with a lease
expiration in January 2019. The loan maturity is August 2014.
Property performance has been stable. Moody's LTV and stressed
DSCR are 84% and 1.09X, respectively, compared to 87% and 1.05X at
last review.


WBCMT 2003-C6: Moody's Affirms Ratings of 12 CMBS Classes
---------------------------------------------------------
Moody's Investors Service (Moody's) upgraded these ratings of four
classes and affirmed 12 CMBS classes of Wachovia Bank Commercial
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2003-C6 as:

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

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

Cl. B, Affirmed at Aaa (sf); previously on Aug 7, 2006 Upgraded to
Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Jul 9, 2007 Upgraded to
Aaa (sf)

Cl. D, Affirmed at Aaa (sf); previously on Aug 9, 2007 Upgraded to
Aaa (sf)

Cl. E, Upgraded to Aaa (sf); previously on Aug 9, 2007 Upgraded to
Aa1 (sf)

Cl. F, Upgraded to Aa2 (sf); previously on Dec 2, 2010 Upgraded to
Aa3 (sf)

Cl. G, Upgraded to A1 (sf); previously on Dec 2, 2010 Upgraded to
A2 (sf)

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

Cl. J, Affirmed at Ba1 (sf); previously on Sep 17, 2003 Definitive
Rating Assigned Ba1 (sf)

Cl. K, Affirmed at Ba2 (sf); previously on Sep 17, 2003 Definitive
Rating Assigned Ba2 (sf)

Cl. L, Affirmed at Ba3 (sf); previously on Sep 17, 2003 Definitive
Rating Assigned Ba3 (sf)

Cl. M, Affirmed at B1 (sf); previously on Sep 17, 2003 Definitive
Rating Assigned B1 (sf)

Cl. N, Affirmed at Caa1 (sf); previously on Dec 2, 2010 Downgraded
to Caa1 (sf)

Cl. O, Affirmed at Caa3 (sf); previously on Dec 2, 2010 Downgraded
to Caa3 (sf)

Cl. IO, Affirmed at Aaa (sf); previously on Sep 17, 2003
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrades are due to an increase in subordination due to loan
payoffs and amortization and overall stable pool performance. The
slight increase in Moody's cumulative base expected loss was
offset by increased subordination. The pool has paid down
approximately 15% since last review.

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
3.5% ($18.4 million ) of the current balance. At last review,
Moody's cumulative base expected loss was 2.4% ($14.8 million ).
Moody's stressed scenario loss is 7.8% of the current balance,
compared to 10.9% at last review.  Depending on the timing of loan
payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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 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 uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 26 compared to 20 at last review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (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 October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 45% to
$525.4 million from $952.8 billion at securitization. The
Certificates are collateralized by 80 mortgage loans ranging
in size from less than 1% to 12% of the pool, with the top ten
loans representing 37% of the pool. Eleven loans, representing
18% of the pool, have defeased and are collateralized with U.S.
Government securities. Defeasance at last review represented 15%
of the pool. The pool also has two loans with investment-grade
credit estimates, representing 15% of the pool.

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

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $1.7 million (11% loss severity). Three
loans, representing 2% of the pool, are currently in special
servicing. Moody's has estimated an aggregate $3.2 million loss
(37% expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for five poorly
performing loans, representing 6% of the pool, and has estimated a
$8.86 million loss (26% expected loss based on a 66% probability
default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 97% and 87% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 80% compared to 85% at last review. Moody's net
cash flow reflects a weighted average haircut of 11% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 8.9%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.48X and 1.30X, respectively, compared to
1.56X and 1.22X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the Lloyd Center
Loan ($60.8 million -- 11.6% of the pool), which is secured by a
1.3 million square foot regional mall located in Portland, Oregon.
This loan represents a 50% pari-passu interest in a $121.5 million
first mortgage loan. The mall is anchored by Macy's Sears and
Nordstrom. As of July 2011, the property was 96% leased compared
to 95% at last review. Moody's current credit estimate and
stressed DSCR are Baa1 and 1.46X, respectively, compared to Baa2
and 1.39X at last review.

The second loan with a credit estimate is the Port Authority
Building Loan ($16.6 million -- 3.2% of the pool), which is
secured by a 304,000 square foot office property located near the
Holland Tunnel in Jersey City, New Jersey. The property is solely
leased to The Port Authority of New York and New Jersey (Moody's
senior unsecured rating of Aa2; negative outlook) through February
2020. Moody's valuation is based on a Lit/Dark analysis. Moody's
current credit estimate and stressed DSCR are Aa2 and 1.15X,
respectively, compared to Aa2 and 1.43X at last review.

The top three performing conduit loans represent 11% of the pool
balance. The largest conduit loan is the Coral Sky Plaza Loan
($21.6 million -- 4.1% of the pool), which is secured by a 233,000
square foot retail center located in Royal Palm Beach, Florida.
The largest tenants are Bed Bath and Beyond, Ross Dress for less
and Old Navy. As of September 2011, the property was 96% leased;
the same as at last review. Property performance has increased
since last review due to increased rental revenues. In addition,
Moody's previous analysis reflected a stressed cash flow due to
concerns about significant lease rollover in 2011. The tenants
with 2011 expirations have all renewed their leases. Moody's LTV
and stressed DSCR are 89% and 1.06X, respectively, compared to
101% and 0.94X at last review.

The second largest conduit loan is The Shoppes at Union Hill Loan
($17.5 million -- 3.3% of the pool), which is secured by a 88,000
square foot retail center located in Denville, New Jersey. The
three largest tenants are Gap Inc, Pier 1 Imports and Talbots. As
of July 2011 the property was 100% leased, the same as last
review. Moody's LTV and stressed DSCR are 70% and 1.40X,
respectively, compared to 74% and 1.32X at last review.

The third largest conduit loan is the Via Tuscany Apartments Loan
($16.6 million -- 3.2% of the pool), which is secured by a 280-
unit Class A multi-family property located in Melbourne, Florida.
The loan is on the servicer's watchlist for low DSCR caused by a
decrease in occupancy. As of June 2011, the property was 79%
leased compared to 81% in 2010. Moody's LTV and stressed DSC are
113% and 0.84X, compared to 100% and 0.95X at last review.


WBCMT 2004-C10: Moody's Affirms Ratings of 14 CMBS Classes
----------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of two
pooled class and one non-pooled, or rake, class, and affirmed 14
classes of Wachovia Bank Commercial Mortgage Securities Trust
Commercial Mortgage Pass-Through Certificates, Series 2004-C10:

Cl. A-4, Affirmed at Aaa (sf); previously on Sep 28, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Sep 28, 2004
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Nov 21, 2006 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Jan 10, 2008 Upgraded
to Aaa (sf)

Cl. D, Upgraded to Aa1 (sf); previously on Dec 2, 2010 Upgraded to
Aa2 (sf)

Cl. E, Upgraded to Aa3 (sf); previously on Jan 10, 2008 Upgraded
to A1 (sf)

Cl. F, Affirmed at A3 (sf); previously on Jan 10, 2008 Upgraded to
A3 (sf)

Cl. G, Affirmed at Baa2 (sf); previously on Sep 28, 2004
Definitive Rating Assigned Baa2 (sf)

Cl. H, Affirmed at Baa3 (sf); previously on Sep 28, 2004
Definitive Rating Assigned Baa3 (sf)

Cl. J, Affirmed at Ba2 (sf); previously on Dec 2, 2010 Downgraded
to Ba2 (sf)

Cl. K, Affirmed at B2 (sf); previously on Dec 2, 2010 Downgraded
to B2 (sf)

Cl. L, Affirmed at Caa1 (sf); previously on Dec 2, 2010 Downgraded
to Caa1 (sf)

Cl. M, Affirmed at Caa3 (sf); previously on Dec 2, 2010 Downgraded
to Caa3 (sf)

Cl. N, Affirmed at Ca (sf); previously on Dec 2, 2010 Downgraded
to Ca (sf)

Cl. O, Affirmed at C (sf); previously on Dec 2, 2010 Downgraded to
C (sf)

Cl. SL, Upgraded to Aaa (sf); previously on Dec 2, 2010 Upgraded
to A1 (sf)

Cl. X-C, Affirmed at Aaa (sf); previously on Sep 28, 2004
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrades of the pooled classes were due to increased credit
subordination from loan payoffs and amortization and an increase
in share of loans in the pool that have been defeased with US
Government securities. Since the prior review, the pool has paid
down by 12% and the share of defeased loans has risen to 44% from
30%. The upgrade of the non-pooled, or rake, class is due to the
defeasance of the Starrett Leigh Building Loan.

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
1.9% of the current balance. At last review, Moody's cumulative
base expected loss was 1.8%. Moody's stressed scenario loss is
6.8% of the current balance. Moody's base expected loss is a
function of the total anticipated losses for the loans remaining
in the pool.  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 methodologies used in this rating were "Moody's Approach to
Rating Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000.

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
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 15, which is the same as at last review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.1 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 2, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 32% to
$874.4 million from $1.29 billion at securitization. The
Certificates are collateralized by 63 mortgage loans ranging in
size from less than 1% to 9% of the pool, with the top ten non-
defeased loans representing 33% of the pool. The pool contains
one loan with an investment grade credit estimate that comprises
6% of the pool. Ten loans have been defeased by US Government
securities.

Twelve loans, representing 11% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (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.

Six loans have been liquidated from the pool, resulting in a
realized loss of $19.0 million (42% loss severity). No loans have
liquidated since the prior review. Currently three loans,
representing 1% of the pool, are in special servicing. The three
specially serviced loans are secured two retail properties and one
multifamily complex. Moody's estimates an aggregate $3.1 million
loss for two of the specially serviced loans (56% expected loss
based on a 100% probability of default).

Moody's has assumed a high default probability for three poorly
performing loans representing 2.3% of the pool and has estimated
an aggregate $2.9 million loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 99%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 90% compared to 95% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 13% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.37X and 1.13X, respectively, compared to
1.45X and 1.07 X 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 loan with an investment grade credit estimate is the 520
Eighth Avenue Loan ($49.0 million -- 5.6% of the pool), which is
secured by three contiguous Class B office buildings totaling
740,000 square feet (SF) located in Manhattan. The property
benefits from low tenant concentration, as no tenant accounts for
greater than 7% of the net rentable area (NRA), and has minimal
near term tenant rollover risk, with leases accounting for only
14% of the NRA expiring in the next 24 months. As of June 2011,
the property was 95% leased compared to 99% in December 2009 and
98% at securitization. The property's financial performance has
been stable. Moody's current credit estimate and stressed DSCR are
Aa1 and 2.25X, respectively, the same as at last review.

The top three conduit loans represent 17% of the pool. The largest
conduit loan is the North Riverside Park Mall Loan ($80.0 million
-- 9.1% of the pool), which is secured by a 440,421 SF portion of
a 1.1 million SF regional mall located 11 miles west of Chicago's
CBD in North Riverside, Illinois. The mall is anchored by a J.C.
Penney, Carson Pirie Scott & Co and Sears. As of September 2011,
the property was 94% leased, which is in-line with the prior year
and up from 87% at securitization. The financial performance of
the property improved significantly in 2010 due to an
approximately $1.0 million decrease in the property's tax expense
and a 2% increase revenue. Moody's viewed the decrease in tax
expense as a non-recurring event and used a tax expense based on
the property's historical average, thus mitigating the extent of
the improved financial performance since the prior review. Moody's
LTV and stressed DSCR are 108% and 0.91X, respectively, compared
to 121% and 0.80X at last review.

The second largest loan is the Villa del Sol Apartments Loan
($41.4 million -- 4.7% of the pool), which is secured by a 562-
unit apartment complex located in Santa Ana, California. The
property was 96% leased in June 2011, which is in-line with the
prior year and securitization. Property performance deteriorated
in 2010 due to lower rental rates which led to an approximately 5%
decline in revenue. However, per CBRE Econometric Advisors,
multifamily rental rates in the Santa Ana submarket increased 2.4%
in the first half of 2011 from year-end 2010. Moody's analysis
incorporated a slight increase in rental revenue due to the
outlook for the submarket and evidence of increased revenue in the
property's first half 2011 financials which partially offset the
decline in revenue in 2010. Moody's LTV and stressed DSCR are 86%
and 1.07X, respectively, compared to 83% and 1.11X at last review.

The third largest loan is the Pine Trail Square Loan
($27.0 million -- 3.1% of the pool), which is secured by a 270,000
SF retail center located in West Palm Beach, Florida. Former
anchor tenant Albertson's, which occupied 20% of the NRA, vacated
the property but will continue to make lease payments until it's
lease expiration in November 2011. The sponsor has leased 32,500
SF of the former's Albertson's space to HH Gregg. As of June 2011,
the property was 88% leased, including the space leased to
Albertson's. Moody's analysis incorporated a decline in revenue
due to the upcoming loss of Albertson's lease payments that will
be only partially offset by HH Gregg's lease payments. Moody's LTV
and stressed DSCR are 82% and 1.19X, respectively, compared to 76%
and 1.2X at last review.


WBCMT 2005-C22: Moody's Reviews Ratings for Possible Downgrade
--------------------------------------------------------------
Moody's Investors Service (Moody's) placed seven classes of
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-
Through Certificates, Series 2005-C22 on review for possible
downgrade:

Cl. A-M, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on December 17, 2010 Downgraded to Aa2 (sf)

Cl. A-J, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on December 17, 2010 Downgraded to Baa1 (sf)

Cl. B, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on December 17, 2010 Downgraded to Baa3 (sf)

Cl. C, Ba3 (sf) Placed Under Review for Possible Downgrade;
previously on December 17, 2010 Downgraded to Ba3 (sf)

Cl. D, B3 (sf) Placed Under Review for Possible Downgrade;
previously on December 17, 2010 Downgraded to B3 (sf)

Cl. E, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on December 17, 2010 Downgraded to Caa2 (sf)

Cl. F, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on December 17, 2010 Downgraded to Caa3 (sf)

RATINGS RATIONALE

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

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.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 7% to $2.35 billion
from $2.53 billion at securitization. The Certificates are
collateralized by 143 mortgage loans ranging in size from less
than 1% to 7% of the pool, with the top ten loans representing 32%
of the pool. Three loans, representing 4% of the pool, have
investment grade credit estimates. Two loans, representing 0.5% of
the pool, have defeased and are secured by U.S. Government
securities.

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

Three loans have been liquidated from the pool, resulting in a
realized loss of $22.5 million (47% loss severity). Currently 18
loans, representing 19% of the pool, are in special servicing.

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


WBCMT 2006-WHALE7: Moody's Affirms Ratings of 11 CMBS Classes
-------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed ratings of eleven
classes and downgraded four rake, or non-pooled classes of
Wachovia Bank Commercial Mortgage Pass-Through Certificates,
Series 2006-WHALE. Moody's rating action is:

Cl. A-1 Certificate, Affirmed at Aaa (sf); previously on October
3, 2006 Definitive Rating Assigned Aaa (sf)

Cl. A-2 Certificate, Affirmed at Baa2 (sf); previously on December
9, 2010 Downgraded to Baa2 (sf)

Cl. B Certificate, Affirmed at Baa3 (sf); previously on December
9, 2010 Downgraded to Baa3 (sf)

Cl. C Certificate, Affirmed at Ba2 (sf); previously on December 9,
2010 Downgraded to Ba2 (sf)

Cl. KH-1 Certificate, Affirmed at B3 (sf); previously on December
9, 2010 Downgraded to B3 (sf)

Cl. KH-2 Certificate, Affirmed at Caa1 (sf); previously on
December 9, 2010 Downgraded to Caa1 (sf)

Cl. WA Certificate, Affirmed at C (sf); previously on March 19,
2009 Downgraded to Ba3 (sf)

Cl. BP-1 Certificate, Affirmed at Caa1 (sf); previously on
December 9, 2010 Downgraded to Caa1 (sf)

Cl. BP-2 Certificate, Affirmed at Caa2 (sf); previously on
December 9, 2010 Downgraded to Caa2 (sf)

Cl. MB-1 Certificate, Downgraded to B2 (sf); previously on
December 9, 2010 Downgraded to Ba2 (sf)

Cl. MB-2 Certificate, Downgraded to B3 (sf); previously on
December 9, 2010 Downgraded to Ba3 (sf)

Cl. MB-3 Certificate, Downgraded to Caa1 (sf); previously on
December 9, 2010 Downgraded to B1 (sf)

Cl. MB-4 Certificate, Downgraded to Caa2 (sf); previously on
December 9, 2010 Downgraded to B2 (sf)

Cl. CM Certificate, Affirmed at C (sf); previously on December 9,
2010 Downgraded to C (sf)

Cl. X-1B Certificate, Affirmed at Aaa (sf); previously on October
3, 2006 Definitive Rating Assigned Aaa (sf)

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 downgrades
are due to the worse than expected performance of the 400 McArthur
loan. Moody's does not rate pooled classes D, E, F, G, H, J, K and
L which provide additional credit support for the more senior
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 CMBS Large Loan/Single Borrower Transactions"
published on July 2000.

Moody's review incorporated the use of the excel-based Large Loan
Model v 8.2. 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 December 9, 2010.

DEAL PERFORMANCE

As of the October 17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased to $2.19 billion from
$2.64 billion at last review. The Certificates are collateralized
by eight floating rate whole loans and senior interests in whole
loans. The loans range in size from 1% to 44% of the pooled
balance, with the top three loans representing approximately 86%
of the pooled balance. All of the loans have matured or have final
maturity dates in 2011, and are currently specially serviced.

Moody's weighted average pooled LTV ratio is 98% compared to 96%
at last review. Moody's weighted average stressed DSCR for pooled
trust debt is 1.19X compared to 1.14X at last review. Outstanding
servicer advances for this transaction total $16.1 million.
Interest shortfalls totaling $9,121 affecting the rake classes
associated with the 4000 MacArthur Boulevard Loan (MB-1, MB02, MB-
3 and MB-4) have been incurred to the trust as of the October 2011
distribution date. The pool has not experienced any losses.

The largest loan in the pool is secured by a fee and leasehold
interests in Kyo-Ya Hotel Pool Loan ($840 million, or 44% of the
pooled balance plus $123 million of rake bonds within the trust).
The hotel portfolio includes five properties located in Hawaii
(Honolulu and Maui) and the sixth asset, the Palace Hotel, is
located in San Francisco. Two hotel properties located in Orlando
were released from the portfolio in 2007. The sponsor is Cerberus
Capital Management. There is additional debt in the form of non-
trust junior component and mezzanine debt outside the trust. The
loan matured in July 2011, and a forbearance agreement has been
executed between the borrower and the servicer. As part of the
agreement, principal paydown of $70 million was made to the pooled
portion of the loan at closing, and an additional $45 million
paydown by July 2012 was agreed. A curtailment payment of
approximately $6.1 million was made to the pooled portion in
September 2011. Forbearance period will continue through July
2013.

For the trailing twelve month period ending July 2011, the Kyo-Ya
Hotel Pool Loan achieved an EBITDA of $141 million, up 47% from
$96 million achieved during the trailing twelve month period
ending July 2010. Moody's weighted average LTV for the pooled
portion is 78% and including rakes is 90% compared to 84% and 95%,
respectively, at last review. Moody's current credit estimate for
the pooled portion is B1 compared to last review of B2.

The Boca Resort Hotel Pool Loan ($632 million, or 33% of pooled
balance plus $148 million of rake bonds within the trust) is
secured by five hotel properties and one golf course located in
Boca Raton, Ft. Lauderdale and Naples, FL. The sponsor is The
Blackstone Group. Moody's does not rate the four rake bonds
associated with this loan (Classes BH-1, BH-2, BH-3 and BH-4).
There is additional debt in the form of non-trust junior component
and mezzanine debt outside the trust. The loan matured in August
2011, and a forbearance agreement has been executed between the
borrower and the servicer. As part of the agreement, principal
paydown of $20 million was made to the pooled portion of the loan,
and an additional $30 million paydown is expected by August 2012.
During the second forbearance year, an additional $7.5 million
payment to the senior loan will be made. Forbearance period will
continue through August 2013.

For the trailing twelve month period ending May 2011, the Boca
Resort Hotel Pool Loan achieved Net Cash Flow (NCF) of $53
million, up from $44 million achieved during the trailing twelve
month period ending December 2010. Moody's weighted average LTV
for the pooled portion is 121%, and including rakes is 150%, same
as last review. Moody's current credit estimate for the pooled
portion is Caa1, the same as last review.

The Westin Aruba Resort & Spa Loan ($97 million, or 5% of pooled
balance plus $3.3 million of rake bond within the trust) has been
in special servicing since November 2008, and matured in April
2009. In May 2009, the trust foreclosed on the Deed of Pledges of
the parent entity of the borrower and the borrower to minimize
Aruba specific tax implications. In addition to the outstanding
P&I advances totaling $15.9 million as of the October 2011
distribution date, there are certain legal and tax issues that
remain unresolved at this time that may result in increased loss
severity for this loan. Mody's current credit estimate for this
loan is C, the same as last review.


WELLS FARGO: Fitch Affirms 'Bsf' Rating on Class F Certificate
--------------------------------------------------------------
Fitch Ratings has affirmed all classes of Wells Fargo Bank N.A.'s
commercial mortgage pass-through certificates, series 2010-C1.

The affirmations reflect stable portfolio performance since
issuance.  Fitch has not designated any loans as Fitch Loans of
Concern, nor has there been any specially serviced or delinquent
loans.  As of the October 2011 distribution date, the pool's
aggregate principal balance has been reduced by 1.28% to
$726.4 million from $735.9 million at issuance.

Park Bridge Financial, as subordinate class representative, has
identified reporting inconsistencies by Wells Fargo, the Master
Servicer, which are currently being resolved.

The largest loan in the pool (25.06%) is secured by a portfolio of
14 properties which consist of: seven office buildings, five
industrial distribution centers, one data center and one R&D
facility.  The properties are located in various states and are
all single-tenant properties with a combined size of 3.6 million
square feet.  The portfolio remains 100% occupied, as it was at
issuance.

The second-largest loan in the pool (7.55%) is secured by a
regional mall located in Watertown, NY.  The property is 91%
occupied compared to 93.6% at issuance.  The largest anchors are:
Sears, Burlington Coat Factory, and Gander Mountain.

The third largest loan in the pool (6.24%) is secured by an
anchored retail center located in Columbus, OH.  The property is
97% leased, as it was at issuance.  The largest tenants are:
Kroger, Jo-Ann Etc., and Best Buy.

Fitch affirms these classes:

   -- $152.6 million class A-1 at 'AAAsf'; Outlook Stable;
   -- $443.3 million class A-2 at 'AAAsf'; Outlook Stable;
   -- $596.7 million class X-A at 'AAAsf'; Outlook Stable;
   -- $22.1 million class B at 'AA'; Outlook Stable;
   -- $31.3 million class C at 'Asf'; Outlook Stable;
   -- $34.0 million class D at 'BBBsf'; Outlook Stable;
   -- $13.8 million class E at 'BBB-sf'; Outlook Stable;
   -- $12.9 million class F at 'Bsf'; Outlook Stable.

Fitch does not rate class G or X-B.


WELLS FARGO: S&P Raises Ratings on 3 Classes From 'D' to 'CC'
-------------------------------------------------------------
Standard & Poor's Ratings Services corrected its ratings on
classes A-1, A-2, and A-4 from Wells Fargo Mortgage Backed
Securities 2006-AR3 Trust by raising them to 'CC (sf)' from
'D (sf)'.

"On Sept. 23, 2011, we lowered our ratings on these classes based
on the trustee's August 2011 remittance report, which indicated
that these classes had experienced a principal write-down.
However, the trustee subsequently issued a revised remittance
report, which removed the realized loss amounts previously
allocated to these classes," S&P related.

"The corrected ratings reflect our view that the current projected
credit support will likely be insufficient to meet the projected
loss amount for these classes," S&P said.

Ratings Corrected

Wells Fargo Mortgage Backed Securities 2006-AR3 Trust
Mortgage pass through certificate series 2006-AR3
                                Rating
Class      CUSIP       Current  09/23/2011  Pre-09/23/2011
A-1        94983GAA6   CC (sf)  D (sf)      CC (sf)
A-2        94983GAB4   CC (sf)  D (sf)      CC (sf)
A-4        94983GAD0   CC (sf)  D (sf)      CC (sf)


WFRBS 2011: Moody's Assigns (P)Ba2 Rating to Cl. F Notes
--------------------------------------------------------
Moody's Investors Service has assigned provisional to ratings
thirteen classes of CMBS securities, issued by WFRBS Commercial
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2011-C5.

Cl. A-1, Assigned (P) Aaa (sf)

Cl. A-2, Assigned (P) Aaa (sf)

Cl. A-3, Assigned (P) Aaa (sf)

Cl. A-4, Assigned (P) Aaa (sf)

Cl. A-S, Assigned (P) Aaa (sf)

Cl. B, Assigned (P) Aa2 (sf)

Cl. C, Assigned (P) A2 (sf)

Cl. D, Assigned (P) Baa1 (sf)

Cl. E, Assigned (P) Baa3 (sf)

Cl. F, Assigned (P) Ba2 (sf)

Cl. G, Assigned (P) B2 (sf)

Cl. X-A, Assigned (P) Aaa (sf)

Cl. X-B, Assigned (P) Aaa (sf)

RATINGS RATIONALE

The Certificates are collateralized by 75 fixed rate loans secured
by 98 properties. The ratings are based on the collateral and the
structure of the transaction.

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

The credit risk of loans is determined primarily by two factors:
1) Moody's assessment of the probability of default, which is
largely driven by each loan's DSCR, and 2) Moody's assessment of
the severity of loss upon a default, which is largely driven by
each loan's LTV ratio.

The Moody's Actual DSCR of 1.37X is higher than the 2007
conduit/fusion transaction average of 1.31X. The Moody's Stressed
DSCR of 1.05X is higher than the 2007 conduit/fusion transaction
average of 0.92X. Moody's Trust LTV ratio of 98.3% is lower than
the 2007 conduit/fusion transaction average of 110.6%. Moody's
Total LTV ratio (inclusive of subordinated debt) of 99.8% is also
considered when analyzing various stress scenarios for the rated
debt.

Moody's also considers both loan level diversity and property
level diversity when selecting a ratings approach. With respect to
loan level diversity, the pool's loan level (includes cross
collateralized and cross defaulted loans) Herfindahl Index is
16.7. The transaction's loan level diversity is lower than the
band of Herfindahl scores found in most multi-borrower
transactions issued since 2009. With respect to property level
diversity, the pool's property level Herfindahl Index is 17.8. The
transaction's property diversity profile is lower than the indices
calculated in most multi-borrower transactions issued since 2009.

Moody's also grades properties on a scale of 1 to 5 (best to
worst) and considers those grades when assessing the likelihood of
debt payment. The factors considered include property age, quality
of construction, location, market, and tenancy. The pool's
weighted average property quality grade is 2.09, which is better
than the indices calculated in most multi-borrower transactions
since 2009.

The principal methodology used in rating WFRBS 2011-C5 was "CMBS:
Moody's Approach to Rating Fusion Transactions" rating methodology
published in April 2005. Other methodologies and factors that may
have been considered in the process of rating this issuer can also
be found on Moody's website.

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

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

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

Moody's Parameter Sensitivities: If Moody's value of the
collateral used in determining the initial rating were decreased
by 5%, 14%, or 23%, the model-indicated rating for the currently
rated Super Senior Aaa classes and the rated Aaa A-S class would
be Aaa, Aaa, and Aa1 and Aa1, Aa2, and A1, respectively. Parameter
Sensitivities are not intended to measure how the rating of the
security might migrate over time; rather they are designed to
provide a quantitative calculation of how the initial rating might
change if key input parameters used in the initial rating process
differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.

These ratings: (a) are based solely on information in the public
domain and/or information communicated to Moody's by the issuer at
the date it was prepared and such information has not been
independently verified by Moody's; (b) must be construed solely as
a statement of opinion and not a statement of fact or an offer,
invitation, inducement or recommendation to purchase, sell or hold
any securities or otherwise act in relation to the issuer or any
other entity or in connection with any other matter. Moody's does
not guarantee or make any representation or warranty as to the
correctness of any information, rating or communication relating
to the issuer. Moody's shall not be liable in contract, tort,
statutory duty or otherwise to the issuer or any other third party
for any loss, injury or cost caused to the issuer or any other
third party, in whole or in part, including by any negligence (but
excluding fraud, dishonesty and/or willful misconduct or any other
type of liability that by law cannot be excluded) on the part of,
or any contingency beyond the control of, Moody's, or any of its
employees or agents, including any losses arising from or in
connection with the procurement, compilation, analysis,
interpretation, communication, dissemination, or delivery of any
information or rating relating to the issuer.


WHITEHORSE II: S&P Raises Rating on Class B-1L Notes to 'BB+'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1L, A-2L, A-3L, and B-1L notes from Whitehorse II Ltd., a
U.S. collateralized loan obligation (CLO) transaction managed by
WhiteHorse Capital Partners L.P. "At the same time, we removed
our ratings on the class A-1L, A-2L, A-3L, and B-1L notes from
CreditWatch, where we placed them with positive implications on
Aug. 2, 2011," S&P related.

"The upgrades reflect a paydown to the class A-1L notes and the
improved performance we have observed in the deal's underlying
asset portfolio since our April 2010 rating actions (see '42
Ratings Lowered On Nine U.S. CLO Transactions That Experienced
Note Cancellations; $4.95 Billion Of Issuance Affected,' published
April 26, 2010). Since that time, the transaction has paid down
the class A-1L notes by approximately $138 million, reducing the
balance to about 40% of the original balance. According to the
Oct. 5, 2011, trustee report, the transaction's asset portfolio
did not hold any defaulted assets, down from the $16 million noted
in the February 2010 trustee report," S&P said.

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

Rating And CreditWatch Actions

Whitehorse II Ltd.
                         Rating
Class                To           From
A-1L                 AAA (sf)     AA- (sf)/Watch Pos
A-2L                 AA+ (sf)     A- (sf)/Watch Pos
A-3L                 A+ (sf)      BB+ (sf)/Watch Pos
B-1L                 BB+ (sf)     CCC+ (sf)/Watch Pos


WORLD OMNI: Moody's Assigns Provisional Ratings to 5 Notes Classes
------------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings of (P)
Prime-1 and (P) Aaa to the four classes of senior notes, and (P)
A2 the subordinate notes to be issued by World Omni Auto
Receivables Trust 2011-B (WOART 2011-B).

Class A-1 Asset Backed Notes, rated (P)Prime-1 (sf)

Class A-2 Asset Backed Notes, rated (P)Aaa (sf)

Class A-3 Asset Backed Notes, rated (P)Aaa (sf)

Class A-4 Asset Backed Notes, rated (P)Aaa (sf)

Class B Asset Backed Notes, rated (P)A2 (sf)

RATINGS RATIONALE

The principal methodology used in this rating was Moody's Approach
to Rating U.S. Auto Loan-Backed Securities, ratings methodology
published in May 2011.

Moody's median cumulative net loss expectation is 1.75% and the
Aaa Level is 10.00% for the WAORT 2011-B pool. Moody's net loss
expectation and Aaa Level for the WAORT 2011-B transaction is
based on an analysis of the credit quality of the underlying
collateral, historical performance trends, the ability of World
Omni Financial Corp. (World Omni) to perform the servicing
functions, and current expectations for future economic
conditions.

The V Score for this transaction is Low/Medium, which is in-line
with the Low/Medium V score assigned for the U.S. Prime Retail
Auto Loan ABS sector. The V Score indicates "Low/Medium"
uncertainty about critical assumptions.

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

Moody's Parameter Sensitivities: If the net loss used in
determining the initial ratings were changed to 3.00%, 4.75%, or
6.50%, the initial model-indicated output for the Class A notes
might change from Aaa to Aa1, A1, and Baa1, respectively. If the
net loss used in determining the initial ratings were changed to
2.00%, 2.75%, or 3.75%,the initial model-indicated output for the
Class B notes might change from A2 to A3, Baa3, and Ba3,
respectively.

Parameter Sensitivities are not intended to measure how the rating
of the security might migrate over time, rather they are designed
to provide a quantitative calculation of how the initial rating
might change if key input parameters used in the initial rating
process differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.

Additional research including a pre-sale report for this
transaction is available at www.moodys.com. The special reports,
"Updated Report on V Scores and Parameter Sensitivities for
Structured Finance Securities" and "V Scores and Parameter
Sensitivities in the U.S. Vehicle ABS Sector" are also available
on moodys.com.


* S&P Raises Ratings on 8 Ford Motor-Related Transactions to 'BB+'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on eight
Ford Motor Co.-related repack transactions to 'BB+' from 'BB-' and
removed them from CreditWatch, where S&P placed them with positive
implications on Oct. 7, 2011.

All of the transactions are pass-through structures. The ratings
on each deal are dependent on the ratings on one of the underlying
securities: Ford Motor Co.'s 7.7% debentures due May 15, 2097
('BB+'); Ford Motor Co.'s 7.45% Global Landmark Secs (GlobLS)
notes due July 16, 2031 ('BB+'); and Ford Motor Co.'s 7.4%
debentures due Nov. 1, 2046 ('BB+').

"The upgrades follow our Oct. 21, 2011, raising of our ratings on
the three underlying securities to 'BB+' from 'BB-' and their
removal from CreditWatch with positive implications. We may take
subsequent rating actions on these transactions due to changes in
our ratings on the underlying securities," S&P related.

                          Rating
Class              To                  From
A1                 BB+                 BB-/Watch Pos

CorTS Trust For Ford Debentures
$300 million 7.4% pass-through due Nov. 1, 2046 (underlying
security: Ford Motor Co.'s 7.4% debentures due Nov. 1, 2046)
                          Rating
Class              To                  From
Certs              BB+                 BB-/Watch Pos

CorTS Trust II For Ford Notes
$219.584 million 8% pass-through series 2003-3 due July 16, 2031
(underlying security: Ford Motor Co.'s 7.45% Global Landmark Secs
(GlobLS) notes due July 16, 2031)
                           Rating
Class              To                  From
Certs              BB+                 BB-/Watch Pos

PPLUS Trust Series FMC-1
$40 million 8.25% pass-through series FMC-1 due July 16, 2031
(underlying security: Ford Motor Co.'s 7.45% Global Landmark Secs
(GlobLS) notes due July 16, 2031)
                           Rating
Class              To                  From
Certs              BB+                 BB-/Watch Pos

PreferredPlus Trust Series FRD-1
$50 million trust certificates series FRD-1 (underlying security:
Ford Motor Co.'s 7.4% debentures due Nov. 1, 2046)
                          Rating
Class              To                  From
Certs              BB+                 BB-/Watch Pos

Public STEERS Series 1998 F-Z4 Trust
$231.903 million pass-through series 1998 F-Z4 due Nov. 15, 2018
(underlying security: Ford Motor Co.'s 7.7% debentures due May 15,
2097)
                           Rating
Class              To                  From
A                  BB+ (sf)            BB-/ (sf) Watch Pos
B                  BB+ (sf)            BB-/ (sf) Watch Pos

SATURNS Trust No. 2003-5
$75.027 million 8.125% pass-through series 2003-5 due July 16,
2031 (underlying security: Ford Motor Co.'s 7.45% Global Landmark
Secs (GlobLS) notes due July 16, 2031)
                          Rating
Class              To                  From
Units              BB+                 BB-/Watch Pos

Trust Certificates (TRUCs) Series 2002-1 Trust
$32 million 7.7% pass-through series 2002-1 due May 15, 2097
(underlying security: Ford Motor Co.'s 7.7% debentures due May 15,
2097)
                           Rating
Class              To                  From
A-1                BB+                 BB-/Watch Pos


* S&P Lowers Ratings on Six Classes of Certificates to 'D'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 10
classes of commercial mortgage pass-through certificates from two
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 six of these classes to 'D (sf)'
because we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. The six classes have had
accumulated interest shortfalls outstanding between one and 14
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 loans;

    The lack of servicer advancing for loans where the servicer
    has made nonrecoverable advance declarations;

    Special servicing fees; and

    Interest rate reductions or deferrals resulting from loan
    modifications.

Standard & Poor's analysis primarily considered the ASER amounts
based on appraisal reduction amounts (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals. "We
also considered servicer nonrecoverable advance declarations and
special servicing fees that are likely, in our view, to cause
recurring interest shortfalls," S&P related.

The servicer implements ARAs and resulting ASER amounts according
to each respective transaction's terms. Typically, these terms
call for the automatic implementation of an ARA equal to 25%
of the stated principal balance of a loan when it is 60 days
delinquent 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 said.

Servicer nonrecoverable advance declarations can prompt
shortfalls due to a lack of debt service advancing, the recovery
of previously made advances deemed nonrecoverable, or the failure
to advance trust expenses when nonrecoverable declarations have
been determined. Trust expenses may include, but are not limited
to, property operating expenses, property taxes, insurance
payments, and legal expenses," S&P said.

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

               GS Mortgage Securities Trust 2006-GG6

"We lowered our ratings on the class E, F, G, H, and J
certificates from GS Mortgage Securities Trust 2006-GG6. We
lowered our ratings on classes G, H, and J to 'D (sf)' because of
accumulated interest shortfalls outstanding between one and 14
months due to ASER amounts related to nine ($197.4 million, 6.2%)
of the 23 assets ($760.6 million, 23.7%) that are currently with
the special servicer, Torchlight Loan Services LLC, as well as
special servicing fees ($156,710) and interest rate reductions
due to loan modifications ($327,772). We lowered our rating on
class F to 'CCC- (sf)' due to reduced liquidity support and the
potential for this class to continue experiencing interest
shortfalls relating to the specially serviced asset. Class F
has had accumulated interest shortfalls outstanding for one month.
We downgraded class E to 'B- (sf)' due to reduced liquidity
support available to this class resulting from the recurring
interest shortfalls," S&P related.

As of the Oct. 13, 2011 trustee remittance report, ARAs totaling
$90.1 million were in effect for nine assets and the total
reported monthly ASER amount was $453,433. The reported monthly
interest shortfalls totaled $1,066,017 and have affected all of
the classes subordinate to and including class F.

JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC19

"We lowered our ratings on the class D, E, F, G, and H
certificates from JPMorgan Chase Commercial Mortgage Securities
Trust 2007-CIBC19. We lowered our ratings on classes F, G, and H
to 'D (sf)' due to accumulated interest shortfalls outstanding for
seven to 14 months. The current interest shortfalls resulted
primarily from ASER amounts related to 18 ($271.2 million, 8.7%)
of the 21 assets ($344.4 million, 11.1%) that are currently with
the special servicer, LNR Partners LLC, as well as special
servicing fees ($71,793). We lowered our rating on class E to
'CCC- (sf)' due to reduced liquidity support and the potential for
this class to experience interest shortfalls resulting from the
specially serviced assets. We downgraded class D to 'B- (sf)' due
to reduced liquidity support available to this class resulting
from the recurring interest shortfalls," S&P said.

As of the Oct. 12, 2011 trustee remittance report, ARAs totaling
$136.1 million were in effect for 18 specially serviced assets
resulting in a total reported monthly ASER amount of $622,641. In
addition, two loans were deemed nonrecoverable resulting in
interest not being advanced amounting to $189,545. The reported
monthly interest shortfalls totaled $661,952, net of the $250,781
ASER recovery for this period, and have affected all of the
classes subordinate to and including class G.

Ratings Lowered

GS Mortgage Securities Trust 2006-GG6
Commercial mortgage pass-through certificates

                              Credit        Reported
          Rating         enhancement   interest shortfalls ($)
Class  To        From            (%)     Current  Accumulated
E      B- (sf)   B+ (sf)        8.46           0            0
F      CCC- (sf) B+ (sf)        7.09      19,583       19,583
G      D (sf)    CCC+ (sf)      5.88     183,139      183,139
H      D (sf)    CCC- (sf)      4.66     183,144    1,141,457
J      D (sf)    CCC- (sf)      3.29     206,035    2,201,330

JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC19
Commercial mortgage pass-through certificates


                              Credit        Reported
          Rating         enhancement   interest shortfalls ($)
Class  To        From            (%)     Current  Accumulated
D      B- (sf)   B+ (sf)        7.20           0            0
E      CCC- (sf) B+ (sf)        5.62           0            0
F      D (sf)    CCC+ (sf)      4.43    (14,656)      114,845
G      D (sf)    CCC- (sf)      3.12     195,803    2,135,279
H      D (sf)    CCC- (sf)      2.06     156,642    2,225,325


* S&P Lowers Ratings on 955 Classes From 89 US RMBS Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 955
classes from 89 U.S. residential mortgage-backed securities (RMBS)
transactions and removed 615 of them from CreditWatch with
negative implications. "Concurrently, we affirmed our ratings
on 222 classes from these transactions and removed 65 of them from
CreditWatch negative. We also withdrew our ratings on 35 classes
from 18 transactions based on our interest-only (IO) criteria and
removed 34 of them from CreditWatch negative," S&P related.

The complete rating list is available in "U.S. RMBS
Classes Affected By The Oct. 31, 2011, Rating Actions,"
published on RatingsDirect on the Global Credit Portal, at
www.globalcreditportal.com. The list is also available on
Standard & Poor's Web site, at www.standardandpoors.com. On
the home page, under Ratings Resources, click on Ratings
Actions, then select Structured Finance.

The 89 RMBS transactions in this review are backed by Alternative-
A (Alt-A) or prime jumbo mortgage loan collateral issued from 2005
through 2007.

"On May 11, 2011, we placed a number of U.S. RMBS ratings on
CreditWatch with negative implications (see '7,389 Ratings From
2005-2007 U.S. Prime, Subprime, And Alt-A RMBS On Watch Neg Due To
Revised Loss Projections'). For revised transaction specific loss
projections associated with these transactions, see 'RMBS:
Transaction-Specific Lifetime Loss Projections For Prime,
Subprime, And Alternative-A U.S. RMBS Issued In 2005-2007,'
published June 27, 2011," S&P said.

"The downgrades reflect our belief that projected credit
enhancement for the affected classes will be insufficient to cover
the projected losses we applied at the applicable rating stresses.
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
said.

"The rating actions take transaction specific loss projections
where applicable and the criteria associated for additional
transactions into account. In order to maintain a 'B' rating on a
class, we assessed whether, in our view, a class could absorb the
remaining base-case loss assumptions we used in our analysis. For
Alt-A transactions, 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 a '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, while we would assess whether a different
class could withstand approximately 120% of our remaining base-
case loss assumptions to maintain a 'BBB' rating. Each class
with an affirmed 'AAA' rating can, in our view, withstand
approximately 150% of our remaining base-case loss assumptions
under our analysis. For prime jumbo transactions, we assessed
whether a class could withstand 127% of our base-case loss
assumption in order to maintain a 'BB' rating, while we assessed
whether a different class could withstand 154% of our base-case
loss assumptions to maintain a 'BBB' rating. Each class that has
an affirmed 'AAA' rating can withstand approximately 235% of our
base-case loss assumptions," S&P said.

"As part of our review, the Lehman Mortgage Trust 2006-1 and
Structured Asset Securities Corp. Mortgage Pass-Through
Certificates Series 2005-15 transactions each contain a real
estate mortgage investment conduit (re-REMIC) structure. For these
structures we analyzed the underlying collateral associated with
these structures and applied our methodology which can be found in
'Methodology For The Surveillance Of U.S. RMBS Re-REMIC
Transactions,' published Dec. 23, 2008," S&P said.

For additional structure-level information regarding delinquencies
and cumulative losses for these transactions through the September
2011 remittance period please see:

Losses And Delinquencies*

Adjustable Rate Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-10       709   42.06    4.39          14.61          12.58
2005-10       386   21.45   12.58          34.49          31.64
2005-7        714   37.98    4.97          13.88          12.18
2005-7        418   18.24    8.25          28.92          25.33
2005-8      1,019   43.82    4.16          19.61          17.28

Alternative Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-18CB     749   42.95    1.11          18.41          12.88
2005-23CB     724   41.45    1.30          15.98          12.19
2005-27     1,562   28.06    6.25          58.65          53.86
2005-28CB     842   41.56    2.11          24.77          19.73
2005-44       801   25.14    7.29          55.26          49.42
2005-76     1,802   35.46   10.56          63.74          58.08
2006-OA16   1,351   52.58   13.59          63.02          56.94

American Home Mortgage Investment Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2      1.379   37.59    6.78          18.73          15.57
2005-2      4.140   24.50    6.81          21.49          17.74
2005-3        737   30.40    6.92          21.36          17.39

Banc of America Funding Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-6        718   41.45    2.12          13.66          10.33

Banc of America Funding Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-6        488   41.53    1.31           8.14           4.97
2005-E        977   26.56    2.48          18.09          15.30
2005-E        432   21.26    5.06          60.42          54.67
2005-G        232   49.43    1.32           6.80           6.10
2006-7        334   40.07    2.34          18.04          14.63
2006-7        404   38.92   15.09          41.44          33.27
2007-C        314   57.99    5.04          15.94          10.77
2007-C        643   55.30    6.71          37.74          31.18
2007-C      2.562   53.53    1.97          13.01           9.59

Banc of America Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-10       545   47.70    0.65          10.94           9.33

Bear Stearns Mortgage Funding Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2007-AR5      690   67.11   14.23          45.02          39.30
2007-AR5      442   49.34    9.69          55.80          49.74

Chase Mortgage Finance Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-S4       530   44.69    3.60          17.92          14.60
2007-S1       430   50.25    3.57          22.20          19.72

CHL Mortgage Pass-Through Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-11       635   21.01    4.07          50.60          46.53
2005-11       493   13.44    0.95          54.89          54.89
2005-11       165   24.78    4.02          17.01          14.46
2006-3        567   28.37    9.69          68.34          63.30
2006-3        262   36.36   11.12          75.13          70.01
2006-3        230   34.45   11.50          75.34          71.65

Credit Suisse First Boston Mortgage Securities Corp.
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2        299   34.51    0.31           8.44           7.66
2005-2        177   31.18    1.08          20.25          18.53
2005-3        282   35.64    2.56          18.22          16.13
2005-3        743   34.00    0.42           5.49           4.58
2005-6        194   28.33    0.02           5.59           5.18
2005-6        332   43.94    2.86          13.66          11.39
2005-10       210   49.06    1.46          19.19          16.60
2005-10       324   27.96    0.36           8.41           7.54
2005-10       622   47.12    7.78          24.59          20.41
2005-11       318   43.94    9.65          22.04          18.36
2005-11       369   43.68    0.62          10.28           8.60

CSMC Mortgage Backed Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2007-5        681   70.40    0.07          18.07          14.34
2007-5        378   56.02   19.70          39.42          34.10

Deutsche Alt-A Securities
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-AR2      661   34.62    6.06          20.04          17.68

DSLA Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-AR3      950   23.64    7.72          30.64          23.46
2006-AR2    1,210   38.17   18.32          34.92          24.06

First Horizon Alternative Mortgage Securities Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-FA5      465   41.83    1.57          15.48          12.35

GMACM  Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-J1       526   48.34    1.18           8.82           5.33

GreenPoint MTA Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-AR3    1,000   20.16    9.51          46.11          39.90

GSR Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-1F       692   31.40    0.57          10.93           7.98
2005-7F       423   34.77    0.76           6.63           5.91
2005-AR6    2,802   37.68    0.93           7.84           5.59
2006-AR2      907   47.18    4.38          17.94          13.50
2007-AR1    1,745   44.52    5.53          23.63          19.73

Harborview Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-10     2,300   33.38    7.31          51.41          48.17
2005-11       687   23.66    8.41          21.53          16.30
2005-8      1,287   25.26    6.78          54.04          51.28
2005-8      1,250   34.81    7.40          55.93          52.90

J.P. Morgan Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2007-A6       783   42.50    2.77          18.43          14.69

JPMorgan Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-A1       831   42.48    3.35          22.33          18.32

Lehman Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-1        957   50.34    2.72          12.68           8.81
2006-1        284   52.66    6.64          20.70          14.61
2006-1        223   53.62    2.47          13.33          10.38

Lehman XS Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-5N     2,757   25.38   10.19          35.01          30.42
2005-6        383   40.97    8.53          22.86          18.36
2005-6        556   18.69   14.11          33.86          29.09

MASTR Adjustable Rate Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-2        750   36.60    2.83          12.01           8.26

MASTR Alternative Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-6        685   50.84    3.03          18.67          13.43

MASTR Asset Backed Securities Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-AB1      782   39.71    7.00          28.24          23.79

MASTR Asset Securitization Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-2        339   43.39    0.56           9.40           5.08

Merrill Lynch Mortgage Investors Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-A5       731   42.93    0.91          13.51          10.06
2005-A8     1,013   38.92    5.28          28.92          22.94

Merrill Lynch Mortgage Investors Trust MLMI
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-A7       463   46.32    1.52          13.05          10.89

Merrill Lynch Mtg Investors Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2006-3        538   31.07    0.83          10.66           6.12

Morgan Stanley Mortgage Loan Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-1        441   34.95    0.74          11.02           8.47
2005-4        672   47.35    2.13          12.58           9.12

MortgageIT Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-5        905   40.74   11.41          14.17          10.69

Opteum Mortgage Acceptance Corporation
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-5        986   37.48   11.85          18.24          14.58

Prime Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-4        264   41.74    1.35          21.12          16.44
2005-4        171   26.54    0.00           3.53           2.33

RAAC Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-SP1      831   27.09    0.11           5.36           4.62

RALI
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-QS12     529   43.49    4.30          17.83          12.79

RALI Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-QA4      525   30.79    5.68          14.99           9.40
2005-QS2      213   40.47    1.86          15.37          11.43

Residential Asset Securitization Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-C        252   36.64    2.38          16.40           9.45

RFMSI Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-S2       261   36.58    0.91           4.09           3.18
2005-S6       413   43.70    0.57           5.63           2.92
2005-S9       367   41.13    3.05           9.79           5.70
2005-SA1      295   20.71    1.42           6.11           4.35
2006-S1       367   43.46    2.99          14.94           7.10
2007-S1       523   48.24    3.97          12.30           6.93

Structured Asset Securities Corporation Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-1      1,300   38.40    0.72           9.25           6.59
2005-5        855   45.33    1.55          10.06           8.07
2005-6      1,704   33.55    0.63           7.89           4.01
2005-15       264   52.39    1.00           6.36           6.10
2005-15       784   47.92    2.08          12.71          10.31
2005-4XS      295   37.75    0.46           8.84           8.59
2005-4XS      465   28.78    3.88          28.76          24.54

Terwin Mortgage Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-12ALT    315   19.42   10.33          21.93          16.27
2006-9HGA     400   35.65   20.24          21.38          15.96

WAMU Mortgage Pass-Through Certificates Trust
         Original    Pool    Cum.          Total         Severe
          balance  factor  losses  delinquencies  delinquencies
Series   (mil. $)     (%)     (%)            (%)            (%)
2005-AR12   1,054   47.49    1.57          17.64          14.43
2005-AR15   2,568   33.56    4.90          36.19          30.22
2005-AR17   1,591   31.30    5.09          34.92          30.24
2006-AR1    1,516   31.83    5.74          36.18          31.30
2006-AR11     580   50.01   11.78          36.56          30.67
2006-AR11   1,057   47.56    7.36          36.37          30.23
2006-AR17   1,136   52.53    8.36          40.43          34.55
2006-AR4      932   32.63    5.70          35.55          28.80
2006-AR5      797   40.45    8.11          41.01          35.39

*Original balance represents the original collateral balance for
the structure represented. Pool factor represents the percentage
of the original pool balance remaining. Cumulative losses are a
percentage of the original pool balance, and total and severe
delinquencies are percentages of the current pool balance.

The information shows average pool factor, cumulative loss, and
total and severe delinquency information by vintage for Alt-A
collateral as of the September 2011 distribution period.

2005 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
      30.55        6.09              30.64              25.78

2006 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
      41.60       13.98              40.58              35.09

2007 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
      54.68       14.20              39.92              34.16


The information below shows average pool factor, cumulative loss,
and total and severe delinquency information by vintage for prime
jumbo collateral as of the September 2011 distribution period.

2005 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
      37.23        1.82              13.68              10.83

2006 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
      42.19        3.30              18.47              14.88

2007 Vintage
    Average     Average            Average            Average
pool factor  cumulative              total             severe
        (%)  losses (%)  delinquencies (%)  delinquencies (%)
      49.84        3.46              19.27              15.62

Subordination, overcollateralization (prior to its depletion), and
excess spread, when applicable, provide credit support for the
affected transactions.


* S&P Lowers Ratings on 15 Classes of Certificates to 'D'
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 24
classes of commercial mortgage pass-through certificates from five
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 15 of these classes to 'D (sf)' because
we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. The classes that we
downgraded to 'D (sf)' have had accumulated interest shortfalls
outstanding between two and nine months," S&P related. 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;

    The lack of servicer advancing for loans where the servicer
    has made nonrecoverable advance declarations;

    Special servicing fees; and
    Interest rate reductions or deferrals resulting from loan
    modifications.

Standard & Poor's analysis primarily considered the ASER amounts
based on appraisal reduction amounts (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals. "We
also considered servicer nonrecoverable advance declarations and
special servicing fees that are likely, in our view, to cause
recurring interest shortfalls," S&P related.

The servicer implements ARAs and resulting ASER amounts in
accordance with each respective transaction's terms. Typically,
these terms call for the automatic implementation of an ARA equal
to 25% of the stated principal balance of a loan when a loan is 60
days past due and an appraisal or other valuation is not available
within a specified timeframe. "We primarily considered ASER
amounts based on ARAs calculated from MAI appraisals when deciding
which classes from the affected transactions to downgrade to 'D
(sf)' because ARAs based on a principal balance haircut are highly
subject to change, or even reversal, once the special servicer
obtains the MAI appraisals," S&P related.

Servicer nonrecoverable advance declarations can prompt shortfalls
due to a lack of debt service advancing, the recovery of
previously made advances deemed nonrecoverable, or the failure to
advance trust expenses when nonrecoverable declarations have been
determined. Trust expenses may include, but are not limited to,
property operating expenses, property taxes, insurance payments,
and legal expenses.

"We detail the 24 downgraded classes from the five U.S. CMBS
transactions," S&P said.

          Banc of America Commercial Mortgage Trust 2008-1

"We lowered our ratings on the class G, H, J, K, and L
certificates from Banc of America Commercial Mortgage Trust
2008-1. We lowered our ratings to 'D (sf)' on the class J, K,
and L certificates to reflect accumulated interest shortfalls
outstanding between seven and eight months. The interest
shortfalls are primarily from ASER amounts related to seven
($85.4 million, 6.9%) of the 10 assets ($96.3 million, 7.7%)
that are currently with the special servicer, CWCapital Asset
Management LLC (CWCapital), as well as special servicing fees
and interest rate reduction due to loan modifications ($30,188).
We downgraded classes G and H due to reduced liquidity support
available to these classes, resulting from continued interest
shortfalls. As of the Oct. 11, 2011, trustee remittance report,
ARAs totaling $50.1 million were in effect for seven assets and
the total reported monthly ASER amount on these assets was
$267,664. The reported monthly interest shortfalls totaled
$320,751 and have affected all of the classes subordinate to and
including class J," S&P said.

      Credit Suisse First Boston Mortgage Securities
                   Corp. Series 2005-C2

"We lowered our ratings on the class A-J, B, C, D, E, and F
certificates from Credit Suisse First Boston Mortgage Securities
Corp.'s series 2005-C2. We downgraded classes B, C, D, E, and F to
'D (sf)' to reflect accumulated interest shortfalls outstanding
for nine months, resulting primarily from ASER amounts related to
10 ($176.0 million, 13.9%) of the 12 ($179.7 million, 14.2%)
assets that are currently with the special servicer, CWCapital,
as well as special servicing fees. We downgraded class A-J due
to reduced liquidity support available to this class, resulting
from continued interest shortfalls. Class A-J has had accumulated
interest shortfalls outstanding for four months. As of the
Oct. 17, 2011 trustee remittance report, ARAs totaling
$113.6 million were in effect for 10 assets in the pooled
trust and the total reported monthly ASER amount on these
assets was $418,281. The reported monthly interest shortfalls
on the pooled trust totaled $483,307 and have affected all of
the classes subordinate to and including class B," S&P said.

   Credit Suisse Commercial Mortgage Trust Series 2006-C5

"We lowered our ratings on the class E, F, and G certificates
from Credit Suisse Commercial Mortgage Trust Series 2006-C5. We
downgraded class G to 'D (sf)' to reflect accumulated interest
shortfalls outstanding for six months, resulting primarily from
ASER amounts related to 18 ($201.4 million, 6.4%) of the 32
($544.2 million, 17.3%) assets that are currently with the special
servicer, LNR Partners LLC, as well as special servicing fees. We
lowered the ratings on classes E and F due to reduced liquidity
support available to these classes, resulting from continued
interest shortfalls. Class F has had accumulated interest
shortfalls outstanding for three months. As of the Oct. 17, 2011,
trustee remittance report, ARAs totaling $99.7 million were in
effect for 18 assets and the total reported monthly ASER amount on
these assets, net of $282,747 ASER recovery for this period, was
$223,358. The reported monthly interest shortfalls totaled
$453,939 and have affected all of the classes subordinate to and
including class F," S&P said.

   Wachovia Bank Commercial Mortgage Trust Series 2002-C2

"We lowered our ratings on the class J, K, L, M, N, and O
certificates from Wachovia Bank Commercial Mortgage Trust's series
2002-C2. We lowered our ratings on classes M, N, and O to 'D (sf)'
to reflect accumulated interest shortfalls outstanding between two
and three months, resulting primarily from reimbursement of the
master servicer's advances ($132,241) and interest rate reduction
from loan modifications ($17,012). We downgraded classes J, K, and
L due to reduced liquidity support available to these classes,
resulting from continued interest shortfalls. According to the
master servicer, Wells Fargo Bank N.A., it plans to continue
recouping the remaining advances totaling $1.3 million over time
on the Steeplecrest Apartments loan ($9.4 million, 1.4%), one of
the two loans ($22.4 million, 3.4%) with the special servicer,
Helios AMC LLC (Helios). As of the Oct. 17, 2011, trustee
remittance report, the reported monthly interest shortfalls
totaled $154,029 and have affected all of the classes subordinate
to and including class M," S&P said.

    Wachovia Bank Commercial Mortgage Trust Series 2006-C29

"We lowered our ratings on the class E, F, G, and H certificates
from Wachovia Bank Commercial Mortgage Trust's series 2006-C29.
We lowered our ratings on classes F, G, and H to 'D (sf)' to
reflect accumulated interest shortfalls outstanding for four
months, resulting primarily from ASER amounts related to 12
($232.7 million, 7.6%) of the 18 ($454.6 million, 14.9%) assets
that are currently with the special servicer, Helios, as well
as special servicing fees, interest not advanced due to a
nonrecoverable determination ($113,277), and interest reduction
due to rate modifications ($265,156). We downgraded class E due to
reduced liquidity support available to this class, resulting from
the continued interest shortfalls and the potential for this class
to continue experiencing interest shortfalls due to the specially
serviced assets. Class E has had accumulated interest shortfalls
outstanding for four months. As of the Oct. 17, 2011, trustee
remittance report, ARAs totaling $90.3 million were in effect for
12 assets and the total reported monthly ASER amount on these
assets was $381,436. The reported monthly interest shortfalls
totaled $866,699 and have affected all of the classes subordinate
to and including class F," S&P stated.

Ratings Lowered

Banc of America Commercial Mortgage Trust 2008-1
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement    Interest Shortfalls ($)
Class  To        From          (%)     Current   Accumulated
G      CCC (sf)  B+ (sf)      7.30           0             0
H      CCC- (sf) B+ (sf)      6.15      (9,587)            0
J      D (sf)    CCC+ (sf)    5.00      71,168       253,013
K      D (sf)    CCC- (sf)    3.85      74,377       542,397
L      D (sf)    CCC- (sf)    2.96      42,890       343,120

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2005-C2

                            Credit          Reported
          Rating       enhancement    Interest Shortfalls ($)
Class  To        From          (%)     Current   Accumulated
A-J    CCC- (sf) B (sf)       9.80     (35,880)       45,962
B      D (sf)    CCC+ (sf)    7.42     125,797       548,555
C      D (sf)    CCC (sf)     6.15      67,628       608,654
D      D (sf)    CCC- (sf)    3.92     119,776     1,077,986
E      D (sf)    CCC- (sf)    2.49      78,804       709,234
F      D (sf)    CCC- (sf)    0.90      80,089       720,799

Credit Suisse Commercial Mortgage Trust Series 2006-C5
Commercial mortgage pass-through certificates

                            Credit          Reported
          Rating       enhancement    Interest Shortfalls ($)
Class  To        From          (%)     Current   Accumulated
E      CCC (sf)  B- (sf)      6.23    (356,332)            0
F      CCC- (sf) CCC+ (sf)    5.14      63,544       382,001
G      D (sf)    CCC- (sf)    3.78     205,393     1,164,540

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2002-C2

                            Credit          Reported
          Rating       enhancement    Interest Shortfalls ($)
Class  To        From          (%)     Current   Accumulated
J      BB+ (sf)  BBB+ (sf)    9.15           0             0
K      B- (sf)   BBB (sf)     6.80           0             0
L      CCC+ (sf) BBB- (sf)    6.13           0             0
M      D (sf)    BB (sf)      4.79      25,575        53,981
N      D (sf)    BB- (sf)     3.61      31,530        75,753
O      D (sf)    B (sf)       2.66      25,390        76,169

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C29

                            Credit          Reported
          Rating       enhancement    Interest Shortfalls ($)
Class  To        From          (%)     Current   Accumulated
E      CCC- (sf) B+ (sf)      7.43    (162,078)       99,814
F      D (sf)    B+ (sf)      6.19     175,918       703,672
G      D (sf)    CCC- (sf)    4.94     177,846       721,403
H      D (sf)    CCC- (sf)    3.84     160,193       649,677

                           *********

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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