TCR_Public/120311.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, March 11, 2012, Vol. 16, No. 70

                            Headlines

AMMC VIII: S&P Withdraws 'BB' Rating on Class E Notes
APHEX 2007-5: S&P Lowers Ratings on 2 Classes to 'CCC-'; Off Watch
APHEX CAPITAL: Moody's Affirms Ca, C Ratings on $245MM Securities
APHEX CAPITAL: Moody's Cuts Ratings on $171MM Securities
APHEX CAPITAL: Moody's Downgrades Rating on Class A-2 Notes to Ca

ARCH ONE 2005-5: S&P Withdraws 'B+' Rating on Class ABBA Notes
AVALON IV: S&P Gives 'BB' Rating on Class E Deferrable Notes
AXIS EQUIPMENT: DBRS Assigns 'BB' Provisional Rating to Class D
BABSON MID-MARKET: S&P Raises Rating on Class E Notes to 'BB+'
BANC OF AMERICA: Increased Loss Prompts Fitch to Lower Ratings

BANC OF AMERICA: Moody's Affirms Ratings on 5 CBMS Classes at 'C'
BEAR STEARNS 2001-TOP4: S&P Raises Class H Cert. Rating From 'BB+'
BLUE HERON: Fitch Affirms 'Csf' Ratings on Six Note Classes
BLUE HERON: Moody's Cuts Rating on US$890MM Class A Notes to Caa3
C-BASS CBO: Fitch Affirms Junk Rating on Four Note Classes

CABELA'S CREDIT: DBRS Assigns 'BB' Final Rating to Class D
CABELA'S CREDIT: DBRS Puts 'BB' Provisional Rating to Class D
CABELA'S CREDIT: Fitch Changes Rating Outlook on Notes to Stable
CABELA'S CREDIT: Fitch Rates $13.75 Mil. Class D Notes at 'BB+sf'
CANNINGTON FUNDING: S&P Raises Rating on Class D Notes to 'BB+'

CAPMARK VII: Fitch Affirms Rating on All Note Classes
CENTERLINE 2007-SRR5: Moodys Keeps 'C' Ratings on 13 Note Classes
CHARLIE MAC: Moody's Cuts Rating on Class L Notes to 'C'
CITIGROUP COMM'L: Moody's Corrects Ratings on Two CMBS Classes
CMBSPOKE 2006-I: Moody's Cuts Rating on Class C Notes to Caa3(sf)

COMM 2004-LNB3: DBRS Confirms Classes L, M & N Ratings at 'C'
COMM 2012-LC4: Moody's Rates Class F Notes at '(P)B2 (sf)'
CREDIT SUISSE: Moody's Affirms Ratings on 2 Class Notes at 'C'
DEUTSCHE ALT-A: S&P Lowers Ratings on 2 Classes to 'D'
DEUTSCHE MORTGAGE: S&P Cuts Rating on Class 3-A-1 to 'CC'

EXETER 2012-1: S&P Gives 'BB' Rating on Class D Notes
EXETER AUTOMOBILE: DBRS Assigns 'BB' Final Rating to Class D
FIFTH THIRD: S&P Reinstates 'BB+' Preferred Stock Rating
FIRST INVESTORS: S&P Gives 'BB+' Rating on Class E Fixed Notes
FIRST UNION: Greater Certainty Prompts Fitch to Lower Ratings

FORE CLO 2007-1: S&P Affirms 'B+' Rating on Class D Notes
GALAXY III: S&P Affirms 'CCC-' Ratings on 3 Classes of Notes
GATEWAY CLO: S&P Raises Rating on Class B Notes to 'B+'
GE CAPITAL: Fitch Affirms Rating on Class O Notes at 'B-sf'
GE CAPITAL: Fitch Downgrades Rating on Class K Notes to 'Csf'

GMACM MORTGAGE: Moody's Cuts Rating on Class 5-A-II to 'Caa1(sf)'
GREEN TREE: Moody's Corrects Class A-7 Tranche Rating From 'Ba1'
GREENWICH CAPITAL: Moody's Cuts Rating on 2 Cert. Classes to 'C'
GREENWICH CAPITAL: Moody's Cuts Rating on Class N-SO CMBS to Caa3
GS MORGAGE: Fitch Affirms Rating on 15 Certificate Classes

HELLER FINANCIAL: Moody's Affirms Caa3(sf) Rating on Class X CMBS
JP MORGAN: Fitch Downgrades Rating on 10 Certificate Classes
JP MORGAN: Fitch Downgrades Rating on Six Note Classes
JPMCC 2005-LDP4: DBRS Downgrades Class P to 'D'
JPMCC 2006-FL2: Moody's Affirms Class L Notes Rating at 'C'

JPMORGAN 2006-CIBC16: S&P Lowers Rating on Class F Certs. to 'D'
KKR FINANCIAL 2005-1: S&P Affirms 'BB+' Rating on Class D Notes
LB-UBS COMMERCIAL: Fitch Lowers Rating on 8 Subor. Note Classes
LONGHORN CDO: S&P Affirms 'CCC+' Ratings on 2 Classes of Notes
MMCAPS FUNDING: Moody's Raises Rating on US$33MM Notes From 'Ba3'

MORGAN STANLEY: Fitch Keeps Neg. Rating Watch on 5 Notes Classes
MORGAN STANLEY: DBRS Downgrades Class P to 'D'
MORGAN STANLEY: S&P Cuts Rating on Class K Certs. to 'D'
MORGAN STANLEY: S&P Lowers Ratings on 6 Classes to 'D'
MONTANA HIGHER: Fitch Keeps Rating on Student Loan Bonds

MORTGAGE EQUITY: Moody's Cuts Ratings on Cl. A Securities to Ba3
MSC 2012-C4: DBRS Assigns 'BB' Provisional Rating to Class F
MSCI 2007: Fitch Downgrades Rating on 15 Note Classes
MYSTIC RE 2012-1: S&P Gives 'BB' Rating on Class A Notes
NAVIGATOR CDO: S&P Lowers Class D Note Rating From 'BB' to 'B+'

NORTHLAKE CDO: Moody's Cuts Rating on US$56-Mil. Notes to 'C'
OCP CLO: S&P Gives 'BB' Rating on Class D Deferrable Notes
ONE WALL STREET: S&P Raises Rating on Class E Notes to 'CCC+'
PREFERRED TERM XXII: Moody's Ups Rating on US$201MM Notes to Ba1
RENTAL CAR: S&P Affirms 'BB' Rating on Class A Notes Series 2007-1

STRUCTURED RECEIVABLES: S&P Assumes 'CCC-' Unrated Carriers Rating
TEXAS WESLEYAN: Moody's Withdraws 'Ba2' Rating on Revenue Bonds
TROPIC CDO: Moody's Cuts Rating on US$50MM Notes to 'B1'
VENTURE II 2002: S&P Affirms 'CCC-' Rating on Class C Notes
WACHOVIA BANK 2007-C33: S&P Cuts Ratings on 6 Cert. Classes to 'D'

WAMU 2006-SL1: S&P Lowers Rating on Class H Certificates to 'D'
WASHINGTON MUTUAL: Moody's Affirms 'C' Rating on 4 Note Classes
WASHINGTON MUTUAL: Moody's Affirms Rating on 3 Note Classes at C
WBMCT 2005-C20: Moody's Affirms Rating on Class H Certs. at C

* Fitch Downgrades Rating on 13 Bonds to 'D'
* S&P Withdraws Ratings on 50 Classes From 31 Transactions



                            *********

AMMC VIII: S&P Withdraws 'BB' Rating on Class E Notes
-----------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 16
classes of notes from eight collateralized debt obligation (CDO)
transactions.

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

505 CLO IV Ltd. is a cash flow collateralized loan obligation
(CLO). The transaction paid the class C, D, and E notes down
completely on the Feb. 21, 2012 payment date, from outstanding
balances of $12.70 million, $25.00 million, and $15.00 million.

AMMC VIII Ltd. is a cash flow CLO. The transaction paid the
class A-1, A-2, B, C, D, and E notes down in full on the Feb. 27,
2012, optional redemption date, from outstanding balances of
$335.37 million, $37.50 million, $25.00 million, $20.00 million,
$20.00 million, and $15.36 million.

Arroyo CDO I Ltd. is a cash flow CDO transaction backed primarily
by residential mortgage-backed securities (RMBS). The transaction
paid the class A notes down in full on the Feb. 15, 2012, payment
date, from an outstanding balance of $2.66 million.

C-Bass CBO VI Ltd. is a cash flow CDO backed by mezzanine
structured finance assets. The transaction paid the class A notes
down in full on the Feb. 6, 2012, payment date, from an
outstanding balance of $0.68 million.

Crest 2002-IG Ltd. is a cash flow CDO transaction backed primarily
by commercial mortgage-backed securities (CMBS). The transaction
paid the class A notes down in full on the Jan. 30, 2012, payment
date, from an outstanding balance of $2.66 million.

Davis Square Funding VII Ltd. is a cash flow CDO backed primarily
by structured finance assets. The transaction paid the class S
notes down in full on the Feb. 2, 2012, payment date, from an
outstanding balance of $0.30 million.

Freeport Offshore 2010-1 LLC is a cash flow CLO. The transaction
paid the class A-1a and A-1b notes down in full on the Jan. 20,
2012 payment date, each from an outstanding balance of
$14.64 million.

Valeo Investment Grade CDO Ltd. is a cash flow CDO transaction
backed by corporate bonds. The transaction paid the class A-1
notes down in full on the Jan. 17, 2012 payment date, from an
outstanding balance of $5.73 million.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

           http://standardandpoorsdisclosure-17g7.com

Ratings Withdrawn

505 CLO IV Ltd.
                          Rating
Class               To                  From
C                   NR                  AAA (sf)
D                   NR                  AA (sf)
E                   NR                  A (sf)

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

Arroyo CDO I Ltd.
                           Rating
Class               To                  From
A                   NR                  AAA (sf)

C-Bass CBO VI Ltd.
                           Rating
Class               To                  From
A                   NR                  AA (sf)

Crest 2002-IG Ltd.
                           Rating
Class               To                  From
A                   NR                  AAA (sf)

Davis Square Funding VII Ltd.
                           Rating
Class               To                  From
S                   NR                  BBB (sf)

Freeport Offshore 2010-1 LLC
                           Rating
Class               To                  From
A-1a                NR                  AAA (sf)
A-1b                NR                  AAA (sf)

Valeo Investment Grade CDO Ltd.
                           Rating
Class               To                  From
A-1                 NR                  AA+ (sf)

NR -- Not rated.


APHEX 2007-5: S&P Lowers Ratings on 2 Classes to 'CCC-'; Off Watch
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 12
tranches from 11 corporate-backed synthetic collateralized debt
obligation (CDO) transactions and removed them from CreditWatch
with positive implications. "In addition, we lowered four ratings
from three synthetic CDO transactions backed by commercial
mortgage-backed securities (CMBS) and removed them from
CreditWatch with negative implications and lowered seven ratings
from seven corporate-backed synthetic CDO transactions and removed
one from CreditWatch with negative implications. Furthermore, we
affirmed eight ratings from eight corporate-backed synthetic
CDO transactions and removed one from CreditWatch with positive
implications," S&P said.

"The upgrades affected synthetic CDOs that experienced a
combination of upward rating migration in their underlying
reference portfolios, seasoning of the underlying reference names,
and an increase in the synthetic rated overcollateralization
(SROC) ratios above 100% at higher rating levels as of the
February review and at our projection of the SROC ratios in 90
days assuming no credit migration. The downgrades affected
synthetic CDOs that experienced negative rating migration in their
underlying reference portfolios or had reductions to the credit
enhancement available to them. The affirmations are from synthetic
CDOs that had appropriate credit support at their current rating
level," S&P said.

           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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

          http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

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

ARLO Ltd.
Series 2006 (OCL-1)
                                 Rating
Class                    To                  From
Tranche                  CC (sf)             CCC- (sf)

Castlereagh Trust - Series 1
                                 Rating
Class                    To                  From
Tranche                  CCC- (sf)           CCC- (sf)

Corsair (Jersey) No. 2 Ltd.
Series 72
                                 Rating
Class                    To                  From
series 72                CC (sf)             CCC- (sf)

Credit Default Swap
Series J17558 (SEQUOIA)
                                 Rating
Class                    To            From
Tranche                  Asrp (sf)     A-srp (sf)/Watch Pos

Credit Default Swap
Series 971879CF
                                 Rating
Class                    To                  From
Tranche                  AAAsrp (sf)         AAAsrp (sf)

Credit Default Swap
$300 mil Morgan Stanley Capital Services Inc. - ESP Funding I,
Ltd.
REF: NGNGX
                                 Rating
Class                 To              From
Tranche               BBB-srb (sf)    BB-srb (sf)/Watch Pos

Credit Default Swap
$380 mil ZZRQD
Series 971878CF
                                 Rating
Class                    To                  From
Tranche                  AAAsrp (sf)         AAAsrp (sf)

Credit Default Swap
$400 mil MS Ref No: ZZRRD
Series pa001
                                 Rating
Class                    To                  From
Tranche                  AAAsrp (sf)         AAAsrp (sf)

Credit Default Swap
$400 mil ZZRVW
Series pa070
                                 Rating
Class                    To                  From
Tranche                  AAAsrp (sf)         AAAsrp (sf)

Credit Default Swap
$500 mil Credit Default Swap - CRA700386
                           Rating
Class              To                  From
Swap               AA+srp (sf)         AAsrp (sf)/Watch Pos

Credit Default Swap
$500 mil Credit Default Swap - CRA700396
                                 Rating
Class              To                  From
Swap               AA+srp (sf)         AAsrp (sf)/Watch Pos

Elva Funding PLC
Series 2008-3
                             Rating
Class                To                  From
Notes                A (sf)              A- (sf)/Watch Pos

Infinity SPC Ltd.
$25 mil Class B Floating Rate Notes (CPORTS POTOMAC 2007-1)
                            Rating
Class               To                  From
B                   B- (sf)             CCC- (sf)/Watch Pos

Jupiter Finance Ltd.
Series 2007-002
                             Rating
Class                To                  From
Port CrLkd           BB (sf)             BB- (sf)/Watch Pos

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

Morgan Stanley ACES SPC
Series 2007-24
                            Rating
Class               To                  From
E                   CCC- (sf)           CCC- (sf)/Watch Pos

NOAJ CDO Ltd.
Series 1
                             Rating
Class                To                  From
Series 1             BB (sf)             BB- (sf)/Watch Pos

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

Obelisk Trust 2007-1-Sonoma Valley
                             Rating
Class                To                  From
A                    A+ (sf)             AA- (sf)/Watch Neg

SELECT ACCESS Investments Ltd. Series 2005-2
                                 Rating
Class                    To                  From
Tranche                  CCC- (sf)           CCC- (sf)

Signum Platinum I Ltd. Series 2006-01
                                 Rating
Class                    To                  From
2006-1                   CC (sf)             CCC- (sf)

Signum Platinum II Ltd. Series 2006-01
                                 Rating
Class                    To                  From
2006-01                  CC (sf)             CCC- (sf)

Signum Platinum III Ltd. Series 2007-01
                                 Rating
Class                    To                  From
Tranche                  CC (sf)             CCC- (sf)

STARTS (Cayman) Ltd.
Series 2007-9
                            Rating
Class               To                  From
Notes               BB+ (sf)            BB (sf)/Watch Pos

STARTS (Cayman) Ltd.
JPY1.1 bil 'AAA' rated floating-rate credit-linked notes due 2012
                                 Rating
Class                    To                  From
2007-35                  CC (sf)             CCC- (sf)

STRATA 2006-35 Ltd.
                             Rating
Class                To                  From
Notes                CCC- (sf)           B (sf)/Watch Neg

Terra CDO SPC Ltd.
Series 2008-1
                             Rating
Class                To                  From
A-1                  BBB- (sf)           BB+ (sf)/Watch Pos

Tiers Brisbane Floating Rate Credit Linked Trust Series 2007-34
                                 Rating
Class                    To                  From
Certificate              AA+ (sf)            AA+ (sf)


APHEX CAPITAL: Moody's Affirms Ca, C Ratings on $245MM Securities
-----------------------------------------------------------------
Moody's Investors Service has affimed nine classes of Notes issued
by Aphex Capital NSCR 2007-7SR, Ltd. The affirmations are 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 Synthetic) transactions.

US$116,000,000 Class A-1A Credit Linked Variable Floating Rate
Notes Due December 2038, Affirmed at Ca (sf); previously on
May 5, 2010 Downgraded to Ca (sf)

US$10,000,000 Class A-1B Credit Linked Variable Floating Rate
Notes Due December 2038, Affirmed at Ca (sf); previously on
May 5, 2010 Downgraded to Ca (sf)

US$54,000,000 Class A-2 Credit Linked Variable Floating Rate Notes
Due December 2038, Affirmed at C (sf); previously on May 5, 2010
Downgraded to C (sf)

US$13,500,000 Class B Credit Linked Variable Floating Rate Notes
Due December 2038, Affirmed at C (sf); previously on May 5, 2010
Downgraded to C (sf)

US$15,750,000 Class C Credit Linked Variable Floating Rate Notes
Due December 2038, Affirmed at C (sf); previously on May 5, 2010
Downgraded to C (sf)

US$5,000,000 Class D-A Credit Linked Variable Floating Rate Notes
Due December 2038, Affirmed at C (sf); previously on May 5, 2010
Downgraded to C (sf)

US$8,500,000 Class D-B Credit Linked Variable Floating Rate Notes
Due December 2038, Affirmed at C (sf); previously on May 5, 2010
Downgraded to C (sf)

US$12,150,000 Class E Credit Linked Variable Floating Rate Notes
Due December 2038, Affirmed at C (sf); previously on May 5, 2010
Downgraded to C (sf)

US$10,350,000 Class F Credit Linked Variable Floating Rate Notes
Due December 2038, Affirmed at C (sf); previously on May 5, 2010
Downgraded to C (sf)

Ratings Rationale

Aphex Capital NSCR 2007-7SR, Ltd., is a static credit linked notes
transaction backed by a portfolio of tranched credit default swaps
referencing $1.8 billion notional amount of commercial mortgage
backed securities (CMBS). All of the CMBS reference obligations
were securitized in 2006 (80.0%) and 2007 (20.0%). Currently,
73.3% of the reference obligations are rated by Moody's.

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.
We have completed updated credit estimates for the non-Moody's
rated reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 6,529 compared to 5,640 at last
review. The distribution of current ratings is as follows: Ba1-Ba3
(6.7% compared to 18.3% at last review), B1-B3 (13.3% compared to
16.7% at last review), and Caa1-C (80.0% compared to 65.0% at last
review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 4.7
years compared to 5.4 at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a variable
WARR with a mean of 1.3%, compared to 2.7% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the reference obligations pool (i.e. the measure of
diversity). Moody's modeled a MAC of 0.0% 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. Rated notes are particularly sensitive to
rating changes within the reference pool. Holding all other key
parameters static, changing all reference obligations' ratings or
credit estimates by one notch downward or by one notch upward,
would result in average rating movement on the rated notes of 0 to
1 notche downward and 0 notche 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 extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

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


APHEX CAPITAL: Moody's Cuts Ratings on $171MM Securities
--------------------------------------------------------
Moody's Investors Service has downgraded two classes of Notes
issued by Aphex Capital NSCR 2007-4, Ltd. The downgrades are due
to the deterioration in the credit quality of the underlying
portfolio of reference obligations as evidenced by an increase in
the weighted average rating factor (WARF). 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-1, Downgraded to Ca (sf); previously on Apr 29, 2011
Downgraded to Caa3 (sf)

Cl. A-2, Downgraded to C (sf); previously on May 5, 2010
Downgraded to Ca (sf)

Ratings Rationale

Aphex Capital NSCR 2007-4, Ltd., is a static credit linked notes
transaction backed by a portfolio of tranched credit default swaps
referencing $1.8 billion notional amount of commercial mortgage
backed securities (CMBS). All of the CMBS reference obligations
were securitized in 2005 (36.7%) and 2006 (63.3%). Currently,
71.7% of the reference obligations are rated by Moody's.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
We have completed updated credit estimates for the non-Moody's
rated reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 4,901 compared to 4,302 at last
review. The distribution of current ratings is as follows: Baa1-
Baa3 (8.3% compared to 11.7% at last review), Ba1-Ba3 (16.7%
compared to 26.7% at last review), B1-B3 (16.7% compared to 13.3%
at last review), and Caa1-C (58.3% compared to 48.3% at last
review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 4.2
years compared to 5.0 at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a variable
WARR with a mean of 4.2%, compared to 6.5% 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 obligations pool (i.e. the measure of
diversity). Moody's modeled a MAC of 21.8% compared to 23.4% at
last review.

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

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
rating changes within the reference pool. Holding all other key
parameters static, changing all reference obligations' ratings or
credit estimates by one notch downward or by one notch upward,
would result in average rating movement on the rated notes of 0 to
1 notche downward and 0 notche 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 extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards
and credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

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


APHEX CAPITAL: Moody's Downgrades Rating on Class A-2 Notes to Ca
-----------------------------------------------------------------
Moody's Investors Service has downgraded two classes of Notes
issued by Aphex Capital NSCR 2007-4, Ltd. The downgrades are due
to the deterioration in the credit quality of the underlying
portfolio of reference obligations as evidenced by an increase in
the weighted average rating factor (WARF). 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-1, Downgraded to Ca (sf); previously on Apr 29, 2011
Downgraded to Caa3 (sf)

Cl. A-2, Downgraded to C (sf); previously on May 5, 2010
Downgraded to Ca (sf)

Ratings Rationale

Aphex Capital NSCR 2007-4, Ltd., is a static credit linked notes
transaction backed by a portfolio of tranched credit default swaps
referencing $1.8 billion notional amount of commercial mortgage
backed securities (CMBS). All of the CMBS reference obligations
were securitized in 2005 (36.7%) and 2006 (63.3%). Currently,
71.7% of the reference obligations are rated by Moody's.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
We have completed updated credit estimates for the non-Moody's
rated reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 4,901 compared to 4,302 at last
review. The distribution of current ratings is as follows: Baa1-
Baa3 (8.3% compared to 11.7% at last review), Ba1-Ba3 (16.7%
compared to 26.7% at last review), B1-B3 (16.7% compared to 13.3%
at last review), and Caa1-C (58.3% compared to 48.3% at last
review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 4.2
years compared to 5.0 at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a variable
WARR with a mean of 4.2%, compared to 6.5% 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 obligations pool (i.e. the measure of
diversity). Moody's modeled a MAC of 21.8% compared to 23.4% at
last review.

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

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
rating changes within the reference pool. Holding all other key
parameters static, changing all reference obligations' ratings or
credit estimates by one notch downward or by one notch upward,
would result in average rating movement on the rated notes of 0 to
1 notche downward and 0 notche 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 extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

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


ARCH ONE 2005-5: S&P Withdraws 'B+' Rating on Class ABBA Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on the
notes issued by Arch One Finance Ltd.'s series 2005-5, 2006-2,
and Athenee CDO PLC's series 2007-15. All three are synthetic
corporate investment-grade collateralized debt obligation (CDO)
transactions.

The withdrawals follow a repurchase and cancellation of the notes.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

         http://standardandpoorsdisclosure-17g7.com

Ratings Withdrawn

Arch One Finance Ltd.
Series 2005-5
                  Rating
Class          To     From
ABBA           NR     B+ (sf)

Arch One Finance Ltd.
Series 2006-2
                  Rating
Class          To     From
Tranche        NR     CCC- (sf)

Athenee CDO PLC
Series 2007-15
                  Rating
Class          To     From
Tranche A      NR     BB+ (sf)

NR -- Not rated.


AVALON IV: S&P Gives 'BB' Rating on Class E Deferrable Notes
------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Avalon IV Capital Ltd./Avalon IV Capital LLC's
$315.75 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," S&P said.

The preliminary ratings are based on information as of March 7,
2012. 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
   Ratings Services' CDO Evaluator model, as assessed by Standard
   & Poor's using the assumptions and methods outlined in its
   corporate collateralized debt obligation criteria.

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

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

* The portfolio 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
   0.30%-12.35%," S&P said.

* 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.

* The transaction's reinvestment overcollateralization test, a
   failure of which will lead to the reclassification of up to 50%
   of excess interest proceeds that are available prior to paying
   uncapped administrative expenses and fees, subordinated hedge
   termination payments, portfolio manager subordinated fees, and
   subordinated note payments into principal proceeds for the
   purchase of additional collateral assets during the
   reinvestment period and to reduce the balance of the rated
   notes outstanding, sequentially, after the reinvestment period.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

           http://standardandpoorsdisclosure-17g7.com

Preliminary Ratings Assigned
Avalon IV Capital Ltd./Avalon IV Capital LLC

Class                  Rating          Amount (mil. $)
A                      AAA (sf)                  231.0
B                      AA (sf)                    23.0
C (deferrable)         A (sf)                     32.0
D (deferrable)         BBB (sf)                   16.0
E (deferrable)         BB (sf)                   13.75
Subordinated notes     NR                        34.25

NR -- Not rated.


AXIS EQUIPMENT: DBRS Assigns 'BB' Provisional Rating to Class D
---------------------------------------------------------------
DBRS has assigned provisional ratings to these classes issued by
Axis Equipment Finance Receivables LLC:

  -- Class A rated AA (sf)
  -- Class B rated A (sf)
  -- Class C rated BBB (sf)
  -- Class D rated BB (sf)
  -- Class E-1 rated B (sf)


BABSON MID-MARKET: S&P Raises Rating on Class E Notes to 'BB+'
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C, D, and E notes from Babson Mid-Market CLO Ltd. 2007-II, a
collateralized loan obligation (CLO) transaction with an
APEX revolver feature managed by Babson Capital Management LLC.
"We also affirmed our ratings on the class A-1, A-2R, A-2B, and B
notes," S&P said.

"The APEX revolver is available to the transaction during its
reinvestment period to absorb principal losses. Wells Fargo Bank
N.A. is the APEX revolver provider. For our review of the
transaction's performance, we have applied our counterparty
criteria," S&P said.

"The upgrades reflect the improved performance we have observed in
the deal's underlying asset portfolio since our March 2010 rating
actions. According to the Jan. 4, 2012 trustee report, the
transaction's asset portfolio held about $8.7 million in defaulted
assets, down from the $18.3 million noted in the February 2010
trustee report. Additionally, the collateral pool consisted of
approximately $32.8 million in assets from obligors rated in the
'CCC' category according to the January 2012 trustee report, down
from $77.5 million noted in February 2010," S&P said.

"The affirmations of our ratings on the class A-1, A-2R, A-2B, and
B notes reflect the sufficient credit support at the classes'
current rating levels," 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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

            http://standardandpoorsdisclosure-17g7.com

Rating Actions

Babson Mid-Market CLO Ltd. 2007-II
                         Rating
Class                To           From
C                    A+ (sf)      A (sf)
D                    BBB+ (sf)    BBB (sf)
E                    BB+ (sf)     BB (sf)

Ratings Affirmed

Babson Mid-Market CLO Ltd. 2007-II
Class                Rating
A-1                  AA+ (sf)
A-2R                 AAA (sf)
A-2B                 AA+ (sf)
B                    AA (sf)


BANC OF AMERICA: Increased Loss Prompts Fitch to Lower Ratings
--------------------------------------------------------------
Fitch Ratings has downgraded six classes and affirmed 17 classes
of Banc of America Commercial Mortgage Inc. Securities Trust 2004-
4, commercial mortgage pass-through certificates.

The downgrades are due to increased loss expectations on the
specially serviced loans.  Fitch modeled losses of 12%, most of
which is due to loans in special servicing.  As of the February
2012 distribution date, seven loans (11.51% of the pool), were in
special servicing.

Fitch expects classes K through P to be fully depleted by losses
on specially serviced loans and class J to be significantly
impacted.  As of February 2012, there are cumulative interest
shortfalls in the amount of $4.8 million currently affecting
classes H through P.

As of the February 2012 distribution date, the pool's aggregate
principal balance has been paid down by 56.5% to $619 million from
approximately $1.426 billion at issuance.  Four loans (5.59%) have
defeased since issuance.

The largest contributor to Fitch expected losses is a Real Estate
Owned (REO) 722,253 square foot (sf) industrial/warehouse property
in North Kingstown, RI (3.1% of the pool). The special servicer
has been working to increase occupancy. New valuations have been
received and are significantly below the debt.

The next largest contributor to Fitch expected losses is REO
159,327 sf retail property (1.74 % of outstanding pool), located
in Pottstown, PA.  The largest tenant at the property, a 52,700 sf
grocery store (35.9% of NRA), has vacated, but the tenant is
expected to continue paying rent through its lease expiration in
2014.  The special servicer has been working to increase occupancy
before pursuing an asset sale.

The third largest contributor to expected losses is a REO 96,576
sf suburban office located in Concord, CA (1.9% of the pool).
Current occupancy is 67%; however, a number of leases have
recently been renewed and the property management team has had
recent success securing new tenants.

Fitch downgrades these classes:

  -- $16.2 million class H to 'CCCsf/RE0' from 'B-sf';
  -- $6.5 million class J to 'Csf/RE0'from 'CCCsf/RE100'
  -- $6.5 million class K to 'Csf/RE0' from 'CCCsf/RE100';
  -- $6.5 million class L to 'Csf/RE0' from 'CCsf/RE40';
  -- $3.2 million class M to 'Csf/RE0' from 'CC/RE0';
  -- $3.2 million class N to 'Csf/RE0' from 'CC/RE0'.

Fitch affirms these classes and Outlooks:

  -- $45.8 million class A-5 at 'AAAsf'; Outlook Stable;
  -- $272.2 million class A-6 at 'AAAsf'; Outlook Stable;
  -- $113.6 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $35.6 million class B at 'AAAsf'; Outlook Stable;
  -- $11.3 million class C at 'AAsf'; Outlook Stable;
  -- $21.1 million class D to 'BBBsf'; Outlook Stable;
  -- $9.7 million class E to 'BBB-sf'; Outlook Stable;
  -- $16.2 million class F at 'Bsf'; Outlook Negative;
  -- $11.3 million class G at 'B-sf'; Outlook Negative;
  -- $4.9 million class O at 'Csf/RE0';
  -- $2.3 million class DM-A at 'A+sf'; Outlook Stable;
  -- $4.8 million class DM-B at 'Asf'; Outlook Stable;
  -- $3.8 million class DM-C at 'A-sf'; Outlook Stable;
  -- $4.1 million class DM-D at 'BBB+sf'; Outlook Stable;
  -- $4.4 million class DM-E at 'BBBsf'; Outlook Stable;
  -- $4 million class DM-F at 'BBB-sf'; Outlook Stable;
  -- $3.7 million class DM-G at 'BBB-sf'; Outlook Stable.

Fitch does not rate the $12.2 million class P and class BC.
Classes A-1, A-2, A-3, and A-4 have paid in full.  Class X-C and
class X-P were previously withdrawn.


BANC OF AMERICA: Moody's Affirms Ratings on 5 CBMS Classes at 'C'
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 21 classes of
Banc of America Commercial Mortgage Trust, Commercial Mortgage
Pass-Through Certificates, Series 2007-3:

Cl. A-2, Affirmed at Aaa (sf); previously on Aug 23, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-2FL, Affirmed at Aaa (sf); previously on Aug 23, 2007
Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Aug 23, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Aug 23, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aa3 (sf); previously on Jan 26, 2010
Downgraded to Aa3 (sf)

Cl. A-5, Affirmed at Aa3 (sf); previously on Jan 26, 2010
Downgraded to Aa3 (sf)

Cl. A-1A, Affirmed at Aa3 (sf); previously on Jan 26, 2010
Downgraded to Aa3 (sf)

Cl. A-M, Affirmed at Baa1 (sf); previously on Jan 26, 2010
Downgraded to Baa1 (sf)

Cl. A-MF, Affirmed at Baa1 (sf); previously on Jan 26, 2010
Downgraded to Baa1 (sf)

Cl. A-MFL, Affirmed at Baa1 (sf); previously on Jan 26, 2010
Downgraded to Baa1 (sf)

Cl. A-J, Affirmed at B3 (sf); previously on Jan 26, 2010
Downgraded to B3 (sf)

Cl. B, Affirmed at Caa2 (sf); previously on Jan 26, 2010
Downgraded to Caa2 (sf)

Cl. C, Affirmed at Caa3 (sf); previously on Jan 26, 2010
Downgraded to Caa3 (sf)

Cl. D, Affirmed at Ca (sf); previously on Jan 26, 2010
Downgraded to Ca (sf)

Cl. E, Affirmed at Ca (sf); previously on Jan 26, 2010
Downgraded to Ca (sf)

Cl. F, Affirmed at C (sf); previously on Jan 26, 2010 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Jan 26, 2010 Downgraded
to C (sf)

Cl. H, Affirmed at C (sf); previously on Jan 26, 2010 Downgraded
to C (sf)

Cl. J, Affirmed at C (sf); previously on Jan 26, 2010 Downgraded
to C (sf)

Cl. K, Affirmed at C (sf); previously on Jan 26, 2010 Downgraded
to C (sf)

Cl. XW, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (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
11.7% of the current balance. At last review, Moody's cumulative
base expected loss was 11.2%. Realized losses have increased from
less than 0.1% of the original balance to 0.3% since the prior
review. Moody's provides a current list of base expected losses
for conduit and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

The methodologies used in this rating were "Moody's Approach to
Rating U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating Structured Finance Interest-
Only Securities" published in February 2012. Please see the Credit
Policy page on www.moodys.com for a copy of these methodologies.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.60 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in 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
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 review also incorporated the CMBS IO calculator ver 1.0,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point. For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

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 31 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 a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated March 23, 2011.

DEAL PERFORMANCE

As of the February 10, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 7% to
$3.29 billion from $3.52 billion at securitization. The
Certificates are collateralized by 147 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 51% of the pool.

Twenty-eight loans, representing 28% of the pool, are on the
master servicer's watchlist. The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the CRE Finance Council (CREFC) 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.

Five loans have been liquidated from the pool, resulting in a
realized loss of $13.1 million (51% loss severity on average).
Currently 12 loans, representing 6% of the pool, are in special
servicing. The largest specially serviced loan is the Metropolis
Shopping Center Loan ($86 million -- 2.6% of the pool), which is
secured by Phase I of a suburban power center located southwest of
Indianapolis, Indiana. The property is also encumbered by a
$9 million B-Note. The property is currently real estate owned
(REO) and the servicer has recognized a $55 million appraisal
reduction for this loan. At this time, the special servicer is
currently collecting valuations on the property to ascertain an
acceptable disposition strategy.

The remaining 11 specially serviced properties are secured
by a mix of property types. Moody's estimates an aggregate
$116 million loss for the specially serviced loans (54% expected
loss on average).

Moody's has assumed a high default probability for 23 poorly
performing loans representing 25% of the pool and has estimated an
aggregate $141 million loss (17% expected loss on average) from
these troubled loans.

Moody's was provided with full year 2010 operating results for 96%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 124% compared to 128% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 8% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.6%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.43X and 0.87X, respectively, compared to
1.35X and 0.85X 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 Presidential Towers Loan
($325.0 million -- 9.9% of the pool), which is secured by four
connected 50-story apartment buildings (2,346 units) located in
the intown submarket of downtown Chicago, Illinois. As of December
2011, the multifamily units were 93% leased compared to 92% at
last review. The property's 87,000 square foot (SF) retail
component completed renovations in 2011 and was 44% leased as of
December 2011 compared to 41% at the last review. Property
performance is expected to improve as the retail space is leased
up. Moody's LTV and stressed DSCR are 122% and 0.71X,
respectively, compared to 133% and 0.65X at the last full review.

The second largest loan is the Renaissance Mayflower Hotel Loan
($200 million -- 6.1% of the pool), which is secured by a 657-unit
hotel located in Washington, D.C. The loan was in special
servicing in 2010 and was subsequently modified. The loan term was
extended by 12 months to March 2013. The loan is current and
property performance has improved since 2009/2010. Moody's LTV and
stressed DSCR are 152% and 0.75X, which is the same as at last
full review.

The third largest loan is the Pacific Shores Building 9 & 10 Loan
($184 million -- 5.6% of the pool), which is secured by two Class
A office buildings located in a suburban office park in Redwood
City, California. The property serves as Facet Biotech's corporate
headquarters. Abbott Laboratories (Moody's senior unsecured rating
A1, negative outlook) acquired Facet Biotech in April 2010. The
property is 100% leased, which is the same as at last review.
Moody's LTV and stressed DSCR are 147% and 0.71X, respectively,
compared to 145% and 0.71X at last review.


BEAR STEARNS 2001-TOP4: S&P Raises Class H Cert. Rating From 'BB+'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on three
classes of commercial mortgage pass-through certificates from Bear
Stearns Commercial Mortgage Securities Inc.'s series 2001-TOP4, a
U.S. commercial mortgage-backed securities (CMBS) transaction.

"In addition, we affirmed our rating on one other class from the
same transaction," S&P said.

"Our rating actions reflect increased credit enhancement levels,
as well as our analysis of the credit characteristics of the
remaining collateral, the deal structure, and the liquidity
available to the trust. Our rating actions also considered the
number of assets with the special servicer and potential interest
shortfalls related to those as well as the remaining loans secured
by real estate in the pool," S&P said.

"Using servicer-provided financial information, we calculated
adjusted debt service coverage (DSC) of 1.35x and a loan-to-value
(LTV) ratio of 62.5% for the loans in the pool. We further
stressed the loans' cash flows under our 'AAA' scenario to yield
a weighted average DSC of 1.14x and an LTV ratio of 85.6%. The
implied defaults and loss severity under the 'AAA' scenario were
43.1% and 41.9%. The DSC and LTV calculations exclude three
($12.9 million, 32.9%) of the four ($17.1 million, 43.1%)
assets that are currently with the special servicer and four
($10.7 million, 27.0%) defeased loans. We separately estimated
losses for the excluded specially serviced assets and included
them in our 'AAA' scenario implied default and loss severity
figures," S&P said.

                   Credit Considerations

As of the Feb. 15, 2012 trustee remittance reports, four assets
($17.1 million, 43.1%) in the pool were with the special servicer,
Berkadia Commercial Mortgage LLC (Berkadia). The reported payment
status of these assets as of the February 2012 trustee remittance
report is: one ($1.9 million, 4.8%) is real estate-owned (REO),
one ($4.2 million, 10.6%) is current, and two ($11.0 million,
27.7%) are matured balloon loans. An appraisal reduction amount
(ARA) of $750,209 was in effect against one of the specially
serviced assets. Details of the specially serviced assets are as
set forth.

"The Pinellas Business Center loan ($8.7 million, 21.9%) is the
largest asset secured by real estate in the pool. The reported
trust exposure on the loan was $9.1 million. The loan is secured
by a 202,847-sq.-ft. industrial property in St. Petersburg, Fla.,
built in 1986. The loan was transferred to the special servicer on
Sept. 23, 2011, due to imminent maturity default. The loan matured
on Sept. 1, 2011. Berkadia stated that it is currently evaluating
a note sale strategy while reviewing a loan modification proposal
from the borrower to extend the loan. The reported DSC was 0.77x
for the three months year-to-date ended March 31, 2011, and
occupancy was 55.0% according to March 2011 rent roll. We expect a
moderate loss upon the eventual resolution of this loan," S&P
said.

The Cook Office Centre loan ($4.2 million, 10.6%), the second-
largest asset secured by real estate in the pool, is secured by a
61,652-sq.-ft. office property in Palm Desert, Calif., built in
1986. The loan was transferred to Berkadia on May 25, 2011, due to
imminent maturity default. The loan matured on Sept. 1, 2011.
According to the special servicer, the loan has been extended for
the period of one year maturing Sept. 1, 2012. The reported DSC
was 2.09x as of year-end 2010; however, according to the July rent
roll, the property is 63% occupied.

"The Airborne Express loan ($2.3 million, 5.8%), the fourth-
largest asset in the pool, is secured by a 79,750-sq.-ft.
industrial property in Parsippany, N.J., built in 1968. The
reported trust exposure was $2.5 million on the asset. The loan
was transferred to the special servicer on June 23, 2011, due to
maturity default after the sole tenant Airborne vacated the
property. Berkadia approved and closed an extension of the loan on
Dec. 16, 2011. It is our understanding that no leases have been
executed to date. We expect a minimal loss upon the resolution of
this asset," S&P said.

"The Plymouth Court asset ($1.9 million, 4.8%), the sixth-largest
asset in the pool, consists of a 44,747-sq.-ft. office property in
Plymouth, Mn. The loan was transferred to the special servicer on
July 26, 2010, due to monetary default and the property became REO
on April 22, 2011. Berkadia indicated that it is currently
negotiating a purchase agreement with a prospective buyer. We
expect a significant loss upon the resolution of this asset," S&P
said.

                     Transaction Summary

"As of the Feb. 15, 2012 trustee remittance report, the
transaction had an aggregate trust balance of $39.7 million (16
loans and one REO asset), compared with $902.5 million (152 loans)
at issuance. The master servicer, Wells Fargo Bank N.A. (Wells
Fargo), provided financial information for 100% of the pool, which
was primarily full-year 2010 and partial-year 2011 information.
"We calculated a weighted average DSC of 1.35x for the loans in
the pool based on the reported figures. Our adjusted DSC and LTV
were 1.35x and 62.5%, which excluded three ($12.9 million, 32.9%)
of the four ($17.1 million, 43.1%) assets that are currently with
the special servicer and four ($10.7 million, 27.0%) defeased
loans. The trust has experienced principal losses to date totaling
$6.1 million from six assets. One loan ($2.9 million, 7.4%) is on
the master servicer's watchlist. Two loans ($10.6 million, 26.7%)
have a reported DSC below 1.00x," S&P said.

         Summary of Top 10 Assets Secured By Real Estate

"The top 10 assets secured by real estate have an aggregate
outstanding trust balance of $26.9 million (67.8%). Using
servicer-reported information, we calculated a weighted average
DSC of 1.33x for nine of the top 10 assets. The remaining top 10
asset ($1.9 million, 4.8%) is currently with the special servicer.
Our adjusted DSC and LTV figures for nine of the top 10 assets,
excluding the one top 10 specially serviced asset, were 1.28x and
67.5%, respectively. One of the top 10 assets ($2.9 million, 7.4%)
is the sole asset in the pool on the master servicer's watchlist.
We discuss this asset," S&P said.

The Hope Mills Crossing loan ($2.9 million, 7.4%) is the third-
largest asset secured by real estate in the pool. The loan is
secured by a 53,041-sq.-ft. retail property in Hope Mills, N.C.
The loan is on Wells Fargo's watchlist due to a major tenant lease
default. While the property is completely vacant, according to
Wells Fargo, the lease is guaranteed by Koninklijke Ahold N.V.
(BBB) and the loan payment status remains current. For the six
months ended June 30, 2011, the reported DSC was 1.36x.

"We stressed the assets in the pool according to our criteria and
the resultant credit enhancement levels are consistent with our
raised and affirmed ratings," S&P said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

           http://standardandpoorsdisclosure-17g7.com

Ratings Raised

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates 2001-TOP4
                 Rating
Class      To               From         Credit enhancement (%)
F          AAA (sf)         BBB+(sf)                     98.39
G          AA+ (sf)          BBB (sf)                    75.66
H          BBB (sf)         BB+ (sf)                     52.93

Rating Affirmed

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates 2001-TOP4
Class      Rating   Credit enhancement (%)
J          BB (sf)                  35.88

N/A -- Not applicable.


BLUE HERON: Fitch Affirms 'Csf' Ratings on Six Note Classes
-----------------------------------------------------------
Fitch Ratings has affirmed the ratings on seven classes of notes
issued by Blue Heron Funding II, Ltd. (Blue Heron II):

-- $245,996,236 class A notes at 'Csf';
-- $17,205,585 class B notes at 'Csf';
-- $34,409,633 class C notes at 'Csf';
-- $22,196,177 class D notes at 'Csf';
-- $17,770,015 class E notes at 'Csf';
-- $17,770,015 class E additional interest (interest only) at
    'Csf';
-- $3,986,875 Certificates (principal only) at 'AAAsf'; Outlook
    Negative.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs'.  The
Structured Finance Portfolio Credit Model (SF PCM) and Fitch's
cash flow model were not used as part of this review because all
of the notes are undercollateralized and structural features were
determined to have minimal impact in the context of the classes'
ratings.

Since Fitch's last rating action in March 2011, the portfolio has
continued to deteriorate, with 32% downgraded a weighted average 6
notches and 3.7% upgraded a weighted average 4.5 notches.
Principal proceeds have continued to be used intermittently to
cover shortfalls in interest collections for interest due to the
class A, class B and class C notes. As a result, all of the notes'
credit enhancement levels have become increasingly negative.

The class A, class B and class C notes are non-deferrable and
continue to receive accrued interest distributions from a
combination of interest and principal collections.  The class D
and E notes, and class E additional interest are no longer
receiving interest distributions due to failing A/B/C coverage
tests.

Based on the current portfolio and anticipated future credit
enhancement erosion from principal leaking to pay interest
obligations, Fitch believes default continues to appear inevitable
for the class A, B, C, D and E notes, and the class E additional
interest.

The Certificates are rated to the ultimate receipt of principal,
where coupon payments received in the interest waterfall are
applied to reduce the outstanding rated balance.  While these
distributions are no longer being made due to failing coverage
tests and are not expected to resume in the future, the principal
of the Certificates is protected by a Certificate Protection
Asset, which is a zero coupon bond with a face value of $6 million
maturing in April 2030, that was issued by Resolution Funding
Corporation, a U.S. government agency.

As per the terms of the transaction, no party to the transaction
other than the Certificate holders have claim against the
Certificate Protection Asset.  Therefore, the Certificates are
affirmed at 'AAAsf', Outlook Negative.

Blue Heron II is a structured finance collateralized debt
obligation (SF CDO) that closed on Dec. 22, 2005 and is managed by
Westdeutsche Landesbank Girozentrale, New York Branch.  The
portfolio is composed of residential mortgage-backed securities
(58.9%), SF CDOs (17.9%), commercial mortgage-backed securities
(13.7%), corporate CDOs (3.7%), corporate debt (3.5%), and
commercial and consumer asset-backed securities (2.3%) from 1998
through 2007 vintage transactions.


BLUE HERON: Moody's Cuts Rating on US$890MM Class A Notes to Caa3
-----------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
rating of one class of notes issued by Blue Heron Funding II Ltd.
The class of notes affected by the rating action is as follows:

US$890,000,000 Class A Blue Heron Funding II Notes, due
December, 2041 (current outstanding balance of $245,996,236);
Downgraded to Caa3 (sf); Previously on June 9, 2010, Downgraded
to Caa2 (sf).

Ratings Rationale

According to Moody's, the rating downgrade is the result of
deterioration in the credit quality of the underlying portfolio.
Such credit deterioration is observed through numerous factors,
including a decrease in the transaction's overcollateralization
ratios and an increase in the Moody's WARF. Based on the latest
trustee report dated February 2012, the Class A/B/C and Class D
overcollateralization ratios are reported at 59.74% and 55.61%,
respectively, versus May 2010 levels of 80.85% and 77.78%,
respectively. Additionally, the trustee reported WARF has
increased to 1678 from 517 in May 2010.

Moody's did not model the transaction, and instead, evaluated the
likelihood of repayment of the notes based on the available
principal proceeds and expected proceeds from the remaining
collateral.

Blue Heron Funding II Ltd. is a collateralized debt obligation
issuance backed primarily by a portfolio of RMBS, CMBS, and
structured finance securities originated from 2002 to 2006.

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

Moody's notes that in arriving at its ratings of SF CDOs, there
exist a number of sources of uncertainty, operating both on a
macro level and on a transaction-specific level. Primary sources
of assumption uncertainty are the extent of the slowdown in growth
in the current macroeconomic environment and the commercial and
residential 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. Among the uncertainties in the residential
real estate property market are those surrounding future housing
prices, pace of residential mortgage foreclosures, loan
modification and refinancing, unemployment rate and interest
rates.


C-BASS CBO: Fitch Affirms Junk Rating on Four Note Classes
----------------------------------------------------------
Fitch Ratings has upgraded one class, affirmed four classes, and
revised the Rating Outlook on one class of notes issued by C-BASS
CBO IX, Ltd./Corp (C-BASS IX):

  -- $7,750,288 class A-1 notes upgraded to 'AAsf' from 'BBBsf';
     Outlook revised to Stable from Negative;
  -- $20,000,000 class A-2 notes affirmed at 'CCCsf';
  -- $10,000,000 class B notes affirmed at 'CCsf';
  -- $12,000,000 class C notes affirmed at 'Csf';
  -- $7,227,634 class D notes affirmed at 'Csf'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Structured Finance Portfolio Credit Model (SF PCM) for
projecting future default levels for the underlying portfolio.
These default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Fitch also considered additional qualitative factors into its
analysis, as described below, to conclude the rating affirmations
for the rated notes.

Since Fitch's last rating action in March 2011, the credit quality
of the collateral has deteriorated with approximately 46% of the
portfolio downgraded a weighted average of 3.3 notches, and 4%
upgraded a weighted average of 4 notches.  Approximately 71.1% of
the portfolio has a Fitch derived rating below investment grade
and 52.7% rated in the 'CCC' category or lower, compared to 64.4%
and 52.8%, respectively, at last review.

The upgrade for the class A-1 notes is due to the amortization of
the notes funded by cash flows from the underlying portfolio,
which also includes interest from defaulted assets.  As a result,
the credit enhancement for the notes has increased.  This, in
Fitch's opinion, outweighs the deterioration of the underlying
portfolio noted above.  Since the last review, the class has
received approximately $16.9 million of principal repayment, or
68.5% of its previous balance.  The remaining outstanding note
balance is expected to be repaid within the next year.  While the
cash flow modeling results vary across different interest rate
and default timing scenarios, they are consistent with a 'AAsf'
rating.  Fitch has revised the Outlook of the class A-1 notes to
Stable from Negative.

The class A-2 notes have also benefited from an increase in credit
enhancement due to the amortization of the class A-1 notes, though
to a lesser extent.  While the cash flow modeling results indicate
passing ratings higher than the current 'CCCsf', significant risks
remain.  The notes are likely to remain outstanding beyond a one
year horizon during which the portfolio may experience further
negative migration and increasing concentration in worse credit
quality assets.  Further, interest coming off defaulted RMBS bonds
which currently contributes to the A-1 notes' paydown may not be
sustainable at the same levels in the future.  A 'CCCsf' rating is
appropriate for the A-2 notes given the risks.

Breakeven levels for the class B, class C, and class D notes were
below SF PCM's 'CCC' default level, the lowest level of defaults
projected by SF PCM.  Therefore Fitch compared the classes' credit
enhancement level to the expected losses from distressed and
defaulted assets in the portfolio (rated 'CCsf' or lower).  Based
on this comparison, the ratings for each of the classes are
affirmed.

C-BASS IX is a cash flow structured finance collateralized debt
obligation (SF CDO) that closed on March 23, 2004.  The portfolio
is currently monitored by NIC Management LLC, an affiliate of
Newcastle Investment Corp. and consists of 85.5% residential
mortgage-backed securities, 10.9% commercial and consumer asset-
backed securities, and 3.6% SF CDOs from 2001 through 2004 vintage
transactions.


CABELA'S CREDIT: DBRS Assigns 'BB' Final Rating to Class D
-------------------------------------------------------------
DBRS, Inc., has assigned final ratings to these classes issued by
Cabela's Credit Card Master Note Trust, Series 2012-I:

  -- Series 2012-1 Notes, Class A-1 rated AAA (sf)
  -- Series 2012-1 Notes, Class A-2 rated AAA (sf)
  -- Series 2012-1 Notes, Class B rated A(high) (sf)
  -- Series 2012-1 Notes, Class C rated BBB (sf)
  -- Series 2012-1 Notes, Class D rated BB (sf)


CABELA'S CREDIT: DBRS Puts 'BB' Provisional Rating to Class D
-------------------------------------------------------------
DBRS has assigned provisional ratings to these classes issued by
Cabela's Credit Card Master Note Trust, Series 2012-I:

  -- Series 2012-1 Notes, Class A-1 rated AAA (sf)
  -- Series 2012-1 Notes, Class A-2 rated AAA (sf)
  -- Series 2012-1 Notes, Class B rated A(high) (sf)
  -- Series 2012-1 Notes, Class C rated BBB (sf)
  -- Series 2012-1 Notes, Class D rated BB (sf)


CABELA'S CREDIT: Fitch Changes Rating Outlook on Notes to Stable
----------------------------------------------------------------
Fitch Ratings revises the expected ratings on Cabela's Credit Card
Master Note Trust's asset-backed notes, series 2012-I:

  -- $425,000,000 Class A fixed/floating-rate 'AAAsf'; Outlook
     Stable;
  -- $40,000,000 Class B fixed-rate 'A+sf'; Outlook Stable;
  -- $21,250,000 Class C fixed-rate 'BBB+sf'; Outlook Stable;
  -- $13,750,000 Class D fixed-rate 'BB+sf'; Outlook Stable.

The expected ratings are being revised due to additional
information received regarding the trust structure and breakdown
of fixed and floating notes.  Fitch's expected 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.

The transaction structure is similar to series 2012-IV, with
credit enhancement totaling 15% for class A, credit enhancement of
7% for the class B, credit enhancement of 2.75% plus an amount
from a spread account for the class C, and credit enhancement of
an amount from a spread account for the class D notes only.


CABELA'S CREDIT: Fitch Rates $13.75 Mil. Class D Notes at 'BB+sf'
-----------------------------------------------------------------
Fitch Ratings assigns these ratings to Cabela's Credit Card Master
Note Trust's asset-backed notes, series 2012-I:

  -- $275,000,000 class A-1 fixed-rate notes 'AAAsf'; Outlook
     Stable;
  -- $150,000,000 class A-2 floating-rate notes 'AAAsf'; Outlook
     Stable;
  -- $40,000,000 class B fixed-rate notes 'A+sf'; Outlook Stable;
  -- $21,250,000 class C fixed-rate notes 'BBB+sf'; Outlook
     Stable;
  -- $13,750,000 class D fixed-rate notes '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.


CANNINGTON FUNDING: S&P Raises Rating on Class D Notes to 'BB+'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B, C, and D notes from Cannington Funding Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
Silvermine Capital Management LLC. "At the same time, we removed
these ratings from CreditWatch, where we placed them with positive
implications on Dec. 20, 2011. We also affirmed the ratings on the
class A-1 and A-2 notes," S&P said.

"The upgrades reflect the improved performance we have observed in
the deal's underlying asset portfolio since we downgraded the
notes on Jan. 26, 2010. As of the Jan. 18, 2012, trustee report,
the transaction's asset portfolio had $4.94 million defaulted
obligations, compared with the $16.32 million noted in the Dec.
16, 2009, trustee report, which we used for our January 2010
rating actions," S&P said.

"We also observed an increase in the overcollateralization (O/C)
available to support the rated notes," S&P said. The trustee
reported the O/C ratios in the Jan. 18, 2012, monthly report:

* The class A O/C ratio was 124.23%, compared with a reported
   ratio of 120.39% in December 2009;

* The class B O/C ratio was 115.40%, compared with a reported
   ratio of 111.83% in December 2009;

* The class C O/C ratio was 109.41%, compared with a reported
   ratio of 106.03% in December 2009; and

* The class D O/C ratio was 105.65%, compared with a reported
   ratio of 102.39% in December 2009.

"The affirmations reflect our opinion that the credit support
available to the class A-1 and A-2 notes is commensurate with the
current ratings," S&P said.

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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

          http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Cannington Funding Ltd.
                       Rating
Class              To          From
B                  A (sf)      A- (sf)/Watch Pos
C                  BBB (sf)    BBB- (sf)/Watch Pos
D                  BB+ (sf)    CCC+ (sf)/Watch Pos

Ratings Affirmed

Cannington Funding Ltd.
Class              Rating
A-1                AA+ (sf)
A-2                AA (sf)


CAPMARK VII: Fitch Affirms Rating on All Note Classes
-----------------------------------------------------
Fitch Ratings has affirmed all classes of Capmark VII-CRE,
Ltd./Corp. (Capmark VII) reflecting Fitch's base case loss
expectation of 21.8%.  Fitch's performance expectation
incorporates prospective views regarding commercial real
estate market value and cash flow declines.

The collateralized debt obligation (CDO) exited its reinvestment
period in August 2011.  As of the February 2012 trustee report,
the transaction had paid down by $418.8 million.  Since last
rating action, nine assets, including five full payoffs, were
removed from the pool while one asset was added.  Realized losses
since Fitch's last rating action were approximately $30 million
while par building was minimal at approximately $517,000.
Defaulted assets and Fitch Loans of Concern are at 19.6%
and 23.4% compared to 7.1% and 21.7% at last review.

Capmark VII is a commercial real estate (CRE) CDO managed by
Urdang Capital Management, a real estate investment subsidiary of
BNY Mellon Asset Management.  The transaction continues to fail
all three of its principal coverage tests resulting in diverted
interest to pay principal to A-1 and capitalized interest to
classes C through H.

Under Fitch's methodology, approximately 74.8% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled average cash flow
decline is 9.4% from, generally, yearend 2011.  Fitch estimates
that average recoveries will be 70.8% due to the senior position
of the assets (100% of the assets are either whole loans or A-
notes).

The largest component of Fitch's base case loss expectation is a
defaulted whole loan (5.6% of the pool) secured by undeveloped
land located adjacent to the Potomac River in Arlington, VA. Fitch
modeled a significant loss on this loan in its base case scenario.

The next largest component of Fitch's base case loss expectation
is an A-note (8.4% of the pool) secured by an office property
located in Emeryville, CA.  While recent leasing at the property
has brought occupancy up to 72%, the property is still considered
over leveraged; Fitch modeled a significant loss on this loan in
its base case scenario.

The third largest component of Fitch's base case loss expectation
is an A-note (5.8% of the pool) secured by an office property
located in Monterey, CA.  This loan, which was formerly cross
collateralized with two other loans, is not performing in line
with expectations.  Fitch modeled a significant loss on this loan
in its base case scenario.

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

The Positive and Stable Rating Outlooks on classes A-1 and A-2
reflect the classes' senior position in the capital structure and
credit enhancement to the classes.

The 'CCC' and below ratings for classes B through H are based
on a deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each classes credit enhancement.

Fitch has affirmed and revised Outlooks and Recovery Estimates for
these classes:

  -- $131.2 million class A-1 at 'BBB'; Outlook to Positive from
     Stable;
  -- $170 million class A-2 at 'BB'; Outlook to Stable from
     Negative;
  -- $80 million class B at 'CCC'; RE 40%;
  -- $30.7 million class C at 'CC'; RE 0%;
  -- $7.7 million class D at 'CC'; RE 0%;
  -- $7.7 million class E at 'C'; RE 0%;
  -- $33.9 million class F at 'C'; RE 0%;
  -- $13.1 million class G at 'C'; RE 0%;
  -- $10.6 million class H at 'C'; RE 0%.


CENTERLINE 2007-SRR5: Moodys Keeps 'C' Ratings on 13 Note Classes
-----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of one
class and affirmed the ratings of thirteen classes of Notes
issued by Centerline 2007-SRR5, Ltd. The downgrade is due to
the deterioration in the credit quality of the underlying
portfolio of reference obligations and an Event of Default
("EOD") which occurred on February 24, 2012; increasing the
likelihood of liquidation. 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.

Moody's rating actions:

US$200,000,000 Class A-1 Senior Secured Floating Rate Notes Due
2052, Downgraded to C (sf); previously on May 19, 2010 Downgraded
to Ca (sf)

US$128,000,000 Class A-2 Senior Secured Floating Rate Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$42,000,000 Class B Senior Secured Floating Rate Notes Due 2052,
Affirmed at C (sf); previously on May 19, 2010 Downgraded to C
(sf)

US$39,000,000 Class C Senior Secured Floating Rate Notes Due 2052,
Affirmed at C (sf); previously on May 19, 2010 Downgraded to C
(sf)

US$24,000,000 Class D Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$42,000,000 Class E Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$17,000,000 Class F Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$34,000,000 Class G Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$4,000,000 Class H Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$10,000,000 Class J Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$8,000,000 Class K Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$10,000,000 Class L Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$7,000,000 Class M Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

US$4,000,000 Class N Floating Rate Deferrable Interest Notes Due
2052, Affirmed at C (sf); previously on May 19, 2010 Downgraded to
C (sf)

Ratings Rationale

Centerline 2007-SRR5, Ltd., is a synthetic CRE CDO transaction
backed by a portfolio of funded credit default swaps on commercial
mortgage backed securities (CMBS) (100.0% of the reference
obligation balance). As of the February 22, 2012 Trustee Report,
the notional balance of the reference obligations has decreased to
$667.6 million from $800.0 million at issuance, due to partial or
full write-downs of seven of the reference obligations.

The transaction entered into EOD on February 24, 2012. The EOD
occurred due to a par value ratio failure, the mechanics of which
as set forth in the Indenture.

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.
We have completed updated credit estimates for the non-Moody's
rated reference collateral. The bottom-dollar WARF is a measure of
the default probability within a collateral pool. Moody's modeled
a bottom-dollar WARF of 9,612 compared to 9,620 at last review.
The distribution of current ratings and credit estimates is as
follows: Caa1-C (100.0% the same as at last review).

WAL acts to adjust the probability of default of the reference
collateral in the pool for time. Moody's modeled to a WAL of 6.5
years compared to 6.7 years at last review.

WARR is the par-weighted average of the mean recovery values for
the reference collateral in the pool. Moody's modeled a variable
WARR with a mean of 0.0%, the same as 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 collateral (i.e. the measure of diversity).
Moody's modeled a MAC of 100.0%, 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.

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 obligations.
However, in light of the performance indicators noted above,
Moody's believes that it is unlikely that the ratings announced
today are sensitive to further change.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

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


CHARLIE MAC: Moody's Cuts Rating on Class L Notes to 'C'
--------------------------------------------------------
Moody's Investors Service has upgraded seven tranches, downgraded
9 tranches, and confirmed the ratings on 38 tranches from seven
RMBS transactions issued by Countrywide, Charlie Mac Trust, Chase
Mortgage Finance, and First Horizon Home Loan Corporation. The
collateral backing these deals primarily consists of first-lien,
fixed and adjustable-rate Jumbo residential mortgages. The actions
impact approximately $564.3 million of RMBS issued in 2003 and
2004.

Complete rating actions are:

Issuer: Charlie Mac Trust 2004-2

Class A-1, Downgraded to A2 (sf); previously on Jan 31, 2012 Aaa
(sf) Placed Under Review for Possible Downgrade

Class A-2, Downgraded to A3 (sf); previously on Jan 31, 2012 Aa1
(sf) Placed Under Review for Possible Downgrade

Class A-3, Downgraded to A3 (sf); previously on Jan 31, 2012 Aa1
(sf) Placed Under Review for Possible Downgrade

Class B-1, Downgraded to Ba3 (sf); previously on Jan 31, 2012 A2
(sf) Placed Under Review for Possible Downgrade

Class B-2, Downgraded to Caa3 (sf); previously on Jan 31, 2012
Ba1 (sf) Placed Under Review for Possible Downgrade

Class B-3, Downgraded to C (sf); previously on Jan 31, 2012 B3
(sf) Placed Under Review for Possible Downgrade

Class L, Downgraded to C (sf); previously on Jan 31, 2012 Caa1
(sf) Placed Under Review for Possible Downgrade

Issuer: Chase Mortgage Finance Trust, Series 2004-S3

Class IA-1, Confirmed at A1 (sf); previously on Dec 22, 2011 A1
(sf) Placed Under Review for Possible Upgrade

Class IIA-3, Confirmed at A1 (sf); previously on Dec 22, 2011 A1
(sf) Placed Under Review for Possible Upgrade

Class IIA-4, Confirmed at A1 (sf); previously on Dec 22, 2011 A1
(sf) Placed Under Review for Possible Upgrade

Class IIA-5, Confirmed at A1 (sf); previously on Dec 22, 2011 A1
(sf) Placed Under Review for Possible Upgrade

Class IIIA-1, Confirmed at A1 (sf); previously on Dec 22, 2011
A1 (sf) Placed Under Review for Possible Upgrade

Class A-P, Confirmed at A1 (sf); previously on Dec 22, 2011 A1
(sf) Placed Under Review for Possible Upgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-46

Class 2-A-1, Upgraded to A3 (sf); previously on Jan 31, 2012
Baa2 (sf) Placed Under Review for Possible Upgrade

Class 6-A-1, Upgraded to A3 (sf); previously on Jan 31, 2012
Baa2 (sf) Placed Under Review for Possible Upgrade

Class 7-A-1, Upgraded to A2 (sf); previously on Jan 31, 2012
Baa2 (sf) Placed Under Review for Possible Upgrade

Class M, Confirmed at B2 (sf); previously on Jan 31, 2012 B2
(sf) Placed Under Review for Possible Upgrade

Class B-1, Confirmed at Caa3 (sf); previously on Dec 22, 2011
Caa3 (sf) Placed Under Review for Possible Upgrade

Issuer: CHL Mortgage Pass-Through Trust 2004-14

Class 2-A-5, Confirmed at B2 (sf); previously on Dec 22, 2011 B2
(sf) Placed Under Review for Possible Upgrade

Class 4-A-1, Confirmed at Ba1 (sf); previously on Jan 31, 2012
Ba1 (sf) Placed Under Review for Possible Downgrade

Class 4-A-2, Confirmed at B3 (sf); previously on Dec 22, 2011 B3
(sf) Placed Under Review for Possible Upgrade

Issuer: CHL Mortgage Pass-Through Trust 2004-8

Class 1-A-2, Upgraded to A2 (sf); previously on Jan 31, 2012
Baa2 (sf) Placed Under Review for Possible Upgrade

Class 1-A-3, Confirmed at B1 (sf); previously on Dec 22, 2011 B1
(sf) Placed Under Review for Possible Upgrade

Underlying Rating: Confirmed at B1 (sf); previously on Apr 19,
2011 Downgraded to B1 (sf)

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

Class 1-A-4, Downgraded to Ba3 (sf); previously on Dec 22, 2011
Baa3 (sf) Placed Under Review for Possible Upgrade

Class 1-A-5, Confirmed at B1 (sf); previously on Dec 22, 2011 B1
(sf) Placed Under Review for Possible Upgrade

Class 1-A-6, Confirmed at B1 (sf); previously on Dec 22, 2011 B1
(sf) Placed Under Review for Possible Upgrade

Class 1-A-7, Confirmed at B1 (sf); previously on Dec 22, 2011 B1
(sf) Placed Under Review for Possible Upgrade

Underlying Rating: Confirmed at B1 (sf); previously on Apr 19,
2011 Downgraded to B1 (sf)

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

Class 1-A-8, Confirmed at Ba2 (sf); previously on Dec 22, 2011
Ba2 (sf) Placed Under Review for Possible Upgrade

Class 1-A-10, Upgraded to A3 (sf); previously on Jan 31, 2012
Baa3 (sf) Placed Under Review for Possible Upgrade

Class 1-A-11, Downgraded to B2 (sf); previously on Dec 22, 2011
Ba3 (sf) Placed Under Review for Possible Upgrade

Class 1-A-12, Upgraded to A2 (sf); previously on Jan 31, 2012
Baa2 (sf) Placed Under Review for Possible Upgrade

Class 1-A-13, Upgraded to A2 (sf); previously on Apr 19, 2011
Downgraded to Baa2 (sf)

Class 2-A-1, Confirmed at Ba2 (sf); previously on Jan 31, 2012
Ba2 (sf) Placed Under Review for Possible Downgrade

Issuer: CWMBS Mortgage Pass-Through Trust 2004-HYB1

Class 2-A, Confirmed at Ba1 (sf); previously on Dec 22, 2011 Ba1
(sf) Placed Under Review Direction Uncertain

Issuer: First Horizon Mortgage Pass-Through Trust 2003-8

Class I-A-4, Confirmed at A1 (sf); previously on Jan 31, 2012 A1
(sf) Placed Under Review for Possible Upgrade

Class I-A-6, Confirmed at A1 (sf); previously on Jan 31, 2012 A1
(sf) Placed Under Review for Possible Upgrade

Class I-A-7, Confirmed at A1 (sf); previously on Jan 31, 2012 A1
(sf) Placed Under Review for Possible Upgrade

Class I-A-10, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-11, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-12, Confirmed at A3 (sf); previously on Jan 31, 2012
A3 (sf) Placed Under Review for Possible Upgrade

Class I-A-17, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-18, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-19, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-20, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-35, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-36, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-37, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-38, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-39, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-40, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-41, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-46, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class I-A-47, Confirmed at A1 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Upgrade

Class II-A-1, Confirmed at A3 (sf); previously on Jan 31, 2012
A3 (sf) Placed Under Review for Possible Upgrade

Ratings Rationale

These actions correct an error in the Structured Finance
Workstation cash flow model used by Moody's in rating these
transactions, specifically in how the model handled cash
distribution from prepayments between senior and subordinate
certificates. When rating these deals, the error in the model led
to some senior certificates not being credited with the
appropriate amount of principal prepayments. It should be noted
that model-generated output is but one factor considered by
Moody's in rating these transactions.

Moody's also assessed deal performance to date and applied its
recently updated "Pre-2005 US RMBS Surveillance Methodology"
published in January 2012, and "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2012. Both methodologies impacted the final rating actions.
Therefore, certain of the rating downgrades announced today can be
attributed to specific deal performance deterioration and the
application of these methodologies.

In transactions involving multiple loan pools the cash flow
modeling was conservative in determining when some performance
triggers would send 100% of prepayments to the senior certificates
in deals.

RMBS structures initially allocate cash collections from voluntary
prepayments only to the senior certificates. Gradually over time,
a portion is then allocated to junior certificates. The amount of
cash that senior certificates receive from prepayments starts off
at 100%. After a certain number of months, that percentage starts
decreasing according to a deal-specific schedule as long as
certain conditions are met. However, the share of prepayments to
the senior certificates can revert back to 100% at any
distribution date if certain performance triggers are breached.

One performance trigger measures whether the current credit
protection, expressed as a percentage, to senior bonds from
subordination is greater than the percentage of original credit
protection. Should the deal perform poorly and absorb losses on
the underlying collateral and available credit protection falls
below the original level, then 100% of prepayment cash reverts
back to the senior certificates.

In cases where a deal has two or more loan pools, the calculation
for this performance trigger can be done in one of three ways.

1. "Aggregate level credit protection" Approach: When the
percentage of credit protection available for all senior
certificates, in aggregate, falls below the original percentage of
credit protection, then the prepayment share to all the senior
certificates groups reverts back to 100%.

2. "Individual group trigger" Approach: When the percentage of
credit protection available for a group of senior certificates
falls below the original percentage of group credit protection,
then the prepayment share to the senior certificates of that
particular group reverts back to 100%. All other senior
certificates' share of prepayment remains unchanged.

3. "Combined" Approach: This is a combination of the above two
approaches. When the percentage of credit protection available for
a senior certificates' group falls below the original percentage
of credit protection, then the prepayment share to all senior
certificates from all groups reverts back to 100%.

These transactions included in these rating actions follow the
"individual group trigger" approach when calculating performance
triggers:

CHL MORTGAGE PASS-THROUGH TRUST 2003-46
CHL MORTGAGE PASS-THROUGH TRUST 2004-8
COUNTRYWIDE ALTERNATIVE LOAN TRUST 2004-HYB1

These transactions included in these rating actions follow the
"combined" approach when calculating performance triggers:

CHL MORTGAGE PASS-THROUGH TRUST 2004-14
CHARLIE MAC TRUST 2004-2
CHASE MORTGAGE FINANCE TRUST, SERIES 2004-S3
FIRST HORIZON MORTGAGE PASS-THROUGH TRUST 2003-8

This trigger helps protect senior certificates if credit
protection is eroding by reducing principal payments to junior
certificates and diverting them to pay the senior certificates
instead. While all three approaches described above benefit senior
certificates, the third approach benefits senior certificates the
most, while the first approach benefits senior certificates the
least. The third approach redirects payments to the senior
certificates sooner than the other two approaches. For example,
consider a deal backed by two distinct pools of mortgages (pool A
and pool B) and over time there is a vast difference in
performance of two underlying pools. Pool A performs much
stronger, with lower losses, while pool B performs much weaker. As
per approach 1, the average loss, when pool A and B are combined,
will be medium and hence current combined credit protection may be
higher than the original credit protection. As a result, payments
will not be diverted to the senior certificates. In contrast,
approach 3 will test pool A and pool B individually instead of
taking the average of the two pools. Since pool B is performing
weaker, current credit protection may be lower than the original
credit protection. As a result, it will divert payments to the
senior certificates backed by both pools A and B. Approach 2 will
only revert payments back to senior certificates backed by pool B,
so it is beneficial for only one group.

The Pooling and Servicing Agreements for the deals impacted by
this rating action require the use of the "combined" and
"individual group trigger" approaches as noted above. As Moody's
explained when these bonds were placed on review, previous rating
actions on these deals mistakenly used the "aggregate level credit
protection" approach in their modeling. Under this approach,
prepayment allocation to senior certificates was changed back to
100% only when all groups failed the test, with the result that
senior certificates received too little credit for prepayments
while junior certificates received too much. As a result the pay-
down rate of the senior certificates was slower than it should
have been, while the reverse was true for the junior certificates.
The cash flow models have been corrected to reflect the
application of the appropriate approach required in the deals. In
resolving the review actions Moody's has taken into account the
corrected models as well as the performance of the impacted
transactions.

The methodologies used in these ratings were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, "Pre-2005 US RMBS Surveillance Methodology"
published in January 2012, and "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2012. Please see the Credit Policy page on www.moodys.com for a
copy of these methodologies.

The approach is also adjusted slightly when estimating losses on
pools left with a small number of loans to account for the
volatile nature of small pools. Even if a few loans in a small
pool become delinquent, there could be a large increase in the
overall pool delinquency level due to the concentration risk. To
project losses on pools with fewer than 100 loans, Moody's first
estimates a "baseline" average rate of new delinquencies for the
pool that varies from 3% to 10% on average. The baseline rates are
higher than the average rate of new delinquencies for larger pools
for the respective vintages.

Once the baseline rate is set, further adjustments are made based
on 1) the number of loans remaining in the pool and 2) the level
of current delinquencies in the pool. The volatility of pool
performance increases as the number of loans remaining in the pool
decreases. Once the loan count in a pool falls below 75, the rate
of delinquency is increased by 1% for every loan less than 75. For
example, for a pool with 74 loans with a base rate of new
delinquency of 3.00%, the adjusted rate of new delinquency would
be 3.03%. In addition, if current delinquency levels in a small
pool is low, future delinquencies are expected to reflect this
trend. To account for that, the rate calculated above is
multiplied by a factor ranging from 0.75 to 2.5 for current
delinquencies ranging from less than 2.5% to greater than 10%
respectively. Delinquencies for subsequent years and ultimate
expected losses are projected using the approach described in the
"Pre-2005 US RMBS Surveillance Methodology" publication.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market. Moody's now
projects house price index to reach a bottom in 2012, with a 3%
remaining decline in 2012, and unemployment rate to start
declining, albeit slowly, as the year progresses.


CITIGROUP COMM'L: Moody's Corrects Ratings on Two CMBS Classes
--------------------------------------------------------------
Moody's Investors Service is correcting the rating for Citigroup
Commercial Mortgage Trust 2006-C5's Cl. XP PAC IO (CUSIP:
17310MAM2) to Aaa(sf) from Ba3(sf) and for CL XC WAC IO (CUSIP:
17310MAN0) to Ba3(sf) from Aaa(sf). Due to an internal
administrative error, as part of the rating action announced on
February 22, 2012, Cl. XP PAC IO was inadvertently downgraded to
Ba3(sf) and CL XC WAC IO was inadvertently affirmed at Aaa(sf).
Cl. XP PAC IO should have been affirmed at Aaa(sf) and CL XC WAC
IO should have been downgraded to Ba3(sf).

The correct current ratings for these two Commercial Mortgage
Pass-Through Certificates are:

Transaction Name:

Citigroup Commercial Mortgage Trust 2006-C5

Tranche Name and Current Rating:

Cl. XP PAC IO, Current Rating Aaa(sf);

Cl. XC WAC IO, Current Rating Ba3(sf).

The Rating List of affected securities from the February 22, 2012
rating action has been updated; a complete list is available at
http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF277364.


CMBSPOKE 2006-I: Moody's Cuts Rating on Class C Notes to Caa3(sf)
-----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of two
classes of Notes issued by CMBSpoke 2006-I Segregated Portfolio
due to deterioration in the credit quality of the underlying
reference obligations as evidenced by the weighted average rating
factor (WARF) and the weighted average recovery rate (WARR). The
affirmation is 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, Affirmed at Caa1 (sf); previously on Apr 6, 2011 Downgraded
to Caa1 (sf)

Cl. B, Downgraded to Caa2 (sf); previously on Apr 6, 2011
Downgraded to Caa1 (sf)

Cl. C, Downgraded to Caa3 (sf); previously on Apr 6, 2011
Downgraded to Caa2 (sf)

Ratings Rationale

CMBSpoke 2006-I, Ltd. is a static synthetic CRE CDO transaction
backed by a portfolio of credit default swaps on commercial
mortgage backed securities (CMBS) (100.0% of the reference pool
balance). As of the February 24, 2012 Trustee report, the
aggregate issued Note balance of the transaction, was
$100.0 million, the same as that at issuance.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
We have completed updated credit estimates for the non-Moody's
rated reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference obligation pool.
Moody's modeled a bottom-dollar WARF of 154 compared to 122 at
last review. The distribution of current ratings and credit
estimates is as follows: Aaa-Aa3 (64.3% compared to 79.2% at last
review), A1-A3 (15.9% compared to 6.9% at last review), Baa1-Baa3
(11.9% compared to 6.9% at last review) and B1-B3 (7.9% compared
to 6.9% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 2.4
years compared to 3.0 years at last review.

WARR is the par-weighted average of the mean recovery values for
the reference obligations in the pool. Moody's modeled a variable
WARR with a mean of 53.2% compared to 59.5% 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 pool (i.e. the measure of
diversity). Moody's modeled a MAC of 36.8% compared to 35.2% at
last review.

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

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
rating changes within the reference obligation pool. Holding all
other key parameters static, changing the current ratings and
credit estimates of the reference obligations by one notch
downward or by one notch upward affects the model results by
approximately 0.9 to 1.0 notches downward and 1.3 to 1.4 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 extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards
and credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

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


COMM 2004-LNB3: DBRS Confirms Classes L, M & N Ratings at 'C'
-------------------------------------------------------------
DBRS has confirmed thirteen classes of COMM 2004-LNB3:

  -- Classes A-1A, A-4, A-5, B and X at AAA (sf)
  -- Class C at AA (high) (sf)
  -- Class D at AA (low) (sf)
  -- Class E at A (sf)
  -- Class F at A (low) (sf)
  -- Class G at BBB (high) (sf)
  -- Classes L, M and N at C (sf)

DBRS has also downgraded three classes of COMM 2004-LNB3:

  -- Class H to BB (high) (sf) from BBB (low) (sf)
  -- Class J to B (low) (sf) from B (sf)
  -- Class K to C (sf) from CCC (sf)

In addition, Class H has added Interest in Arrears and has been
noted as such.  Classes J, K, L, M and N previously had Interest
in Arrears and the designation remains in place.

The downgrades are a result of projected losses for the loans in
special servicing, with particular attention to the status of Beau
Terre Office Building (Prospectus ID#16, 3.82% of the current pool
balance).

Beau Terre Office Building (Prospectus ID#16) is secured by a
373,884 sf office property in Bentonville, Arkansas.  This loan
transferred to special servicing in May 2010 for imminent default.
Bentonville is the corporate headquarters for Wal-Mart Stores,
Inc. (Wal-Mart) and new office supply grew significantly from 2005
through 2007 following Wal-Mart's public announcement that it
preferred to use local suppliers.  The community's office market
suffered when Wal-Mart relocated its apparel division to New York.
Units at this property are smaller in nature, with the largest
tenant, ConAgra Food Sales, representing 4.9% of the net rentable
area (NRA).  A June 2011 appraisal suggests a property value of
$16.3 million, representing 211% of the outstanding loan balance.
Following the reduced appraised value, the appraisal subordinate
entitlement reduction (ASER) amount related to this loan was
increased by approximately $40,000, causing interest shortfalls to
spill into Class H.  The property is now real estate owned (REO)
and the short-term strategy reportedly involves leasing up vacant
space in order to stabilize the asset.  DBRS believes that the
projected loss severity associated with the liquidation of this
property will hinge on the success of this stabilization period;
the success may actually increase recovery over the current
appraised value.

The uncertainty surrounding the timing of the liquidation of Beau
Terre Office Building (Prospectus ID#16) and the second loan in
special servicing, Cordova Shops (Prospectus ID#68, 0.3% of the
current pool balance), as well as the increase to interest
shortfalls has contributed to the downgrade of Class H, Class J
and Class K.  In addition, DBRS has placed Class H and Class J on
Negative trend due to the limited credit enhancement that would be
available to these classes if DBRS's liquidation scenario of
$22.1 million should materialize.

DBRS continues to monitor this transaction on a monthly basis,
with increased focus on these pivotal loans and the other loans
currently on the servicer's watchlist.  As a whole, the
transaction has exhibited stable performance, with observed
improvement over time.  The current weighted-average (WA) debt
service coverage ratio (DSCR) and WA debt yield for the pool are
1.9 times (x) and 14.1%, respectively.  In comparison, the WA DSCR
and WA debt yield at issuance were 1.6x and 10.3%, respectively.
Several of the original top ten loans have paid out of the pool,
contributing to the full principal repayment of Class A-1, Class
A-2 and Class A-3, as well as significant pay down to Class A-4.
The transaction has significant bar-belled performance, benefiting
from its volume of fully defeased loans (19.4% of current pool
balance) and the three largest loans (31.8%) which are shadow-
rated investment-grade by DBRS.


COMM 2012-LC4: Moody's Rates Class F Notes at '(P)B2 (sf)'
----------------------------------------------------------
Moody's Investors Service has assigned ratings to twelve classes
of CMBS securities, issued by COMM 2012-LC4 Commercial Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series 2012-
LC4.

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-M, Assigned (P)Aaa (sf)

Cl. B, Assigned (P)Aa2 (sf)

Cl. C, Assigned (P)A2 (sf)

Cl. X-A, Assigned (P)Aaa (sf)

Cl. X-B, Assigned (P)Ba3 (sf)

Cl. D, Assigned (P)Baa3 (sf)

Cl. E, Assigned (P)Ba2 (sf)

Cl. F, Assigned (P)B2 (sf)

Ratings Rationale

The Certificates are collateralized by 43 fixed rate loans secured
by 67 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 1.63X is higher than the 2007
conduit/fusion transaction average of 1.31X. The Moody's Stressed
DSCR of 1.19X is higher than the 2007 conduit/fusion transaction
average of 0.92X.

Moody's Trust LTV ratio of 90.3% is lower than the 2007
conduit/fusion transaction average of 110.6%. Moody's Total LTV
ratio (inclusive of subordinated debt) of 94.9% 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 22.0. The transaction's loan level diversity
is in-line with 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 27.5. The
transaction's property diversity profile is in-line with 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 2.4, which is slightly
worse with the indices calculated in most multi-borrower
transactions since 2009.

The transaction benefits from two loans, representing
approximately 9.4% of the pool balance in aggregate, assigned an
investment grade credit estimate. Loans assigned investment grade
credit estimates are not expected to contribute any loss to a
transaction in low stress scenarios, but are expected to
contribute minimal amounts of loss in high stress scenarios.
Moody's also considers the creditworthiness of loans when
evaluating the effects of pooling among portfolio assets.
Generally, a loan's affect on the diversity profile of a portfolio
is inversely correlated with the loan's creditworthiness. As such,
high quality loans only marginally benefit a pool's diversity
profile when they are small, or marginally harm a pool's diversity
profile when they are large.

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 Structured Finance Interest-Only
Securities" published in February 2012.

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. Moody's
analysis also uses the CMBS IO calculator ver1.0 which references
the following inputs to calculate the proposed IO rating based on
the published methodology: original and current bond ratings and
credit estimates; original and current bond balances grossed up
for losses for all bonds the IO(s) reference(s) within the
transaction; and IO type corresponding to an IO type as defined in
the published methodology.

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%, 13%, or 21%, the model-indicated rating for the currently
rated Super Senior Aaa classes and the rated Aaa A-M 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.


CREDIT SUISSE: Moody's Affirms Ratings on 2 Class Notes at 'C'
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of four classes,
confirmed two classes and affirmed five classes of Credit Suisse
First Boston Mortgage Securities Corp., Commercial Mortgage Pass-
Through Certificates, Series 2001-CKN5:

Cl. D, Affirmed at Aaa (sf); previously on Dec 16, 2011
Confirmed at Aaa (sf)

Cl. E, Downgraded to A3 (sf); previously on Dec 16, 2011
Downgraded to Aa3 (sf) and Remained On Review for Possible
Downgrade

Cl. F, Downgraded to B1 (sf); previously on Dec 16, 2011
Downgraded to Ba1 (sf) and Remained On Review for Possible
Downgrade

Cl. G, Downgraded to B3 (sf); previously on Dec 16, 2011
Downgraded to B1 (sf) and Remained On Review for Possible
Downgrade

Cl. H, Downgraded to Caa2 (sf); previously on Dec 16, 2011
Downgraded to B3 (sf) and Remained On Review for Possible
Downgrade

Cl. J, Confirmed at Caa3 (sf); previously on Dec 16, 2011
Downgraded to Caa3 (sf) and Remained On Review for Possible
Downgrade

Cl. K, Confirmed at Ca (sf); previously on Dec 16, 2011
Downgraded to Ca (sf) and Remained On Review for Possible
Downgrade

Cl. L, Affirmed at C (sf); previously on Dec 16, 2011 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Aug 4, 2010 Downgraded
to C (sf)

Cl. A-X, Affirmed at Caa2 (sf); previously on Feb 22, 2012
Downgraded to Caa2 (sf) and Placed Under Review for Possible
Downgrade

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

Ratings Rationale

The downgrades are due to expected ongoing interest shortfalls and
lower estimated recoveries resulting from the continued credit
deterioration and servicer advancements made on the Macomb Mall
and One Sugar Creek Place loans since the prior review.

The confirmations and 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 our 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
51.9% of the current balance. At last review, Moody's cumulative
base expected loss was 47.9%. Realized losses have increased from
2.1% of the original balance to 2.2% since the prior review. While
many of the healthy loans exited the pool at maturity, troubled
loans now represent an outsized portion of the pool, resulting in
the high expected loss. Moody's provides a current list of base
expected losses for conduit and fusion CMBS transactions on
moodys.com at:

  http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.

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

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

The methodologies used in this rating were "Moody's Approach to
Rating U.S. CMBS Conduit Transactions" published in September
2000, "Moody's Approach to Rating Structured Finance Interest-Only
Securities" published in February 2012, 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 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
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 review also incorporated the CMBS IO calculator ver 1.0,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point . For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 4 compared to 5 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 a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated December 4, 2011.

DEAL PERFORMANCE

As of the February 17, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 87%
to $139 million from $1.07 billion at securitization. The
Certificates are collateralized by 21 mortgage loans ranging in
size from less than 1% to 30% of the pool, with the top ten loans
representing 99.4% of the pool. The pool does not contain any
loans with investment grade credit estimates or that have been
defeased by US Government securities.

Two 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 our
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Nineteen loans have been liquidated from the pool, resulting in a
realized loss of $23.1 million (23% loss severity). Currently six
loans, representing 76% of the pool, are in special servicing,
including the two largest loans in the pool. The largest exposure
in the pool is the Macomb Mall Loan ($41.6 million -- 29.9% of the
pool), which is secured by a Class B mall located fifteen miles
north of downtown Detroit, Michigan. Three additional regional
malls operate within ten miles of the subject property. In
September 2009, the loan was transferred to special servicing due
to imminent monetary default. As recently as May 2011 the sponsor
and special servicer appeared to be close to a modification
agreement but negotiations faltered and a foreclosure suit was
filed. The property became REO in October 2011. Since the onset of
the recession, the property has struggled to maintain strong
occupancy levels and was 71% leased as of June 2011. Not included
in the collateral is shadow anchor tenant Sears, which occupies
385,000 square feet (SF) at the property. Moody's anticipates a
$31.4 million loss (based on a 76% expected loss) for the loan.

The second largest exposure in the pool is the One Sugar Creek
Place Loan ($40.5 million -- 29.1% of the pool). The loan is
secured by a 509,428 SF office property located 20 miles from
downtown Houston. The property was 100% occupied by Unocal until
the tenant vacated at lease expiration in March 2010. The property
was transferred to special servicing in April 2010 and became REO
in January 2011. As of February 2012, the property was 18% leased.
The building has inadequate parking, with a parking ratio of only
2.1 spaces per thousand square feet. While the sole tenant
occupies just 18% of the NRA (net rentable area), it is allocated
approximately 50% of all parking spaces at the property, hindering
the lease-up process.

The remaining four specially serviced loans are secured by a mix
of property types. Moody's estimates an aggregate $67.7 million
loss for the six serviced loans (65% expected loss on average).

Once the Macomb Mall Loan took an appraisal reduction in November
2011, classes F to N began to experience interest shortfalls.
Moody's anticipates that the pool will continue to experience
interest shortfalls to Classes F to N until the Macomb Mall and
One Sugar Creek Place loans are resolved. During the February 2012
reporting period classes F and G did not experience interest
shortfalls as some funds from the Macomb Mall cash sweep account
were used to satisfy some outstanding payments. Moody's considers
this a one-time event. Interest shortfalls are caused by special
servicing fees, including workout and liquidation fees, appraisal
subordinate entitlement reductions (ASERs) and extraordinary trust
expenses. Loss estimates will continue to increase for the Macomb
Mall and One Sugar Creek Place loans as advances are made by the
servicer while they are REO. Servicer advancements and ASERs are
paid back before the trust receives any liquidation proceeds. This
is addition to concerns regarding continued performance
deterioration.

Moody's was provided with full year 2010 operating results for 87%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 120% compared to 116% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 26% to the most recently available net operating
income. The high haircut is due to a significant discount to
current performance for Bayshore due to concerns about future
performance declines. uMall Moody's value reflects a weighted
average capitalization rate of 10.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 0.87X and 1.03X, respectively, compared to
0.94X and 1.09X 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 conduit loan represents 21.1% of the pool, with no
additional conduit loans accounting for more than 1.6% of the
pool. The largest loan is the Bayshore Mall Loan ($29.2 million --
21.1% of the pool), which is secured by a 430,000 SF regional mall
located in Eureka, California. A GGP sponsored loan, the asset is
one of thirty properties being spun off into Rouse Properties. The
loan's term was extended until September 2016 as part of GGP's
restructuring. Property performance deteriorated this year as the
property was 70% leased as of September 2011, compared to 77%
leased at year-end 2010. Property performance has suffered from
higher vacancy along with lower base rents and expense recoveries.
Moody's LTV and stressed DSCR are 127% and 0.85X, respectively,
compared to 128% and 0.85X at last review.


DEUTSCHE ALT-A: S&P Lowers Ratings on 2 Classes to 'D'
------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 12
classes from five U.S. residential mortgage-backed securities
(RMBS) transactions issued from 2003 through 2007. "Concurrently,
we affirmed our ratings on 99 classes from all of the reviewed
transactions. The 12 RMBS transactions in this review are backed
by various types of mortgage loan collateral," S&P said.

"he 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.
For certain classes, the downgrades incorporated our interest
shortfall criteria," S&P said.

"he affirmations reflect our belief that projected credit
enhancement available for the affected classes will be more than
sufficient to cover our projected losses at the current rating
levels; however, we are not upgrading some of these ratings to
reflect our view of ongoing market risk," S&P said.

"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. 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
said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

         http://standardandpoorsdisclosure-17g7.com

Rating Actions

Deutsche Alt-A Securities Inc Mortgage Loan Trust Series 2003-4XS
Series      2003-4XS
                               Rating
Class      CUSIP       To                   From
A-5        251510CF8   B+ (sf)              A+ (sf)
A-6A       251510CG6   A- (sf)              AAA (sf)
A-6B       251510CT8   A- (sf)              AAA (sf)
M-1        251510CJ0   D (sf)               CCC (sf)
M-2        251510CK7   D (sf)               CC (sf)

First Horizon Alternative Mortgage Securities Trust 2005-AA4
Series      2005-AA4
                               Rating
Class      CUSIP       To                   From
I-A-1      32051GNH4   CC (sf)              CCC (sf)

Morgan Stanley Mortgage Loan Trust 2007-13
Series      2007-13
                               Rating
Class      CUSIP       To                   From
7-A-11     61756HCD0   CC (sf)              CCC (sf)
5-A-3      61756HBK5   CC (sf)              CCC (sf)

Structured Asset Securities Corporation Mortgage Loan Trust 2006-
GEL1
Series      2006-GEL1
                               Rating
Class      CUSIP       To                   From
M1         863576EG5   BB (sf)              AA (sf)
M2         863576EH3   CC (sf)              A+ (sf)
M3         863576EJ9   CC (sf)              CCC (sf)

WaMu Mortgage Pass-Through Certificates Series 2005-AR1 Trust
Series      2005-AR1
                               Rating
Class      CUSIP       To                   From
B-1        939336Y23   CC (sf)              CCC (sf)

RATINGS AFFIRMED

Alternative Loan Trust 2005-3CB
Series      2005-3CB
Class      CUSIP       Rating
1-A-1      12667FW76   CCC (sf)
1-A-2      12667FW84   CCC (sf)
1-A-3      12667FW92   CCC (sf)
1-A-4      12667FX26   CCC (sf)
1-A-5      12667FX34   CCC (sf)
1-A-7      12667FX59   CCC (sf)
1-A-8      12667FX67   CCC (sf)
1-A-9      12667FX75   CCC (sf)
1-A-10     12667FX83   CCC (sf)
1-A-11     12667FX91   CCC (sf)
1-A-13     12667FY33   CCC (sf)
1-A-14     12667FY41   CCC (sf)
2-A-1      12667FY58   CCC (sf)
PO         12667FY66   CC (sf)
M          12667FY82   CC (sf)
B-1        12667FY90   CC (sf)

Alternative Loan Trust 2005-73CB
Series      2005-73CB
Class      CUSIP       Rating
1-A-1      12668AT62   CCC (sf)
1-A-2      12668AT70   CC (sf)
1-A-3      12668AT88   CC (sf)
1-A-4      12668AT96   CC (sf)
1-A-5      12668AU29   CC (sf)
1-A-7      12668AU45   CC (sf)
1-A-8      12668AU52   CC (sf)
1-A-9      12668AU60   CC (sf)
1-A-10     12668AU78   CC (sf)
1-A-11     12668AU86   CC (sf)
1-A-12     12668AU94   CC (sf)
1-A-13     12668AV28   CC (sf)
2-A-1      12668AV36   CC (sf)
2-A-2      12668AV44   CC (sf)
2-A-3      12668AV51   CC (sf)
2-A-4      12668AV69   CC (sf)
2-A-5      12668AW68   CC (sf)
PO         12668AV93   CC (sf)

Alternative Loan Trust 2005-75CB
Series      2005-75CB
Class      CUSIP       Rating
A-1        12668AF67   CC (sf)
A-3        12668AF83   CC (sf)
A-4        12668AF91   CC (sf)
A-5        12668AG25   CC (sf)
A-6        12668AG33   CC (sf)
A-7        12668AG41   CC (sf)
PO         12668AG66   CC (sf)

Alternative Loan Trust 2006-HY12
Series      2006-HY12
Class      CUSIP       Rating
A-1        02146PAA3   A- (sf)
A-2        02146PAB1   A- (sf)
A-3        02146PAC9   BB- (sf)
A-4        02146PAD7   B (sf)
A-5        02146PAF2   B- (sf)

Citigroup Mortgage Loan Trust Inc.
Series      2005-WF2
Class      CUSIP       Rating
AF-4       17307GVJ4   CCC (sf)
AF-5       17307GVK1   CCC (sf)
AF-6A      17307GVL9   CCC (sf)
AF-6B      17307GVM7   CCC (sf)
AF-7       17307GVN5   CCC (sf)
MF-1       17307GVP0   CC (sf)
AV-3       17307GVV7   AAA (sf)
MV-1       17307GVW5   AA (sf)
MV-2       17307GVX3   A (sf)
MV-3       17307GVY1   CCC (sf)
MV-4       17307GVZ8   CC (sf)

Deutsche Alt-A Securities Inc Mortgage Loan Trust Series 2003-4XS
Series      2003-4XS
Class      CUSIP       Rating
A-4        251510CE1   AAA (sf)

First Horizon Alternative Mortgage Securities Trust 2005-AA4
Series      2005-AA4
Class      CUSIP       Rating
II-A-1     32051GNK7   CCC (sf)

IndyMac INDX Mortgage Loan Trust 2005-AR17
Series      2005-AR17
Class      CUSIP       Rating
1-A-1      45660LUS6   CC (sf)
2-A-1      45660LUU1   CC (sf)
4-A-1      45660LUX5   CCC (sf)
6-A-1      45660LVA4   CCC (sf)

Morgan Stanley Mortgage Loan Trust 2007-13
Series      2007-13
Class      CUSIP       Rating
1-A-1      61756HAA8   CC (sf)
1-A-2      61756HAB6   CC (sf)
1-A-3      61756HAC4   CC (sf)
1-A-P      61756HAD2   CC (sf)
2-A-1      61756HAF7   CC (sf)
2-A-2      61756HAG5   CC (sf)
2-A-3      61756HAH3   CC (sf)
2-A-P      61756HAJ9   CC (sf)
3-A-1      61756HAK6   CC (sf)
4-A-4      61756HAQ3   CC (sf)
4-A-6      61756HAS9   CC (sf)
4-A-8      61756HAU4   CC (sf)
6-A-1      61756HBN9   CC (sf)
6-A-3      61756HBQ2   CC (sf)
6-A-4      61756HBR0   CC (sf)
6-A-5      61756HBS8   CC (sf)
7-A-1      61756HBT6   CC (sf)
7-A-4      61756HBW9   CCC (sf)
7-A-6      61756HBY5   CC (sf)
7-A-8      61756HCA6   CCC (sf)
7-A-17     61756HCK4   CC (sf)
5-A-1      61756HBH2   CC (sf)
5-A-P      61756HBM1   CC (sf)

Structured Asset Securities Corporation Mortgage Loan Trust 2006-
GEL1
Series      2006-GEL1
Class      CUSIP       Rating
A2         863576EF7   AAA (sf)

WaMu Mortgage Pass-Through Certificates Series 2005-AR1 Trust
Series      2005-AR1
Class      CUSIP       Rating
A-1A       939336X40   AAA (sf)
A-1B       939336X57   A (sf)
A-2A1      939336X65   AAA (sf)
A-2A3      939336X81   AAA (sf)
A-2B       939336X99   A (sf)
A-3        939336Z22   A+ (sf)
X          939336Y56   AAA (sf)
B-2        939336Y31   CC (sf)

WaMu Mortgage Pass-Through Certificates Series 2006-AR15 Trust
Series      2006-AR15
Class      CUSIP       Rating
1A         93363QAA6   CCC (sf)
1A-1B      93363QAB4   CC (sf)
2A         93363QAC2   B (sf)
2A-1B      93363QAD0   CC (sf)


DEUTSCHE MORTGAGE: S&P Cuts Rating on Class 3-A-1 to 'CC'
---------------------------------------------------------
Standard & Poor's Ratings Services reinstated its rating on
class 2-A-X, an interest-only (IO) class from Deutsche Mortgage
Securities Inc. "REMIC Trust Certificates Series 2008-RS1 (DMS
2008-RS1), which we incorrectly withdrew on Aug. 31, 2011. We then
lowered the rating to 'AA+ (sf)' from 'AAA (sf)'. The downgrade of
class 2-A-X reflects the application of our IO criteria," S&P
said.

"We also corrected our rating on class 2-A-1 by lowering it
to 'AA+ (sf)'. Due to an administrative error, we did not
contemporaneously downgrade this class with the Aug. 5, 2011
downgrade of the long-term sovereign credit rating on the U.S. to
'AA+' from 'AAA'," S&P said.

"Concurrently, we lowered our rating on class 3-A-1 to 'CC (sf)'
from 'CCC (sf)' and affirmed our 'CCC (sf)'rating on 4-A-1. These
rating actions reflect our view that the projected credit support
within the re-REMIC available for these classes is insufficient to
cover the losses we project the underlying classes will pass
through to the re-REMIC," S&P said.

"In performing our ratings analysis on the re-REMIC transaction,
we reviewed the interest and principal amounts due on the
underlying securities, which are then passed through to the
applicable re-REMIC classes. We applied our loss projections,
incorporating our 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 said.

Deutsche Mortgage Securities, Inc. REMIC Trust Certificates Series
2008-RS1 is a U.S. residential mortgage-backed securities (RMBS)
resecuritized real estate mortgage investment conduit (re-REMIC)
transaction. The group 2 underlying certificates are guaranteed by
Fannie Mae. The group 3 and group 4 underlying certificates are
backed by Alt-A mortgage loan collateral.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

            http://standardandpoorsdisclosure-17g7.com

Ratings Corrected

Deutsche Mortgage Securities Inc. REMIC Trust Certificates Series
2008-RS1
                                 Rating
Class  CUSIP      Current  Interim   08/31/11  Pre-08/31/11
2-A-X  25156BAF1  AA+ (sf) AAA (sf)  NR        AAA (sf)

                             Rating
Class     CUSIP         To           From
2-A-1     25156BAE4     AA+ (sf)     AAA (sf)

Rating Action

Deutsche Mortgage Securities Inc. REMIC Trust Certificates Series
2008-RS1

                             Rating
Class     CUSIP         To           From
3-A-1     25156BAG9     CC (sf)      CCC (sf)

Rating Affirmed

Deutsche Mortgage Securities Inc. REMIC Trust Certificates Series
2008-RS1

Class      CUSIP         Rating
4-A-1      25156BAL8     CCC (sf)

NR -- Not rated.


EXETER 2012-1: S&P Gives 'BB' Rating on Class D Notes
-----------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Exeter
Automobile Receivables Trust 2012-1's $200 million automobile
receivables-backed notes series 2012-1.

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

The ratings reflect S&P's view of:

* "The availability of approximately 46%, 39%, 32%, and 24% of
   credit support for the class A, B, C, and D notes based on
   stress cash flow scenarios (including excess spread), which
   provide coverage of more than 2.8x, 2.3x, 1.75x, and 1.4x our
   14.00%-15.00% expected cumulative net loss (CNL)," S&P said.

* The timely interest and principal payments made under stress
   cash flow modeling scenarios appropriate to the assigned
   ratings.

* "Our expectation that under a moderate ('BBB') stress scenario,
   all else being equal, our ratings on all classes of notes would
   remain within one rating category of the assigned 'AA (sf)', 'A
   (sf)', 'BBB (sf)', and 'BB (sf)' ratings during the first year.
   These potential rating movements are consistent with our credit
   stability criteria, which outlines the outer bound of credit
   deterioration equal to a one-category downgrade within the
   first year for 'AA' rated securities and a two-category
   downgrade within the first year for 'A' through 'BB' rated
   securities under the moderate stress conditions," S&P said.

* The servicer's experienced management team with an average of
   over 16 years of experience in the auto finance industry.

* "Our analysis of three-and-a-half years of static pool data on
   Exeter Finance Corp.'s lending programs," S&P said.

* "The fact that the company is not profitable yet, has a
   relatively short performance history (3.5 years) compared to
   its peer companies, and that the company, itself, doesn't have
   a securitization track record. We also took into account the
   company's rapid growth plan," S&P said.

* The transaction's payment/credit enhancement 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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

      http://standardandpoorsdisclosure-17g7.com

Ratings Assigned
Exeter Automobile Receivables Trust 2012-1


Class     Rating      Type            Interest          Amount
                                      rate            (mil. $)
A         AA (sf)     Senior          Fixed             142.00
B         A (sf)      Subordinate     Fixed              23.50
C         BBB (sf)    Subordinate     Fixed              17.50
D         BB (sf)     Subordinate     Fixed              17.00


EXETER AUTOMOBILE: DBRS Assigns 'BB' Final Rating to Class D
------------------------------------------------------------
DBRS, Inc., has assigned final ratings to these classes issued by
Exeter Automobile Receivables Trust 2012-1:

  -- Series 2012-1 Notes, Class A rated AAA (sf)
  -- Series 2012-1 Notes, Class B rated 'A' (sf)
  -- Series 2012-1 Notes, Class C rated BBB (sf)
  -- Series 2012-1 Notes, Class D rated BB (sf)


FIFTH THIRD: S&P Reinstates 'BB+' Preferred Stock Rating
--------------------------------------------------------
Standard & Poor's Ratings Services corrected its removal of
preliminary ratings on securities registered for issuance by Fifth
Third Bancorp and five Capital Trust subsidiaries under a shelf
registration by reinstating the ratings. The shelf registration is
dated March 25, 2010.

"On Dec. 6, 2011, in conjunction with our rating action on Fifth
Third Bancorp and its banking subsidiaries under our new bank
criteria, we inadvertently withdrew our preliminary ratings on the
shelf," S&P said.

Ratings Reinstated

Fifth Third Bancorp
Senior Unsecured                          BBB(prelim)
Subordinated                              BBB-(prelim)
Preferred Stock                           BB+(prelim)

Fifth Third Capital Trust VIII
Fifth Third Capital Trust IX
Fifth Third Capital Trust X
Fifth Third Capital Trust XI
Fifth Third Capital Trust XII
Preferred Stock                           BB+(prelim)


FIRST INVESTORS: S&P Gives 'BB+' Rating on Class E Fixed Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to First
Investors Auto Owner Trust 2012-1's $150 million automobile
receivables-backed notes.

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

The ratings reflect S&P's view of:

* "The availability of approximately 34.28%, 29.50%, 22.91%,
   17.03%, and 15.31% credit support for the class A, B, C, D, and
   E notes based on stressed cash flow scenarios (including excess
   spread). These credit support levels provide more than 3.75x,
   3.25x, 2.50x, 1.90x, and 1.67x coverage of our 8.00%-8.50%
   expected cumulative net loss range for the class A, B, C, D,
   and E notes," S&P said.

* The timely interest and principal payments made under stressed
   cash flow modeling scenarios that are appropriate to the
   assigned ratings.

* "Our expectation that under a moderate, or 'BBB', stress
   scenario, the ratings on the class A and B notes would not
   decline by more than one rating category, which is consistent
   with our rating stability criteria, and the ratings on the
   class C and D notes would remain within the two-rating category
   outlined in our rating stability criteria," S&P said.

* The collateral characteristics of the pool being securitized.

* First Investors Financial Services Inc.'s (First Investors')
   22-year history of originating and underwriting auto loans, 13-
   year history of servicing auto loans for itself and other
   companies as a third-party servicer, and track record of
   securitizing auto loans since 2000; and

* Wells Fargo Bank N.A.'s experience as the committed back-up
   servicer; and

* 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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

            http://standardandpoorsdisclosure-17g7.com

Ratings Assigned
First Investors Auto Owner Trust 2012-1


Class     Rating        Type          Interest        Amount
                                      rate          (mil. $)
A-1       A-1+ (sf)     Senior        Fixed            23.30
A-2       AAA (sf)      Senior        Fixed            93.70
B         AA (sf)       Subordinate   Fixed            10.00
C         A (sf)        Subordinate   Fixed            12.00
D         BBB (sf)      Subordinate   Fixed             9.00
E         BB+ (sf)      Subordinate   Fixed             2.00


FIRST UNION: Greater Certainty Prompts Fitch to Lower Ratings
-------------------------------------------------------------
Fitch Ratings has downgraded one class and affirmed four classes
of First Union National Bank Commercial Mortgage Trust 2001-C3,
commercial mortgage pass-through certificates.

The downgrade is due to greater certainty of Fitch expected losses
based on updated valuations for specially serviced loans.  The
affirmations are a result of sufficient credit enhancements to
offset increasing loan concentrations and adverse selection with
only 12 loans remaining.  Fitch modeled losses of 13.44% of the
outstanding pool.  The expected losses of the original pool are at
3.44%, which includes 3.16% to date.  Current cumulative interest
shortfalls totaling $932,217 are affecting classes N through P.

As of the February 2012 distribution date, the pool's certificate
balance has paid down 93.32% to $28.7 million from $818.8 million.
Fitch identified four (57.9%) Fitch Loans of Concern, of which
three (44.8%) are specially serviced.  There is one (17.1%)
defeased loan within the pool.

The largest contributor to expected losses is a loan (19.19%)
secured by a 103,703 square foot (SF) office property located in
Wheaton, IL.  The loan transferred to special servicing in
December 2010 for imminent default.  The loan subsequently matured
in April 2011 and is currently due for the November 2011 debt
service payment.  Fitch expects losses upon disposition of the
assets based on valuations obtained by the special servicer.

The second largest contributor to expected losses is a loan
(17.13%) secured by a 102,170 SF office building located in Kansas
City, MO.  The loan transferred to special servicing in July 2011
for maturity default and is paid current on its debt payment as of
the same month.  As per the property's rent roll, it was 71.34%
occupied as of 2011 year-end.  Fitch expects losses upon
resolution of the loan based on recent valuations obtained by the
special servicer.

The third largest contributor to Fitch expected losses is a loan
(8.5%) secured by a 56,382 SF office property in Schaumburg, IL.
The loan transferred to the special servicer in June 2011 for
maturity default.

Fitch downgrades this class and assigns a Recovery Estimate (RE):

  -- $6.1 million class N to 'Csf' from 'CCCsf'; RE 65%.

Fitch affirms these classes:

  -- $11.6 million class K at 'BBBsf'; Outlook Stable;
  -- $6.1 million class L at 'BBsf'; Outlook Stable;
  -- $4 million class M at 'Bsf'; Outlook to Stable from Negative.

Fitch does not rate class P.

Class A-1, A-2, A-3, IO-II, B, C, D, E, F, G, H and J have paid in
full. Classes O will remain at 'D' with a Recovery Estimate of 0%
due to incurred losses.

Fitch has previously withdrawn the ratings on the interest-only
class IO-I.


FORE CLO 2007-1: S&P Affirms 'B+' Rating on Class D Notes
---------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on the
class A-1a, A-1b, A-2, B, C, and D notes from Fore CLO Ltd. 2007-
1, a collateralized loan obligation (CLO) transaction managed by
Fore Research and Management L.P.

"The affirmed ratings reflect the availability of credit support
at the notes' current rating levels. As of the Jan. 12, 2011,
trustee report, the transaction held $0 in defaulted assets. This
is the same level as the November 2009 trustee report, which we
referenced for our December 2009 rating actions, when we
downgraded five classes. The transaction held $18.4 million
in assets from underlying obligors with ratings in the 'CCC'
range, down from $23.4 million over the same time period. The
transaction has maintained overcollateralization (O/C) ratios at
approximately the same levels since November 2009," S&P said.

"The transaction is still in its reinvestment period and all of
the rated classes have their original principal balances
outstanding, except for class D, which has paid down to 86.4% of
its original balance," S&P said.

"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 to support them and take rating
actions as we deem necessary," S&P said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

          http://standardandpoorsdisclosure-17g7.com

Ratings Affirmed

Fore CLO Ltd. 2007-1
Class                   Rating
A-1a                    AA+ (sf)
A-1b                    AA+ (sf)
A-2                     AA+ (sf)
B                       AA (sf)
C                       BBB+ (sf)
D                       B+ (sf)


GALAXY III: S&P Affirms 'CCC-' Ratings on 3 Classes of Notes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, and D notes from Galaxy III CLO Ltd., a collateralized loan
obligation (CLO) transaction managed by PineBridge Investments
LLC. "At the same time, we removed them from CreditWatch positive.
We affirmed our ratings on the class A-1, A-2, E-1, E-2, and E-3
notes," S&P said.

"The upgrades and affirmations of the class A notes reflect the
principal paydowns to the senior notes since our March 2010 rating
actions, for which we referenced the February 2010 trustee report.
These paydowns have led to significant improvements in the
overcollateralization (O/C) levels. As of the February 2012
trustee report, the class A-1 and A-2 notes have paid down to
24% of their original balances from 94% as reported in the
February 2010 report. During the same period, the class C O/C
ratio increased to 137.30% from 118.95%, and the number of
defaulted assets reported by the trustee also fell to one from
14," S&P said.

The affirmations of the class E notes reflect the availability of
sufficient credit support at the current rating levels.

"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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

          http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Galaxy III CLO Ltd.
                   Rating
Class        To               From
B            AAA (sf)         AA+ (sf)/Watch Pos
C            AA+ (sf)         A+ (sf)/Watch Pos
D            BBB+ (sf)        BB+ (sf)/Watch Pos

Ratings Affirmed

Galaxy III CLO Ltd.
Class        Rating
A-1          AAA (sf)
A-2          AAA (sf)
E-1          CCC- (sf)
E-2          CCC- (sf)
E-3          CCC- (sf)


GATEWAY CLO: S&P Raises Rating on Class B Notes to 'B+'
-------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
B notes from Gateway CLO Ltd., a collateralized loan obligation
(CLO) backed by corporate loans to 'B+ (sf)' from 'CCC- (sf)'.
Prudential Investment Management manages the transaction.

"At the same time, we removed the rating from CreditWatch with
positive implications where we had placed it on Dec. 20, 2011,"
S&P said.

"The upgrade reflects an increase in the overall credit support
available to the rated notes since our December 2009 rating action
on the notes," S&P said.

"The amount of defaulted asset in the transaction's asset pool had
decreased to $4.27 million as of the January 2012 trustee report,
which we used in our current analysis, from $26.00 million
according to the October 2009 monthly report, which we used for
our December 2009 action. The trustee report also noted that
the amount of assets rated 'CCC' or lower had decreased to
$17.91 million from $36.53 million over the same time period. As a
result, the class B overcollateralization (O/C) ratio was 104.5%
in January 2012, compared with 102.5% in October 2009," S&P said.

"The rating on the class B tranche was constrained by the
application of the largest obligor default test, a supplemental
stress test we introduced as part of our 2009 corporate CDO
criteria update," S&P said.

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

           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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

           http://standardandpoorsdisclosure-17g7.com


GE CAPITAL: Fitch Affirms Rating on Class O Notes at 'B-sf'
-----------------------------------------------------------
Fitch Ratings has upgraded three classes of GE Capital Commercial
Mortgage Corp.'s (GECCM) commercial mortgage pass-through
certificates, series 2002-3.

The upgrades reflect increased credit enhancement as a result of
paydown and defeasance and stable performance of the underlying
collateral resulting in minimal Fitch expected losses.  Fitch
modeled losses of 2%. There are no loans in special servicing.

As of the February 2012 distribution date, the pool's certificate
balance has been reduced by 39.1% (including 0.2% in realized
losses) to $712.6 million from $1.2 billion.  There are 23
defeased loans (22.4%). There are cumulative interest shortfalls
in the amount of $585,043 currently affecting class P.

The largest loan in the pool (11.7%) is a portfolio of two malls
located in California.  One of the malls suffered substantial fire
damage in October 2010.  The damaged section opened in October
2011. Both of the properties have maintained high occupancy rates
and debt service coverage for several years.

Fitch upgrades these classes:

-- $11.7 million class H to 'AAsf' from 'AA-sf'; Outlook to
    Stable from Positive;
-- $27.8 million class J to 'Asf' from 'A-sf'; Outlook Stable;
-- $8.8 million class L to 'BBBsf' from 'BBB-sf'; Outlook
    Stable;

Fitch has affirmed these classes and Outlooks:

-- $482.4 million class A-2 at 'AAAsf'; Outlook Stable;
-- $46.8 million class B at 'AAAsf'; Outlook Stable;
-- $16.1 million class C at 'AAAsf'; Outlook Stable;
-- $26.3 million class D at 'AAAsf'; Outlook Stable;
-- $14.6 million class E at 'AAAsf'; Outlook Stable;
-- $10.2 million class F at 'AAAsf'; Outlook Stable;
-- $17.6 million class G at 'AAAsf'; Outlook Stable;
-- $10.2 million class K at 'BBBsf'; Outlook Stable;
-- $10.2 million class M at 'BBsf'; Outlook Stable;
-- $8.8 million class N at 'B+sf'; Outlook Stable;
-- $5.9 million class O at 'B-sf'; Outlook Stable.

Classes A-1 and X-2 are paid in full. Fitch does not rate class P.
The rating on class X-1 was previously withdrawn.


GE CAPITAL: Fitch Downgrades Rating on Class K Notes to 'Csf'
-------------------------------------------------------------
Fitch Ratings has downgraded two classes of GE Capital Commercial
Mortgage Corporation's commercial mortgage pass-through
certificates, series 2001-2.

The downgrade is the result of greater certainty of Fitch expected
losses following updated valuations of specially serviced loans.
As of the February 2012 distribution date, the pool's certificate
balance has been reduced by 97.4% (including 3.1% in realized
losses) to $25.9 million from $1 billion.  There are five loans
remaining in the pool. There are cumulative interest shortfalls in
the amount of $1.2 million currently affecting classes K through
N.  The entire pool (100%) is in special servicing.

The largest contributor to losses (40.4% of pool balance) is an
office building located in Campbell, CA. Occupancy is currently
97%. The special servicer is pursuing a note sale and Fitch
expects losses upon disposition of the loan.

Fitch downgrades these classes:

-- $5 million class J to 'CCCsf' from 'BBsf'; RE 100%;
-- $7.5 million class K to 'Csf' from 'CCCsf'; RE to 55% from
    100%.

In addition, Fitch affirms these classes:

-- $9.6 million class I at 'BBB-sf'; Outlook Stable;
-- $3.8 million class L at 'Dsf'; RE to 0% from 35%.

Classes A-1 through H and class X2 are paid in full.  Fitch does
not rate classes M and N.  The rating on class X1 was previously
withdrawn.


GMACM MORTGAGE: Moody's Cuts Rating on Class 5-A-II to 'Caa1(sf)'
-----------------------------------------------------------------
Moody's Investors Service has upgraded 14 tranches, downgraded 31
tranches and confirmed the ratings on eight tranches from 11 RMBS
transactions issued by GMACM, Merrill Lynch, Sequoia, and
Thornburg Mortgage Loan Trusts.  The collateral backing these
deals primarily consists of first-lien, fixed and adjustable-rate
Jumbo residential mortgages.  The actions impact approximately
$763 million of RMBS issued from 2002 to 2004.

Complete rating actions are:

Issuer: GMACM Mortgage Loan Trust 2004-AR2

Class 1-A, Downgraded to B2 (sf); previously on Jan 31, 2012 Ba2
(sf) Placed Under Review for Possible Downgrade

Class 2-A, Downgraded to B2 (sf); previously on Jan 31, 2012 Ba1
(sf) Placed Under Review for Possible Downgrade

Class 3-A, Downgraded to B3 (sf); previously on Jan 31, 2012 Ba3
(sf) Placed Under Review for Possible Downgrade

Class 4-A, Downgraded to B2 (sf); previously on Jan 31, 2012 Ba2
(sf) Placed Under Review for Possible Downgrade

Class 5-A-I, Downgraded to Baa3 (sf); previously on Jan 31, 2012
Aa3 (sf) Placed Under Review for Possible Downgrade

Class 5-A-II, Downgraded to Caa1 (sf); previously on Jan 31,
2012 Ba2 (sf) Placed Under Review for Possible Downgrade

Issuer: Merrill Lynch Mortgage Investors Trust MLCC 2004-A

Class A-1, Upgraded to A3 (sf); previously on Apr 18, 2011
Downgraded to Baa2 (sf)

Class A-2, Upgraded to Baa2 (sf); previously on Dec 22, 2011 Ba1
(sf) Placed Under Review for Possible Upgrade

Class X-A-2, Upgraded to Baa1 (sf); previously on Feb 22, 2012
Downgraded to Baa3 (sf)

Class B-1, Upgraded to B1 (sf); previously on Jan 31, 2012 Caa1
(sf) Placed Under Review for Possible Upgrade

Issuer: Merrill Lynch Mortgage Investors Trust MLCC 2004-C

Class A-1, Downgraded to Baa2 (sf); previously on Apr 18, 2011
Downgraded to A3 (sf)

Class A-2, Upgraded to A2 (sf); previously on Dec 22, 2011 Baa2
(sf) Placed Under Review for Possible Upgrade

Class A-2A, Upgraded to A1 (sf); previously on Jan 31, 2012 Baa2
(sf) Placed Under Review for Possible Upgrade

Class A-2B, Upgraded to A3 (sf); previously on Dec 22, 2011 Baa3
(sf) Placed Under Review for Possible Upgrade

Class A-3, Downgraded to A3 (sf); previously on Jan 31, 2012 Aa2
(sf) Placed Under Review for Possible Downgrade

Class X-A, Upgraded to Baa1 (sf); previously on Feb 22, 2012
Downgraded to Baa2 (sf)

Issuer: Sequoia Mortgage Trust 2003-3

Class A-2, Confirmed at Baa2 (sf); previously on Dec 22, 2011
Baa2 (sf) Placed Under Review Direction Uncertain

Class B-1, Confirmed at Caa2 (sf); previously on Jan 31, 2012
Caa2 (sf) Placed Under Review for Possible Upgrade

Class B-2, Downgraded to C (sf); previously on Dec 22, 2011 Ca
(sf) Placed Under Review for Possible Downgrade

Issuer: Sequoia Mortgage Trust 2003-5

Class A-1, Downgraded to Baa3 (sf); previously on Jan 31, 2012
Baa1 (sf) Placed Under Review for Possible Downgrade

Class A-2, Downgraded to Baa3 (sf); previously on Jan 31, 2012
Baa2 (sf) Placed Under Review for Possible Downgrade

Class X-1A, Downgraded to Baa3 (sf); previously on Apr 27, 2011
Downgraded to Baa1 (sf)

Class X-1B, Downgraded to Baa3 (sf); previously on Apr 27, 2011
Downgraded to Baa1 (sf)

Class X-2, Downgraded to Baa3 (sf); previously on Apr 27, 2011
Downgraded to Baa2 (sf)

Issuer: Sequoia Mortgage Trust 2004-11

Class A-1, Downgraded to Baa3 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Downgrade

Class A-2, Downgraded to Baa3 (sf); previously on Jan 31, 2012
A1 (sf) Placed Under Review for Possible Downgrade

Class A-3, Downgraded to Ba1 (sf); previously on Jan 31, 2012 A2
(sf) Placed Under Review for Possible Downgrade

Class X-A1, Downgraded to Baa3 (sf); previously on Apr 27, 2011
Downgraded to A1 (sf)

Class X-A2, Downgraded to Ba1 (sf); previously on Apr 27, 2011
Downgraded to A2 (sf)

Class X-B, Downgraded to Ca (sf); previously on Feb 22, 2012
Downgraded to B3 (sf)

Class B-1, Downgraded to Caa3 (sf); previously on Jan 31, 2012
Ba2 (sf) Placed Under Review for Possible Downgrade

Class B-2, Downgraded to C (sf); previously on Jan 31, 2012 Caa2
(sf) Placed Under Review for Possible Downgrade

Issuer: Sequoia Mortgage Trust 2004-6

Class A-1, Upgraded to Baa1 (sf); previously on Jan 31, 2012
Baa3 (sf) Placed Under Review for Possible Upgrade

Class A-2, Upgraded to A3 (sf); previously on Jan 31, 2012 Baa2
(sf) Placed Under Review for Possible Upgrade

Class A-3-A, Upgraded to Baa1 (sf); previously on Jan 31, 2012
Baa3 (sf) Placed Under Review for Possible Upgrade

Class A-3-B, Upgraded to Baa3 (sf); previously on Jan 31, 2012
Ba2 (sf) Placed Under Review for Possible Upgrade

Class X-A, Upgraded to Baa1 (sf); previously on Feb 22, 2012
Downgraded to Baa3 (sf)

Class B-1, Upgraded to B2 (sf); previously on Jan 31, 2012 Caa1
(sf) Placed Under Review for Possible Upgrade

Issuer: Thornburg Mortgage Securities Trust 2002-3

Class A-1, Downgraded to Baa2 (sf); previously on Apr 20, 2011
Downgraded to A1 (sf)

Class A-2, Downgraded to Baa2 (sf); previously on Dec 22, 2011
A1 (sf) Placed Under Review for Possible Upgrade

Class A-3, Downgraded to Baa2 (sf); previously on Apr 20, 2011
Downgraded to A3 (sf)

Class A-4, Downgraded to Baa2 (sf); previously on Apr 20, 2011
Downgraded to A2 (sf)

Class B-1, Downgraded to B3 (sf); previously on Jan 31, 2012 Ba3
(sf) Placed Under Review for Possible Downgrade

Issuer: Thornburg Mortgage Securities Trust 2003-3

Class A1, Confirmed at Baa2 (sf); previously on Dec 22, 2011
Baa2 (sf) Placed Under Review for Possible Upgrade

Class A2, Downgraded to Baa2 (sf); previously on Dec 22, 2011 A3
(sf) Placed Under Review for Possible Upgrade

Class A3, Downgraded to Baa2 (sf); previously on Dec 22, 2011 A3
(sf) Placed Under Review for Possible Upgrade

Class A4, Downgraded to Baa2 (sf); previously on Jan 31, 2012 A2
(sf) Placed Under Review for Possible Downgrade

Class B1, Downgraded to B3 (sf); previously on Apr 20, 2011
Downgraded to B1 (sf)

Issuer: Merrill Lynch Mortgage Investors Trust MLCC 2003-H

Class A-1, Confirmed at Baa2 (sf); previously on Dec 22, 2011
Baa2 (sf) Placed Under Review Direction Uncertain

Class A-3B, Confirmed at Baa2 (sf); previously on Dec 22, 2011
Baa2 (sf) Placed Under Review Direction Uncertain

Issuer: Mortgage Pass-Through Certificates, MLMI Series 2003-A2

Class II-A-2, Confirmed at A1 (sf); previously on Dec 22, 2011
A1 (sf) Placed Under Review Direction Uncertain

Class II-A-3, Confirmed at A1 (sf); previously on Dec 22, 2011
A1 (sf) Placed Under Review Direction Uncertain

Class II-A-4, Confirmed at A1 (sf); previously on Dec 22, 2011
A1 (sf) Placed Under Review Direction Uncertain

Ratings Rationale

These actions correct an error in the Structured Finance
Workstation cash flow model used by Moody's in rating these
transactions, specifically in how the model handled cash
distribution from prepayments between senior and subordinate
certificates. When rating these deals, the error in the model led
to some senior certificates not being credited with the
appropriate amount of principal prepayments. It should be noted
that model-generated output is but one factor considered by
Moody's in rating these transactions.

Moody's also assessed deal performance to date and applied its
recently updated "Pre-2005 US RMBS Surveillance Methodology"
published in January 2012, and "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2012. Both methodologies impacted the final rating actions.
Therefore, certain of the rating downgrades announced today can be
attributed to specific deal performance deterioration and the
application of these methodologies.

In transactions involving multiple loan pools the cash flow
modeling was conservative in determining when some performance
triggers would send 100% of prepayments to the senior certificates
in deals.

RMBS structures initially allocate cash collections from voluntary
prepayments only to the senior certificates. Gradually over time,
a portion is then allocated to junior certificates. The amount of
cash that senior certificates receive from prepayments starts off
at 100%. After a certain number of months, that percentage starts
decreasing according to a deal-specific schedule as long as
certain conditions are met. However, the share of prepayments to
the senior certificates can revert back to 100% at any
distribution date if certain performance triggers are breached.

One performance trigger measures whether the current credit
protection, expressed as a percentage, to senior bonds from
subordination is greater than the percentage of original credit
protection. Should the deal perform poorly and absorb losses on
the underlying collateral and available credit protection falls
below the original level, then 100% of prepayment cash reverts
back to the senior certificates.

In cases where a deal has two or more loan pools, the calculation
for this performance trigger can be done in one of three ways.

1. "Aggregate level credit protection" Approach: When the
   percentage of credit protection available for all senior
   certificates, in aggregate, falls below the original
   percentage of credit protection, then the prepayment share to
   all the senior certificates groups reverts back to 100%.

2. "Individual group trigger" Approach: When the percentage of
   credit protection available for a group of senior certificates
   falls below the original percentage of group credit
   protection, then the prepayment share to the senior
   certificates of that particular group reverts back to 100%.
   All other senior certificates' share of prepayment remains
   unchanged.

3. "Combined" Approach: This is a combination of the above two
   approaches. When the percentage of credit protection available
   for a senior certificates' group falls below the original
   percentage of credit protection, then the prepayment share to
   all senior certificates from all groups reverts back to 100%.

These transactions included in these rating actions follow the
"individual group trigger" approach when calculating performance
triggers:

GMACM Mortgage Loan Trust 2004-AR2
Merrill Lynch Mortgage Investors Trust MLCC 2003-H
Mortgage Pass-Through Certificates, MLMI Series 2003-A2
Merrill Lynch Mortgage Investors Trust MLCC 2004-A
Merrill Lynch Mortgage Investors Trust MLCC 2004-C
Sequoia Mortgage Trust 2004-11
Sequoia Mortgage Trust 2004-6
Thornburg Mortgage Securities Trust 2002-3
Thornburg Mortgage Securities Trust 2003-3

The following transactions included in these rating actions follow
the "combined" approach when calculating performance triggers:

Sequoia Mortgage Trust 2003-3
Sequoia Mortgage Trust 2003-5

This trigger helps protect senior certificates if credit
protection is eroding by reducing principal payments to junior
certificates and diverting them to pay the senior certificates
instead. While all three approaches described above benefit senior
certificates, the third approach benefits senior certificates the
most, while the first approach benefits senior certificates the
least. The third approach redirects payments to the senior
certificates sooner than the other two approaches. For example,
consider a deal backed by two distinct pools of mortgages (pool A
and pool B) and over time there is a vast difference in
performance of two underlying pools. Pool A performs much
stronger, with lower losses, while pool B performs much weaker. As
per approach 1, the average loss, when pool A and B are combined,
will be medium and hence current combined credit protection may be
higher than the original credit protection. As a result, payments
will not be diverted to the senior certificates. In contrast,
approach 3 will test pool A and pool B individually instead of
taking the average of the two pools. Since pool B is performing
weaker, current credit protection may be lower than the original
credit protection. As a result, it will divert payments to the
senior certificates backed by both pools A and B. Approach 2 will
only revert payments back to senior certificates backed by pool B,
so it is beneficial for only one group.

The Pooling and Servicing Agreements for the deals impacted by
this rating action require the use of the "combined" and
"individual group trigger" approaches as noted above. As Moody's
explained when these bonds were placed on review, previous rating
actions on these deals mistakenly used the "aggregate level credit
protection" approach in their modeling. Under this approach,
prepayment allocation to senior certificates was changed back to
100% only when all groups failed the test, with the result that
senior certificates received too little credit for prepayments
while junior certificates received too much. As a result the pay-
down rate of the senior certificates was slower than it should
have been, while the reverse was true for the junior certificates.
The cash flow models have been corrected to reflect the
application of the appropriate approach required in the deals. In
resolving the review actions Moody's has taken into account the
corrected models as well as the performance of the impacted
transactions.

The methodologies used in these ratings were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, "Pre-2005 US RMBS Surveillance Methodology"
published in January 2012, and "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2012.

The approach is also adjusted slightly when estimating losses on
pools left with a small number of loans to account for the
volatile nature of small pools. Even if a few loans in a small
pool become delinquent, there could be a large increase in the
overall pool delinquency level due to the concentration risk. To
project losses on pools with fewer than 100 loans, Moody's first
estimates a "baseline" average rate of new delinquencies for the
pool that varies from 3% to 10% on average. The baseline rates are
higher than the average rate of new delinquencies for larger pools
for the respective vintages.

Once the baseline rate is set, further adjustments are made based
on 1) the number of loans remaining in the pool and 2) the level
of current delinquencies in the pool. The volatility of pool
performance increases as the number of loans remaining in the pool
decreases. Once the loan count in a pool falls below 75, the rate
of delinquency is increased by 1% for every loan less than 75. For
example, for a pool with 74 loans with a base rate of new
delinquency of 3.00%, the adjusted rate of new delinquency would
be 3.03%. In addition, if current delinquency levels in a small
pool is low, future delinquencies are expected to reflect this
trend. To account for that, the rate calculated above is
multiplied by a factor ranging from 0.75 to 2.5 for current
delinquencies ranging from less than 2.5% to greater than 10%
respectively. Delinquencies for subsequent years and ultimate
expected losses are projected using the approach described in the
"pre-2005 US RMBS Surveillance Methodology" publication.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market. Moody's now
projects house price index to reach a bottom in 2012, with a 3%
remaining decline in 2012, and unemployment rate to start
declining, albeit slowly, as the year progresses.


GREEN TREE: Moody's Corrects Class A-7 Tranche Rating From 'Ba1'
----------------------------------------------------------------
Moody's Investors Service has corrected the rating of the Class A-
7 tranche issued by Green Tree Financial Corporation MH 1997-03 to
Baa1 (sf) from Ba1 (sf). This tranche was erroneously downgraded
to Ba1 (sf) from Baa1 (sf) on March 30, 2009, as part of the
rating action taken on certain Manufactured Housing transactions.
On April 3, 2009, Moody's corrected the ratings for some of the
tranches that were rated incorrectly as part of the March 30, 2009
rating action and issued a correction to text press release for
the March 30, 2009 press release.

Due to an internal administrative error, the Class A-7 tranche
issued by Green Tree Financial Corporation MH 1997-03 was omitted
from the correction. Moody's has now removed the erroneous
March 30, 2009 downgrade for Class A-7 to Ba1 (sf) from Baa1 (sf).
The correct current rating for this tranche is Baa1 (sf).


GREENWICH CAPITAL: Moody's Cuts Rating on 2 Cert. Classes to 'C'
----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of two
classes of Certificates issued by Greenwich Capital Commercial
Mortgage Trust 2007-RR2 due to deterioration in the credit quality
of the underlying collateral as evidenced by material increase in
interest shortfalls as well as realized losses. 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 and Re-remic)
transactions.

Cl. A-1FL, Downgraded to C (sf); previously on Apr 22, 2011
Downgraded to Caa3 (sf)

Cl. A-1FX, Downgraded to C (sf); previously on Apr 22, 2011
Downgraded to Caa3 (sf)

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

Cl. X, Affirmed at C (sf); previously on Feb 22, 2012 Downgraded
to C (sf)

Ratings Rationale

Greenwich Capital Commercial Mortgage Trust 2007-RR2 is a static
cash Re-Remic transaction backed by a portfolio of commercial
mortgage backed securities (CMBS) (100.0% of the pool balance). As
of the February 23, 2012 Trustee report, the aggregate Certificate
balance of the transaction, has decreased to $469.2 million from
$528.7 million at issuance, due to realized losses on the
underlying collateral. Class F through Class S have sustained full
realized losses while Class E has sustained partial realized
losses.

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.
We have 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 9,116 compared to 8,989 at last review. The
distribution of current ratings and credit estimates is as
follows: B1-B3 (4.2% compared to 6.5% at last review), and Caa1-C
(95.8% compared to 93.5% 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 6.1 years, the same
as that at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
0.2% compared to 0.3% 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 0.0%, 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.

Moody's review also incorporated the CMBS IO calculator ver 1.0,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point. For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. However, in light of the
performance indicators noted above, Moody's believes that it is
unlikely that the ratings announced today are sensitive to further
change.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected
range will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

The methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in November 2010, "Moody's Approach to
Rating Commercial Real Estate CDOs" published in July 2011, and
"Moody's Approach to Rating Structured Finance Interest-Only
Securities" published in February 2012.


GREENWICH CAPITAL: Moody's Cuts Rating on Class N-SO CMBS to Caa3
-----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of six classes
and affirmed the ratings of four classes of Greenwich Capital
Commercial Funding Corp. Series 2004-FL2:

Cl. C, Affirmed at Aaa (sf); previously on Dec 14, 2006 Upgraded
to Aaa (sf)

Cl. D, Affirmedat Aaa (sf); previously on Dec 14, 2006 Upgraded
to Aaa (sf)

Cl. E, Affirmed at Aaa (sf); previously on Dec 14, 2006 Upgraded
to Aaa (sf)

Cl. F, Affirmedat Aa1 (sf); previously on Jul 20, 2011 Upgraded
to Aa1 (sf)

Cl. G, Downgraded to A3 (sf); previously on Jul 20, 2011
Upgraded to A1 (sf)

Cl. H, Downgraded to Baa3 (sf); previously on Jul 20, 2011
Upgraded to Baa1 (sf)

Cl. J, Downgraded to B1 (sf); previously on Jul 20, 2011
Upgraded to Ba3 (sf)

Cl. K, Downgraded to B3 (sf); previously on Jul 20, 2011
Upgraded to B2 (sf)

Cl. L, Downgraded to Caa2 (sf); previously on Aug 4, 2010
Downgraded to Caa1 (sf)

Cl. N-SO, Downgraded to Caa3 (sf); previously on Aug 4, 2010
Downgraded to Caa1 (sf)

Ratings Rationale

The downgrades are due to the deterioration in performance of the
one remaining loan in the pool, the Southfield Town Center Loan,
and its impending final maturity date of July 1, 2012. 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 extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

The principal methodology used in this rating was "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 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 a review utilizing
MOST(R) (Moody's Surveillance Trends) Reports and Remittance
Statements. On a periodic basis, Moody's also performs a full
transaction review that involves a rating committee and a press
release. Moody's prior transaction review is summarized in a press
release dated July 20, 2011.

DEAL PERFORMANCE

As of the February 7, 2012 Payment Date, the transaction's
certificate balance decreased by 83% to $155.9 million from
$921.7 million at securitization due to the payoff of 15 loans
originally in the pool and scheduled amortization. Currently the
mortgage pool consists of one loan, the Southfield Town Center
Loan. The loan is secured by a four building 2.1 million square
foot office complex situated on 35 acres in Southfield, Michigan.
The trust debt, which consists of $145.5 million of pooled debt
and $7.4 million of non-pooled, or rake, debt (Class N-SO), is
senior to approximately $65.1 million of non-trust mortgage debt
and $25.0 million of mezzanine debt. The loan, which matured in
July 2009 with no extensions remaining, had been transferred to
special servicing in May 2009 for imminent default. The loan was
returned to the master servicer in August 2009 as a modified loan
with an extended maturity date of July 1, 2011 and the option to
extend for an additional 12 months to July 1, 2012. Additionally,
the loan was converted from interest-only to amortizing on a 30-
year schedule, and monthly contributions to the rollover reserve
account were increased.

Southfield Town Center has over 200 tenants. The three largest are
Fifth Third Bank (105,041 square feet, lease expiration in 2016),
Microsoft (57,364 square feet, lease expiration in 2017 and 2018)
and Alix Partners (54,686 square feet, lease expiration in 2018).
These three tenants lease about 10% of the total net rentable
area. The complex was 70% leased as of September 30, 2011,
compared to 72% at Moody's last review and 73% at securitization.
Although vacancy has not significantly changed since
securitization, property performance has been hurt by declining
rents, rent concessions given both to retain existing tenants and
attract new ones, and a high market vacancy with little
improvement forecasted over the next several years. Net operating
income for calendar year 2011 decreased by 20% from 2010. CBRE,
Inc., indicated a Southfield submarket vacancy of approximately
33%, as of the fourth quarter 2011, with a further decrease in
market rents projected through 2012 and modest improvement
beginning in 2013. Moody's loan to value (LTV) ratio for the trust
debt is slightly over 100%. Moody's credit estimate for the pooled
balance is Caa2, compared to B3 at lst review.


GS MORGAGE: Fitch Affirms Rating on 15 Certificate Classes
----------------------------------------------------------
Fitch Ratings has downgraded seven classes and affirmed 15 classes
of GS Mortgage Securities Corporation II (GSMSC II) commercial
mortgage pass-through certificates, series 2006-GG8 due to
increased loss expectations on the specially serviced loans and
further deterioration of loan performance.

Fitch modeled losses of 13.1% of the remaining pool; expected
losses on the original pool balance total 12%, including losses
already incurred.  The pool has experienced $59.3 million (1.4% of
the original pool balance) in realized losses to date.  Fitch has
designated 73 loans (47.9%) as Fitch Loans of Concern, which
includes 21 specially serviced assets (14%).

As of the February 2012 distribution date, the pool's aggregate
principal balance has been reduced by 19.1% to $3.43 billion from
$4.24 billion at issuance.  No loans have defeased since issuance.
Interest shortfalls are currently affecting classes D through S.

The largest contributor to modeled losses is the Pointe South
Mountain Resort loan (5.5% of the pool), which is secured by a
640-key resort complex located in Phoenix, AZ.  The property is
now called the Arizona Grand Resort.  The loan has been modified
and returned to the master servicer after the original loan was
split into an A/B note structure.  Although property performance
improved in 2011, the property does not generate sufficient cash
flow to service its total debt.

The next largest contributor to modeled losses is the real-estate
owned (REO) Ariel Preferred Portfolio (2.6%), which is a six
retail outlet center portfolio located in various states.  The
portfolio transferred to special servicing in June 2009 for
imminent default.  The most recent servicer reported average for
the portfolio is 66% as of December 2011, compared to the overall
portfolio occupancy of 82.7% at issuance.

The third largest contributor to modeled losses is the REO Tower
Place 200 property (1.5%), which is secured by an office building
located in the Buckhead section of Atlanta, GA.  The asset
transferred to the special servicer in July 2009 and the reported
occupancy has increased to 85%.

Fitch downgrades these classes and assigns or revises Recovery
Estimates (REs):

  -- $53 million class C to 'CCCsf' from 'B-sf'; RE 20%;
  -- $37.1 million class D to 'CCCsf' from 'B-sf'; RE 0%;
  -- $53 million class G to 'CCsf' from 'CCCsf'; RE 0%;
  -- $47.7 million class H to 'CCsf' from 'CCCsf'; RE 0%;
  -- $53 million class J to 'Csf' from 'CCCsf'; RE 0%;
  -- $42.4 million class K to 'Csf' from 'CCsf'; RE 0%;
  -- $26.5 million class L to 'Csf' from 'CCsf'; RE 0%.

Fitch affirms these classes and assigns or revises Rating Outlooks
and REs:

  -- $302.3 million class A-J at 'BBsf'; Outlook to Negative from
     Stable;
  -- $26.5 million class B at 'Bsf'; Outlook to Negative from
     Stable;
  -- $37.1 million class E at 'CCCsf'; RE 0%;
  -- $42.4 million class F at 'CCCsf'; RE 0%.

Fitch affirms these classes:

  -- $298.7 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $52.9 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $104.6 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $1.6 billion class A-4 at 'AAAsf'; Outlook Stable;
  -- $162.8 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $424.3 million class A-M at 'AAAsf'; Outlook Stable;
  -- $15.9 million class M at 'Csf'; RE 0%;
  -- $15.9 million class N at 'Csf'; RE 0%;
  -- $10.6 million class O at 'Csf'; RE 0%;
  -- $10.6 million class P at 'Csf'; RE 0%.

The $14.9 million class Q remains at 'Dsf'; RE 0%.

The class A-1 certificates have paid in full. Fitch does not rate
the fully depleted class S certificates.  Fitch previously
withdrew the rating on the interest-only class X certificates.


HELLER FINANCIAL: Moody's Affirms Caa3(sf) Rating on Class X CMBS
-----------------------------------------------------------------
Moody's Investors Service upgraded the rating of one class and
affirmed one class of Heller Financial Commercial Mortgage Asset
Corp., Mortgage Pass-Through Certificates, Series 1999-PH1:

Cl. G, Upgraded to Aaa (sf); previously on May 12, 2010 Upgraded
to Aa3 (sf)

Cl. X, Affirmed at Caa3 (sf); previously on Feb 22, 2012
Downgraded to Caa3 (sf)

Ratings Rationale

The upgrade is due to the significant increase in subordination
due to loan payoffs and amortization and defeasance. The pool has
paid down by 22% since Moody's last review. Four loans,
representing 25% of the pool, have defeased and are collateralized
with U.S. Government securities.

The rating of the IO Class, Class X, is consistent with the
expected credit performance of the pool and thus is affirmed.

Moody's rating action reflects a cumulative base expected loss of
6.1% of the current balance. At last review, Moody's cumulative
base expected loss was 13.2%. Moody's provides a current list of
base expected losses for conduit and fusion CMBS transactions on
moodys.com at:

  http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.

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

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

The methodologies used in this rating were "Moody's Approach to
Rating Fusion U.S. CMBS Transactions" published in April 2005,
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000, and "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012.

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 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 review also incorporated the CMBS IO calculator ver 1.0,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point. For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

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 3 compared to 5 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 a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated
March 30, 2011.

DEAL PERFORMANCE

As of the February 15, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 93%
to $68.7 million from $1.0 billion at securitization. The
Certificates are collateralized by 12 mortgage loans ranging in
size from less than 1% to 40% of the pool, with the top ten loans
representing 73% of the pool. The pool contains one loan with an
investment grade credit estimate that represents 7% of the pool.

Three loans, representing 25% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of our
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Eighteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $54.3 million (55% loss severity
overall). Currently, there are no loans in special servicing.

Moody's has assumed a high default probability for three poorly
performing loans representing 25% of the pool and has estimated a
$3.2 million aggregate loss (19% 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 71% and 43% of the pool, respectively.
Excluding troubled loans, Moody's weighted average LTV is 87%
compared to 82% at Moody's prior review. Moody's net cash flow
reflects a weighted average haircut of 13% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 10.9%.

Excluding troubled loans, Moody's actual and stressed DSCRs are
1.01X and 1.43X, respectively, compared to 1.22X and 1.56X 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 rating is the Station Plaza Office
Complex Loan ($4.8 million -- 7.0% of the pool), which is secured
by three office buildings totaling 320,000 square feet (SF)
located in Trenton, New Jersey. The buildings were 95% leased as
of September 2011 compared to 100% at last review, with 86% of the
office space leased to several New Jersey state agencies through
October 2017. The loan, which matures August 2013, fully amortizes
over its 15-year term and has amortized by approximately 36% since
last review. The buildings are situated in downtown Trenton with
convenient access to both Amtrak and NJ Transit rail services.
Performance has declined due to a drop in base rents. Moody's
current credit estimate and stressed DSCR are Aaa and 7.5X,
respectively, compared to Aaa and 4.0X at last review.

The largest performing conduit loan represents 40% of the pool
balance. The Barefoot Landing Loan ($27.2 million), which is
secured by a 244,000 SF entertainment/retail center, is located in
Myrtle Beach, South Carolina. The property was 98% leased as of
September 2011 compared to 89% at last review. Recent operating
performance shows an improvement due to lower vacancy. Moody's LTV
and stressed DSCR are 87% and 1.36X, respectively, compared to 93%
and 1.28X at last review.


JP MORGAN: Fitch Downgrades Rating on 10 Certificate Classes
------------------------------------------------------------
Fitch Ratings has downgraded 10 classes and affirmed 11 classes of
JP Morgan Chase Commercial Mortgage Pass-Through Certificates,
Series 2005-LDP4.

The downgrades are primarily due to increased loss expectations on
the specially serviced loans, including the Silver City Galleria
(6.3%), the largest asset in the pool and currently real estate
owned (REO).  Fitch modeled losses of 12.9%, most of which is due
to loans in special servicing.  As of the February 2012
distribution date, 14 loans, 14.4% of the pool, were in special
servicing.

Fitch expects classes F through P to be fully depleted by losses
on specially serviced loans and class E to be significantly
impacted.  As of the February 2012, there are cumulative interest
shortfalls in the amount of $10.4 million currently affecting
classes F through NR.

As of the February 2012 distribution date, the pool's aggregate
principal balance has been paid down by 27.7% to $1.935 billion
from approximately $2.677 billion at issuance.  Four loans (5.9%)
have defeased since issuance.

The largest contributor to Fitch expected losses is the 714,898 sf
Silver City Galleria (6.8% of the pool), a regional mall located
in Taunton, MA.  The property has suffered occupancy issues,
including the loss of two major tenants.  New valuations have been
received and are significantly below the debt.  The special
servicer has been working to increase occupancy and retain the
current tenants.  The building is currently listed for sale.

The next largest contributor to Fitch expected losses is the five
property suburban office portfolio (2.2%) consisting 230,061 sf
located in three states (CA, OR, and TX).  The CA properties were
recently sold and the proceeds applied to the unpaid principal
balance.  The special servicer plans to list the remaining
properties for sale in early 2012

The third largest contributor to expected losses is a foreclosed
129,020 sf retail property (2.1%) located in Lincoln, CA.  Current
occupancy is 84% with a limited number of tenant leases coming up
for renewal in the next few years.  The special servicer continues
to evaluate work out options. The property is scheduled to convert
to REO in the next 30 days.

Fitch downgrades, revises outlooks and assigns recovery ratings:

  -- $204.1 million class A-J to 'BBsf' from 'BBBsf'; Outlook to
     Negative from Stable;
  -- $50.2 million class B to 'Bsf' from 'BBsf'; Outlook to
     Negative from Stable;
  -- $23.4 million class C to 'CCCsf' from 'BBsf'; 'RE0'; Outlook
     Stable;
  -- $46.8 million class D to 'CCsf' from 'Bsf'; 'RE0'; Outlook
     Stable;
  -- $23.4 million class E to 'Csf' from 'CCCsf; 'RE0';
  -- $40.1 million class F to 'Csf'from 'CCsf'; 'RE0';
  -- $26.8 million class G to 'Csf' from 'CCsf'; 'RE0';
  -- $30.1 million class H to 'Csf' from 'CCsf'; 'RE0';
  -- $10.0 million class J to 'Csf' from 'CCsf'; 'RE0'.

This class has been downgraded to 'Dsf/RE0' based on incurred
realized losses:

  -- $8.5 million class P to 'Dsf' from 'Csf'; 'RE0'.

Fitch affirms these classes, rating outlooks and recovery ratings:

  -- $203.8 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $86.9 million class A-3A1 at 'AAAsf'; Outlook Stable;
  -- $75.0 million class A-3A2 at 'AAAsf'; Outlook Stable;
  -- $580.3 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $84.4 million class A-SB at 'AAAsf'; Outlook Stable;
  -- $267.7 million class A-M at 'AAAsf'; Outlook Stable;
  -- $13.4 million class K at 'Csf';'RE0';
  -- $13.4 million class L at 'Csf';'RE0';
  -- $6.7 million class M at 'Csf';'RE0';
  -- $3.3 million class N at 'Csf';'RE0'.

Classes A-1, A-2, and A-2FL have paid in full.  Class NR has been
reduced to zero due to realized losses.  Classes X-1 and X-2 were
previously withdrawn.




JP MORGAN: Fitch Downgrades Rating on Six Note Classes
------------------------------------------------------
Fitch Ratings has downgraded six classes and affirmed 14 classes
of JP Morgan Chase Commercial Mortgage Securities Corp.  Series
2005-LDP1 (JPMCC 2005-LDP1) commercial mortgage pass-through.

The downgrades are the result of an increase in Fitch expected
losses following updated valuations of specially serviced assets
and performance deterioration of some performing loans with
increasing vacancy.  Fitch modeled losses of 5.5% of the remaining
pool; expected losses on the original pool balance total 5.2%,
including losses already incurred. The pool has experienced
$48.5 million (1.7% of the original pool balance) in realized
losses to date.  Fitch has designated 33 loans (22.4%) as Fitch
Loans of Concern, which includes 11 specially serviced assets
(4.3%).  Fitch expects classes L through N to be fully depleted
from losses associated with the specially serviced assets.

As of the February 2012 distribution date, the pool's aggregate
principal balance has been reduced by 35.9% to $1.85 billion from
$2.88 billion at issuance.   Per the servicer reporting, 12 loans
(6.4% of the pool) have defeased since issuance.  Interest
shortfalls are currently affecting classes J through NR.

The largest contributor to expected losses is a loan secured
by a 243,000 sf office property (4%) located in Playa Vista,
CA.  The property was formerly 100% leased to a world-wide
software company; however, the tenant recently negotiated a 10-
year lease extension and 55% space reduction, effective July 2011.
The leases for several sub-tenants (18% of NRA) were reportedly
assigned to the landlord. The remaining space was being marketed
for lease.  A leasing reserve has a reported balance of
$3.48 million.  Further, the loan is past its anticipated
repayment date of February 2010.

The next largest contributor to Fitch modeled losses is a loan
secured by a 129,000 sf single tenant office building (1.9%)
located in Washington D.C.  The District of Columbia is vacating
its space in the next few months. The space is currently being
marketed for lease.  A leasing reserve has a reported balance of
$2.76 million.  Further, the loan is past its anticipated
repayment date of February 2010.

The third largest contributor to expected losses is a defaulted
loan (1.1%), which is secured by a 252,000 sf grocery anchored
retail shopping center located in Hamilton Township, NJ.  The loan
was transferred to special servicing in March 2010 due to missed
debt service payments; a foreclosure action was commenced in
October 2010.  Negotiations regarding a borrower settlement are
ongoing.

Fitch downgrades these classes and assigns or revises Rating
Outlooks and Recovery Estimates (REs):

  -- $28.8 million class E to 'BBB-sf' from 'BBBsf', Outlook to
     Negative from Stable;
  -- $46.8 million class F to 'Bsf' from 'BBsf', Outlook to
     Negative from Stable;
  -- $28.8 million class G to 'CCCsf' from 'Bsf', RE 0%;
  -- $10.8 million class J to 'CCsf' from 'CCCsf', RE 0%;
  -- $14.4 million class K to 'Csf' from 'CCsf', RE 0%;
  -- $10.8 million class L to 'Csf' from 'CCsf', RE 0%.

Fitch affirms these classes and assigns or revises Rating Outlooks
and REs:

  -- $54 million class D at 'Asf', Outlook to Negative from
     Stable;
  -- $32.4 million class H at 'CCCsf', RE 0%.

Fitch affirms these classes:

  -- $256.1 million class A-1A at 'AAAsf', Outlook Stable;
  -- $244.2 million class A-2 at 'AAAsf', Outlook Stable;
  -- $157.5 million class A-3 at 'AAAsf', Outlook Stable;
  -- $601.5 million class A-4 at 'AAAsf', Outlook Stable;
  -- $59.2 million class A-SB at 'AAAsf', Outlook Stable;
  -- $94.3 million class A-J at 'AAAsf', Outlook Stable;
  -- $100 million class A-JFL at 'AAAsf', Outlook Stable;
  -- $68.4 million class B at 'AAsf', Outlook Stable;
  -- $25.2 million class C at 'Asf', Outlook Stable;
  -- $7.2 million class M at 'Csf', RE 0%;
  -- $5.5 million class N at 'Dsf', RE 0%;
  -- $0 class P at 'Dsf', RE 0%.

The class A-1 certificates have paid in full.  Fitch does not rate
the class NR certificates. Fitch previously withdrew the ratings
on the interest-only class X-1 and X-2 certificates.


JPMCC 2005-LDP4: DBRS Downgrades Class P to 'D'
-----------------------------------------------
DBRS has downgraded the rating of Class P of JPMCC 2005-LDP4 (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 one
loan.

Prospectus ID#84 (Hulen Gardens) was liquidated at a total loss of
$2.96 million to the Trust as of the February 2012 remittance
report.  As a result of the loss, the original balance of the
Class P certificates has been reduced to $8.48 million as of the
February 2012 remittance report.


JPMCC 2006-FL2: Moody's Affirms Class L Notes Rating at 'C'
-----------------------------------------------------------
Moody's Investors Service affirmed 11 class of J.P. Morgan Chase
Commercial Mortgage Securities Corp. Commercial Mortgage Pass-
Through Certificates, Series 2006-FL2.

Cl. A-2, Affirmed at Aa2 (sf); previously on Sep 22, 2010
Downgraded to Aa2 (sf)

Cl. B, Affirmed at A1 (sf); previously on Sep 22, 2010 Downgraded
to A1 (sf)

Cl. C, Affirmed at A2 (sf); previously on Sep 22, 2010 Downgraded
to A2 (sf)

Cl. D, Affirmed at A3 (sf); previously on Sep 22, 2010 Downgraded
to A3 (sf)

Cl. E, Affirmed at Baa1 (sf); previously on Sep 22, 2010
Downgraded to Baa1 (sf)

Cl. F, Affirmed at Baa3 (sf); previously on Sep 22, 2010
Downgraded to Baa3 (sf)

Cl. G, Affirmed at Ba1 (sf); previously on Sep 22, 2010 Downgraded
to Ba1 (sf)

Cl. H, Affirmed at Ba2 (sf); previously on Sep 22, 2010 Downgraded
to Ba2 (sf)

Cl. J, Affirmed at B1 (sf); previously on Sep 22, 2010 Downgraded
to B1 (sf)

Cl. K, Affirmed at Ca (sf); previously on Sep 22, 2010 Downgraded
to Ca (sf)

Cl. L, Affirmed at C (sf); previously on Sep 22, 2010 Downgraded
to C (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 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 extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

The principal methodology used in this rating was "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 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 a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and
Remittance Statements. On a periodic basis, Moody's also performs
a full transaction review that involves a rating committee and a
press release. Moody's prior transaction review is summarized in a
press release dated August 15, 2011. Please see the ratings tab on
the issuer / entity page on moodys.com for the last rating action
and the ratings history.

DEAL PERFORMANCE

As of the February 15, 2012 distribution date, the
transaction's certificate balance decreased by approximately 78%
to $389.9 million from $1.5 billion at securitization due to the
payoff of ten loans and principal pay downs associated with four
loans. The Certificates are collateralized by six floating-rate
loans ranging in size from 4% to 26% of the pooled trust mortgage
balance. The largest three loans account for 71% of the pooled
balance. The pool composition includes office properties (86% of
the pooled balance) and hotel properties (14%). Moody's has been
notified that the Menlo Oaks Corporate Center Loan ($15 million;
14.9%) has been paid off since the most recent remittance report.
Moody's anaysis reflects this payoff.

The deal has a modified pro-rata structure. Interest on the pooled
trust certificates are distributed first to Classes A-1, X-1 and
X-2, pro rata, and then to Classes A-2, B, C, D, E, F, G, H, J, K,
and L, sequentially. Prior to a monetary or material non-monetary
event of default, scheduled and unscheduled principal payments are
allocated to the Pooled Classes and junior participation interests
on a pro rata basis. Initially, 80% of the principal received is
paid to the Class A-1 and A-2 certificates sequentially and 20%
will be allocated pro rata to the other certificates. Principal
distributions are made sequentially from the most senior to the
most junior class after the outstanding principal balance of the
Pooled Trust Assets (exclusive of Trust Assets related to
Specially Service Mortgage Loans) is less than 20% of the initial
principal balance of the Trust Assets. All losses and shortfalls
are allocated first to the relevant junior interest, and then to
Classes L, K, J, H, G, F, E, D, C, B, and A-2 in that order, and
then to Class A-1.

The pool has experienced losses of $678,915 since securitization.
There are no loans in special servicing. The 1111 Marcus Avenue
Loan has transferred back to the master servicer and the Menlo
Oakes Corporate Center loan has paid off.

Moody's weighed average pooled loan to value (LTV) ratio is 96%,
compared to 92% at last review on August 25, 2011 and 66% at
securitization. Moody's pooled stressed debt service coverage
(DSCR) is 1.23X, compared to 1.20X at last review and 1.38X at
securitization.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. Large
loan transactions have a Herf of less than 20. The pool has a Herf
of 4 compared to 6 at Moody's prior review.

The largest loan in the pool remaining is the Marina Village loan
($94.2 million, 31.0%). The loan is secured by a 1.2 million
square foot suburban office property in the Alameda submarket of
Oakland, California. Occupancy and net cash flow have fallen
significantly since securitization. As of November 2011, occupancy
for the property was 62% compared to 74% at last review and 80% at
securitization. At the time of securitization, the property had
recently lost two tenants but had historically performed better. A
return to prior cash flow levels had been anticipated at
securitization, however this has not materialized. A June 2011
loan modification included a $9 million principal payment and loan
maturity has been extended through 2013. Moody's current loan to
value ratio ("LTV") is over 100% and Moody's stressed DSCR for the
loan is 0.80X. Moody's credit estimate for the pooled balance is
C, the same as at last review.

The RREEF Silicon Valley Office Portfolio Loan ($94.2 million,
28.4%) is the second largest loan in the remaining pool. It is a
21% portion of a $455 million pari passu split loan structure.
There is an additional $138.8 million B-Note held outside the
trust. The loan is secured by a 4.4 million square foot portfolio
of office/R&D properties located in Santa Clara, Sunnyvale,
Mountain View, Milpitas and San Jose, California. Occupancy as of
March 2011 was 72%, compared to 71% at securitization. At
securitization, the largest tenant was Maxtor, leasing
approximately 15% of the NRA on multiple leases that expire in
2011. Moody's current loan to value ratio ("LTV") and stressed
DSCR for the pooled loan are 98% and 1.06X. Moody's credit
estimate for the pooled balance is Ba3, the same as last review.

The third largest loan is the 1111 Marcus Avenue loan
($80.0 million, 21.4%) which is secured by a 920,000 square foot
office property on Long Island, NY. As of February 2012, the
property was 82% occupied compared to 80% at securitization. In
September 2011, the loan was transferred to the special servicer.
It was returned to the master servicer in February 2012 with a 2-
year forbearance through November 2013; $12 million of new equity
in the Leasing Reserve and hard cash management. An October 2011
appraisal valued the property at $160 million. Moody's current
loan to value ratio ("LTV") and stressed DSCR for the pooled loan
are 76% and 1.29X. Moody's credit estimate for the pooled balance
is Ba2, the same as last review.


JPMORGAN 2006-CIBC16: S&P Lowers Rating on Class F Certs. to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of commercial mortgage pass-through certificates from
JPMorgan Chase Commercial Mortgage Securities Trust 2006-CIBC16, a
U.S. commercial mortgage-backed securities (CMBS) transaction.
"Concurrently, we affirmed our ratings on eight other classes from
the same transaction," S&P said.

"Our rating actions follow our analysis of the transaction,
including a review of the deal structure and the liquidity
available to the trust. The downgrades reflect credit support
erosion that we anticipate will occur upon the eventual
resolution of nine ($158.3 million, 8.3%) of the transaction's
12 ($253.2 million, 13.3%) assets with the special servicer. We
also considered the monthly interest shortfalls affecting the
trust. We lowered our rating on the class F certificate to 'D
(sf)' because we believe the accumulated interest shortfalls will
remain outstanding for the foreseeable future," 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)' ratings on the class X-1
and X-2 interest-only (IO) certificates based on our current
criteria," S&P said.

"Our analysis included a review of the credit characteristics of
all the remaining assets in the pool. Using servicer-provided
financial information, we calculated an adjusted debt service
coverage (DSC) of 1.40x and a loan-to-value (LTV) ratio of 107.3%.
We further stressed the loans' cash flows under our 'AAA' scenario
to yield a weighted-average DSC of 0.92x and an LTV ratio of
142.9%. The implied defaults and loss severity under the 'AAA'
scenario were 79.0% and 40.2%. The DSC and LTV calculations noted
exclude nine ($158.3 million, 8.3%) of the transaction's 12
($253.2 million, 13.3%) specially serviced assets. We separately
estimated losses for the excluded specially serviced assets and
included them in our 'AAA' scenario implied default and loss
severity figures," S&P said.

"As of the Feb. 13, 2012 trustee remittance report, the trust
experienced net interest shortfalls totaling $566,736, which
reflect one-time interest recoveries of $99,927. The interest
shortfalls were primarily due to interest not advanced due to a
nonrecoverable determination ($367,263), appraisal subordinate
entitlement reduction (ASER) amounts ($131,132), and special
servicing and workout fees ($67,827). The trustee remittance
report reflected $367,263 of nonrecoverable interest on the City
View Portfolio 1 loan ($69.0 million, 3.6%). The net interest
shortfalls affected class D and all classes subordinate to it.
Class F has experienced cumulative interest shortfalls for six
consecutive months, and we expect these shortfalls to remain
outstanding for the foreseeable future. Consequently, we
downgraded class F to 'D (sf)'," S&P said.

                     Credit Considerations

"As of the Feb. 13, 2012 trustee remittance report, 12 assets
($253.2 million, 13.3%) 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: three are
real estate-owned (REO) ($20.6 million, 1.1%); one is in
foreclosure ($17.3 million, 0.9%); four are 90-plus-days
delinquent ($115.0 million, 6.0%); one is 30 days delinquent
($5.4 million, 0.3%); one is a matured balloon loan ($3.1 million,
0.2%); and two are current ($91.9 million, 4.8%). Appraisal
reduction amounts (ARAs) totaling $69.9 million are in effect
against nine of the specially serviced assets," S&P said.

"The REPM Portfolio loan ($86.1 million, 4.5%) is the largest
specially serviced asset and fifth-largest loan in the pool. The
loan was transferred to the special servicer on April 1, 2011,
due to imminent monetary default. The loan's payment status is
reported as current. The loan is secured by 10 industrial
properties totaling 1.6 million-sq.-ft. across eight states and
was built between 1972 and 2001. C-III approved a modification
proposal resulting in a minor change to the waterfall distribution
with no modifications to the interest rate or principal balance.
The servicer-reported DSC was 1.29x for year-end 2010 and
occupancy was 97.1% according to the March 2011 rent roll," S&P
said.

"The City View Portfolio 1 loan ($69.0 million, 3.6%) is the
second-largest specially serviced asset and eighth-largest loan in
the pool. The loan has a total exposure of $81.4 million. The loan
was transferred to the special servicer on Feb. 12, 2010, due to
monetary default. The loan's payment status is reported as 90-
plus-days delinquent. The loan is secured by eight multifamily
properties totaling 2,712 units in Houston built between 1976 and
1984. According to C-III, the property is currently under contract
for sale. An ARA of $45.4 million is in effect against this loan.
We expect a severe loss upon the resolution of this loan," S&P
said.

"The Avalon and River Oaks Apartments Portfolio loan
($27.5 million, 1.5%) is the third-largest specially serviced
asset. The loan has a total exposure of $32.4 million. The loan
was transferred to the special servicer on April 24, 2009, due to
imminent payment default. The loan's payment status is reported
as 90-plus-days delinquent. The loan is secured by two multifamily
properties comprising 523 units in Columbus, Ohio. An ARA of
$9.6 million is in effect against this loan. We expect a
significant loss upon the eventual resolution of this loan," S&P
said.

"The remaining nine specially serviced assets have individual
balances that represent less than 1.0% of the total pool balance.
ARAs totaling $14.9 million were in effect against seven of the
remaining specially serviced assets. Standard & Poor's estimated a
weighted-average loss severity of 30.3% for seven of the remaining
specially serviced assets. One of the assets not included in the
above weighted-average loss severity figure was recently
transferred to the special servicer and the other has been
modified," S&P said.

                    Transaction Summary

As of the Feb. 13, 2012 trustee remittance report, the collateral
pool balance was $1.90 billion, which is 88.6% of the balance at
issuance. The pool includes 109 loans and three REO assets, down
from 120 loans at issuance. The master servicer, Berkadia
Commercial Mortgage LLC (Berkadia), provided financial information
for 85.8% of the asset balance, the majority of which reflected
full-year 2010 or partial-year 2011 data.

"We calculated a weighted average DSC of 1.29x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.40x and 107.3%. Our adjusted figures reflect
our examination of more recent reporting information for several
loans. Furthermore, these figures exclude nine ($158.3 million,
8.3%) of the transaction's 12 ($253.2 million, 13.3%) specially
serviced assets, for which we separately estimated losses. The
transaction has experienced $38.7 million in principal losses to
date from 13 assets. Thirty-Four loans ($503.8 million, 26.5%) in
the pool are on the master servicer's watchlist, including the
fourth- ($92.7 million, 4.9%), seventh- ($76.6 million, 4.0%), and
10th-largest ($37.0 million, 1.9%) loans in the pool. Twenty-five
loans ($311.6 million, 16.4%) have reported DSC of less than
1.10x, 20 of which ($280.0 million, 14.7%) have reported DSC below
1.00x," S&P said.

                   Summary of The Top 10 Loans

"The top 10 loans have an aggregate outstanding balance of
$1.00 billion (52.8%). We calculated an adjusted DSC and LTV ratio
of 1.37x and 111.6% for the top 10 loans. The fourth-, seventh-,
and 10th-largest loans in the pool are on the master servicer's
watchlist," S&P said.

The Sequoia Plaza loan ($92.7 million, 4.9%), the fourth-largest
loan in the pool, is secured by a 370,638-sq.-ft. class A office
complex in Arlington, Va. The special servicer returned the loan
to the master servicer as a corrected mortgage in May 2011.
Berkadia has since placed the loan on its watchlist due to a low
reported DSC. The servicer-reported DSC and occupancy were 0.39x
and 86.0% for year-end 2010.

The Lightstone Michigan Multifamily Portfolio loan ($76.6 million,
4.0%), the seventh-largest loan in the pool, is secured by six
multifamily properties consisting of 1,947 units in Michigan,
built between 1970 and 1986. The special servicer returned the
loan to the master servicer as a corrected mortgage in September
2011. Berkadia has since placed the loan on its watchlist due to a
low reported DSC. The servicer-reported DSC and occupancy were
1.02x and 90.2% for the three months ended March 31, 2011.

The Westfield Richland Mall loan ($37.0 million, 1.9%), the 10th-
largest loan in the pool, is secured by an approximately 396,000-
sq.-ft. regional mall in Mansfield, Ohio. Berkadia placed this
loan on its watchlist due to a low reported DSC. The servicer-
reported DSC and occupancy were 0.82x and 94.2% for the trailing-
12-months ended June 30, 2011.

Standard & Poor's stressed the assets in the pool according to its
current criteria. The resultant credit enhancement levels are
consistent with S&P's rating actions.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

          http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

JPMorgan Chase Commercial Mortgage Securities Trust 2006-CIBC16
Commercial mortgage pass-through certificates

               Rating
Class       To          From           Credit enhancement (%)
A-J         BB  (sf)    BBB- (sf)                       11.65
B           BB- (sf)    BB+ (sf)                         9.53
C           B+ (sf)     BB (sf)                          8.69
D           B (sf)      BB- (sf)                         7.13
E           CCC-(sf)    CCC+(sf)                         5.72
F           D (sf)      CCC- (sf)                        4.17

Ratings Affirmed

JPMorgan Chase Commercial Mortgage Securities Trust 2006-CIBC16
Commercial mortgage pass-through certificates

Class       Rating                  Credit enhancement (%)
A-3FL       AAA (sf)                                 31.82
A-3B        AAA (sf)                                 31.82
A-4         AAA (sf)                                 31.82
A-SB        AAA (sf)                                 31.82
A-1A        AAA (sf)                                 31.82
A-M         A (sf)                                   20.54
X-1         AAA (sf)                                   N/A
X-2         AAA (sf)                                   N/A

N/A -- Not applicable.


KKR FINANCIAL 2005-1: S&P Affirms 'BB+' Rating on Class D Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, B, C, E, and F notes from KKR Financial CLO 2005-1 Ltd., a
U.S. collateralized loan obligation (CLO) transaction managed by
KKR Financial Advisors. "At the same time, we affirmed our 'BB+
(sf)' rating on class D notes. Simultaneously, we removed our
ratings on these classes from CreditWatch, where we had placed
them with positive implications on Dec. 20, 2011," S&P said.

"The upgrades reflect factors that have improved the credit
enhancement available to support the notes since we downgraded
them in April 2010. The primary factor has been the note paydowns.
Since April 2010, the transaction has paid down approximately
$136 million to the class A-1 notes, including a $17 million
payment on the Feb. 15, 2012 distribution date," S&P said.

"KKR Financial CLO 2005-1 Ltd. cancelled $12 million of its class
D notes in July 2009, reducing the class' balance to $52 million
from $64 million. For the transactions that have experienced
subordinated debt cancellations, our surveillance reviews include
the application of an additional rating stress designed to assess
the potential creditworthiness of the affected transactions
without the support of interest diversion," S&P said.

* "We generated cash flow analysis using two scenarios. The first
   scenario gave effect to the current balances of the notes
   (including any note cancellations) when modeling the interest
   or principal diversion mechanisms. For purposes of the second
   scenario, we assumed that currently outstanding subordinated
   tranches had been cancelled and, accordingly, we only reflected
   the balance of the senior notes in the calculation of any
   interest or principal diversion mechanisms," S&P said.

* "For each tranche, we applied the lower of the rating levels
   indicated by the cash flow analysis under the two scenarios
   described as the starting point for our rating analysis," S&P
   said.

* "We then reviewed the level of cushion relative to our credit
   stability criteria and made further adjustments to the ratings
   that we believe are appropriate," S&P said.

"The rating affirmation reflects our view that the tranche has
adequate credit support at the current rating after applying the
additional stresses and according to our updated criteria," S&P
said.

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

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

           http://standardandpoorsdisclosure-17g7.com

Rating Actions

KKR Financial CLO 2005-1 Ltd.
                        Rating
Class              To           From
A-1                AAA (sf)     AA+ (sf)/Watch Pos
B                  AA+ (sf)     A+ (sf)/Watch Pos
C                  A (sf)       BBB+ (sf)/Watch Pos
D                  BB+ (sf)     BB+ (sf)/Watch Pos
E                  BB (sf)      BB- (sf)/Watch Pos
F                  B (sf)       B- (sf)/Watch Pos

Transaction Information
Issuer:             KKR Financial CLO 2005-1 Ltd.
Coissuer:           KKR Financial CLO 2005-1 Corp.
Collateral manager: KKR Financial Advisors
Underwriter:        Morgan Stanley
Indenture trustee:  The Bank of New York Mellon
Transaction type:   Cash flow CDO


LB-UBS COMMERCIAL: Fitch Lowers Rating on 8 Subor. Note Classes
---------------------------------------------------------------
Fitch Ratings has downgraded eight subordinate classes of LB-UBS
Commercial Mortgage Trust (LB-UBS), series 2007-C7, commercial
mortgage pass through certificates, and affirmed the super senior
and mezzanine 'AAA' classes.

The downgrades reflect greater certainty of Fitch expected losses
following updated valuations of specially serviced assets.  Fitch
modeled losses of 9.2% of the remaining pool. Expected losses of
the original pool are at 12.3%, including losses realized to date.
Fitch has designated 23 loans (39.1% of the pool balance) as Fitch
Loans of Concern, which include eleven loans (23.6%) currently in
special servicing.  Seven of the Fitch Loans of Concern (33.6%)
are within the transaction's top 15 loans by unpaid principal
balance.  Fitch expects that class K may eventually be fully
depleted, and class J partially depleted from losses associated
with loans currently in special servicing.

As of the February 2012 distribution date, the pool's aggregate
principal balance has reduced by approximately 4.1% (including
3.44% in realized losses) to $3.04 billion from $3.17 billion at
issuance.  One loan (1.5%) is partially defeased. Interest
shortfalls are affecting classes F through T.

The largest contributor to Fitch-modeled losses is the District at
Tustin Legacy loan (6.77%), which is collateralized by 521,694
square feet (SF) of a 979,883 SF retail center in Tustin, CA.
Major tenants include Target, Whole Foods, TJ Maxx, Best Buy and
an AMC Theater.  Non-collateral anchors are Costco and Lowes.  The
December 2011 rent roll reported occupancy at 94.7%. Despite the
high occupancy since issuance, the property's net operating income
(NOI) has performed lower than expected as rental rates and
reimbursements remain below underwritten levels.  The NOI debt
service coverage ratio (DSCR) reported at 0.92 times (x) and 0.96x
for year end (YE) December 2011 and YE December 2010,
respectively.  The loan remains current as of the February 2012
remittance.

The second largest contributor to Fitch-modeled losses is The
Legends at Village West loan (4.51%), which is secured by a
680,157 SF retail center in Kansas City, KS.  The open-air life
style center, built in 2006, features several restaurants as well
as 'premium brand' outlet tenants including Saks Fifth Avenue,
Tommy Hilfiger, Polo Ralph Lauren, Nike, and BCBG.  The January
2012 rent roll reported occupancy at 92.5%, a significant
improvement from 79% in June 2011 as several leases for new
tenants were signed in late 2011.

The servicer reported the property has experienced cash flow
issues due to an increase in expenses since underwriting.  Based
on the servicer provided financial statements the YE December 2011
NOI DSCR reported at 1.06x, an improvement from YE December 2010
at 0.86x, however below 1.39x at underwriting.  The loan
transferred to special servicing in November 2011 for monetary
default.  The servicer has initiated the foreclosure process,
while negotiations with the borrower continue.

The third largest contributor to losses is the Innkeepers Hotel
Portfolio loan (11.10%) which is secured by 44 limited service
hotels and 1 full service hotel totaling 5,683 rooms, located
across 16 states.  The properties are affiliated with Marriott,
Hilton Hotels, and Global Hyatt.  The subject portfolio is also
secured by an identical pari pasu note which was securitized in
the LBUBS 2007-C6 transaction.

The loan transferred to special servicing in April 2010 due to
monetary default as a result of declining occupancy and cash flows
stemming from the economic downturn. The original borrowing
entities, the Innkeepers USA Real Estate Investment Trust (REIT),
filed for Chapter 11 bankruptcy relief in July 2010.  In October
2011, Innkeepers USA REIT had closed on the sale of 64 hotels
(including the subject collateral) to Cerberus Capital Management
LP (Cerberus).  As a result of the portfolio sale the subject
loans (including the pari pasu LBUBS 2007-C6 note) were assumed by
Cerberus, and modified with the each of the loan principals
written down to $337.5 million from $412.7 million.  The February
2012 remittance reported the subject loans as current under the
modified terms.  Based on the modified terms and the servicer
provided trailing twelve month July 2011 financials, the NOI DSCR
calculates to 1.36x.

Fitch downgrades these classes, revises Rating Outlooks and
assigns Recovery Estimates (REs):

  -- $269.5 million class A-J to 'B-sf' from 'Bsf'; Outlook to
     Negative from Stable;
  -- $47.5 million class B to 'CCCsf' from 'B-sf'; RE 0%;
  -- $35.7 million class C to 'CCsf' from 'B-sf'; RE 0%;
  -- $23.8 million class D to 'CCsf' from 'CCCsf'; RE 0%;
  -- $27.7 million class E to 'CCsf' from 'CCCsf; RE 0%;
  -- $15.6 million class F to 'Csf' from 'CCsf'; RE 0%;
  -- $31.7 million class G to 'Csf' from 'CCsf'; RE 0%;
  -- $21.7 million class K to 'Dsf' from 'Csf'; RE 0%.

Fitch also affirms these classes, and revises Rating Outlooks:

  -- $3.5 million class A-1 at 'AAAsf'; Outlook Stable;
  -- $194 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $74 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $1.7 billion class A-3 at 'AAAsf'; Outlook Stable;
  -- $260.4 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $317 million class A-M at 'AAAsf'; Outlook to Negative from
     Stable;
  -- $27.7 million class H at 'Csf'; RE 0%;
  -- $23.8 million class J at 'Csf'; RE 0%.

Classes L through S will remain at 'Dsf', RE 0% due to realized
losses.

Fitch does not rate class T, which has been reduced to zero due to
realized losses.


LONGHORN CDO: S&P Affirms 'CCC+' Ratings on 2 Classes of Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on one class
of notes from Longhorn CDO III Ltd., a collateralized loan
obligation (CLO) transaction backed by corporate loans. BlackRock
Financial Management Inc. manages the transaction. "At the same
time, we removed the affected rating from CreditWatch with
positive implications, where we had placed it on Dec. 20, 2011. We
affirmed the five other ratings in the transaction and removed two
of them from CreditWatch with positive implications," S&P said.

"The upgrade reflects an increase in the overall credit support
available to the rated notes and principal paydowns since our
February 2011 rating action on the notes," S&P said.

The affirmations reflect credit quality commensurate with their
current rating levels.

"The transaction has completely paid down the class A-1 notes
fully, as well as 13.8 million of the class A-2 notes since our
February 2011 rating action. Also, the transaction's defaulted
asset amount has decreased to $0.9 million as of the February
2012 trustee report, which we used in our current analysis, from
$1.3 million according to the December 2010 monthly report, which
we used for our February 2011 actions. Over the same time period,
the trustee's amount of assets in the 'CCC+' to 'D' range has also
decreased to $7.7 million from $15.8 million," S&P said. As a
result, the overcollateralization (O/C) ratios increased for all
classes, except class E:

* The class B O/C ratio was 220.13% in February 2012, compared to
   140.73% in December 2010;

* The class C O/C ratio was 133.24% in February 2012, compared to
   115.21% in December 2010;

* The class D O/C ratio was 108.50% in February 2012, compared to
   104.28% in December 2010; and

* The class E O/C ratio was 98.96% in February 2012, compared to
   99.06% in December 2010.

"The class C, D-1, and D-2 tranches were constrained by the
application of the largest obligor default test, a supplemental
stress test we introduced as part of our 2009 corporate CDO
criteria update," 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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

           http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Longhorn CDO III Ltd.
              Rating
Class     To           From
C         A+ (sf)      BBB+ (sf)/Watch Pos
D-1       CCC+ (sf)    CCC+ (sf)/Watch Pos
D-2       CCC+ (sf)    CCC+ (sf)/Watch Pos

Ratings Affirmed

Longhorn CDO III Ltd.
Class         Rating
A-2           AAA (sf)
B             AAA (sf)
E             CCC- (sf)


MMCAPS FUNDING: Moody's Raises Rating on US$33MM Notes From 'Ba3'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on these notes
issued by MMCAPS Funding XVII, Ltd.:

-- US$162,000,000 Class A-1 Floating Rate Notes Due 2035
    (current outstanding balance of $130,005,958), Upgraded to A3
    (sf); previously on August 20, 2009 Downgraded to Baa1 (sf);

-- US$19,500,000 Class A-2 Floating Rate Notes Due 2035 (current
    outstanding balance of $19,500,000), Upgraded to Baa1 (sf);
    previously on March 27, 2009 Downgraded to Ba1 (sf);

-- US$33,000,000 Class B Floating Rate Notes Due 2035 (current
    outstanding balance of $33,000,000), Upgraded to Baa3 (sf);
    previously on March 27, 2009 Downgraded to Ba3 (sf).

Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the Class A-1 Notes and an
increase in the transaction's overcollateralization ratios as well
as the improvement in the credit quality of the underlying
portfolio since the last rating action in August 2009.

Moody's notes that the Class A-1 Notes have been paid down by
approximately 16% or $25 million since the last rating action, as
a result of diversion of excess interest proceeds and disbursement
of principal proceeds from redemptions of underlying assets. Due
to the deleveraging, the Class A-1 notes' par coverage improved
from 150.87% to 174.47%, as calculated by Moody's since the last
rating action. Based on the latest trustee report dated November
2011, the Class A/B Principal Coverage Ratio and the Class C
Principal Coverage Ratio are reported at 125.38% (limit 125.00%)
and 90.33% (limit 102.10%), respectively, versus May 2009 levels
of 123.56% and 92.06%, respectively. Going forward, the Class A-1
notes will continue to benefit from the diversion of excess
interest.

Moody's also notes that the deal benefited from a slight
improvement in the credit quality of the underlying portfolio.
Based on Moody's calculation, the weighted average rating factor
(WARF) improved to 1166 compared to 1226 as of the last rating
action date. The Moody's cumulative assumed defaulted amount has
declined to $49.7 million from $61.9 million as of the last rating
action date. The decline is due to improvement in the credit
quality and the financial ratios of the banks that issued the four
of the assets that were assumed to be defaulted in the last rating
action.

Due to the impact of revised and updated key assumptions
referenced in our rating methodology, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers.
In its base case, Moody's analyzed the underlying collateral
pool to have a performing par balance of $227 million,
defaulted/deferring par of $50 million, a weighted average default
probability of 23.8% (implying a WARF of 1166), Moody's Asset
Correlation of 21.4%, and a weighted average recovery rate upon
default of 9.6%. In addition to the quantitative factors that are
explicitly modeled, qualitative factors are part of rating
committee considerations. Moody's considers the structural
protections in the transaction, the risk of triggering an Event of
Default, recent deal performance under current market conditions,
the legal environment, and specific documentation features. All
information available to rating committees, including
macroeconomic forecasts, inputs from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.

MMCAPS Funding XVII, Ltd., issued in September 2005, is a
collateralized debt obligation backed by a portfolio of bank and
insurance trust preferred securities.

The portfolio of this CDO is mainly comprised of trust preferred
securities (TruPS) issued by small to medium sized U.S. community
banks and insurance companies that are generally not publicly
rated by Moody's. To evaluate the credit quality of bank TruPS
without public ratings, Moody's uses RiskCalc model, an
econometric model developed by Moody's KMV, to derive their credit
scores. Moody's evaluation of the credit risk for a majority of
bank obligors in the pool relies on FDIC financial data received
as of Q3-2011. For insurance TruPS without public ratings, Moody's
relies on the insurance team and the underlying insurance firms'
annual financial reporting to assess their credit quality. Moody's
also evaluates the sensitivity of the rated transaction to the
volatility of the credit estimates, as described in Moody's Rating
Implementation Guidance "Updated Approach to the Usage of Credit
Estimates in Rated Transactions" published in October 2009.

The principal methodology used in this rating was "Moody's
Approach to Rating TRUP CDOs" published in May 2011.


MORGAN STANLEY: Fitch Keeps Neg. Rating Watch on 5 Notes Classes
----------------------------------------------------------------
Fitch Ratings maintains the Negative Rating Watch on five classes
of Morgan Stanley Capital I Trust 2007-TOP25, and affirms the
remaining 14 classes of the transaction.

Classes A-M through D remain on Rating Watch Negative based on an
increase in Fitch expected losses for the five remaining specially
serviced loans as well as higher than expected losses for the
recently disposed Village Square real estate owned (REO) asset (4%
of the pool).

Fitch expects to resolve the Rating Watch status within the next
several months following a complete review of the transaction
which will incorporate year-end 2011 operating history.  Fitch
expects class A-M could be downgraded several categories given
limited subordination of the remaining classes to offset losses.

Fitch maintains these classes on Rating Watch Negative:

  -- $155.5 million class A-M 'AAAsf';
  -- $110.8 million class A-J 'BBBsf-';
  -- $27.2 million class B 'BBsf';
  -- $11.7 million class C 'Bsf';
  -- $25.3 million class D 'B-sf'.

In addition, Fitch affirms these classes:

  -- $65.1 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $60.7 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $784.4 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $135.9 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $11.7 million class E at 'Csf/RE0%';
  -- $13.1 million class F at 'Dsf/RE0%'
  -- $0 million class G at 'Dsf/RE0%';
  -- $0 million class H at 'Dsf/RE0%';
  -- $0 million class J at 'Dsf/RE0%';
  -- $0 million class K at 'Dsf/RE0%';
  -- $0 million class L at 'Dsf/RE0%';
  -- $0 million class M at to'Dsf/RE0%';
  -- $0 million class N at 'Dsf/RE0%';
  -- $3.9 million class O at 'Dsf/RE0%'.


MORGAN STANLEY: DBRS Downgrades Class P to 'D'
----------------------------------------------
DBRS has downgraded the Commercial Mortgage Pass-Through
Certificates, Series 2005-HQ6, Class P (the Class P) rating of
Morgan Stanley Capital I Trust 2005-HQ6 (the Trust) to D (sf) from
C (sf).  As part of this rating action, DBRS has also removed the
Interest in Arrears designation from the Class P.

The downgrade is the consequence of realized losses to the Trust
as a result of the liquidation of two loans out of the Trust.

Prospectus ID #104 (Rocklin Portfolio) was liquidated at a loss of
$2.81 million as of the February 2012 remittance report.  That
loan was secured by one free-standing industrial property
comprising 52,000 square feet (sf) and a retail property
comprising 18,000 sf in Rocklin, California.  The loan transferred
to the special servicer in July 2010 after the borrower requested
a modification.  The properties were fully occupied as of the most
recent update provided by the special servicer.  The most recent
appraisal, dated July 2011, valued the properties at $3.8 million.
The property has been real estate owned (REO) since Q3 2011 and
recently sold for approximately $2.75 million, with $2.03 million
available in proceeds for principal repayment at liquidation.  As
of the February 2012 remittance report, the realized loss severity
was 58.1%.

Prospectus ID #140 (Oaks Plaza) was liquidated at a loss of
$1.5 million as of the February 2012 remittance report.  The loan
was secured by a suburban office portfolio comprising 42,000 sf,
located in Temple Terrace, Florida.  At the time of the loan's
transfer to the special servicer in 2010, the property was 62%
occupied and found to be in Fair condition overall by the
special servicer.  A July 2011 appraisal valued the property
at $2 million.  The property has been REO since Q1 2011 and
recently sold at a price of approximately $1.95 million, with
$1.5 million in proceeds available for principal repayment at
liquidation.  As of the February 2012 remittance report, the
realized loss severity was 49.4%.

DBRS will conduct a full surveillance review of this transaction
in the next 30 days to address concerns with these and other
recent losses to the trust and the remaining loans in special
servicing.


MORGAN STANLEY: S&P Cuts Rating on Class K Certs. to 'D'
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on three
classes of commercial mortgage pass-through certificates from
Morgan Stanley Capital I Trust 2006-HQ9, a U.S. commercial
mortgage-backed securities (CMBS) transaction. "Concurrently, we
affirmed our ratings on 16 other classes from the same
transaction," S&P said.

"Our rating actions follow our analysis of the credit
characteristics of the collateral remaining in the pool, the deal
structure, and the liquidity available to the trust. The
downgrades reflect credit support erosion that we anticipate will
occur upon the eventual resolution of 16 ($140.5 million,
5.9%) of the 19 assets ($185.9 million, 7.8%) that are with the
special servicer and reduced liquidity support available to the
trust. We also considered the monthly interest shortfalls that are
affecting the trust. We lowered our rating on the class K
certificates to 'D (sf)' because we 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 X and X-MP interest-only (IO)
certificates based on our current criteria," S&P said.

"Using servicer-provided financial information, we calculated an
adjusted debt service coverage (DSC) of 1.60x and a loan-to-value
(LTV) ratio of 90.2%. We further stressed the loans' cash flows
under our 'AAA' scenario to yield a weighted average DSC of 1.06x
and an LTV ratio of 123.7%. The implied defaults and loss severity
under the 'AAA' scenario were 60.2% and 34.7%. The DSC and LTV
calculations exclude 16 ($140.5 million, 5.9%) of the 19 assets
($185.9 million, 7.8%) that are with the special servicer. We
separately estimated losses for the specially serviced assets and
included them in our 'AAA' scenario implied default and loss
severity figures," S&P said.

"As of the Feb. 14, 2012, trustee remittance report, the trust
experienced net monthly interest shortfalls totaling $172,118.
These shortfalls were primarily related to appraisal subordinate
entitlement reduction (ASER) amounts ($196,359), interest not
advanced on assets the master servicer has deemed nonrecoverable
($56,031), interest rate modifications ($27,126), and special
servicing and workout fees ($44,362). The interest shortfalls were
partially offset by a one-time recovery of ASER interest due to
the bonds ($110,378). The interest shortfalls affected all classes
subordinate to and including class K. Class K experienced
cumulative interest shortfalls of nine months, and we expect these
interest shortfalls to remain outstanding for the foreseeable
future. Consequently, we downgraded this class to 'D (sf)'," S&P
said.

                  Credit Considerations

"As of the Feb. 14, 2012 trustee remittance report, 19 assets
($185.9 million, 7.8%) in the pool were with the special servicer,
C-III Asset Management LLC (C-III). C-III modified two assets,
Country Hills Plaza ($13.2 million, 0.6%) and Eastwood
Professional Center ($2.0 million, 0.1%), by bifurcating them into
an A note and B note structure. As of the most recent trustee
remittance report, the Country Hills Plaza A note ($11.0 million,
0.5%) was in its grace period, and the B note ($2.2 million,
0.1%) was current. The Eastwood Professional Center A note
($1.8 million, 0.1%) was reported as being in foreclosure and the
B note ($0.2 million, .01%) was reported as being current. The
reported payment status for the remaining 17 specially serviced
assets was as: five are real estate-owned (REO) ($31.8 million,
1.3%), three are in foreclosure ($36.4 million, 1.5), seven are
90-plus-days delinquent ($74.5 million, 3.1%), one is 60 days
delinquent ($3.6 million, 0.2%), and one is a matured balloon loan
($24.4 million, 1.0%). Appraisal reduction amounts (ARAs) totaling
$52.9 million are in effect against 13 of the 19 specially
serviced assets. Details of the two largest specially serviced
assets are as set forth," S&P said.

"The Center Point Complex Portfolio loan ($30.2 million, 1.3%) is
the largest specially serviced asset. The total reported exposure
was $33.7 million. The loan is secured by the four retail
properties totaling 460,681 sq. ft. built between 1895 and 1966 in
High Point, N.C. There is no recent financial data for this loan.
Based on the Feb. 14, 2012, remittance report, the payment status
of this loan is 90-plus-days delinquent. An ARA of $17.5 million
is in effect against this asset. C-III has indicated that it is
close to finalizing loan modification terms with the borrower,"
S&P said.

"The Mayo Medical Building loan ($28.1 million, 1.2%) is the
second-largest specially serviced asset. The total reported
exposure was $28.1 million. The loan is secured by a 204,846-sq.-
ft. medical office building in Rochester, Mn. The property is 100%
leased to Mayo Medical until 2016. The loan was transferred to the
special servicer on Aug. 24, 2011, due to maturity default. The
most recent reported DSC was 1.23x for the year ended Dec. 31,
2010," S&P said.

"Based on the Feb. 14, 2012 remittance report, the loan is in
foreclosure. We expect a significant loss upon the eventual
resolution of the asset," S&P said.

"The 17 remaining assets with the special servicer have individual
balances that represent less than 1.1% of the total trust balance.
ARAs totaling $35.4 million are in effect against 12 of these
assets. We estimated losses for 15 of the 17 remaining assets,
arriving at a weighted-average loss severity of 40.5%," S&P said.

"Five loans totaling $15.6 million that were previously with the
special servicer have been returned to the master servicer.
According to the transaction documents, the special servicer is
entitled to a workout fee equal to 1.0% of all future principal
and interest payments on the corrected loans, provided that they
continue to perform and remain with the master servicer," S&P
said.

                          Transaction Summary

"As of the Feb. 14, 2012 trustee remittance report, the collateral
pool had an aggregate trust balance of $2.38 billion, down from
$2.58 billion at issuance. The pool comprises 191 loans and five
REO assets, down from 211 loans at issuance. The master servicer,
Wells Fargo Bank N.A., provided financial information for 95.8% of
the loans in the pool (by balance), most of which
reflected data for full-year 2010 or interim 2011," S&P said.

"We calculated a weighted average DSC of 1.65x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV were 1.60x and 90.2%. Our adjusted figures exclude 16
($140.5 million, 5.9%) of the 19 assets ($185.9 million, 7.8%)
that are with the special servicer. To date, the transaction has
experienced $34.9 million in principal losses from 13 assets.
Seventy-five loans ($536.9 million, 22.6%) in the pool are on the
master servicer's watchlist, three of which are top 10 loans that
are discussed. Fifty-four loans ($323.8 million, 13.6%) have a
reported DSC of less than 1.10x, 37 of which ($190.4 million,
4.1%) have a reported DSC of less than 1.00x," S&P said.

                      Summary of Top 10 Loans

"The top 10 loans have an aggregate outstanding trust balance
of $1.22 billion (51.1%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.99x for the top 10 loans.
Our adjusted DSC and LTV were 1.84x and 84.3% for the top 10
loans. Three of the top 10 loans ($162.5 million, 6.8%) are on the
master servicer's watchlist," S&P said.

"The 633 Indiana Avenue NW loan ($53.0 million, 2.2%) is the
eighth-largest loan in the pool and the largest loan on the master
servicer's watchlist. The loan is secured by a 143,730-sq.-ft.
office building in Washington, D.C. The property is 100% occupied
by the Court Services and Offender Supervisory Agency (CSOSA), a
government entity with lease expiration on Sept. 30, 2020. The
reported DSC as of Sept. 30, 2011, was 1.41x," S&P said.

"The DCT Industrial Portfolio loan has a trust balance of
$68.5 million (2.9%) and a whole-loan balance of $95.5 million. It
is the ninth-largest loan in the pool and the second-largest loan
on the master servicer's watchlist. The $68.5 million trust
balance consists of a $50 million senior pooled component and a
$18.5 million subordinate nonpooled component, which is not rated
by Standard & Poor's. The loan is secured by six industrial
properties with a total of 2.6 million sq. ft. in six U.S. states.
The anticipated repayment date (ARD) is March 1, 2012, and the
final maturity date is March 2, 2036. The reported DSC as of
Sept. 30, 2011, was 2.08x and based on the February 2012 rent roll
provided the occupancy was 79.5%," S&P said.

"The RLJ Hotel Portfolio loan is the 10th-largest loan in the pool
and the third-largest loan on the master servicer's watchlist. The
loan has a $492.9 million whole-loan balance that is split into
eight pari-passu pieces, $41.0 million of which makes up 1.7% of
the trust balance. The loan is secured by 43 hotels totaling 5,429
rooms in eight U.S. states. The loan payment status was reported
as current as of the Feb. 14, 2012, trustee remittance report. The
loan is on Wells Fargo's watchlist due to a low reported combined
DSC, which was 1.15x for the 12 months ended Sept. 30, 2011. The
reported combined occupancy was 68.3% for the same period," S&P
said.

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

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

         http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

Morgan Stanley Capital I Trust 2006-HQ9
Commercial mortgage pass-through certificates
             Rating
Class     To         From         Credit enhancement (%)
G         B+ (sf)    BB (sf)                        5.08
H         CCC+ (sf)  B- (sf)                        3.85
K         D (sf)     CCC- (sf)                      2.48

Ratings Affirmed

Morgan Stanley Capital I Trust 2006-HQ9
Commercial mortgage pass-through certificates
Class     Rating    Credit enhancement (%)
A-1A      AAA (sf)                   31.36
A-2       AAA (sf)                   31.36
A-3       AAA (sf)                   31.36
A-AB      AAA (sf)                   31.36
A-4       AAA (sf)                   31.36
A-4FL     AAA (sf)                   31.36
A-M       AAA (sf)                   20.41
A-J       A (sf)                     11.79
B         A- (sf)                    10.97
C         BBB+ (sf)                   9.46
D         BBB (sf)                    8.23
E         BBB- (sf)                   7.27
F         BB+ (sf)                    6.18
J         CCC- (sf)                   2.48
X         AAA (sf)                     N/A
X-MP      AAA (sf)                     N/A

N/A -- Not applicable.


MORGAN STANLEY: S&P Lowers Ratings on 6 Classes to 'D'
------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D (sf)'
from 'CCC- (sf)' on six classes from Morgan Stanley Managed ACES
SPC series 2006-6 and on six classes from Morgan Stanley Managed
ACES SPC series 2006-9.

The lowered ratings follow losses on account of recent credit
events in the underlying reference entities that have caused the
notes to incur partial principal losses.

Rating Lowered

Morgan Stanley Managed ACES SPC 2006-6
           Rating
Class    To        From
IA       D (sf)    CCC- (sf)
IB       D (sf)    CCC- (sf)
IC       D (sf)    CCC- (sf)
IIA      D (sf)    CCC- (sf)
IIB      D (sf)    CCC- (sf)
IID      D (sf)    CCC- (sf)

Morgan Stanley Managed ACES SPC 2006-9

           Rating
Class    To        From
IA       D (sf)    CCC- (sf)
IC       D (sf)    CCC- (sf)
IIA      D (sf)    CCC- (sf)
IIB      D (sf)    CCC- (sf)
IIC      D (sf)    CCC- (sf)
IID      D (sf)    CCC- (sf)


MONTANA HIGHER: Fitch Keeps Rating on Student Loan Bonds
--------------------------------------------------------
Fitch Ratings currently maintains ratings on the student loan
bonds issued under the Montana Higher Education Student Assistance
Corporation (MHESAC) indenture of trust dated as of Aug. 1, 1993,
as amended and supplemented (the 1993 Indenture).

MHESAC has requested that Fitch confirm the outstanding ratings
assigned to the student loan bonds issued under the 1993 Indenture
(the bonds) in connection with the execution of (1) a backup
servicing agreement (the SAF Backup Servicing Agreement) between
the Student Assistance Foundation of Montana (SAF; as Servicer)
and the Pennsylvania Higher Education Assistance Agency (PHEAA; as
Backup Servicer), (2) a servicing agreement (the PHEAA Servicing
Agreement) among MHESAC, PHEAA (as Servicer) and Wells Fargo Bank,
National Association (as Eligible Lender Trustee), (3) an eighth
amendment (the SAF Servicing Agreement Amendment) to the servicing
agreement among MHESAC, SAF (as Servicer) and Wells Fargo Bank,
National Association (as Trustee), and (4) a Twentieth
Supplemental Indenture of Trust (the Supplemental Indenture),
amending certain provisions of the 1993 Indenture.

Consistent with its statements on policies regarding rating
confirmations in structured finance transactions (Jan. 13, 2009)
and student loan confirmations (May 8, 2009), Fitch is treating
this request for rating confirmation as a notification.

After reviewing the related legal documentation, Fitch has
determined that the execution of the SAF Backup Servicing
Agreement, the PHEAA Servicing Agreement, the SAF Servicing
Agreement Amendment and the Supplemental Indenture will not have
an impact on the existing ratings of the bonds at this time.  This
determination only addresses the effect of the execution of the
SAF Backup Servicing Agreement, the PHEAA Servicing Agreement, the
SAF Servicing Agreement Amendment and the Supplemental Indenture
on the current ratings assigned by Fitch to the bonds.  It does
not address whether the execution of the SAF Backup Servicing
Agreement, the PHEAA Servicing Agreement, the SAF Servicing
Agreement Amendment and the Supplemental Indenture is permitted by
the terms of the transaction documents, nor does it address
whether it is in the best interest of, or prejudicial to, some or
all of the holders of the bonds.

Fitch currently rates of the bonds:

MHESAC 1993 Indenture:

  -- Series 1995-A 'AAAsf'; Rating Watch Negative;
  -- Series 1995-B 'AAAsf'; Rating Watch Negative;
  -- Series 1995-C 'AAAsf'; Rating Watch Negative;
  -- Series 1998-A 'AAAsf'; Rating Watch Negative;
  -- Series 1999-A 'AAAsf'; Rating Watch Negative;
  -- Series 2000-A 'AAAsf'; Rating Watch Negative;
  -- Series 2000-B 'AAAsf'; Rating Watch Negative;
  -- Series 2000-C 'AAAsf'; Rating Watch Negative;
  -- Series 2001-A 'AAAsf'; Rating Watch Negative;
  -- Series 2001-B 'AAAsf'; Rating Watch Negative;
  -- Series 2001-C 'AAAsf'; Rating Watch Negative;
  -- Series 2002-A 'AAAsf'; Rating Watch Negative;
  -- Series 2002-B 'AAAsf'; Rating Watch Negative;
  -- Series 2002-D 'AAAsf'; Rating Watch Negative;
  -- Series 2003-A 'AAAsf'; Rating Watch Negative;
  -- Series 2003-B 'AAAsf'; Rating Watch Negative;
  -- Series 2003-C 'AAAsf'; Rating Watch Negative;
  -- Series 2004-A 'AAAsf'; Rating Watch Negative;
  -- Series 2004-B 'AAAsf'; Rating Watch Negative;
  -- Series 2005-B 'AAAsf'; Rating Watch Negative;
  -- Series 2006-A 'AAAsf'; Rating Watch Negative;
  -- Series 2006-B 'AAAsf'; Rating Watch Negative;
  -- Series 2006-D 'AAAsf'; Rating Watch Negative;
  -- Series 2006-E 'AAAsf'; Rating Watch Negative;
  -- Series 2006-F 'AAAsf'; Rating Watch Negative;
  -- Series 1998-B 'Bsf'; Rating Watch Negative;
  -- Series 1999-B 'Bsf'; Rating Watch Negative;
  -- Series 2002-E 'Bsf'; Rating Watch Negative;
  -- Series 2003-D 'Bsf'; Rating Watch Negative;
  -- Series 2004-C 'Bsf'; Rating Watch Negative;
  -- Series 2006-C 'Bsf'; Rating Watch Negative;
  -- Series 2006-G 'Bsf'; Rating Watch Negative.




MORTGAGE EQUITY: Moody's Cuts Ratings on Cl. A Securities to Ba3
----------------------------------------------------------------
Moody's Investors Service has downgraded 13 securities from 10
deals backed by Home Equity Conversion Mortgages (HECM). Moody's
also downgraded six reverse mortgage backed resecuritization bonds
from two deals.

The collateral backing these transactions consists primarily of
HECM reverse mortgages that benefit from mortgage insurance
protection from the Federal Housing Administration, a federal
agency in the Department of Housing and Urban Development (HUD).

Complete rating actions are:

Issuer: Mortgage Equity Conversion Asset Trust 2006-SFG1

Cl. A, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Issuer: Mortgage Equity Conversion Asset Trust 2006-SFG2

Cl. A, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Issuer: Mortgage Equity Conversion Asset Trust 2006-SFG3

Cl. A, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Issuer: Mortgage Equity Conversion Asset Trust 2007-FF1

Cl. A, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Issuer: Mortgage Equity Conversion Asset Trust 2007-FF2

Cl. A, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Issuer: Mortgage Equity Conversion Asset Trust 2007-FF3

Cl. A, Downgraded to B1 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Cl. IO, Downgraded to B1 (sf); previously on Feb 22, 2012
Downgraded to Aa1 (sf)

Issuer: Reverse Mortgage Loan Trust, Series REV 2007-2

Cl. A, Downgraded to Ba2 (sf); previously on Nov 21, 2011
Downgraded to Aa2 (sf) and Placed Under Review for Possible
Downgrade

Issuer: Riverview HECM Trust, Series 2007-1

CL. A, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa2 (sf) and Placed Under Review for Possible
Downgrade

Issuer: Riverview Mortgage Loan Trust 2007-2

Cl. A-2, Downgraded to B1 (sf); previously on Nov 21, 2011
Downgraded to Aa2 (sf) and Placed Under Review for Possible
Downgrade

Cl. X, Downgraded to Ba2 (sf); previously on Feb 22, 2012
Downgraded to Aa1 (sf)

Issuer: Riverview Mortgage Loan Trust 2007-3

CL. A-1, Downgraded to B1 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Cl. X, Downgraded to B1 (sf); previously on Feb 22, 2012
Downgraded to Aa1 (sf)

Issuer: Riverview HECM Trust 2007-4

CL. A, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa2 (sf) and Placed Under Review for Possible
Downgrade

Issuer: Riverview HECM Trust, Series 2008-1

Cl. A-1, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Cl. A-2, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Cl. A-3, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Cl. A-4, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Cl. A-5, Downgraded to Ba3 (sf); previously on Nov 21, 2011
Downgraded to Aa1 (sf) and Placed Under Review for Possible
Downgrade

Ratings Rationale

The rating actions are triggered by revised loss projections
(reflecting falling home prices and longer liquidation timelines)
and the relatively thin credit enhancement, typically 1%-3% of
outstanding pool balance and 0.2%-0.7% of excess spread per year.
Even though these mortgages are insured by HUD, they could be
exposed to losses if the properties backing them are not
liquidated within six months of entering REO.

The methodology that was used in assigning initial ratings to the
HECM deals assumed minimal losses from appraisal based claims
because very few loans were sold after six months in REO and those
loans were usually sold for more than their appraisal amounts.

For Home Equity Conversion Mortgages, servicers have to follow
strict HUD liquidation guidelines, once a borrower dies or vacates
the property permanently and HUD verifies that the loan is due and
payable.

Typically, the servicer must first give the borrower's estate six
months to pay the loan in full before initiating foreclosure. If
the property does not sell during the foreclosure sale, the loan
enters real estate owned (REO), at which point the servicer starts
marketing the property. If the property remains unsold after six
months in REO, the servicer has to provide HUD an appraisal of the
property conducted by a HUD-approved appraiser. HUD will base its
reimbursement for the liquidated property on the appraisal amount
(the appraisal-based claim).

HUD will cover the difference between the unpaid loan balance at
liquidation and the latest appraisal amount if the appraisal
amount is lower than the unpaid loan balance. HUD will not cover
any shortfalls if the property sells for less than this appraised
amount. In that case, the trust will cover the shortfall between
the latest appraisal value and the actual REO proceeds.

With falling home prices and longer liquidation timelines, the
risk that loans will take longer than six months to sell after
entering REO has risen significantly, a trend corroborated by data
from servicers. Losses on loans that have sold six months after
entering REO have averaged 20%, that is, on average, properties
are selling for 20% less than their appraised amounts. These
trends are generally consistent with that of forward mortgages
where REO properties are sold on average at about 15% lower than
their updated appraisal values and where the majority of the REO
properties are sold six months after the foreclosure sale.

METHODOLOGY:

Repayment of a reverse mortgage is triggered primarily when the
loan matures either due to a mortality event when the last
borrower dies or by a mobility event when the borrower(s)
permanently move out of the property. Repayment is also triggered
when the servicers assign the loan to HUD upon loan balance
reaching 98% of the Maximum Claim Amount (MCA). Loan balances
increase each month by accrued interest, borrower draws on their
respective available lines of credit, servicer fees and other
expenses.

The credit risks for HECM reverse mortgages are property values,
interest rates, maturity rates, i.e., the rate at which the
maturity events will occur, and draw rates. In addition, expected
losses are sensitive to the probability for a matured loan to have
an appraisal based claim, the shortfall between the latest
appraisal value and the actual REO proceeds (appraisal haircut)
for such claim, and the time period for which the shortfall will
be experienced.

Moody's assumed that HUD would pay the loan in full that servicers
assign to them upon loan balance reaching 98% of the MCA and that
the borrower estate would pay the loan in full if the loan has
positive equity upon maturity, both scenarios resulting in no loss
to the trust. For the rest of the matured loans with no equity,
Moody's assigned an 85% probability that an appraisal based claim
will be filed resulting in a loss of 20% of the latest appraisal
value to the trust. Moody's further assumed that there will be no
loss from the appraisal based claims after the next 2, 3, and 5
years for B, Ba, and Baa rating levels respectively.

Moody's assumptions on property values, interest rates, maturity
rates, and draw rates are as described below:

* Moody's assumed that house prices will decline by approximately
1.5% from the 4Q 2011 levels until end of 4Q 2012 after which
house prices will increase at annual rate of 5% until the end of
2016, and then increase at an annual rate of 3.5% in the base case
(B2 rating level) based on Moody's Macroeconomic Board projection.
For higher rating levels these assumptions were stressed. In the
Aaa scenario, Moody's assumed home prices to further decline by
30% from the 4Q 2011 levels until 4Q 2012 with no increase
thereafter to be able to withstand a similar peak to trough house
price decline experienced since 2007. The Baa scenario is
calibrated in between Aaa and B2 rating levels where Moody's
assumed home prices to further decline by 15% from 4Q 2011 levels
until 4Q 2012 and then increase at an annual rate of 2.5%.

* For interest rates, the assumption is for the 1 year CMT rate to
remain flat at 0.1% for the next 3 years until the end of 2014,
increase to 1% by 2Q 2016, and then increase to 4% by 4Q 2017 and
stabilize thereafter. The interest rate is kept low for the next
three years to account for the Fed's policy of keeping interest
rates low through 2014 and the long term rate is set to 4% based
on Moody's Analytics' forecast. In the Aaa rating level, Moody's
assumed that the CMT rate would increase from the current rate of
0.1% to 7%, the highest rate that CMT has risen to in the last 20
years, by 4Q 2013 and stabilize thereafter. The Baa scenario is
calibrated in between Aaa and B2 rating levels where Moody's
assumed CMT rates to remain flat at 0.1% until the end of 2014,
increase to 1% by 1Q 2015, and then at a faster pace until it
reaches 4.75% by the end of 2Q 2017 with a long term average of
4.25%.

* Moody's mortality rate assumptions, i.e. the rate at which
mortality events occur, are based on "Annuity 2000 Mortality
Tables" available in the Transactions of Society of Actuaries
1995-96 Reports. These tables provide mortality rates by age
separately for males and females. Moody's mobility rate
assumptions, i.e. the rate at which mobility events occur, are
based on US Census Bureau, 2007 results. A monthly maturity rate
is calculated to derive the portion of the loan that will be paid
down each month based on the mobility and mortality rates for each
borrower. These assumptions do not change by rating levels as they
have very low correlation with different economic scenarios.

* Moody's annual draw rate assumption, i.e. the rate at which the
borrowers will draw on their available line of credit is
approximately 10%, which is based on the actual amount drawn over
available line of credit since the closing of the deals and is
kept constant for different rating levels.

In order to derive the ratings, Moody's first defined economic
scenarios for the six rating levels (B2, Ba2, Baa2, A2, Aa2 and
Aaa) as noted above and then projected cashflows for each rating
level for the life of the deal. Monthly loan balances were
calculated based on the projected accrued interest, amounts drawn,
and fees. Moody's then applied the monthly maturity rate to
determine the portion of the loan that will be paid down each
month. The net monthly cash flow proceeds from each loan available
to pay down the bonds was then calculated as the outstanding loan
balance if the loan has equity, if the loan balance exceeds 98% of
MCA, or if the loan matures after the next 2, 3, and 5 years for
B, Ba, and Baa rating levels respectively. In other scenarios, the
net monthly cash flow proceeds from each loan was calculated as
the difference between outstanding loan balance and 20% of the
latest appraisal value. These proceeds were then applied to the
bonds per the deal structure, accounting for the funding account
available to mitigate shortfalls in cash.

As a part of the sensitivity analysis, Moody's stressed the credit
risk drivers by an additional 10% and found that the implied
ratings of the bonds do not change.

The primary reason for the uncertainty about actual sales prices
and possible shortfall is the weak macro-economic environment.
Properties are taking longer to sell, and sales prices are often
lower than the latest appraisal values.


MSC 2012-C4: DBRS Assigns 'BB' Provisional Rating to Class F
---------------------------------------------------------------
DBRS has assigned provisional ratings to the classes of Commercial
Mortgage Pass-Through Certificates, Series 2012-C4 to be issued by
MSC 2012-C4 Mortgage Trust. The trends are Stable.

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

The collateral consists of 38 fixed-rate loans secured by 77
multifamily, mobile home parks and commercial properties.  The
portfolio has a balance of $1,098,695,600.  The pool consists of
relatively low-leverage financing, with a DBRS weighted-average
term debt service coverage ratio (DSCR) and debt yield of 1.56
times (x) and 10.9%, respectively. Of the collateral, 92.8% is
located in suburban or urban locations and benefits from
relatively diverse economies.  Underwriting was generally prudent,
and the average DBRS net cash flow variance was -6.2%. In
addition, two loans, representing 14.9% of the pool, are shadow-
rated investment grade by DBRS.

The pool is concentrated with the top three loan and top ten loan
concentrations representing 27.7% and 62.7% of the pool,
respectively, which is greater than other CMBS transactions issued
in 2010 and 2011.  This is mitigated by the fact that the top ten
loans include four portfolios and a total of 33 properties.
Generally, the largest ten loans are located in unique markets.
The deal is further challenged by the concentration of hotel loans
and other non-traditional property types (MHC, self-storage,
military housing and student housing), which combined, represent,
33.5% of the pool.  For hotel loans, the DBRS cash flow volatility
incorporates significant cash stresses, which ultimately increases
the probability of default for these loans.  The remaining non-
traditional property types were either included in a portfolio,
had favorable DBRS debt yield metrics, have reported stable
historical performance and are located in suburban markets, or
have been modeled with below average cash flow stability which
increases the loan's term probability of default.

The ratings assigned to the Certificates by DBRS are based
exclusively on the credit provided by the transaction structure
and underlying trust assets.  All classes will be subject to
ongoing surveillance which could result in upgrades or downgrades
by DBRS after the date of issuance.

Finalization of ratings is contingent upon receipt of final
documents conforming to information already received.


MSCI 2007: Fitch Downgrades Rating on 15 Note Classes
-----------------------------------------------------
Fitch Ratings has downgraded 15 classes of Morgan Stanley Capital
Trust I, 2007-HQ12 due to further deterioration of performance,
most of which involves increased losses on the specially serviced
loans.

The downgrades reflect an increase in Fitch expected losses across
the pool. Fitch modeled losses of 20.26% of the remaining pool, or
18.46% of the original pool balance.  The affirmations of the
super senior classes were the result of sufficient credit
enhancement in light of paydown of the most senior classes.

Fitch has designated 24 loans (58.2%) as Fitch Loans of Concern,
which includes 11 specially serviced loans (18.4%).  Fitch expects
classes K thru Q may be fully depleted from losses associated with
the specially serviced assets and class J will also be impaired.

As of the February 2012 distribution date, the pool's aggregate
principal balance has been paid down by approximately 15.7% to
$1.65 billion from $1.96 billion at issuance.  Interest shortfalls
are currently affecting classes A-J thru S.

The largest contributors to modeled losses are four (46.4%) of the
top 15 loans in the transaction, two (13%) of which are currently
specially serviced.

Columbia Center (23%) is secured by a 1.5 million square foot
(sf), 76-story office building located in the Seattle downtown
CBD.  The property has experienced significant declines in
occupancy since issuance most recently associated with the vacancy
of the largest tenant, Amazon, vacating at lease expiration in
February 2011.  Amazon physically occupied (11.7%) of net rentable
area (NRA) and represented 12% of total rent at origination.

Currently, the largest tenants are General Services Administration
(GSA) (10%), lease expirations (6% 2025, 2% in 2013 and 2% in
2015); Dorsey & Whitney LLP (4%), lease expiration in October
2019; and Seed Intellectual (3%), lease expiration in March 2018.
As of the September 2011 rent roll, the property had below market
occupancy at 63.5% with average in-place rent $23.55 per square
foot (psf).  Per REIS, as of the fourth quarter of 2011 (4Q'11),
the Seattle metro office market had a vacancy rate of 15.1% with
average rent $28.21 psf.  The most recent servicer-reported debt-
service coverage ratio (DSCR) as of the 3Q'11 is DSCR 0.89x.  The
loan was previously modified in September 2010 and the maturity
date was extended to May 8, 2015 from May 8, 2012 with two one-
year extension options.  The modification also included a tenant
rollover reserve funded by the borrower.  While Fitch modeled
significant losses on the loan based on current cash flow, the
high quality nature of the asset was also taken into account.
Fitch will continue to revisit the analysis of the loan as it
approaches its extended maturity date.

Parkoff Portfolio (10.3%) is secured by a 312 unit, six-property
portfolio of multifamily buildings located on the upper east side
of Manhattan.  Two of the buildings include retail stores with
frontage on Madison Avenue, and another building is in close
proximity to Central Park.

Property stabilization remains behind schedule as the borrower has
been unable to convert rent-stabilized units to market as quickly
as they had anticipated at issuance.  At issuance, the portfolio
included 87 rent-stabilized units that the borrower planned to
convert to market rate units through renovations and capital
investments.  As of February 2012, there are currently 76 rent
stabilized units remaining.

As of the February 2012 rent roll, the property was 96% occupied
with an average rent per unit $4,690.  Per REIS, as of 4Q'11, the
Upper East Side New York City submarket vacancy rate is 1% with
asking rent of $3,725. Although, the most recent servicer-reported
DSCR as of June 30, 2011 was 0.76x, the loan remains current.  At
issuance, the borrower had posted a $5 million letter of credit as
additional collateral.  Fitch has been unable to confirm whether
the letter of credit has or will be renewed.  While Fitch modeled
losses on the loan based on the current cash flow, the high
likelihood of ultimate recovery of the loan given the assets'
strong position in the market was also considered.

Beacon Seattle and D.C. Portfolio (6.9%) was initially secured by
16 properties, the pledge of the mortgage and the borrower's
ownership interest in one property, as well as the pledge of cash
flows from three properties.  In the aggregate, the 20 properties
comprised approximately 9.8 million sf of space.  The loan
transferred to special servicing in April 2010 and remained
current as the borrower was negotiating a modification which
closed in December 2010.  Key modification terms included a five-
year extension of the loan to May 2017, a deleveraging structure
that provides for the release of properties over time, and an
interest rate reduction.

Under the modification plan, six properties have been released as
of the February 2012 remittance, which includes Market Square
(Washington, D.C.), Key Center (Bellevue, WA), 1616 North Fort
Myer Drive (Arlington, VA), Liberty Place (Washington, D.C.),
1300 North Seventeenth Street (Arlington, VA), and Reston Town
Center (Reston, VA).  Gross proceeds from the releases totaled
$819 million, which have paid down the trust loan balance by 30%,
repaid prior interest shortfalls, and built up the Master Reserve
Account to $92 million.

The combined occupancy for the 14 remaining properties is 80.3%,
down from 96.5% at issuance for the same properties.  For the nine
months ending Sept. 30, 2011, the annualized servicer-reported net
operating income (NOI) was down 10% from 2010 and 13% below 2008
and 2009 for the same properties.

Douglas Entrance (6.1%) is secured by five office buildings
totaling 469,822 sf located in Coral Gables, FL. The largest
tenants are AECOM Technology Corp (7%), Univision Radio Florida
(6%), and Mastec Inc. (16%). These tenants have lease expirations
in 2019, 2015, and 2017, respectively.

The loan was transferred to special servicing in April 2010 due
to imminent default.  The loan was modified in June 2011 and is
performing per the terms of the modification agreement which
included an extension of the loan to April 2014.  As of the
December 2011 rent roll, the consolidated occupancy for the
properties was 74.9% with average in-place rent of $27.75 sf which
is below the current market vacancy for the Coral Gables submarket
of 10.5% and market rents of $36 sf as reported by REIS as of the
4th quarter 2011.

Fitch downgrades, assigns Outlooks, and assigns or lowers Recovery
Estimates on these classes:

  -- $170.9 million class A-M to 'Bsf' from 'BBB-sf'; Outlook
     Negative;
  -- $25 million class A-MFL to 'Bsf' from 'BBB-sf'; Outlook
     Negative;
  -- $53 million class A-J to 'CCCsf' from 'B-sf'; RE 60%;
  -- $91.4 million class A-JFL to 'CCCsf' from 'B-sf'; RE 0%;
  -- $41.6 million class B to 'CCCsf' from 'B-sf'; RE 0%;
  -- $22 million class C to 'CCCsf' from 'B-sf'; RE 0%;
  -- $24.5 million class D to 'CCsf' from 'B-sf'; RE 0%;
  -- $14.7 million class E to 'CCsf' from 'B-sf'; RE 0%;
  -- $24.5 million class F to 'CCsf' from 'B-sf'; RE 0%;
  -- $22 million class G to 'CCsf' from 'B-sf'; RE 0%;
  -- $22 million class H to 'Csf' from 'CCCsf'; RE to 0% from
     100%;
  -- $14.7 million class J to 'Csf' from 'CCCsf'; RE to 0% from
     100%;
  -- $4.9 million class K to 'Csf' from 'CCsf'; RE to 0% from 60%.

Classes A-M, A-MFL, A-J, A-JFL, B, C, D, E, F, and G are also
removed from Rating Watch Negative.

Fitch also affirms these classes:

  -- $192.7 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $261.3 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $214.1 million class A-2FL at 'AAAsf'; Outlook Stable;
  -- $142.9 million class A-2FX at 'AAAsf'; Outlook Stable;
  -- $131.5 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $66.4 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $83 million class A-5 at 'AAAsf' Outlook Stable;
  -- $7.3 million class L at 'Csf'; RE 0%;
  -- $4.9 million class M at 'Csf'; RE 0%;
  -- $4.9 million class N at 'Csf'; RE 0%;
  -- $4.9 million class O at 'Csf'; RE 0%;
  -- $4.9 million class P at 'Csf'; RE 0%;
  -- $2 million class Q at 'Dsf'; RE 0%.

The class A-1 certificates have been paid in full.  Fitch does not
rate class S.





MYSTIC RE 2012-1: S&P Gives 'BB' Rating on Class A Notes
--------------------------------------------------------
Standard & Poor's Ratings Services assigned ratings of 'BB(sf)'
and 'B(sf)' to the Series 2012-1 Class A and Class B notes issued
by Mystic Re III Ltd. The notes cover losses from hurricanes and
earthquakes on a per-occurrence basis in the covered area.

"Our views of the transaction's credit risk reflect the
counterparty credit ratings on all of the parties involved that
can affect the timely payment of interest and the ultimate payment
of principal on the notes. Our ratings on the notes take into
account our rating on Liberty Mutual Insurance Co., which will
make quarterly premium payments to Mystic Re III; the implied
rating on the catastrophe risk ('BB' for the Class A notes and 'B'
for the Class B notes); and the rating on the assets in the
collateral account ('AAAm'). The ratings reflect the lower of
these three ratings, which for each class of notes is the implied
rating on the catastrophe risk," S&P said.

"The notes will cover losses from hurricanes and earthquakes,
including fire following, in the covered area on a per-occurrence
basis. The covered area for hurricane is the following states:
Alabama, Arkansas, Connecticut, Delaware, Florida, Georgia,
Hawaii, Illinois, Indiana, Kentucky, Louisiana, Maine, Maryland,
Massachusetts, Mississippi, Missouri, New Hampshire, New Jersey,
New York, North Carolina, Ohio, Oklahoma, Pennsylvania, Rhode
Island, South Carolina, Tennessee, Texas, Vermont, Virginia, West
Virginia, and the District of Columbia. The covered area for
earthquake is all 50 states and the District of Columbia, though
the Class A notes will not cover losses in California from
earthquakes," S&P said.

Ratings List
New Ratings
Mystic Re III Ltd.
  Series 2012-1 Class A Notes                BB(sf)
  Series 2012-1 Class B Notes                B(sf)


NAVIGATOR CDO: S&P Lowers Class D Note Rating From 'BB' to 'B+'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B, C-1, and C-2 notes from Navigator CDO 2003 Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
GE Capital Debt Advisors LLC. "Simultaneously, we removed our
ratings on these classes from CreditWatch, where we had placed
them with positive implications on Dec. 20, 2011. At the same
time, we lowered our 'BB (sf)' rating on the class D notes and
withdrew our 'AAA (sf)' ratings on the class A-3A and A-3B notes,"
S&P said.

"The upgrades reflect factors that have improved the credit
enhancement available to support the notes since we upgraded them
in June 2011. The primary factor has been the deleveraging of the
senior notes to cure failing class D interest coverage test. Since
June 2011, the transaction has paid down approximately $17 million
to class A-2 notes, $22 million to the class A-3A notes, $16
million to class A-3B and $7 million to class B notes," S&P said.

"We have also lowered our 'BB (sf)' rating on the class D notes.
The downgrade was driven by the largest obligor default test due
to the reduced par balance of the portfolio resulting in a higher
concentration of assets," S&P said.

"We withdrew our 'AAA (sf)' ratings on the class A-3A and A-3B
notes following their complete paydown on February 2012 payment
date," S&P said.

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

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

           http://standardandpoorsdisclosure-17g7.com

Rating Actions

Navigator CDO 2003 Ltd.
                        Rating
Class              To           From
A-3A               NR (sf)      AAA (sf)
A-3B               NR (sf)      AAA (sf)
B                  AAA (sf)     AA+ (sf)/Watch Pos
C-1                A (sf)       BBB (sf)/Watch Pos
C-2                A (sf)       BBB (sf)/Watch Pos
D                  B+ (sf)      BB (sf)

Transaction Information
Issuer:             Navigator CDO 2003 Ltd.
Coissuer:           Navigator CDO 2003 Corp.
Collateral manager: GE Capital Debt Advisors LLC
Underwriter:        Citigroup Inc.
Indenture trustee:  Bank of America NA
Transaction type:   Cash flow CDO


NORTHLAKE CDO: Moody's Cuts Rating on US$56-Mil. Notes to 'C'
-------------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of these notes issued by NorthLake CDO I, Limited:

  US$174,000,000 Class I-MM Floating Rate Notes Due 2033
  (current outstanding balance of 64,854,207.91), Downgraded to
  Caa3 (sf); previously on March 26, 2009 Downgraded to Caa1
  (sf);

  US$56,000,000 Class I-A Floating Rate Notes, Due 2033 (current
  outstanding balance of 49,798,697.21), Downgraded to C (sf);
  previously on March 26, 2009 Downgraded to Ca (sf).

Ratings Rationale

According to Moody's, the rating downgrade is the result of
deterioration in the credit quality of the underlying portfolio.
Such credit deterioration is observed through numerous factors,
including an increase in the WARF, an increase in the dollar
amount of defaulted securities and a decrease in the transaction's
overcollateralization ratios. Based on the latest trustee report
dated January 31, 2012, the WARF of the portfolio has increased to
1818 from 945 since the last rating action in March 2009.
Defaulted securities have increased from $36.1 million in February
2009 to $53.8 million in January 2012. Additionally, the Senior
and Mezzanine Par Value Tests are reported at 37.0% and 33.7%,
respectively, versus February 2009 levels of 72.2% and 67.8%,
respectively.

NorthLake CDO I, Limited, issued in February 2003, is a
collateralized debt obligation backed primarily by a portfolio of
RMBS, CMBS and Corporate CDOs originated from 2001 to 2006.

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

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.8 to model the loss distribution for SF CDOs. Within this
framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference.
Specifically, correlated defaults are simulated using a normal (or
"Gaussian") copula model that applies the asset correlation
framework. Recovery rates for defaulted credits are generated by
applying within the simulation the distributional assumptions,
including correlation between recovery values. Together, the
simulated defaults and recoveries across each of the Monte Carlo
scenarios define the loss distribution for the reference pool.

Once the loss distribution for the collateral has been calculated,
each collateral loss scenario derived through the CDOROM loss
distribution is associated with the interest and principal
received by the rated liability classes via the CDOEdge cash-flow
model. The cash flow model takes into account the following:
collateral cash flows, the transaction covenants, the priority of
payments (waterfall) for interest and principal proceeds received
from portfolio assets, reinvestment assumptions, the timing of
defaults, interest-rate scenarios and foreign exchange risk (if
present). The Expected Loss (EL) for each tranche is the weighted
average of losses to each tranche across all the scenarios, where
the weight is the likelihood of the scenario occurring. Moody's
defines the loss as the shortfall in the present value of cash
flows to the tranche relative to the present value of the promised
cash flows. The present values are calculated using the promised
tranche coupon rate as the discount rate. For floating rate
tranches, the discount rate is based on the promised spread over
Libor and the assumed Libor scenario.

Moody's notes that in arriving at its ratings of SF CDOs, there
exist a number of sources of uncertainty, operating both on a
macro level and on a transaction-specific level. Primary sources
of assumption uncertainty are the extent of the slowdown in growth
in the current macroeconomic environment and the commercial and
residential 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. Among the uncertainties in the residential
real estate property market are those surrounding future housing
prices, pace of residential mortgage foreclosures, loan
modification and refinancing, unemployment rate and interest
rates.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios, discussed below. Results are shown in terms
of the number of notches' difference versus the current model
output, where a positive difference corresponds to lower expected
loss, assuming that all other factors are held equal:

Moody's Caa Assets notched up by 2 rating notches:

  Class IMM: 0
  Class I-A: 0

Moody's Caa Assets notched down by 2 rating notches:

  Class IMM: -1
  Class I-A: 0


OCP CLO: S&P Gives 'BB' Rating on Class D Deferrable Notes
----------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to OCP CLO 2012-1 Ltd./OCP CLO 2012-1 Corp.'s
$294.6 million floating-rate notes.

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

The preliminary rating is based on information as of March 1,
2012.

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
   preference shares.

* 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.

* 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 portfolio 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
   0.34%-11.36%," S&P said.

* 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.

* The transaction's reinvestment overcollateralization test, a
   failure of which will lead to the reclassification of excess
   interest proceeds, that are available prior to paying uncapped
   administrative expenses and fees; portfolio manager incentive
   fees; and preference share payments, to principal proceeds for
   the purchase of additional collateral assets during the
   reinvestment period.

           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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

      http://standardandpoorsdisclosure-17g7.com

Preliminary Ratings Assigned
OCP CLO 2012-1 Ltd./OCP CLO 2012-1 Corp.


Class                Rating             Amount
                                      (mil. $)
A-1                  AAA (sf)            217.5
A-2                  AA (sf)              16.5
B (deferrable)       A (sf)               26.5
C (deferrable)       BBB (sf)             17.3
D (deferrable)       BB (sf)              16.8
Preference shares    NR                   32.2


ONE WALL STREET: S&P Raises Rating on Class E Notes to 'CCC+'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised and removed from
CreditWatch positive its ratings on six classes of notes from
One Wall Street CLO II Ltd., a reinvesting collateralized loan
obligation (CLO) transaction managed by Alcentra Ltd.

"The upgrades reflect positive rating migration in the underlying
portfolio since we lowered our ratings on the notes in February
2010. As of the January 2012 trustee report, the balance of
defaulted assets decreased to $2.71 million from $19.42 million in
December 2009, while the overcollateralization (O/C) haircut
amount fell to $2.60 million from $15.88 million. This has led
to an increase in the senior O/C test to 116.25% from 114.81%
during the same period," S&P said.

"The class D and E notes were previously constrained by the
largest obligor default test. This is a supplemental stress test
that was introduced as part of the 2009 corporate criteria update,
at 'CCC+ (sf)' and 'CCC- (sf)'. This is no longer the case," S&P
said.

"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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

           http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

One Wall Street CLO II Ltd.

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




PREFERRED TERM XXII: Moody's Ups Rating on US$201MM Notes to Ba1
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Preferred Term Securities XXII, Ltd.:

US$762,500,000 Floating Rate Class A-1 Senior Notes Due
September 22, 2036 (current outstanding balance
$603,002,927.13), Upgraded to A3 (sf); previously on April 29,
2011 Downgraded to Ba1 (sf);

US$201,800,000 Floating Rate Class A-2 Senior Notes Due
September 22, 2036 (current outstanding balance
$196,866,697.09), Upgraded to Ba1 (sf); previously on April 29,
2011 Downgraded to B1 (sf).

Ratings Rationale

According to Moody's, the rating actions taken are primarily the
result of deleveraging of the Class A-1 Notes and an increase in
the transaction's overcollateralization ratios since the last
rating action in April 2011.

Moody's notes that the Class A-1 Notes have been paid down by
approximately 14% or $100 million since the last rating action, as
a result of diversion of excess interest proceeds and disbursement
of principal proceeds from redemptions of underlying assets. As a
result of this deleveraging, the Class A-1 Notes' par coverage
improved by 7.4 % since the last rating action. Based on the
latest trustee report dated December 22, 2011, the Senior Coverage
Test is at 113.17% (limit 128%) and the Class B Mezzanine Coverage
Test is at 95.12% (limit 115%) versus March 2011 levels of 105.78%
and 90.64% respectively. Going forward, the Class A-1 Notes will
continue to benefit from the diversion of excess interest and
diversion of principal proceeds due to continued failure of the
Senior Principal Coverage Test.

The Moody's cumulative assumed defaulted amount has declined to
$401.5 million from $504.5 million as of the last rating action.
The decline is due to improvement in the credit quality and the
financial ratios of the banks that issued three of the assets that
were assumed to be defaulted in the last rating action and assets
redemptions at par, total balance of $75 million.

Due to the impact of revised and updated key assumptions
referenced in Moody's rating methodology, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers. In its
base case, Moody's analyzed the underlying collateral pool to have
a performing par of $900.1 million , defaulted/deferring par of
$401.5 million, a weighted average default probability of 24.89%
(implying a WARF of 1065), Moody's Asset Correlation of 21.08%,
and a weighted average recovery rate upon default of 7.6%. In
addition to the quantitative factors that are explicitly modeled,
qualitative factors are part of rating committee considerations.
Moody's considers the structural protections in the transaction,
the risk of triggering an Event of Default, recent deal
performance under current market conditions, the legal
environment, and specific documentation features. All information
available to rating committees, including macroeconomic forecasts,
inputs from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, may influence the final rating decision.

Preferred Term Securities XXII, Ltd, issued on June 15, 2006, is a
collateralalized debt obligation backed by a portfolio of bank and
insurance trust preferred securities (the 'TruPS CDO').

The portfolio of this CDO is mainly comprised of trust preferred
securities (TruPS) issued by small to medium sized U.S. community
banks and insurance companies that are generally not publicly
rated by Moody's. To evaluate the credit quality of bank TruPS
without public ratings, Moody's uses RiskCalc model, an
econometric model developed by Moody's KMV, to derive their credit
scores. Moody's evaluation of the credit risk for a majority of
bank obligors in the pool relies on FDIC financial data received
as of Q3-2011. For insurance TruPS without public ratings, Moody's
relies on the insurance team and the underlying insurance firms'
annual financial reporting to assess their credit quality. Moody's
also evaluates the sensitivity of the rated transaction to the
volatility of the credit estimates, as described in Moody's Rating
Implementation Guidance "Updated Approach to the Usage of Credit
Estimates in Rated Transactions" published in October 2009.

The principal methodology used in this rating was "Moody's
Approach to Rating TRUP CDOs" published in May 2011.

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

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. We analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased by 135 points from the
base case of 1065, the model-implied rating of the Class A-1 Notes
is one notch worse than the base case result. Similarly, if the
WARF is decreased by 150 points, the model-implied rating of the
Class A-1 Notes is one notch better than the base case result.

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as the agency's outlook on the banking
sector remains negative, although there have been some recent
signs of stabilization. The pace of FDIC bank failures continues
to decline in 2012 compared to 2011, 2010 and 2009, and some of
the previously deferring banks have resumed interest payment on
their trust preferred securities.  Moody's outlook on the
insurance sector is stable.


RENTAL CAR: S&P Affirms 'BB' Rating on Class A Notes Series 2007-1
------------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its 'BB (sf)' rating
on Rental Car Finance Corp.'s class A rental car asset-backed
notes series 2007-1. The issuer is a special-purpose wholly owned
subsidiary of Dollar Thrifty Automotive Group Inc. (B+/Stable).

"The rating affirmation reflects our opinion that the credit
enhancement available to the class A notes is sufficient to
support the transaction at its current rating level," S&P said.

The series 2007-1 notes are expected to be redeemed on the July
2012 payment date.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

          http://standardandpoorsdisclosure-17g7.com


STRUCTURED RECEIVABLES: S&P Assumes 'CCC-' Unrated Carriers Rating
------------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on the
class A and B notes from Structured Receivables Finance 2010-A
LLC. Structured Receivables Finance 2010-A LLC is a U.S.
securitization backed by structured settlement payments.

"Structured settlement payments are payments resulting from an
arrangement between a claimant (for example, a plaintiff that has
settled a personal injury lawsuit) and a defendant and/or the
defendant's liability insurer that are typically structured as
installment payments to satisfy the settlement. The defendant
generally arranges to discharge its payment obligation to the
claimant by assigning the obligation to a settlement counterparty.
The settlement counterparty then typically funds the obligation to
make the agreed-upon payments by purchasing an annuity contract
from an annuity provider," S&P said.

"Because the ultimate source of structured settlement payments
originates at insurance companies, Standard & Poor's must address
the risk of a pool of payments from these companies," S&P said.
The is an explanation of S&P's gross default stress assumptions:

* "We base our analysis of gross defaults for the pool on the
   output from Standard & Poor's CDO Evaluator and the results of
   two supplemental tests. The default rates are affected by
   industry correlation and affiliations among the annuity
   providers. If there is common ownership among rated carriers,
   we can further consolidate the portfolio," S&P said.

* "We use our existing corporate credit ratings and public
   ratings in our analysis and assume a 'CCC-' rating for carriers
   that Standard & Poor's doesn't rate," S&P said.

* "Although we have observed higher actual levels of recovery in
   the structured settlement sector, under a stress scenario, we
   assume a 50% immediate recovery rate for the largest-obligor
   test and a 60% immediate recovery rate for the largest-industry
   test. We assume a 70% recovery when we conduct the cash flow
   analysis to test the scenario default rates generated by CDO
   Evaluator," S&P said.

"The affirmations reflect the presence of sufficient credit
support to maintain the current ratings even though lowered
corporate obligor credit ratings in the collateral pool have
outnumbered raised ratings since the securitization was
originated. The credit support for these transactions is provided
by overcollateralization, a cash reserve account, and
subordination for the higher-rated tranches. The transaction
continues to build overcollateralization over time as payments are
made to the notes," 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.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

         http://standardandpoorsdisclosure-17g7.com

Ratings Affirmed

Structured Receivables Finance 2010-A LLC

Class     Rating
A         AAA (sf)
B         A (sf)


TEXAS WESLEYAN: Moody's Withdraws 'Ba2' Rating on Revenue Bonds
---------------------------------------------------------------
Moody's Investors Service has withdrawn the Ba2 rating on
Texas Wesleyan University's (TX) Revenue Bonds, Series 1997A which
were issued through the Fort Worth Higher Education Finance
Corporation.  The rating withdrawal follows the redemption of
these bonds.  At this time, Texas Wesleyan University no longer
maintains debt outstanding with a Moody's rating based on its own
credit quality.


TROPIC CDO: Moody's Cuts Rating on US$50MM Notes to 'B1'
--------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings on these notes issued by Tropic CDO II, Ltd.:

US$145,000,000 Class A-1L Floating Rate Notes Due April 2034
(current balance of $109,817,388), Downgraded to Baa3 (sf);
previously on October 30, 2009 Downgraded to Baa2 (sf);

US$50,000,000 Class A-2L Floating Rate Notes Due April 2034
(current balance of $50,000,000), Downgraded to B1 (sf);
previously on March 27, 2009 Downgraded to Ba2 (sf).

Ratings Rationale

According to Moody's, the rating downgrade actions taken are
primarily the result of the par loss due to an increase in the
defaulted amount in the underlying portfolio which has resulted in
loss of overcollateralization for the Class A-1L and A-2L Notes
since the rating action in October 2009.

Moody's notes that the assumed defaulted amount increased to
$152.57 million from $115.0 million since the rating action in
October 2009. Based on the latest trustee report dated January
2012, the Senior Overcollateralization Ratio and the Subordinate
Overcollateralization Ratio are reported at 88.6% (limit 120.00%)
and 62.17% (limit 104.00%), respectively, versus October 2009
trustee reported levels of 106.68% and 76.23%.

Due to the impact of revised and updated key assumptions
referenced in Moody's rating methodology, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers. In its
base case, Moody's analyzed the underlying collateral pool to have
a performing par of $160.6 million, defaulted/deferring par of
$152.6 million, a weighted average default probability of 29.5%
(implying a WARF of 1549), Moody's Asset Correlation of 16.73%,
and a weighted average recovery rate upon default of 10%. In
addition to the quantitative factors that are explicitly modeled,
qualitative factors are part of rating committee considerations.
Moody's considers the structural protections in the transaction,
the risk of triggering an Event of Default, recent deal
performance under current market conditions, the legal
environment, and specific documentation features. All information
available to rating committees, including macroeconomic forecasts,
inputs from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, may influence the final rating decision.

Tropic CDO II, Ltd., issued on October 15, 2003, is a collateral
debt obligation backed by a portfolio of bank trust preferred
securities.

The portfolio of this CDO is mainly comprised of trust preferred
securities (TruPS) issued by small to medium sized U.S. community
banks and insurance companies that are generally not publicly
rated by Moody's. To evaluate the credit quality of bank TruPS
without public ratings, Moody's uses RiskCalc model, an
econometric model developed by Moody's KMV, to derive their credit
scores. Moody's evaluation of the credit risk for a majority of
bank obligors in the pool relies on FDIC financial data received
as of Q3-2011. Moody's also evaluates the sensitivity of the rated
transaction to the volatility of the credit estimates, as
described in Moody's Rating Implementation Guidance "Updated
Approach to the Usage of Credit Estimates in Rated Transactions"
published in October 2009.

The principal methodology used in this rating was "Moody's
Approach to Rating TRUP CDOs" published in May 2011.

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

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. Moody's analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased by 200 points from the
base case of 1549, the model-implied rating of the Class A-1 notes
is one notch worse than the base case result. Similarly, if the
WARF is decreased by 200 points, the model-implied rating of the
Class A-1 notes is one notch better than the base case result.

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as Moody's outlook on the banking
sector remains negative, although there have been some recent
signs of stabilization. The pace of FDIC bank failures continues
to decline in 2012 compared to 2011, 2010 and 2009, and some of
the previously deferring banks have resumed interest payment on
their trust preferred securities.


VENTURE II 2002: S&P Affirms 'CCC-' Rating on Class C Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-2 and B notes from Venture II CDO 2002 Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by MJX
Asset Management LLC. We also affirmed our ratings on the class A-
1 and C notes. "At the same time, we removed the class A-2, B, and
C ratings from CreditWatch, where we had placed them with positive
implications on Dec. 20, 2011," S&P said.

"The upgrades reflect the principal paydown on the class A-1
notes and the improved performance we have observed in the
deal's underlying asset portfolio since our Jan. 26, 2011
rating actions. The class A-1 notes have paid down approximately
$63.67 million since their last upgrade. As of the Feb. 7,
2012 trustee report, the transaction's asset portfolio had
$8.38 million in defaulted obligations, compared with the
$9.89 million noted in the Jan. 5, 2011 trustee report, which
we used for our January 2011 rating actions," S&P said.

"We also observed an increase in the overcollateralization (O/C)
available to support the rated notes," S&P said. The trustee
reported the O/C ratios in the Feb. 7, 2012 monthly report:

* The class A O/C ratio was 160.80%, compared with a reported
   ratio of 124.12% in January 2011;

* The class B O/C ratio was 134.09%, compared with a reported
   ratio of 114.64% in January 2011; and

* The class C O/C ratio was 109.36%, compared with a reported
   ratio of 103.84% in January 2011.

"The affirmation of class A-1 reflects our opinion that the credit
support available to the class A-1 notes is commensurate with the
'AAA (sf)' rating," S&P said.

"The affirmation of the class C notes at 'CCC- (sf)' partly
reflects that the transaction has approximately $12.34 million
(17.46%) in underlying collateral that matures after the legal
final maturity of the transaction," S&P said.

"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," S&P said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

         http://standardandpoorsdisclosure-17g7.com

Rating And Creditwatch Actions

Venture II CDO 2002 Ltd.
                       Rating
Class              To          From
A-2                AAA (sf)    A+ (sf)/Watch Pos
B                  A+ (sf)     BBB (sf)/Watch Pos
C                  CCC- (sf)   CCC- (sf)/Watch Pos

Rating Affirmed

Venture II CDO 2002 Ltd.
Class              Rating
A-1                AAA (sf)


WACHOVIA BANK 2007-C33: S&P Cuts Ratings on 6 Cert. Classes to 'D'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage pass-through certificates from
Wachovia Bank Commercial Mortgage Trust's series 2007-C33, a
U.S. commercial mortgage-backed securities (CMBS) transaction.
"Concurrently, we affirmed our ratings on nine other classes from
the same transaction," S&P said.

"Our rating actions follow our analysis of the credit
characteristics of the collateral remaining in the pool, the
deal structure, and the liquidity available to the trust. The
downgrades reflect credit support erosion that we anticipate will
occur upon the eventual resolution of 12 ($365.7 million, 10.4%)
of the 16 assets ($832.0 million, 23.7%) that are with the special
servicer. We also considered the monthly interest shortfalls that
are affecting the trust. We lowered our ratings on the class D, E,
F, G, H, and J certificates to 'D (sf)' because we 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 IO interest-only (IO) certificate based
on our current criteria," S&P said.

"Using servicer-provided financial information, we calculated an
adjusted debt service coverage (DSC) of 1.25x and a loan-to-value
(LTV) ratio of 127.3%. We further stressed the loans' cash flows
under our 'AAA' scenario to yield a weighted average DSC of 0.71x
and an LTV ratio of 188.5%. The implied defaults and loss severity
under the 'AAA' scenario were 92.3% and 48.8%. The DSC and LTV
calculations noted above exclude 12 ($365.7 million, 10.4%) of
the 16 assets ($832.0 million, 23.7%) that are with the special
servicer and two defeased loans ($28.8 million, 0.8%). We
separately estimated losses for the specially serviced assets and
included them in our 'AAA' scenario implied default and loss
severity figures," S&P said.

"As of the Feb. 17, 2012 trustee remittance report, the trust
experienced monthly interest shortfalls totaling $1,596,353.
These shortfalls were primarily related to appraisal subordinate
entitlement reduction (ASER) amounts of $259,690 (which included a
pay back of $65,568 related to a loan liquidation), interest rate
modifications of $1,015,120, and special servicing and workout
fees of $286,069. The interest shortfalls affected all classes
subordinate to and including class D. Classes D through J
experienced cumulative interest shortfalls between one and two
months, and we expect these interest shortfalls to continue for
the foreseeable future. Consequently, we downgraded these classes
to 'D (sf)'," S&P said.

                      Credit Considerations

"As of the Feb. 17, 2012 trustee remittance report, 16 assets
($832.0 million, 23.7%) in the pool were with the special
servicer, LNR Partners LLC (LNR)," S&P said.

"The 666 Fifth Avenue asset, with a pooled balance of
$285.5 million (8.2%) and whole loan balance of $1.2 billion, was
modified on Dec. 15, 2011, and now comprises two A notes and two
B notes. Two other assets, 110 East 42nd Street ($83.1 million,
2.4%) and Loudon Gateway IV ($13.7 million, 0.4%), were also
modified and are bifurcated into one A note and one B note each.
The reported payment status of the specially serviced assets as
of the most recent trustee remittance report is: six are real
estate owned (REO) ($99.8 million, 2.8%), one is in foreclosure
($14.5 million, 0.4%), three are 90-plus-days delinquent
($29.4 million, 0.8%), one is 30 days delinquent ($89.0 million,
2.5%), four are late but less than 30 days delinquent
($290.4 million, 8.3%), and one is current ($285.5 million,
8.2%). Appraisal reduction amounts (ARAs) totaling $119.5 million
are in effect against 12 of the 16 specially serviced assets.
Details of the five largest specially serviced assets, all of
which are top 10 assets, are as set forth," S&P said.

"The 666 Fifth Avenue loan, with a trust balance of $285.5 million
(8.2%) and a whole-loan balance of $1.2 billion, is the largest
loan in the pool and the largest specially serviced asset. The
total reported exposure was $285.5 million. The loan is secured by
a 39-story, 1.5 million-sq.-ft. class A office building in Midtown
Manhattan on Fifth Avenue between West 52nd and West 53rd streets.
The loan was transferred to the special servicer on March 3, 2010,
because the borrower requested a restructuring of the loan due to
declining financial performance of the asset. A loan modification,
which closed on Dec. 15, 2011, bifurcated the whole loan into a
$1.1 billion A note and $115.0 million B note and extended the
maturity by two years to Feb. 5, 2019. In addition, interest on
the A note accrues at a rate of 6.353%, but is paid at 3% during
the first year, 4% the second year, and then increases 0.5%
annually thereafter with the unpaid accrual added to the B note.
The B note accrues at the original rate of 6.353% with no current
pay. This pool contains two A notes, each totaling $129.2 million,
and two B notes, each totaling $13.5 million. The most recent
reported DSC and occupancy were 0.49x and 78.0% as of Dec. 31,
2010. As of the Feb. 17, 2012, remittance report, the payment
status of the loan was reported as current," S&P said.

"The Three Borough Pool loan ($133.0 million, 3.8%) is the
seventh-largest loan in the pool and the second-largest specially
serviced asset. The total reported exposure was $133.6 million.
The loan is secured the by the fee interest in 1,646 multifamily
units and 24 commercial units across 42 apartment buildings in
Manhattan, the Bronx, and Brooklyn. The buildings were developed
between 1910 and 1969 and are composed of a mix of elevator and
walk-up buildings. Each building contains between 17 and 220
apartment units. At issuance, 1,282 of the units were rent
stabilized, 320 were Section 8, 29 were rent controlled, and 15
were vacant. At the time of loan origination, we expected the
subsidized units would be converted to market-rate units. The
loan's reported DSC has been adversely affected to date because
the subsidized units have not been converted to market-rate units.
The loan was transferred to the special servicer on Sept. 13,
2010, for imminent default. Per the Feb. 17, 2012 remittance
report, the payment status of the loan is late but less than 30
days delinquent. According to the special servicer, various
water/sewer and accounts payable remain outstanding, in addition
to $1.6 million in liens filed against the collateral. There is
currently no recent financial data for this loan. We expect a
moderate loss upon the eventual resolution of this loan," S&P
said.

"The Central/Eastern Industrial Pool loan ($89.0 million, 2.5%) is
the eighth-largest loan in the pool and third-largest specially
serviced asset. The total reported exposure was $89.0 million. The
loan is secured by 13 industrial properties throughout the U.S.
Based on the Feb. 17, 2012 remittance report, the loan is 30 days
delinquent. At origination, all of the locations were leased under
absolute triple-net leases. The tenant has abandoned or vacated
the premises at two locations and rejected the leases. A tenant at
a third property abandoned 50% of the leased property," S&P said.

"The loan was transferred to the special servicer on July 23,
2010, due to imminent default. There is currently no recent
financial data for this loan. Based on the Feb. 17, 2012,
remittance report, the payment status of this loan is late but
less than 30 days delinquent. We expect a moderate loss upon the
eventual resolution of the asset," S&P said.

"The Renaissance loan is the ninth-largest loan in the pool and
the fourth-largest with the special servicer. The whole loan
consists of an $84.0 million senior A note that is included in the
trust and a $9.0 million B note held outside of the trust. The
loan is secured by a 221-unit residential condominium complex on
floors 14 to 34 of a 34-story mixed-use building in lower
Manhattan on John Street, just west of Pearl Street. The lower
floors consist of office and retail space. The property was built
in 1931 and renovated in 1999. The loan was transferred to the
special servicer on March 4, 2010. There is currently no recent
financial data for this loan. An ARA of $22.4 million is in effect
against this asset. Based on the Feb. 17, 2012, remittance report,
the payment status of this loan is late but less than 30 days
delinquent and it has been returned to the master servicerm," S&P
said.

"The 110 East 42nd Street loan is the 10th-largest loan in the
pool and the fifth-largest with the special servicer. It has a
$83.1 million (2.4%) trust and whole loan balance. In addition,
there is a $16.0 million mezzanine loan secured by the equity
interests in the borrower. The loan is secured by a 20-story,
190,691-sq.-ft. masonry office building built in 1921 on 42nd
Street across from Grand Central Terminal in Midtown Manhattan.
The collateral comprises floors six through 18 above a ground-
level restaurant, Cipriani, and condominium units. The loan was
transferred to the special servicer on July 21, 2010, for imminent
default. The loan was modified on June 24, 2011, and the original
$90 million loan was bifurcated into a $65 million A note and an
$18 million B note. The letter of credit was used to pay down the
loan by $6.9 million. The mezzanine lender assumed the loan and
provided $20 million of additional equity. Based on the Feb. 17,
2012, remittance report, the payment status of this loan is late
less than 30 days delinquent. An ARA of $20.8 million is in effect
against this asset," S&P said.

"The 11 remaining assets with the special servicer have individual
balances that represent less than 1.2% of the total pooled trust
balance. ARAs totaling $76.3 million are in effect against 10 of
these assets. We estimated losses for 10 of the 11 remaining
assets, arriving at a weighted-average loss severity of 51.8%,"
S&P said.

Eight loans totaling $83.6 million (2.3%) that were previously
with the special servicer have been returned to the master
servicer. According to the transaction documents, the special
servicer is entitled to a workout fee equal to 1.0% of all future
principal and interest payments on the corrected loans, provided
that they continue to perform and remain with the master servicer.

                      Transaction Summary

As of the Feb. 17, 2012 trustee remittance report, the collateral
pool had an aggregate trust balance of $3.51 billion, down from
$3.60 billion at issuance. The pool comprises 147 loans and six
REO assets, down from 166 loans at issuance. The master servicer,
Wells Fargo Bank N.A., provided financial information for 85.0% of
the loans in the pool (by balance), most of which reflected data
for full-year 2011 and the nine months ended Sept. 30, 2011.

"We calculated a weighted average DSC of 1.25x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV were 1.25x and 127.3%. Our adjusted figures exclude 12
($365.7 million, 10.4%) of the 16 assets ($832.0 million, 23.7%)
that are with the special servicer, and two defeased loans
($28.8 million, 0.8%). To date, the transaction has experienced
$34.2 million in principal losses from 11 assets. Forty-two loans
($451.8 million, 12.9%) in the pool are on the master servicer's
watchlist, none of which are top 10 assets. Forty-one loans
($764.5 million, 21.8%) have a reported DSC of less than 1.10x, 24
of which ($543.5 million, 15.5%) have a reported DSC of less than
1.00x," S&P said.

                      Summary of Top 10 Assets

"The top 10 assets have an aggregate outstanding pooled balance of
$1.85 billion (52.8%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.15x for five of the top 10
assets. The remaining five top 10 assets ($674.6 million, 19.3%)
are with the special servicer. Our adjusted DSC and LTV were 1.21x
and 134.5% for five of the top 10 assets, excluding the five
specially serviced assets. The second-largest loan in the pool,
the ING Hospitality Pool loan is a near-term maturing loan with
a trust balance of $283.9 million and whole loan balance of
$567.7 million. The loan is secured by 46 limited-service
Residence Inns and Homewood Suites located throughout the U.S.
The loan is interest only with a June 11, 2012 maturity date.
The reported DSC was 1.23x as of year-end 2012 and combined
occupancy was 74.8% as of Sept, 9, 2011," S&P said.

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

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

         http://standardandpoorsdisclosure-17g7.com

Ratings Lowered

Wachovia Bank Commercial Mortgage Trust's Series 2007-C33
Commercial mortgage pass-through certificates
             Rating
Class     To         From         Credit enhancement (%)
B         B (sf)     B+ (sf)                       11.46
C         CCC (sf)   B (sf)                        10.31
D         D (sf)     B (sf)                         9.28
E         D (sf)     B (sf)                         8.39
F         D (sf)     B- (sf)                        7.62
G         D (sf)     B- (sf)                        6.59
H         D (sf)     B- (sf)                        5.44
J         D (sf)     CCC+ (sf)                      4.03

Ratings Affirmed

Wachovia Bank Commercial Mortgage Trust's Series 2007-C33
Commercial mortgage pass-through certificates
Class     Rating    Credit enhancement (%)
A-2       AAA (sf)                   29.80
A-3       AAA (sf)                   29.80
A-PB      AAA (sf)                   29.80
A-4       BBB (sf)                   29.80
A-5       BBB (sf)                   29.80
A-1A      BBB (sf)                   29.80
A-M       BB (sf)                    19.54
A-J       B+ (sf)                    12.49
IO        AAA (sf)                     N/A

N/A -- Not applicable.


WAMU 2006-SL1: S&P Lowers Rating on Class H Certificates to 'D'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
from 'CCC- (sf)' on the class H commercial mortgage pass-through
certificates from WaMu Commercial Mortgage Securities Trust 2006-
SL1, a U.S. commercial mortgage-backed securities (CMBS)
transaction.

"We downgraded class H to 'D (sf)' to reflect a principal loss due
to a loan liquidation of $537,766. The trust incurred a total loss
of $546,369, as reflected in the Feb. 23, 2012, trustee remittance
report. Consequently, class H sustained a 16% loss to its
beginning balance of $2.6 million. The class J certificates, which
we previously lowered to 'D (sf)', lost 100% of its $138,459
beginning balance," S&P said.

"As of the Feb. 23, 2012 trustee remittance report, the collateral
pool consisted of 375 assets with an aggregate trust balance of
$395.1 million, down from 443 loans totaling $511.4 million at
issuance. To date, the trust has experienced losses totaling
$17 million from 23 assets," S&P said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Reports
included in this credit rating report are available at:

          http://standardandpoorsdisclosure-17g7.com


WASHINGTON MUTUAL: Moody's Affirms 'C' Rating on 4 Note Classes
---------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 13 classes of
Washington Mutual Commercial Mortgage Pass-Through Certificates,
Series 2007-SL2:

Cl. A, Affirmed at A1 (sf); previously on Feb 25, 2010
Downgraded to A1 (sf)

Cl. A-1A, Affirmed at A1 (sf); previously on Feb 25, 2010
Downgraded to A1 (sf)

Cl. B, Affirmed at Baa1 (sf); previously on Feb 25, 2010
Downgraded to Baa1 (sf)

Cl. C, Affirmed at Ba1 (sf); previously on Feb 25, 2010
Downgraded to Ba1 (sf)

Cl. D, Affirmed at B1 (sf); previously on Feb 25, 2010
Downgraded to B1 (sf)

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

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

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

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

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

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

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

Cl. X, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (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. Based on our
current base expected loss, the credit enhancement levels for the
affirmed classes are sufficient to maintain their current ratings.

This transaction is classified as a small balance CMBS
transaction. Small balance transactions, which represent
approximately 1% of the Moody's rated conduit/fusion universe,
have generally experienced higher defaults and losses than
traditional conduit and fusion transaction.

Moody's rating action reflects a cumulative base expected loss of
5.8% of the current balance. At last review, Moody's cumulative
base expected loss was 6.0%. Moody's provides a current list of
base expected losses for conduit and fusion CMBS transactions on
moodys.com at:

  http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.

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 extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

The principal methodologies used in this rating were CMBS:
"Moody's Approach to Rating Conduit Transactions", published in
September 2000 and CMBS: "Moody's Approach to Small Loan
Transactions" published in December 2004. Other methodologies used
include Moody's Approach to Rating Structured Finance Interest-
Only Securities published on February 22, 2012.

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 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
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 review also incorporated the CMBS IO calculator ver 1.0,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point . For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

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 268 compared to 230 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 a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated
March 2, 2011.

DEAL PERFORMANCE

As of the February 27, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 24%
to $640.4 million from $842.1 million at securitization. The
Certificates are collateralized by 541 mortgage loans ranging in
size from less than 1% to 2% of the pool, with the top ten loans
representing 11% of the pool. The pool is characterized by both
geographic and property type concentrations. Approximately 64% of
the pool is located in California and 70% of the pool is secured
by multi-family properties.

One hundred-forty six loans, representing 30% of the pool, are on
the master servicer's watchlist. The watchlist includes loans
which meet certain portfolio review guidelines established as part
of the CRE Finance Council (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.

Twenty-six loans have been liquidated from the pool since
securitization, resulting in an aggregate $17.4 million loss
(48% loss severity on average). Currently, there are 29 loans,
representing 4.2% of the pool in special servicing. Of the
$7.3 million in appraisal reductions, the master servicer has
recognized a $6.9 million for the loans in special servicing.
Moody's has estimated an aggregate $10.0 million loss (50%
expected loss on average) for the specially serviced loans.
Moody's has also assumed a high default probability for 63 poorly
performing loans, representing 13.5% of the pool, and has
estimated an aggregate $12.9 million loss (15% expected loss based
on a 50% probability default) for the troubled loans.
Moody's was provided with full year 2009 and 2010 operating
results for 95% and 89%, respectively, of the pool. Excluding
specially serviced and troubled loans, Moody's weighted average
LTV is 100% compared to 101% 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 9.3%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.27X and 1.09X, respectively, compared to
1.29X and 1.01X 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.


WASHINGTON MUTUAL: Moody's Affirms Rating on 3 Note Classes at C
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 16 classes of
Washington Mutual Commercial Mortgage Pass-Through Certificates,
Series 2007-SL3:

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

Cl. A-1A, Affirmed at Aaa (sf); previously on Mar 9, 2011
Confirmed at Aaa (sf)

Cl. A-J, Affirmed at A1 (sf); previously on Feb 25, 2010
Downgraded to A1 (sf)

Cl. B, Affirmed at A3 (sf); previously on Feb 25, 2010
Downgraded to A3 (sf)

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

Cl. D, Affirmed at Ba1 (sf); previously on Feb 25, 2010
Downgraded to Ba1 (sf)

Cl. E, Affirmed at Ba2 (sf); previously on Feb 25, 2010
Downgraded to Ba2 (sf)

Cl. F, Affirmed at B2 (sf); previously on Feb 25, 2010
Downgraded to B2 (sf)

Cl. G, Affirmed at B3 (sf); previously on Feb 25, 2010
Downgraded to B3 (sf)

Cl. H, Affirmed at Caa2 (sf); previously on Feb 25, 2010
Downgraded to Caa2 (sf)

Cl. J, Affirmed at Caa3 (sf); previously on Feb 25, 2010
Downgraded to Caa3 (sf)

Cl. K, Affirmed at Ca (sf); previously on Feb 25, 2010
Downgraded to Ca (sf)

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

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

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

Cl. X, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (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. Based on our
current base expected loss, the credit enhancement levels for the
affirmed classes are sufficient to maintain their current ratings.

This transaction is classified as a small balance CMBS
transaction. Small balance transactions, which represent
approximately 1% of the Moody's rated conduit/fusion universe,
have generally experienced higher defaults and losses than
traditional conduit and fusion transaction.

Moody's rating action reflects a cumulative base expected loss of
5.4% of the current balance. At last review, Moody's cumulative
base expected loss was 6.4%. Moody's provides a current list of
base expected losses for conduit and fusion CMBS transactions on
moodys.com at:

  http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels.

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 extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster Holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

The principal methodologies used in this rating were CMBS:
"Moody's Approach to Rating Conduit Transactions", published on
September 15, 2000 and CMBS: "Moody's Approach to Small Loan
Transactions" published in December 2004. Other methodologies
included Moody's Approach to Rating Structured Finance Interest-
Only Securities published on February 22, 2012.

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 review also incorporated the CMBS IO calculator ver 1.0,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point . For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

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 315 compared to 323 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 a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated March 2, 2011.

Deal Performance

As of the February 27, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 20%
to $1.02 billion from $1.28 billion at securitization. The
Certificates are collateralized by 766 mortgage loans ranging in
size from less than 1% to 2% of the pool, with the top ten loans
representing 10% of the pool. The pool is characterized by both
geographic and property type concentration. Approximately 68% of
the pool is located in California and the 48% of the pool is
secured by multi-family properties.

Two-hundred-twenty three loans, representing 30% of the pool, are
on the master servicer's watchlist. The watchlist includes loans
which meet certain portfolio review guidelines established as part
of the CRE Finance Council (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.

Forty-seven loans have been liquidated from the pool since
securitization, resulting in an aggregate $26.9 million loss (42%
loss severity on average). Currently, there are 32 loans,
representing 4% of the pool in special servicing. The master
servicer has recognized an aggregate $9.7 million for the loans in
special servicing. Moody's has estimated an aggregate
$15.9 million loss (42% expected loss on average) for the
specially serviced loans. Moody's has also assumed a high default
probability for 87 poorly performing loans, representing 12% of
the pool, and has estimated an aggregate $18.0 million loss (15%
expected loss based on a 50% probability default) for the troubled
loans.

Moody's was provided with full year 2010 operating results for
95%, respectively, of the pool. Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 102% compared to
104% 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 9.3%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.31X and 1.12X, respectively, compared to
1.31X 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.


WBMCT 2005-C20: Moody's Affirms Rating on Class H Certs. at C
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 17 classes of
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-
Through Certificates, Series 2005-C20:

Cl. A-6A, Affirmed at Aaa (sf); previously on Sep 8, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-6B, Affirmed at Aaa (sf); previously on Sep 8, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-PB, Affirmed at Aaa (sf); previously on Sep 8, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-7, Affirmed at Aaa (sf); previously on Sep 8, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Sep 8, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-MFL, Affirmed at Aa1 (sf); previously on Sep 9, 2010
Downgraded to Aa1 (sf)

Cl. A-MFX, Affirmed at Aa1 (sf); previously on Sep 9, 2010
Downgraded to Aa1 (sf)

Cl. A-J, Affirmed at A3 (sf); previously on Sep 9, 2010
Downgraded to A3 (sf)

Cl. B, Affirmed at Baa2 (sf); previously on Sep 9, 2010
Downgraded to Baa2 (sf)

Cl. C, Affirmed at Ba1 (sf); previously on Sep 9, 2010
Downgraded to Ba1 (sf)

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

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

Cl. F, Affirmed at Caa3 (sf); previously on Sep 9, 2010
Downgraded to Caa3 (sf)

Cl. G, Affirmed at Ca (sf); previously on Sep 9, 2010 Downgraded
to Ca (sf)

Cl. H, Affirmed at C (sf); previously on Sep 9, 2010 Downgraded
to C (sf)

Cl. X-P, Affirmed at Aaa (sf); previously on Sep 8, 2005
Definitive Rating Assigned Aaa (sf)

Cl. X-C, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (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 our 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
4.1% of the current balance. At last review, Moody's cumulative
base expected loss was 4.0%. Realized losses represent 3.6% of the
original balance. Moody's provides a current list of base expected
losses for conduit and fusion CMBS transactions on moodys.com at:

  http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

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

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics.

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
commercial real estate property markets. While commercial real
estate property values are beginning to move in a positive
direction, a consistent upward trend will not be evident until the
volume of investment activity increases, distressed properties are
cleared from the pipeline, and job creation rebounds. The hotel
and multifamily sectors continue to show positive signs and
improvements in the office sector continue with minimal additions
to supply. However, office demand is closely tied to employment,
where unemployment remains above long-term averages and business
confidence remains below long-term averages. Performance in the
retail sector has been mixed with lackluster holiday sales driven
by sales and promotions. Consumer confidence remains low. Across
all property sectors, the availability of debt capital continues
to improve with increased securitization activity of commercial
real estate loans supported by a monetary policy of low interest
rates. Moody's central global macroeconomic scenario reflects: an
overall downward revision of real growth forecasts since last
quarter, amidst ongoing and policy-induced banking sector
deleveraging leading to a tightening of bank lending standards and
credit contraction; financial market turmoil continuing to
negatively impact consumer and business confidence; persistently
high unemployment levels; and weak housing markets resulting in a
further slowdown in growth.

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 Structured Finance Interest-Only
Securities" published in February 2012.

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 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
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 review also incorporated the CMBS IO calculator ver. 1.0,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point. For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

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 33 compared to 37 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated March 31, 2011.

DEAL PERFORMANCE

As of the February 15, 2012 distribution date, the
transaction's aggregate certificate balance has decreased by 33%
to $2.47 billion from $3.66 billion at securitization. The
Certificates are collateralized by 158 mortgage loans ranging in
size from less than 1% to 8% of the pool, with the top ten loans
representing 46% of the pool. Seven loans, representing less than
2% of the pool, have defeased and are secured by U.S. Government
securities. The pool contains two loans with investment grade
credit estimates, representing 9% of the pool.

Twenty-five 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 the
rating agency'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 $140.4 million (78% loss severity on average).
Taking out the Macon & Burlington Mall loan liquidation, realized
losses would be $13.9 million resulting in an average loss
severity of 28%. Currently ten loans, representing 5% of the pool,
are in special servicing. The largest specially serviced loan is
the 101 Avenue of the Americas Loan ($54.0 million -- 2.2% of the
pool), which represents a pari-passu interest in a $135 million
senior loan. The loan is secured by a 411,097 square foot (SF)
office building located in the SoHo area of New York City, New
York. The loan was transferred to special servicing in October
2011 due to maturity default when the sole tenant vacated the
property at lease maturity. The borrower and special servicer
agreed on modifying the loan through a loan extension. The
borrower plans on redeveloping the property. The redevelopment
plan for the building is currently underway and will result in an
institutional quality Class A office building that will be LEED
EB-Silver certified. The loan is expected to return to the master
servicer within the next couple of months.

The remaining specially serviced properties are secured by a mix
of property types. Moody's estimates an aggregate $28.0 million
loss for the specially serviced loans (43% expected loss on
average).

Moody's has assumed a high default probability for 12 poorly
performing loans representing 5% of the pool and has estimated an
aggregate $17.9 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 95%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 99% compared to 105% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 8% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.5%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.50X and 1.09X, respectively, compared to
1.47X 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 a credit estimate is the 60 Hudson Street
Loan ($160.0 million -- 6.5% of the pool), which is secured by a
1.1 million SF Class B office and telecommunication building
located in the TriBeCa area of New York City, New York. The
largest tenants are MCI, Inc. (12% of the net rentable area (NRA);
lease expiration December 2014) and Sprint Communications (5% of
the NRA; lease expiration December 2012). As of December 2011, the
property was 71% leased compared to 64% at the prior review.
Property performance is expected to improve going forward as
occupancy increased since the prior review. Moody's credit
estimate and stressed DSCR are A1 and 1.94X, respectively,
compared to A2 and 1.86X at last review.

The second loan with a credit estimate is the Westfield San
Francisco Centre Loan ($60.0 million -- 2.4% of the pool), which
represents a pari-passu interest in a $120.0 million first
mortgage loan. The loan is secured by a 498,100 SF retail center
located in downtown San Francisco, California. The sponsor is the
Westfield Group. The property was 97% leased as of December 2010,
which was the same as at last review. The property is anchored by
Nordstrom and Bloomingdale's. Moody's credit estimate and stressed
DSCR are Baa2 and 1.27X, respectively, compared to Baa2 and 1.31X
at last review.

The top three conduit loans represent 21% of the pool balance. The
largest loan is the NGP Rubicon GSA Pool Loan ($190.3 million --
7.7% of the pool), which represents a pari-passu interest in a
$381 million first mortgage loan. The loan is secured by a
portfolio of 13 office properties and one distribution center
located in ten states and the District of Columbia. The portfolio
was 100% leased as of December 2011 compared to 99% at last
review. Moody's LTV and stressed DSCR are 97% and 0.96X,
respectively, compared to 108% and 0.87X at last review.

The second largest loan is Americas Mart A-2 Loan ($188.3 million
-- 7.0% of the pool), which represents a pari-passu interest in
a $370 million first mortgage loan. The loan is secured by a
4.1 million SF world market center consisting of a campus of three
integrated, interconnected buildings located in Atlanta, Georgia.
The property was 83% occupied as of August 2011, compared to 96%
at securitization. Property performance has deteriorated due to
declining rental rates and a decline in occupancy. Moody's LTV and
stressed DSCR are 88% and 1.28X, respectively, compared to 86% and
1.30X at last review.

The third largest loan is the Millennium Park Plaza Loan
($140. million -- 5.7% of the pool), which is secured by a 720,400
SF mixed use property located in Chicago, Illinois. The property
consists of 551 residential units, 36,700 SF of retail space and a
94,200 SF office and telecom component. The property was 99%
leased as of July 2011, essentially the same as at last review.
Per the rent roll, current rents are 25% below market. As leases
roll over, the property should be able to achieve higher rents.
Moody's LTV and stressed DSCR are 84% and 1.12X, respectively,
compared to 101% and 0.94X at last review.


* Fitch Downgrades Rating on 13 Bonds to 'D'
--------------------------------------------
Fitch Ratings has downgraded 13 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.

Today's 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.

In addition, Fitch has affirmed the following class of Morgan
Stanley Capital I Trust Series 1997-HF1 due to losses already
incurred:

  -- $91,421 class J at 'Dsf'.


* S&P Withdraws Ratings on 50 Classes From 31 Transactions
----------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 50
classes from 29 commercial mortgage-backed securities, (CMBS), one
commercial real estate-collateralized debt obligation (CRE CDO),
and one resecuritized real estate mortgage investment conduit (re-
REMIC) transactions.

"We withdrew our ratings on 37 principal and interest paying
classes from 25 CMBS and one CRE CDO and one re-REMIC transactions
following the repayment in full of each class' principal balance,
as noted in each transaction's February 2012 trustee remittance
report. We withdrew our ratings on five interest-only (IO) classes
from five CMBS transactions following the reduction of the
classes' notional balances, as noted in each transaction's trustee
remittance report," S&P said.

"In addition, we withdrew our ratings on eight IO classes from six
CMBS transactions following the repayment of all principal and
interest paying classes rated 'AA- (sf)' or higher, according to
our criteria for rating IO securities," S&P said.

            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 Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at:

         http://standardandpoorsdisclosure-17g7.com

Ratings Withdrawn Following Repayment Of Principal Balance Or
Reduction Of Notional Balance

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2000-2

                                 Rating
Class                    To                  From
H                        NR                  BB- (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2002-2

                                 Rating
Class                    To                  From
CM-A                     NR                  AAA (sf)
CM-B                     NR                  AA+ (sf)
CM-C                     NR                  AA (sf)
CM-D                     NR                  AA- (sf)
CM-E                     NR                  A+ (sf)

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2001-TOP2
                                      Rating
Class                    To                  From
B                        NR                  AA (sf)

Bear Stearns Commercial Mortgage Securities Trust 2004-PWR6
Commercial mortgage pass-through certificates

                                 Rating
Class                    To                  From
A-4                      NR                  AAA (sf)

Bear Stearns Commercial Mortgage Securities Trust 2007-BBA8
Commercial mortgage pass-through certificates

                                 Rating
Class                    To                  From
X-4                      NR                  AAA (sf)


Bear Stearns Commercial Mortgage Securities Trust 2007-PWR15
Commercial mortgage pass-through certificates

                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)


Citigroup Commercial Mortgage Trust, Series 2006-FL2
Commercial mortgage pass-through certificates

                                 Rating
Class                    To                  From
F                        NR                  AA (sf)

Column Canada Issuer Corp.
Commercial mortgage pass-through certificates series 2002-CCL1

                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CKN5

                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CK6

                                 Rating
Class                    To                  From
E                        NR                  AA+ (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-CKP1

                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)


Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-CP5

                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

First Union-Lehman Brothers Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 1997-C1

                                 Rating
Class                    To                  From
F                        NR                  A (sf)


First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2001-C3

                                 Rating
Class                    To                  From
J                        NR                  BBB- (sf)

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2002-C1

                                 Rating
Class                    To                  From
F                        NR                  AA- (sf)


GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2001-3

                                 Rating
Class                    To                  From
E                        NR                  AA- (sf)


GE Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2005-C1

                                 Rating
Class                    To                  From
X-P                      NR                  AAA (sf)

GMAC Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2000-C2

                                 Rating
Class                    To                  From
F                        NR                  BBB- (sf)

Greenwich Capital Commercial Funding Corp.
Commercial mortgage pass-through certificates series 2005-GG3

                                 Rating
Class                    To                  From
X-P                      NR                  AAA (sf)

Hartford Mezzanine Investors I - CRE CDO 2007-1 Ltd.
Commercial real estate-collateralized debt obligations

                                 Rating
Class                    To                  From
A-1                      NR                  A- (sf)

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

                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)

LB Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 1998-C4

                                 Rating
Class                    To                  From
F                        NR                  BBB+ (sf)


LB-UBS Commercial Mortgage Trust 2002-C1
Commercial mortgage pass-through certificates

                                 Rating
Class                    To                  From
A-4                      NR                  AAA (sf)
B                        NR                  AAA (sf)
C                        NR                  AAA (sf)
D                        NR                  AAA (sf)
E                        NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2004-C7
Commercial mortgage pass-through certificates

                                 Rating
Class                    To                  From
A-4                      NR                  AAA (sf)

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

                                 Rating
Class                    To                  From
X-2                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2007-TOP27
Commercial mortgage pass-through certificates

                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
C1                       NR                  AA+ (sf)
C2                       NR                  AA+ (sf)
C2X                      NR                  AA+ (sf)
D                        NR                  AA (sf)

Salomon Brothers Commercial Mortgage Trust 2002-KEY2
Commercial mortgage pass-through certificates

                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

TIAA CMBS I Trust
Commercial mortgage pass-through certificates series 2001-C1

                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2003-C5

                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2005-C17

                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

RATINGS WITHDRAWN DUE TO REPAYMENT OF ALL PRINCIPAL AND INTEREST
PAYING
CLASSES RATED 'AA- (sf)' OR HIGHER

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2000-2

                                 Rating
Class                    To                  From
X                        NR                  AAA (sf)

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2001-TOP2
                                      Rating
Class                    To                  From
X-1                      NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CKN5

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

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2002-C1

                                 Rating
Class                    To                  From
IO-I                     NR                  AAA (sf)

GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2001-3

                                 Rating
Class                    To                  From
X-1                      NR                  AAA (sf)

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
X                        NR                  AAA (sf)
X1                       NR                  AAA (sf)

                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers"
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR.  Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors" Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Howard C. Tolentino, Joseph Medel C. Martirez, Denise
Marie Varquez, 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 2012.  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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