TCR_Public/120401.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

              Sunday, April 1, 2012, Vol. 16, No. 91

                            Headlines

1888 FUND: S&P Affirms 'BB+' Rating on Class C Notes
ABS CAPITAL: Moody's Cuts Rating on US$10MM Combi Notes to 'Caa2'
ALBURN REAL ESTATE: Moody's Cuts Rating on Class A Notes to Caa2
ALEXANDER PARK: S&P Lowers Rating to Class A-2 Notes to 'D'
ALTERNATIVE LOAN 2005-22T1: S&P Cuts 4 RMBS Class Ratings to 'CC'

AMERICREDIT 2010-4: S&P Raises Rating on Class E Notes From 'BB'
AMMC CLO X: S&P Gives 'BB-' Rating on $7MM Class F Notes
ANTHRACITE CDO III: Moody's Keeps Caa3 Ratings on 2 Note Classes
APIDOS I: S&P Raises Rating on Class C Notes From 'BB+'
AXIS EQUIPMENT: DBRS Assigns 'BB' Ratings to Class D Securities

BEAR STEARNS 2002-PBW1: Moody's Cuts Rating on J Certs. to 'C'
BEAR STEARNS 2006-PWR11: S&P Cuts Ratings on 3 Cert Classes to 'D'
BLACK DIAMOND 2006-1: S&P Raises Rating on Class E Notes to 'BB'
BLUEMOUNTAIN CLO: S&P Affirms 'BB+' Rating on Class D Notes
CALLIDUS FUND V: S&P Affirms 'BB' Class D Notes Rating; Off Watch

CANARAS SUMMIT: S&P Raises Rating on Class D Notes From 'BB+'
CAPITAL ONE: S&P Affirms 'BB(sf)' Rating on Class D Securities
CARLYLE BRISTOL: S&P Raises Ratings on 2 Classes of Notes to 'B+'
CARLYLE GLOBAL 2012-1: Moody's Rates US$22.7MM Class E Notes 'Ba2'
CARLYLE GLOBAL 2012-1: S&P Assigns 'BB' Rating on Class E Notes

CITIGROUP 2006-FL2: S&P Lowers Ratings on 3 Cert. Classes to 'D'
CITIGROUP 2009-1: S&P Lowers Ratings on 2 Classes to 'CCC'
CITIGROUP MORTGAGE 2009-11: S&P Raises Class 1A2 Rating from 'B+'
CLYDESDALE CLO: S&P Raises Rating on Class D Notes to 'BB'
COLUMBUSNOVA 2006-II: S&P Affirms 'BB' Rating on Class E Notes

COMM 2005-FL11: S&P Affirms 'B-' Rating on Class K Certificates
COMBINE RE: Moody's Assigns 'Ba3' Rating to Class B Notes
COMMERCIAL MORTGAGE 2012-C4: DBRS Rates Class F Certificates 'BB'
CORVUS INVESTMENTS: Fitch Withdraws Junk Ratings on 2 Note Classes
CPS AUTO 2012-A: Moody's Assigns 'B3(sf)' Rating to Class D Notes

CREDIT SUISSE 1997-C2: Moody's Affirms C Rating on Class I Certs.
DFR MIDDLE MARKET: Moody's Lifts Rating on Class D Notes From Ba1
DORAL CLO: S&P Assigns Prelim. 'BB' Rating on $21MM Class D Notes
DRYDEN XVIII: S&P Raises Rating on Class B Note to 'B+(sf)'
DSC 2011-VFN1: S&P Raises Class D Note Rating to 'B+'; Off Watch

EASTLAND CLO: S&P Raises Class D Note Rating to 'B+'; Off Watch
FIRST UNION 1999-C2: Moody's Keeps 'C' Rating on M Certificates
FIRST UNION 2001-C1: Moody's Keeps 'Ca' Rating on Class J Certs.
FLATIRON CLO 2011-1: S&P Affirms 'BB' Rating on Class E Notes
G-STAR 2002-1: Moody's Raises Rating on Class C Notes to 'Caa1'

GALAXY XII: S&P Gives 'BB' Rating on Class E Deferrable Notes
GALE FORCE 3: S&P Raises Rating on Class E Notes to 'BB'
GMAC 2000-C1: Moody's Affirms Caa3 Rating on Class X Certificates
GREENS CREEK: S&P Raises Rating on Class D Notes to 'BB+'
GREENWICH CAPITAL 2005-GG5: Moody's Reviews 'Ca' Ratings

GS MORTGAGE 2010-C1: Moody's Affirms 'B2' Rating on Class F Notes
GS MORTGAGE 2006-CC1: Moody's Cuts Rating on Cl. A Notes to 'Ca'
HARCH CLO III: S&P Affirms 'CCC+' Rating on Class E Notes
ICE GLOBAL: S&P Assigns 'BB' Rating on $20MM Class E Notes
JPMC 2004-CIBC8: Moody's Affirms 'C' Ratings on Four CMBS Classes

JPMCC 2006-FL1: S&P Affirms 'CCC' Rating on Class K Certificates
KENNECOTT FUNDING: S&P Affirms 'BB-' Ratings on 2 Classes of Notes
LNR CDO III: Moody's Cuts Rating on Class B Notes to 'Ca(sf)'
MERRILL LYNCH 2001-C5: DBRS Rates Class E Certificates 'B(sf)'
MJH EDUCATION: Moody's Keeps 'Ca' Rating on Housing Revenue Bonds

ML-CFC 2006-2: S&P Lowers Rating on Class F Certificates to 'D'
MORGAN STANLEY 2003-1Q5: Moody's Affirms Caa1 Rating on N Certs.
MORGAN STANLEY 2004-TOP15: Moody's Affirms C Ratings on 2 Certs.
MORGAN STANLEY 2006-TOP21: S&P Cuts Class M Cert Rating to 'D'
MORGAN STANLEY 2007-TOP27: DBRS Cuts Rating on N/O Certs. to 'D'

MSC 2006-SRR1: Moody's Affirms 'C' Ratings on 16 Note Classes
MUZINICH II: S&P Raises Ratings on 2 Classes of Notes to 'CC'
N-STAR VII: S&P Lowers Ratings on 3 Classes of Notes to 'CC'
NATIONAL COLLEGIATE 2007-2: S&P Lowers Class C Notes Rating to 'D'
NERVA LTD: Fitch Withdraws Junk Rating on Class A Notes

NEXTSTUDENT MASTER: Moody's Withdraws 'C' Ratings on 25 Notes
NOMURA ASSET 1998-D6: Moody's Affirms Ba3 Rating on PS-1 Notes
NORTH STREET: Moody's Cuts Ratings on Two Note Classes to 'Caa2'
NYLIM FLATIRON: Moody's Raises Rating to Class D Notes to 'Ba1'
PACIFIC COAST: Moody's Raises Rating on US$450MM Notes to 'Caa1'

SANTANDER DRIVE: Moody's Assigns 'Ba1' Rating to Class E Notes
SECURITY NAT'L 2005-A: Moody's Cuts Rating on B Notes to 'Caa3'
STRATA 2006-34: S&P Withdraws 'CCC-' Rating on Notes
WICKER PARK: S&P Raises Rating on Class B Notes to 'B+'
* S&P Lowers Ratings on 427 Classes of Certificates to 'D'

* DBRS Takes Action on 44 U.S. RMBS Securities
* S&P Raises Ratings on 22 Tranches From 16 U.S. Synthetic CDOs
* S&P Cuts 51 Classes Ratings From 52 US RMBS Transactions to 'D'


                            *********

1888 FUND: S&P Affirms 'BB+' Rating on Class C Notes
----------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
A-1, A-2, and B notes from 1888 Fund Ltd., a collateralized loan
obligation (CLO) transaction, with APEX credit swap, APEX balance
swap, and APEX income swap features, managed by Guggenheim
Investment Management LLC. "We also affirmed our rating on the
class C notes," S&P said.

"The APEX credit swap protects the issuer against principal
losses. The APEX swap counterparty reimburses principal losses by
up to $47 million (the swap limit). The APEX balance swap
counterparty paid the class C notes' spread during the
reinvestment period. Wells Fargo Bank N.A. is the APEX swaps
provider. For our review of the transaction's performance, we
applied our counterparty criteria," S&P said.

"The upgrades mainly reflect a paydown to the class A-1 and A-2
notes since our February 2011 rating actions. Since that time, the
transaction has paid down the class A-1 and A-2 notes by
approximately $73 million and $19 million, respectively, reducing
the balance to about 18% of the original balance," S&P said.

These paydowns have led to significant improvements in the
overcollateralization (O/C) levels. According to the Feb. 6, 2012,
trustee report, the class A O/C ratio was 213.03%, up from a
reported ratio of 144.90% in January 2011.

"The affirmation of our rating on the class C notes reflects the
sufficient credit support at the class' current rating level," 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

1888 Fund Ltd.
                         Rating
Class                To           From
A-1                  AAA (sf)     AA+ (sf)
A-2                  AAA (sf)     AA+ (sf)
B                    AAA (sf)     AA+ (sf)

RATING AFFIRMED

1888 Fund Ltd.
Class                Rating
C                    BB+ (sf)


ABS CAPITAL: Moody's Cuts Rating on US$10MM Combi Notes to 'Caa2'
-----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of the
following note issued by ABS Capital Funding II, Ltd.:

US$10,000,000 Class 1 Combination Notes Due November 2037
(current rated balance of $1,944,740), Downgraded to Caa2 (sf);
previously on November 2, 2009 Downgraded to Ba1 (sf).

Ratings Rationale

According to Moody's, the rating action taken on the note is
primarily the result of deterioration in the credit quality of the
underlying portfolio since the last rating action in July 2010.
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 February 2012, the WARF of the portfolio has increased to
1969 from 1168 in May 2010. The defaulted par has increased to
$51.8 million versus $42.5 million in May 2010. Additionally, the
Class A/B and Class C overcollateralization ratios are reported at
41.46% and 36.51%, respectively, versus May 2010 levels of 61.48%
and 54.58%, respectively.

As reported by the trustee, on April 18, 2011 the transaction
experienced an "Event of Default" caused by a failure of the
overcollateralization ratio with respect to the Class A Notes to
be at least equal to 100%, as required under Section 5.1(i) of the
indenture dated November 26, 2002. This Event of Default is
continuing.

ABS Capital Funding II, Ltd., issued in November 2002, is a
collateralized debt obligation backed primarily by a portfolio of
RMBS, CMBS and SF CDOs originated from 1995 to 2007.

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

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.8 to model the loss distribution for SF CDOs. Within this
framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference.
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.


ALBURN REAL ESTATE: Moody's Cuts Rating on Class A Notes to Caa2
----------------------------------------------------------------
Moody's Investors Service has downgraded the Class A Notes issued
by Alburn Real Estate Capital Ltd. (amounts reflecting initial
outstanding) as follows:

Issuer: Alburn Real Estate Capital Limited

    GBP125.05M Class A Notes, Downgraded to Caa2 (sf); previously
    on Nov 7, 2011 Downgraded to B2 (sf)

Moody's does not rate the Class B, Class C, Class D and the Class
E Notes.

Ratings Rationale

The downgrade reflects Moody's increased loss expectation for the
single loan in the pool since its last review in November 2011.
This is primarily due to further capital value declines and the
increased likelihood of reduced recoveries as a result of prior
ranking swap liabilities. The current rating of the Class A points
to a principal loss of up to 20%.

The key parameters in Moody's analysis is the default probability
of the securitised loan (both during the term and at maturity) as
well as Moody's value assessment for the properties securing the
loan. Moody's derives from those parameters a loss expectation for
the single loan in the pool.

Alburn Real Estate Capital Limited represents the true-sale
securitisation of a GBP183.6 million senior loan secured by 45
properties located across the UK with a four year weighted average
unexpired lease term. The property portfolio is predominantly
offices (73% by value), with some industrial (17%) and retail
(10%). There is also a GBP11.8 million Junior Loan that is not
securitised but is secured by the same properties. The Loan to
Value Financial Ratio was breached in May 2011 following an
updated Valuation. The Loan Event of Default is continuing, as the
borrower has failed to cure. On December 1, 2011, Brookland
Partners LLP, as financial adviser to the Loan Servicer (and
working with CB Richard Ellis as property adviser and Clifford
Chance LLP as legal adviser) recommended a managed sell down of
the assets (with the majority of the assets being sold in the near
term). It was further recommended to take appropriate enforcement
steps in the absence of a consensual solution.

The Moody's Class A Note to Value is now 107% (or 119% including
the GBP13.6 million swap liabilities as at March 16, 2012),
compared to 103% on the last review. The value decline since
closing is in Moody's view due to (i) the secondary and tertiary
nature of the properties in the pool and (ii) the reduced cash-
flows reflecting the increased vacancy rate and the adverse
rollover profile (44.2% of leases expire by 2013).

In general, Moody's analysis reflects a forward-looking view of
the likely range of commercial real estate collateral performance
over the medium term. From time to time, Moody's may, if
warranted, change these expectations. Performance that falls
outside an acceptable range of the key parameters such as property
value or loan refinancing probability for instance, 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 . There may be mitigating or
offsetting factors to an improvement or decline in collateral
performance, such as increased subordination levels due to
amortisation and loan re- prepayments or a decline in
subordination due to realised losses.

Primary sources of assumption uncertainty are the current stressed
macro-economic environment and continued weakness in the
occupational and lending markets. Moody's anticipates (i) delayed
recovery in the lending market persisting through 2013, while
remaining subject to strict underwriting criteria and heavily
dependent on the underlying property quality, (ii) strong
differentiation between prime and secondary properties, with
further value declines expected for non-prime properties, and
(iii) occupational markets will remain under pressure in the short
term and will only slowly recover in the medium term in line with
anticipated economic recovery. Overall, Moody's central global
macroeconomic scenario is for a material slowdown in growth in
2012 for most of the world's largest economies fueled by fiscal
consolidation efforts, household and banking sector deleveraging
and persistently high unemployment levels. Moody's expects a mild
recession in the Euro area.

As the Euro area crisis continues, the rating of the structured
finance notes remain exposed to the uncertainties of credit
conditions in the general economy. The deteriorating
creditworthiness of euro area sovereigns as well as the weakening
credit profile of the global banking sector could negatively
impact the ratings of the notes.

The methodologies used in this rating were Moody's Approach to
Real Estate Analysis for CMBS in EMEA: Portfolio Analysis (MoRE
Portfolio) published in April 2006, and Update on Moody's Real
Estate Analysis for CMBS Transactions in EMEA published in June
2005.

Other Factors used in this rating are described in European CMBS:
2012 Central Scenarios published in February 2012.

The updated assessment is a result of Moody's on-going
surveillance of commercial mortgage backed securities (CMBS)
transactions. Moody's prior assessment is summarised in a press
release dated November 7, 2011. The last Performance Overview for
this transaction was published on February 21, 2012.

In rating this transaction, Moody's used both MoRE Portfolio and
MoRE Cash Flow to model the cash-flows and determine the loss for
each tranche. MoRE Portfolio evaluates a loss distribution by
simulating the defaults and recoveries of the underlying portfolio
of loans using a Monte Carlo simulation. This portfolio loss
distribution, in conjunction with the loss timing calculated in
MoRE Portfolio is then used in MoRE Cash Flow, where for each loss
scenario on the assets, the corresponding loss for each class of
notes is calculated taking into account the structural features of
the notes. As such, Moody's analysis encompasses the assessment of
stressed scenarios.


ALEXANDER PARK: S&P Lowers Rating to Class A-2 Notes to 'D'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)
from 'CC (sf)' on the class A-2 notes from Alexander Park CDO I
Ltd., a cash flow mezzanine structured finance collateralized debt
obligation (CDO) transaction managed by Princeton Advisory Group
Inc.

"We lowered the rating on the class A-2 to 'D (sf)' because this
nondeferrable class did not receive its most recent interest
payment, according to the March 7, 2012, payment report," S&P
said.

"The rating action is consistent with the criteria we use to
assess ratings on CDO transactions subject to acceleration or
liquidation after an event of default (EOD) has occurred," S&P
said.

"We received a notice of acceleration from the trustee dated March
2, 2012, stating that a majority of the controlling classholders
had declared the principal of all the notes to be immediately due
and payable. Earlier, we received a notice dated Feb. 8, 2012,
stating that the transaction had experienced an event of default
(EOD) because it failed an overcollateralization-based EOD
trigger," S&P said.


ALTERNATIVE LOAN 2005-22T1: S&P Cuts 4 RMBS Class Ratings to 'CC'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 16
classes from five U.S. residential mortgage-backed securities
(RMBS) transactions issued in 1996 through 2007, and removed one
of them from CreditWatch with negative implications.
"Concurrently, we raised our ratings on four classes from one of
the transactions with lowered ratings and two additional
transactions. Furthermore, we affirmed our ratings on 112 classes
from all of the reviewed transactions and removed one of them from
CreditWatch negative," S&P said.

The 20 RMBS transactions in this review are backed by Alternative-
A (Alt-A) and subprime mortgage loan collateral.

"The downgrades reflect our belief that projected credit
enhancement for the affected classes will be insufficient to cover
the projected losses we applied at the applicable rating stresses.
We lowered our rating on class 3-A-1 from Banc of America Funding
2006-G Trust to 'AA+ (sf)' based on our interest shortfall
criteria," S&P said.

"Among other factors, the upgrades reflect our view of decreased
delinquencies within the structures associated with the affected
classes. This has reduced the remaining projected losses for these
structures, allowing these classes to withstand more stressful
scenarios. In addition, each upgrade reflects our assessment that
the projected credit enhancement for each affected class will be
more than sufficient to cover projected losses at the revised
rating levels; however, we are limiting the extent of the upgrades
to reflect our view of ongoing market risk," S&P said.

"The 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," 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 Reports
included in this credit rating report are available at:

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Alternative Loan Trust 2005-22T1
Series 2005-22T1
                               Rating
Class      CUSIP       To                   From
A-3        12667GGQ0   CC (sf)              CCC (sf)
A-4        12667GGR8   CC (sf)              CCC (sf)
A-5        12667GMA8   CC (sf)              CCC (sf)
PO         12667GGS6   CC (sf)              CCC (sf)

Alternative Loan Trust 2005-62
Series 2005-62
                               Rating
Class      CUSIP       To                   From
1-A-1      12668ATN5   CCC (sf)             CC (sf)

Banc of America Funding 2006-G Trust
Series 2006-G
                               Rating
Class      CUSIP       To                 From
3-A-1      05950MAG5   AA+ (sf)           AAA (sf)/Watch Neg
3-A-2      05950MAH3   BBB- (sf)          BBB- (sf)/Watch Neg
3-A-3      05950MAJ9   CC (sf)            CCC (sf)

CSMC Mortgage-Backed Trust 2007-3
Series 2007-3
                               Rating
Class      CUSIP       To                   From
2-A-4      12638PAW9   CC (sf)              CCC (sf)
2-A-12     12638PBE8   CC (sf)              CCC (sf)

CWABS Asset-Backed Certificates Trust 2006-15
Series 2006-15
                               Rating
Class      CUSIP       To                   From
A-3        12666UAC7   CC (sf)              CCC (sf)
A-4        12666UAD5   CC (sf)              CCC (sf)
A-5A       12666UAE3   CC (sf)              CCC (sf)
A-6        12666UAG8   CC (sf)              CCC (sf)

CWABS Asset-Backed Certificates Trust 2007-4
Series 2007-4
                               Rating
Class      CUSIP       To                   From
A-1A       12668WAA5   BB (sf)              CCC (sf)
A-1B       12668WAT4   BB (sf)              CCC (sf)
M-1        12668WAR8   CC (sf)              CCC (sf)
M-2        12668WAS6   CC (sf)              CCC (sf)
M-3        12668WAG2   CC (sf)              CCC (sf)
M-4        12668WAH0   CC (sf)              CCC (sf)

DSLA Mortgage Loan Trust 2005-AR6
Series 2005-AR6
                               Rating
Class      CUSIP       To                   From
2A-1A      23332UFV1   BB (sf)              B (sf)


RATINGS AFFIRMED

Alternative Loan Trust 2005-22T1
Series 2005-22T1
Class      CUSIP       Rating
A-1        12667GGN7   AA- (sf)

Alternative Loan Trust 2005-62
Series 2005-62
Class      CUSIP       Rating
1-A-2      12668ATP0   CC (sf)
2-A-1      12668ATT2   CC (sf)
2-A-2      12668ATU9   CC (sf)
2-A-3      12668ATV7   CC (sf)
2-A-4      12668AYB5   AA- (sf)

Alternative Loan Trust 2007-OA10
Series 2007-OA10
Class      CUSIP       Rating
1-A-1      02149QAA8   CCC (sf)
1-A-2      02149QAB6   AA- (sf)
2-A-1      02149QAD2   CCC (sf)
2-A-2      02149QAE0   AA- (sf)
2-A-3      02149QAF7   AA- (sf)
M-1        02149QAJ9   CC (sf)

American Home Mortgage Assets Trust 2007-4
Series 2007-4
Class      CUSIP       Rating
A3         026934AC3   AA- (sf)

Argent Securities Inc.
Series 2003-W6
Class      CUSIP       Rating
AV-1       040104CM1   AAA (sf)
AF-5       040104CT6   AAA (sf)
M-1        040104CU3   AA- (sf)
M-2        040104CV1   CCC (sf)
M-3        040104CW9   CC (sf)

Banc of America Funding 2006-G Trust
Series 2006-G
Class      CUSIP       Rating
1-A-1      05950MAA8   BB (sf)
2-A-1      05950MAB6   BB+ (sf)
2-A-3      05950MAD2   AAA (sf)
2-A-4      05950MAE0   BB+ (sf)
2-A-5      05950MAF7   CCC (sf)
M-1        05950MAK6   CC (sf)
M-2        05950MAL4   CC (sf)

Bear Stearns Asset Backed Securities I Trust 2005-AC5
Series 2005-AC5
Class      CUSIP       Rating
I-A-1      073879ZW1   CCC (sf)
I-A-2      073879ZX9   CCC (sf)
I-A-3      073879ZY7   CCC (sf)
I-A-4      073879ZZ4   CCC (sf)
I-M-1      073879A32   CC (sf)
I-M-2      073879A40   CC (sf)
I-M-3      073879A57   CC (sf)
II-A-1     073879A99   AA- (sf)
II-A-2     073879B23   AA- (sf)
II-A-3     073879B31   CC (sf)
II-PO      073879B72   CC (sf)

Cityscape Home Equity Loan Trust 1996-2
Series 1996-2
Class      CUSIP       Rating
A-5        178779AQ7   AA- (sf)

CSAB Mortgage Backed Trust 2006-4
Series 2006-4
Class      CUSIP       Rating
A-2-A      12628LAD2   CCC (sf)
A-2-B      12628LAE0   CC (sf)
A-3        12628LAF7   CC (sf)
A-4        12628LAG5   AA- (sf)
A-5        12628LAH3   CC (sf)
A-6-A      12628LAJ9   CCC (sf)
A-6-B      12628LAK6   CC (sf)

CSAB Mortgage-Backed Trust 2006-3
Series 2006-3
Class      CUSIP       Rating
A-1-A      12628KAA0   CCC (sf)
A-1-B-1    12628KAB8   CCC (sf)
A-1-B-2    12628KAC6   CCC (sf)
A-1-C      12628KAD4   CCC (sf)
A-2        12628KAE2   CCC (sf)
A-3-A      12628KAF9   CCC (sf)
A-3-B      12628KAG7   CCC (sf)
A-4-A      12628KAH5   AA- (sf)
A-4-B      12628KAJ1   CCC (sf)
A-5-A      12628KAK8   AA- (sf)
A-5-B      12628KAL6   CCC (sf)
A-6        12628KAM4   AA- (sf)
A-7        12628KAN2   CCC (sf)

CSAB Mortgage-Backed Trust 2007-1
Series 2007-1
Class      CUSIP       Rating
1-A-1A     12629EAA3   CCC (sf)
1-A-1B     12629EAB1   CCC (sf)
1-A-2      12629EAC9   CCC (sf)
1-A-3A     12629EAD7   CCC (sf)
1-A-3B     12629EAE5   CCC (sf)
1-A-4      12629EAF2   AA- (sf)
1-A-5      12629EAG0   AA- (sf)
1-A-6A     12629EAH8   CCC (sf)
1-A-6B     12629EAJ4   CCC (sf)

CSMC Mortgage-Backed Trust 2007-3
Series 2007-3
Class      CUSIP       Rating
1-A-1A     12638PAB5   CCC (sf)
1-A-1B     12638PAC3   CCC (sf)
1-A-2      12638PAD1   CCC (sf)
1-A-3A     12638PAE9   CCC (sf)
1-A-3B     12638PAF6   CCC (sf)
1-A-4      12638PAG4   AA- (sf)
1-A-5      12638PAH2   AA- (sf)
1-A-6A     12638PAJ8   CCC (sf)
1-A-6B     12638PAK5   CCC (sf)
4-A-3      12638PBS7   CCC (sf)
4-A-4      12638PBT5   CCC (sf)

CWABS Asset-Backed Certificates Trust 2006-15
Series 2006-15
Class      CUSIP       Rating
A-2        12666UAB9   BB (sf)
A-5B       12666UAF0   AA- (sf)
M-1        12666UAH6   CC (sf)
M-2        12666UAJ2   CC (sf)
M-3        12666UAK9   CC (sf)
M-4        12666UAL7   CC (sf)
M-5        12666UAM5   CC (sf)
M-6        12666UAN3   CC (sf)

CWABS Asset-Backed Certificates Trust 2007-4
Series 2007-4
Class      CUSIP       Rating
A-2        12668WAB3   CCC (sf)
A-3        12668WAC1   CCC (sf)
A-4W       12668WAD9   AA- (sf)
A-5        12668WAE7   CCC (sf)
A-5W       12668WAU1   AA- (sf)
A-6        12668WAF4   CCC (sf)
A-6W       12668WAV9   AA- (sf)
M-5        12668WAJ6   CC (sf)
M-6        12668WAK3   CC (sf)

Deutsche Alt-B Securities Mortgage Loan Trust Series 2006-AB1
Series 2006-AB1
Class      CUSIP       Rating
A-3        251510ML4   AA- (sf)

Deutsche Alt-B Securities Mortgage Loan Trust Series 2006-AB3
Series 2006-AB3
Class      CUSIP       Rating
A-4        25151EAD5   AA- (sf)
A-5A       25151EAE3   AA- (sf)

DSLA Mortgage Loan Trust 2005-AR6
Series 2005-AR6
Class      CUSIP       Rating
1A-1B      23332UGJ7   AA- (sf)
2A-1B      23332UFW9   CC (sf)

FBR Securitization Trust 2005-1
Series 2005-1
Class      CUSIP       Rating
A-1        30246QAA1   AA- (sf)
A-2        30246QAB9   AA- (sf)

GSAA Home Equity Trust 2005-12
Series 2005-12
Class      CUSIP       Rating
AF-3       362341SR1   CCC (sf)
AF-3W      362341TK5   AA- (sf)
AF-4       362341SS9   CCC (sf)
AF-5       362341ST7   CCC (sf)
AF-6       362341SU4   CCC (sf)
M-1        362341SV2   CC (sf)
M-2        362341SW0   CC (sf)
M-3        362341SX8   CC (sf)

HomeGold Home Equity Loan Trust 1999-1
Series 1999-1
Class      CUSIP       Rating
A-1        43740CAB4   AA- (sf)
A-2        43740CAA6   AA- (sf)


AMERICREDIT 2010-4: S&P Raises Rating on Class E Notes From 'BB'
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on seven
classes of subordinated notes from AmeriCredit Automobile
Receivables Trust's series 2010-3 and 2010-4, and removed them
from CreditWatch with positive implications, where it placed them
on Dec. 6, 2011. "In addition, we affirmed our 'AAA (sf)' ratings
on class A-2 and A-3 from the same transactions," S&P said.

"The rating actions reflect each transaction's collateral
performance to date, our views regarding future collateral
performance, the structure of each transaction, and the respective
credit enhancement levels. In addition, our analysis incorporates
secondary credit factors, such as credit stability, payment
priorities under various scenarios, and sector--and issuer-
specific analysis. In our opinion, the total credit support, as a
percent of the amortizing pool balance, compared with our revised
expected remaining losses, is adequate for each of the raised or
affirmed ratings," S&P said.

"We placed the long-term ratings on class B, C, and D from series
2010-3 and 2010-4, as well as class E from series 2010-4, on
CreditWatch with positive implications on Dec. 6, 2011. The
CreditWatch placements reflected the fact that collateral
performance appeared to be trending better than our initial
expectations; however, we maintained our initial loss expectations
at that time pending further performance. After an additional four
months of performance, we have lowered our loss expectations to
reflect the improvement and our future expectations in performance
trends (see table 1)," S&P said.

Table 1
Collateral Performance (%)
As of March 2012 distribution

                              Initial       Revised
              Pool    Current lifetime      lifetime
Series    Mo. Factor  CNL     CNL exp.      CNL exp.
2010-3    18  63.46   2.21    12.50-13.00   6.60-6.80
2010-4    16  57.75   2.27    11.75-12.25   5.75-5.95

CNL - cumulative net loss.

Each transaction has credit enhancement in the form of a spread
account, overcollateralization, subordination for the more senior
classes, and excess spread. The credit support levels have grown
for all outstanding classes as a percent of the declining
collateral balances (see table 2).

Table 2
Hard Credit Support
As of the March 2012 distribution

                                                Current
                              Total hard        total hard
                   Pool       credit support    credit support(ii)
Series      Class  Factor(%)  at issuance(i)    (% of current)
2010-3      A-2    63.46      37.60             61.91
2010-3      A-3    63.46      37.60             61.91
2010-3      B      63.46      29.85             49.69
2010-3      C      63.46      19.80             33.86
2010-3      D      63.46      10.50             19.20
2010-4      A-2    57.75      35.20             62.28
2010-4      A-3    57.75      35.20             62.28
2010-4      B      57.75      27.95             49.73
2010-4      C      57.75      18.95             34.15
2010-4      D      57.75      10.10             18.82
2010-4      E      57.75       7.75             14.75

(i)Consists of a reserve account and overcollateralization, as
well as subordination for the higher rated tranches, and excludes
excess spread that can also provide additional enhancement.
(ii)Total hard credit support at issuance and Current total hard
credit support are as a percent of the initial pool balance.

"We incorporated cash flow analysis in the review of the series,
which included current and historical performance to estimate
future performance. The various cash flow scenarios included
forward-looking assumptions on recoveries, timing of losses, and
voluntary absolute prepayment speeds that we believe are
appropriate given the transaction's current performance. The
results demonstrated, in our view, that all of the classes have
adequate credit enhancement at their raised and affirmed rating
levels," S&P said.

"We will continue to monitor the performance of each transaction
to ensure that the credit enhancement remains sufficient, in our
view, to cover our revised cumulative net loss expectations under
our stress scenarios for each of the rated classes," 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

AmeriCredit Automobile Receivables Trust

LONG-TERM RATINGS RAISED AND REMOVED FROM CREDITWATCH POSITIVE
AmeriCredit Automobile Receivables Trust
                        Rating
Series    Class     To        From
2010-3    B         AA+(sf)   AA(sf)/Watch Pos
2010-3    C         AA(sf)    A(sf)/Watch Pos
2010-3    D         AA-(sf)   BBB(sf)/Watch Pos
2010-4    B         AA+(sf)   AA(sf)/Watch Pos
2010-4    C         AA(sf)    A+(sf)/Watch Pos
2010-4    D         AA-(sf)   BBB(sf)/Watch Pos
2010-4    E         A+(sf)    BB(sf)/Watch Pos

LONG-TERM RATINGS AFFIRMED

AmeriCredit Automobile Receivables Trust

Series   Class      Rating
2010-3   A-2        AAA(sf)
2010-3   A-3        AAA(sf)
2010-4   A-2        AAA(sf)
2010-4   A-3        AAA(sf)


AMMC CLO X: S&P Gives 'BB-' Rating on $7MM Class F Notes
--------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to AMMC
CLO X Ltd./AMMC CLO X Corp.'s $372.1 million floating-rate notes.

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

The ratings reflect S&P's view of:

* The credit enhancement provided to the 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
   (excluding 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 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 rated notes, which we assessed using
   our cash flow analysis and assumptions commensurate with the
   assigned ratings under various interest-rate scenarios,
   including LIBOR ranging from 0.35%-13.84%," 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
   subordinated portfolio manager fees, uncapped administrative
   expenses and fees, portfolio manager incentive fees, and
   payments to the subordinated 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 ASSIGNED
AMMC CLO X Ltd./AMMC CLO X Corp.

Class                 Rating          Amount
                                     (mil. $)
A                     AAA (sf)          267.6
B                     AA (sf)            42.0
C (deferrable)        A (sf)             22.0
D (deferrable)        BBB (sf)           15.9
E (deferrable)        BB+ (sf)           17.6
F (deferrable)        BB- (sf)            7.0
Subordinated notes    NR                 37.9

NR - Not rated.


ANTHRACITE CDO III: Moody's Keeps Caa3 Ratings on 2 Note Classes
----------------------------------------------------------------
Moody's Investors Service has upgraded the rating of one class and
affirmed the ratings of eight classes of Notes issued by
Anthracite CDO III, Ltd. The upgrade is due to material paydown to
the class A and the improvement in the credit quality of the
underlying portfolio as evidenced by a decrease in the weighted
average rating factor (WARF). 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, Upgraded to Aa3 (sf); previously on May 11, 2011 Downgraded
to A1 (sf)

Cl. B-FL, Affirmed at Ba1 (sf); previously on May 11, 2011
Downgraded to Ba1 (sf)

Cl. B-FX, Affirmed at Ba1 (sf); previously on May 11, 2011
Downgraded to Ba1 (sf)

Cl. C-FL, Affirmed at B1 (sf); previously on May 11, 2011
Downgraded to B1 (sf)

Cl. C-FX, Affirmed at B1 (sf); previously on May 11, 2011
Downgraded to B1 (sf)

Cl. D-FL, Affirmed at Caa1 (sf); previously on May 11, 2011
Downgraded to Caa1 (sf)

Cl. D-FX, Affirmed at Caa1 (sf); previously on May 11, 2011
Downgraded to Caa1 (sf)

Cl. E-FL, Affirmed at Caa3 (sf); previously on May 11, 2011
Downgraded to Caa3 (sf)

Cl. E-FX, Affirmed at Caa3 (sf); previously on May 11, 2011
Downgraded to Caa3 (sf)

Ratings Rationale

Anthracite CDO III, Ltd. is a static cash CRE CDO transaction
backed by a portfolio of commercial mortgage backed securities
(CMBS) (88.0% of the pool balance), real estate investment trust
(REIT) debt (7.7%) and a credit tenant lease (CTL) loan (4.3%). As
of the March 21, 2012 Trustee Report, the aggregate Note balance
of the transaction has decreased to $349.7 million from $435.3
million at issuance, with the paydown directed to Class A Notes.
The majority of paydown was due to amortization of the collateral;
however a portion of the paydown was due to interest proceeds
being reclassified as principal for those assets declared as
defaulted.

Fifty-three assets with a par balance of $256.4 million (67.0% of
the pool balance) were listed as Defaulted or Impaired Securities
as of the March 21, 2012 Trustee Report, due to interest
shortfalls, credit rating downgrades or negative watch status.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 3,977 compared to 4,263 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (8.9% compared to 8.4% at last review), A1-A3
(9.4% compared to 8.4% at last review), Baa1-Baa3 (16.4% compared
to 13.7% at last review), Ba1-Ba3 (8.3% compared to 12.4% at last
review), B1-B3 (23.3% compared to 14.6% at last review), and Caa1-
C (33.7% compared to 42.4% 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 4.0 years compared
to 4.1 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed 17.3%
WARR compared to 17.8% at last review. This slightly lower WARR is
due to the greater portion of CMBS assets in the pool compared to
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 8.5% compared to 9.7% at last review.

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

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

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
17.3% to 12.3% or up to 22.3% would result in average rating
movement on the rated tranches of 0 to 2 notches downward or 1 to
2 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 methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in November 2010, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


APIDOS I: S&P Raises Rating on Class C Notes From 'BB+'
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on three
classes of notes from Apidos CDO I, a collateralized loan
obligation (CLO) transaction managed by Apidos Capital Management
LLC. "We also affirmed our ratings on two classes from the same
transaction," S&P said.

"The upgrades reflect the underlying portfolio's improved credit
quality since our December 2009 rating action. As of the February
2012 trustee report, the balance of defaulted assets decreased to
$2.22 million from $12.57 million in November 2009, while the
balance of 'CCC' rated assets decreased to $6.38 million from
$27.49 million. Also, the class A-1 notes have started to amortize
and have paid down to 91% from 100% of its original balance. These
factors have led to the increase in the class
overcollateralization (O/C) test to 123.69% from 120.30% during
the same period," S&P said.

The rating affirmations on the class A-1 and D notes reflect the
availability of sufficient credit support at their 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 Report
included in this credit rating report is available at:

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Apidos CDO I

                   Rating
             To               From
A-2          AA+ (sf)         A+ (sf)
B            A (sf)           BBB+ (sf)
C            BBB- (sf)        BB+ (sf)

RATING AFFIRMED

Apidos CDO I

             Rating
A-1          AA+ (sf)
D            B+ (sf)


AXIS EQUIPMENT: DBRS Assigns 'BB' Ratings to Class D Securities
---------------------------------------------------------------
DBRS, Inc. has assigned final ratings to the following 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)


BEAR STEARNS 2002-PBW1: Moody's Cuts Rating on J Certs. to 'C'
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of two classes
and affirmed the ratings of nine classes of Bear Stearns
Commercial Mortgage Securities Trust Commercial Mortgage Pass-
Through Certificates, Series 2002-PBW1 as follows:

Cl. A-2, Affirmed at Aaa (sf); previously on Oct 3, 2002
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Apr 6, 2006 Upgraded to
Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Sep 20, 2007 Upgraded
to Aaa (sf)

Cl. D, Affirmed at Aaa (sf); previously on Sep 20, 2007 Upgraded
to Aaa (sf)

Cl. E, Affirmed at Aaa (sf); previously on Sep 25, 2008 Upgraded
to Aaa (sf)

Cl. F, Affirmed at Aa2 (sf); previously on Sep 25, 2008 Upgraded
to Aa2 (sf)

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

Cl. H, Downgraded to Caa1 (sf); previously on Sep 22, 2010
Downgraded to B2 (sf)

Cl. J, Downgraded to C (sf); previously on Sep 22, 2010 Downgraded
to Caa3 (sf)

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

Cl. X-1, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

Ratings Rationale

The downgrades are due to higher than expected losses from
specially serviced and liquidated loans, as well as greater
Moody's loan to value (LTV) ratio dispersion for the conduit loans
in the pool.

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

The rating of the IO Class, Class X-1, is consistent with the
expected credit performance of its reference classes and thus is
affirmed.

Moody's rating action reflects a cumulative base expected loss of
4% of the current balance. At last review, Moody's cumulative base
expected loss was 6.2%. Realized losses have increased from 1.2%
of the original balance to 3.6% since the prior review. Moody's
provides a current list of base 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 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 31 compared to 41 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through 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 May 4, 2011.

DEAL PERFORMANCE

As of the March 12, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 60% to $370 million
from $921 million at securitization. The Certificates are
collateralized by 68 mortgage loans ranging in size from less than
1% to 5.5% of the pool, with the top ten non-defeased loans
representing 29% of the pool. Eleven loans, representing 35.6% of
the pool, have defeased and are secured by U.S. Government
securities. Defeasance at last review represented 32.6% of the
pool. The pool contains one loan with an investment grade credit
estimates, representing 5.5% of the pool.

Twenty-seven loans, representing 35.6% of the pool, are on the
master servicer's watchlist. The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the CRE Finance Council (CREFC) monthly reporting package. As part
of Moody's ongoing monitoring of a transaction, Moody's reviews
the watchlist to assess which loans have material issues that
could impact performance.

Four loans have been liquidated from the pool, resulting in a
realized loss of $32.7 million (83% loss severity). Currently six
loans, representing 5% of the pool, are in special servicing.
Moody's estimates an aggregate $8.2 million loss for the specially
serviced loans (47% expected loss on average).

Moody's has assumed a high default probability for two poorly
performing loans representing 3% of the pool and has estimated an
aggregate $3 million loss (27.5% expected loss based on a 69%
probability default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 78%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 79% compared to 74% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 11.2% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.32X and 1.39X, respectively, compared to
1.53X and 1.58X 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 one loan with a credit estimate is the RREEF Textron Portfolio
Loan ($20.4 million -- 5.5% of the pool), which is secured by four
properties, including industrial, multifamily, retail and office
buildings, located in the District of Columbia, Florida, Texas and
Washington. Performance has declined slightly since last review,
however the overall performance over the life of this loan has
remained stable. Moody's underlying rating and stressed DSCR are
Aaa and 3.42X, respectively, compared to Aaa and 3.90X at last
review.

The top three performing conduit loans represent 10.7% of the pool
balance. The largest loan is the CNL Retail Portfolio Loan ($18.2
million -- 5% of the pool), which is secured by five freestanding
single-tenant retail properties located in Florida (4) and
Virginia. Borders, which occupied one of the properties (30,000 SF
-- 14% of the portfolio's net rentable area), has vacated its
space due to bankruptcy. In addition, Kash n' Karry which occupied
the largest property in the portfolio (58,635 SF
-- 28% of the portfolio's net rentable area) has also vacated
their space. This has driven the portfolio's occupancy to 58%,
compared to 100% at last review. Moody's analysis incorporated a
dark/lit blended value for the entire portfolio. Moody's LTV and
stressed DSCR are 89% and 1.22X, respectively, compared to 61% and
1.73X at last review.

The second largest loan is the North Decatur Shopping Center Loan
($11.9 million -- 3.2% of the pool), which is secured by a 136,000
SF retail center located in Atlanta, Georgia. The property was 88%
leased as of December 2011 compared to 87% as of December 2010.
Performance is in line with last review, however has declined
overall compared to 2009, mainly due to the drop in occupancy.
Moody's net cash flow reflects a slightly bigger hair cut to the
2011 net operating income due to the uncertainty of the borrower
obtaining refinancing, as the loan matures in July of 2012.
Moody's LTV and stressed DSCR are 115% and 0.89X, respectively,
compared to 113% and 0.91X at last review.

The third largest loan is the South Parc at Bethany Apartments
Loan ($9.2 million -- 2.5% of the pool), which is secured by a 152
unit multifamily property located in Portland Oregon, about 10
miles outside the central business district. The property was 99%
leased as of December 2011 compared to 95% as of December 2010.
Performance has increased mainly due to the increase in occupancy.
Moody's LTV and stressed DSCR are 84% and 1.09X, respectively,
compared to 97% and 0.95X at last review.


BEAR STEARNS 2006-PWR11: S&P Cuts Ratings on 3 Cert Classes to 'D'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 11
classes of commercial mortgage pass-through certificates from Bear
Stearns Commercial Mortgage Securities Trust 2006-PWR11, a U.S.
commercial mortgage-backed securities (CMBS) transaction.
"Concurrently, we affirmed our 'AAA (sf)' ratings on seven other
classes from the same transaction," S&P said.

"Our rating actions follow our analysis of the transaction
primarily using our U.S. conduit/fusion CMBS criteria, which
included a review of credit characteristics of the remaining
collateral 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 resolution of 10
($90.7 million, 5.4%) of the 11 assets ($101.3 million, 6.0%) that
are currently with the special servicer, as well as one additional
loan ($3.1 million, 0.2%) that we determined to be credit-
impaired. We also considered the monthly interest shortfalls that
are affecting the trust. We lowered our ratings to 'D (sf)' on
the class H, J, and K certificates 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)' rating on the class X
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 1.35x and a loan-to-value
(LTV) ratio of 109.1%. We further stressed the loans' cash flows
under our 'AAA' scenario to yield a weighted-average DSC of 0.87x
and an LTV ratio of 154.2%. The implied defaults and loss severity
under the 'AAA' scenario were 82.9% and 42.5%. The DSC and LTV
calculations noted above exclude one ($1.0 million) defeased loan,
10 ($90.7 million, 5.4%) of the 11 assets ($101.3 million, 6.0%)
that are currently with the special servicer, and one ($3.1
million, 0.2%) loan that we determined to be credit-impaired. We
separately estimated losses for the excluded specially serviced
and credit-impaired assets and included them in our 'AAA' scenario
implied default and loss severity figures," S&P said.

"As of the March 12, 2012, trustee remittance report, the trust
experienced monthly interest shortfalls totaling $231,378. The
interest shortfalls were due primarily to appraisal subordinate
entitlement reduction (ASER) amounts totaling $172,611, interest
reduction of $36,043 due to a nonrecoverability determination with
respect to the Scranton Center loan, a one-time adjustment to
interest due to a principal paydown according to the master
servicer, and special servicing fees of $20,427. The class H, J,
and K certificates have experienced cumulative interest shortfalls
for two consecutive months, and are expected to remain outstanding
for the foreseeable future. Consequently, we downgraded these
classes to 'D (sf)'. The class L, M, N, and O certificates, which
we previously downgraded to 'D (sf)', have experienced cumulative
interest shortfalls for periods ranging from two to 23 consecutive
months, and we expect the shortfalls to remain outstanding for the
foreseeable future," S&P said.

                   CREDIT CONSIDERATIONS

"As of the March 12, 2012, trustee remittance report, 11 assets
($101.3 million, 6.0%) 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) ($36.2 million, 2.1%); two are in foreclosure ($15.2
million, 0.9%); four are 90-plus-days delinquent ($22.9 million,
1.4%); one is in its grace period ($16.5 million, 1.0%); and one
($10.5 million, 0.6%) is current. Appraisal reduction amounts
(ARAs) totaling $41.9 million are in effect against 10 of the 11
specially serviced assets. Details on the two largest assets with
the special servicer are as set forth," S&P said.

"The Forum Center asset ($18.7 million, 1.1%), a 134,963-sq.-ft.,
anchored retail center in Louisville, Ky., is the largest
specially serviced asset. The loan was transferred to the special
servicer on April 7, 2009, due to imminent payment default and
became REO on Nov. 10, 2011. An ARA of $11.9 million is in effect
for this asset. According to C-III, a receiver is working to re-
tenant the property. Recent financial information is not available
for this asset. Standard & Poor's anticipates a significant loss
upon the eventual resolution of this asset," S&P said.

"The 411 Theodore Fremd Avenue loan ($16.5 million, 1.0%) is the
second-largest specially serviced asset. The loan was transferred
to special servicing on Dec. 7, 2011, due to imminent payment
default. The loan has a reported in grace payment status. The
collateral is an 111,546-sq.-ft. suburban office building in Rye,
N.Y. C-III indicated that it is negotiating a workout strategy
with the borrower. Servicer-reported DSC was 0.99x as of Sept. 30,
2011. Standard & Poor's anticipates a moderate loss upon the
eventual resolution of this loan," S&P said.

"The remaining nine specially serviced assets have individual
balances that represent 0.7% or less of the total pool balance.
ARAs totaling $30.0 million were in effect against these nine
remaining specially serviced assets. Standard & Poor's estimated
losses for eight of the nine specially serviced assets,
representing a weighted-average loss severity of 48.9%. C-III
indicated that the remaining loan has been modified and is
expected to be returned to the master servicer in a few months,"
S&P said.

"In addition to the specially serviced assets, we determined the
Memphis Industrial loan ($3.1 million, 0.2%) to be credit-
impaired. The loan is secured by a 224,749-sq.-ft. industrial
building located in Memphis, Tenn. The loan is on the combined
master servicers' watchlist due to a decline in DSC. The loan's
reported payment status is 60-plus-days delinquent. As of Dec. 31,
2011, the reported DSC was 0.16x. According to the master
servicer, the largest unit (200,749 sq. ft.) has been vacant since
March 31, 2011, while the remaining unit (24,000 sq. ft.) is
leased on a month-to-month basis. Given the reported poor
performance and payment delinquency, we consider this loan to be
at an increased risk of default and loss," S&P said.

                    TRANSACTION SUMMARY

"As of the March 12, 2012, trustee remittance report, the
collateral pool balance was $1.69 billion, which is 90.9% of the
balance at issuance. The pool includes 168 loans and three REO
assets down from 181 loans at issuance. The master servicers,
Prudential Asset Resources Inc. and Wells Fargo Bank N.A.,
provided financial information for 95.1% of the nondefeased loan
balance, 50.2% of which was full-year 2010 data and 44.9% was
interim or full-year 2011 data," S&P said.

"We calculated a weighted average DSC of 1.40x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.35x and 109.1%. Our adjusted DSC and LTV
figures exclude one ($1.0 million) defeased loan, 10 ($90.7
million, 5.4%) of the transaction's 11 ($101.3 million, 6.0%)
specially serviced assets, and one ($3.1 million, 0.2%) loan that
we determined to be credit-impaired. The transaction has
experienced $16.4 million in principal losses from five assets to
date. Fifty-six loans ($618.8 million, 36.6%) in the pool are on
the combined master servicers' watchlist, including four ($330.0
million, 19.5%) of the top 10 loans in the pool. Thirty-six loans
($250.8 million, 14.8%) have a reported DSC of less than 1.10x, 25
of which ($155.4 million, 9.2%) have reported a DSC below 1.00x,"
S&P said.

                SUMMARY OF THE TOP 10 LOANS

"The top 10 loans have an aggregate outstanding balance of $763.3
million (45.2%). Using servicer-reported numbers, we calculated a
weighted average DSC of 1.45x for the top 10 loans. Our adjusted
DSC and LTV ratio for the top 10 loans were 1.31x and 123.1%. Four
($330.0 million, 19.5%) of the top 10 loans in the pool are on the
combined master servicers' watchlist," S&P said.

"The Investcorp Retail Portfolio 1 & 2 loan ($184.4 million,
10.9%) is the second-largest loan in the pool and is secured by a
portfolio of eight retail properties totaling 1,676,738 sq. ft.:
five properties are in Cincinnati, Ohio, two are in Columbus,
Ohio, and one is in Fort Wayne, Ind. The loan was placed on the
combined master servicers' watchlist due to a decline in DSC. The
servicer-reported DSC was 1.11x for the year ended Dec. 31, 2010,
and the combined occupancy was 92.0% according to the Sept. 30,
2011 rent rolls," S&P said.

"The SBC - Hoffman Estates loan, the third-largest loan in the
pool, has a trust balance of $90.8 million (5.4%) and a whole-loan
balance of $185.4 million. The loan is secured by a 1,690,214-sq.-
ft., single-tenanted office complex located in Hoffman Estates,
Ill., about 35 miles northwest of Chicago. The tenant, SBC
Communications, is now known as AT&T Inc. (A-/Stable/A-2). The
loan was placed on the combined master servicers' watchlist due to
the borrower's inability to pay off the loan at its anticipated
repayment date of Dec. 1, 2010. The loan has a final maturity date
of Dec. 1, 2035. According to the master servicer, excess cash
flow is being captured in a lock box, and the loan is hyper-
amortizing. The servicer-reported DSC was 2.25x as of Dec. 31,
2010, and occupancy was 100% according to the March 2011 rent
roll," S&P said.

The Hickory Point Mall loan ($30.1 million, 1.8%) is the eighth-
largest loan in the pool and is secured by an 824,696-sq.-ft.
regional shopping mall in Forsyth, Ill., about 120 miles northeast
of St. Louis. The loan was placed on the combined master
servicers' watchlist due to a decline in DSC. The servicer-
reported DSC was 1.05x as of Dec. 31, 2011, and occupancy was
92.3%, according to the Sept. 30, 2011 rent roll.

The 91-31 Queens Boulevard loan ($24.7 million, 1.4%), the 10th-
largest loan in the pool, is secured by an 84,393-sq.-ft. office
building in Elmhurst, N.Y., about 10 miles from midtown Manhattan.
The loan was placed on the combined master servicers' watchlist
because of a decline in DSC. The servicer-reported DSC was 1.38x
for the year-ended Dec. 31, 2011. Occupancy was 88.8% according to
the Oct. 1, 2011, rent roll.

"Standard & Poor's stressed the collateral in the pool according
to its current criteria. The resultant credit enhancement levels
are consistent with our rating actions," 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

Bear Stearns Commercial Mortgage Securities Trust 2006-PWR11
Commercial mortgage pass-through certificates

                Rating
Class       To          From        Credit enhancement (%)
A-M         A (sf)      A+ (sf)                      21.03
A-J         BBB- (sf)   BBB (sf)                     12.37
B           BB (sf)     BBB- (sf)                    10.17
C           BB- (sf)    BB+ (sf)                      8.79
D           B (sf)      BB (sf)                       7.14
E           B (sf)      BB- (sf)                      6.04
F           B- (sf)     B+ (sf)                       4.81
G           CCC (sf)    B+ (sf)                       3.71
H           D (sf)      B (sf)                        2.33
J           D (sf)      B- (sf)                       1.92
K           D (sf)      CCC (sf)                      1.51

RATINGS AFFIRMED

Bear Stearns Commercial Mortgage Securities Trust 2006-PWR11
Commercial mortgage pass-through certificates

Class       Rating              Credit enhancement (%)
A-1         AAA (sf)                             32.03
A-2         AAA (sf)                             32.03
A-3         AAA (sf)                             32.03
A-AB        AAA (sf)                             32.03
A-4         AAA (sf)                             32.03
A-1A        AAA (sf)                             32.03
X           AAA (sf)                               N/A

N/A - Not applicable.


BLACK DIAMOND 2006-1: S&P Raises Rating on Class E Notes to 'BB'
----------------------------------------------------------------
Standard & Poor's Ratings Services raised and simultaneously
removed from CreditWatch its ratings on four classes of notes from
Black Diamond CLO 2006-1 (Luxembourg) S.A., a collateralized loan
obligation (CLO) transaction managed by Black Diamond Capital
Management LLC. "We also affirmed four ratings and withdrew one
rating from the same transaction," S&P said.

"The upgrades reflect positive rating migration of the underlying
portfolio since our February 2010 rating action. As of the January
2012 trustee report, the balance of defaulted assets decreased to
$40.43 million from $81.99 million in December 2009, while the
balance of 'CCC' rated assets decreased to $38.66 million from
$64.27 million. Additionally, the class A/B overcollateralization
test has increased to 130.82% from 125.56% within the same
period," S&P said.

"We affirmed our ratings on the class X, A-D, A-E, and A-R notes
to reflect the availability of sufficient credit support at their
current rating levels," S&P said.

"We withdrew the rating on the class P note because the principal
balance of the note has been paid down to zero," 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

Black Diamond CLO 2006-1 (Luxembourg) S.A.


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

RATINGS AFFIRMED

Black Diamond CLO 2006-1 (Luxembourg) S.A.

                              Rating
X                             AAA (sf)
A-D                           AA+ (sf)
A-E                           AA+ (sf)
A-R                           AA+ (sf)

RATING WITHDRAWN

Black Diamond CLO 2006-1 (Luxembourg) S.A.

                   Rating
             To               From
P            NR               AAA (sf)

NR - Not Rated


BLUEMOUNTAIN CLO: S&P Affirms 'BB+' Rating on Class D Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, and C notes from BlueMountain CLO Ltd., a U.S.
collateralized loan obligation transaction managed by BlueMountain
Capital Management L.P. "We also withdrew our rating on class A-1
revolving notes following their conversion to the existing class
A-1 notes, and we affirmed our rating on the class D notes," S&P
said.

"BlueMountain CLO Ltd. ended its reinvestment period in November
2011 and is currently in its amortization period. On the Feb. 15,
2012, payment date, there was a $27.53 million paydown to the
class A-1 notes' principal balance, which we factored into our
current review," S&P said.

"The upgrades also reflect improved performance we have observed
in the deal's underlying asset portfolio since we downgraded the
notes on Dec. 16, 2009. As of the Feb. 7, 2012, trustee report,
the transaction's asset portfolio had $1.50 million defaulted
obligations and $22.91 million in assets with an rating of 'CCC',
compared with $8.62 million in defaulted obligations and $47.00
million in 'CCC' obligations noted in the Nov. 4, 2009, trustee
report, which we referenced for our December 2009 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/B O/C ratio was 122.35%, compared with a reported
   ratio of 120.63% in November 2009;

* The class C O/C ratio was 115.84%, compared with a reported
   ratio of 114.21% in November 2009; and

* The class D O/C ratio was 108.84%, compared with a reported
   ratio of 107.31% in November 2009.

"Pursuant to the transaction's structural provisions, when the
reinvestment period ended, the class A-1 revolving notes were
combined with the existing class A-1 notes. Therefore, we are
withdrawing our rating on the class A-1 revolving notes," S&P
said.

"Our affirmation of the class D notes reflects our opinion that
the credit support available is commensurate with the notes'
current rating level," 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 ACTIONS

BlueMountain CLO Ltd.
                       Rating
Class              To          From
A-1                AAA (sf)    AA+ (sf)
A-1 Rev            NR          AA+ (sf)
A-2                AA+ (sf)    AA (sf)
B                  AA- (sf)    A+ (sf)
C                  A- (sf)     BBB+ (sf)

NR - Not rated.

RATING AFFIRMED

Class              Rating
D                  BB+ (sf)


CALLIDUS FUND V: S&P Affirms 'BB' Class D Notes Rating; Off Watch
-----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, and C notes from Callidus Debt Partners CLO Fund V Ltd., a
U.S. collateralized loan obligation (CLO) managed by
GSO/Blackstone Debt Funds Management. "Simultaneously, we affirmed
the ratings on the class A-1A, A-1B, and D notes. We removed our
ratings on all the classes in this review from CreditWatch, where
we placed them with positive implications on Dec. 20, 2011," S&P
said.

"The transaction is in its reinvestment period (scheduled to end
November 2013) and has improved its credit support to the notes
since we last lowered most  of the ratings in December 2009,
following the application of our September 2009 corporate
collateralized debt obligation (CDO) criteria," S&P said.

"The trustee reports $16.46 million of 'CCC' rated assets in the
February 2012 monthly report, down from $54.91 million in the
November 2009 monthly report, which we used for the December 2009
actions. When calculating the overcollateralization (O/C) ratios,
the trustee haircuts from the O/C numerator a portion of the 'CCC'
rated collateral that exceed the threshold specified in the
transaction documents. This threshold was breached in November
2009 leading to a haircut when calculating the O/C ratios. Since
the current level of 'CCC' rated collateral is less than the
threshold, there was no haircut in the O/C calculations in the
February 2012 report," S&P said.

"In addition, the transaction's default levels also declined
during this period. According to the February 2012 trustee report,
the transaction held $0.34 million in defaults, down from $6.65
million in the November 2009 trustee report," S&P said.

"Standard & Poor's also notes that the interest diversion test is
currently passing. The transaction is structured such that failure
of this test--measured during the reinvestment period in the
interest proceeds section of the waterfall--will divert 60% of the
available interest proceeds to purchase additional collateral
obligations. Based on the February 2012 trustee report, this test
result was 106.80%; it last failed in November 2009 (103.30% vs.
minimum requirement of 103.40%) and interest proceeds were
diverted toward reinvestment accordingly," S&P said.

As a result of the improvements previously mentioned, the O/C
ratios improved. The trustee reported these O/C ratios in the
February 2012 trustee report:

* The class A O/C ratio was 124.97%, compared with a reported
   ratio of 120.70% in November 2009;

* The class B O/C ratio was 117.31%, compared with a reported
   ratio of 113.40% in November 2009;

* The class C O/C ratio test was 110.65%, compared with a
   reported ratio of 107.00% in November 2009; and

* The class D O/C ratio test was 106.83%, compared with a
   reported ratio of 103.30% in November 2009.

"Due to the improvement in credit support, we are raising our
ratings on the class A-2, B, and C notes. We affirmed the ratings
on the class A-1A, A-1B, and D notes based on sufficient credit
support at their current ratings," 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 AND CREDITWATCH ACTIONS

Callidus Debt Partners CLO Fund V Ltd.

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


CANARAS SUMMIT: S&P Raises Rating on Class D Notes From 'BB+'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, and D notes from Canaras Summit CLO Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
Canaras Capital Management. "At the same time, we affirmed our
ratings on the class A-1, A-2, and E notes," S&P said.

The upgrades reflect improved collateral performance, and the
affirmations reflect adequate credit support at the current rating
levels.

"This transaction will be in its reinvestment period until June
2013. Since the time of our last rating action, the outstanding
note balances have remained the same, as the transaction has
remained in compliance with its coverage tests," S&P said.

"The credit quality of the transaction's underlying asset
portfolio has improved since our last rating action on Nov. 30,
2010, and the improvements have benefited the rated notes.
Specifically, the transaction's asset pool includes significantly
less obligations rated in the 'CCC' range than in November 2010.
Other positive factors for the transaction include an increase in
the weighted average spread, a $1.34 million increase in total
collateral backing the rated liabilities, and increases in the
class A/B, C, D, and E overcollateralization ratios," S&P said.

"The class E rating remains constrained at 'B+ (sf)' by the
application of the largest obligor default test, a supplemental
stress test we introduced as part of our September 2009 corporate
criteria update," S&P said.

"We affirmed our ratings on the class A-1, A-2, and E notes to
reflect our belief that the credit support available is
commensurate with the current rating levels," S&P said.

"We have also provided preliminary rating confirmation to the
collateral manager for an amendment which, if it becomes
effective, would permit the collateral manager to increase the
weighted average life of the assets. A preliminary rating
confirmation is our indication that we are willing to provide a
rating confirmation letter on the execution date if there are no
substantive changes to the execution version of the amendment,"
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 Report
included in this credit rating report is available at

        http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Canaras Summit CLO Ltd.
                        Rating
Class              To           From
B                  AA (sf)      A+ (sf)
C                  A (sf)       BBB+ (sf)
D                  BBB (sf)     BB+ (sf)

RATINGS AFFIRMED

Canaras Summit CLO Ltd.
Class              Rating
A-1                AA+ (sf)
A-2                AA+ (sf)
E                  B+ (sf)


CAPITAL ONE: S&P Affirms 'BB(sf)' Rating on Class D Securities
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 28
classes and affirmed its ratings on 214 classes issued by the six
largest originators/issuers of U.S. bank credit card asset-backed
securities (ABS) transactions.

"The upgrades and rating affirmations concluded our recent review
of each of the credit card ABS deals backed by the six largest
originators of U.S. bank credit card ABS that we rate. The overall
collateral performance of the credit card receivables backing each
of these credit card ABS transactions has stabilized and improved
during the last 18 to 24 months. As part of the review, we
updated, in certain instances, our base-case assumptions and
stresses to the key performance variables (yield, charge-off rate,
and payment rate) used in modeling and rating credit card ABS,"
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

American Express Credit Account Secured Note Trust
                        Rating
Series      Class     To        From
2004-2                A(sf)    BBB+(sf)
2005-2                A(sf)    BBB+(sf)
2005-4                A(sf)    BBB+(sf)
2005-7                A(sf)    BBB+(sf)
2007-2                AA(sf)   A-(sf)
2007-5                AA(sf)   A-(sf)
2007-7                AA(sf)   A-(sf)
2008-4                AA(sf)   A-(sf)
2011-1      1         AA-(sf)  A-(sf)
2011-2      1         AA-(sf)  A-(sf)

BA Credit Card Trust
                        Ratings
Class        To           From
B(2003-4)    A+(sf)        A(sf)
B(2004-1)    A+(sf)        A(sf)
B(2005-1)    A+(sf)        A(sf)
B(2005-3)    A+(sf)        A(sf)
B(2006-1)    A+(sf)        A(sf)
B(2006-2)    A+(sf)        A(sf)
B(2007-2)    A+(sf)        A(sf)
B(2007-3)    A+(sf)        A(sf)
B(2008-1)    A+(sf)        A(sf)

Capital One Multi-asset Execution Trust

                        Rating
Class              To        From
Class B(2004-3)   A+(sf)      A(sf)
Class B(2004-7)   A+(sf)      A(sf)
Class B(2005-1)   A+(sf)      A(sf)
Class B(2005-3)   A+(sf)      A(sf)
Class B(2006-1)   A+(sf)      A(sf)
Class B(2007- 1)  A+(sf)      A(sf)
Class B(2009-C)   A+(sf)      A(sf)


Chase Credit Card Owner Trust
                      Rating
Series    Class    To          From
2003-4    B        AA-(sf)     A(sf)


Chase Issuance Trust
ChaseSeries
                Rating
Class        To           From
B(2007-1)    A+(sf)       A(sf)


RATINGS AFFIRMED

American Express Issuance Trust
Series    Class   Rating
2005-2     A      AAA(sf)
2005-2     B      AA-(sf)
2005-2     C      BBB(sf)
2007-2     A      AAA(sf)
2007-2     B      A(sf)
2007-2     C      BBB(sf)

American Express Credit Account Master Trust
Series    Class   Rating
2004-2      A     AAA(sf)
2004-2      B     AA+(sf)
2005-2      A     AAA(sf)
2005-2      B     AA+(sf)
2005-4      A     AAA(sf)
2005-4      B     AA+(sf)
2005-7      A     AAA(sf)
2005-7      B     AA+(sf)
2007-2      A     AAA(sf)
2007-2      B     AA+(sf)
2007-5      A     AAA(sf)
2007-5      B     AA+(sf)
2007-7      A     AAA(sf)
2007-7      B     AA+(sf)
2007-8      A     AAA(sf)
2007-8      B     AA+(sf)
2008-2      A     AAA(sf)
2008-2      B     AA+(sf)
2008-4      A     AAA(sf)
2008-4      B     AA+(sf)
2008-5      A     AAA(sf)
2008-5      B     AA+(sf)
2008-6      A     AAA(sf)
2008-6      B     AA+(sf)
2008-7      A     AAA(sf)
2008-7      B     AA+(sf)
2008-9      A     AAA(sf)
2008-9      B     AA+(sf)
2009-1      A     AAA(sf)
2009-1      B     AA+(sf)
2009-2      A     AAA(sf)
2009-2      B     AA+(sf)
2010-1      A     AAA(sf)
2010-1      B     AA+(sf)
2011-1      A     AAA(sf)
2011-1      B     AA+(sf)
2011-2      A     AAA(sf)
2011-2      B     AA+(sf)

American Express Credit Account Secured Note Trust *
Series     Class  Rating
2009-1      1     A-(sf)
2009-2      1     A-(sf)
2010-1      1     A-(sf)

* Although similar credit enhancement as American Express Credit
  Account Secured Note Trust 2011-1 and 2011-2 which ratings are
  raised, due to a different structural feature related to re-
  allocated principal, the rating of these series are affirmed.

BA Credit Card Trust
Class       Rating
A(2002-3)   AAA(sf)
A(2003-10)  AAA(sf)
A(2004-1)   A+(sf)
A(2004-3)   AAA(sf)
A(2005-2)   AAA(sf)
A(2005-10)  AAA(sf)
A(2006-2)   AAA(sf)
A(2006-5)   AAA(sf)
A(2006-7)   AAA(sf)
A(2006-8)   AAA(sf)
A(2006-11)  AAA(sf)
A(2006-13)  AAA(sf)
A(2006-14)  AAA(sf)
A(2007-1)   AAA(sf)
A(2007-3)   AAA(sf)
A(2007-4)   AAA(sf)
A(2007-5)   AA-(sf)
A(2007-6)   AAA(sf)
A(2007-8)   AAA(sf)
A(2007-9)   AAA(sf)
A(2007-10)  AAA(sf)
A(2007-11)  AAA(sf)
A(2007-14)  AAA(sf)
A(2007-15)  AAA(sf)
A(2008-2)   AAA(sf)
A(2008-4)   AAA(sf)
A(2008-6)   AAA(sf)
A(2008-7)   AAA(sf)
A(2008-8)   AAA(sf)
A(2008-10)  AAA(sf)
A(2010-1)   AAA(sf)
C(2002-3)   BBB(sf)
C(2002-6)   BBB(sf)
C(2002-7)   BBB(sf)
C(2003-4)   BBB(sf)
C(2003-7)   BBB(sf)
C(2004-2)   BBB(sf)
C(2006-1)   BBB(sf)
C(2006-5)   BBB(sf)
C(2006-6)   BBB(sf)
C(2008-5)   BBB(sf)

Capital One Multi-asset Execution Trust

Class              Rating
Class A(2004-1)    AAA(sf)
Class A(2004-4)    AAA(sf)
Class A(2005-1)    AAA(sf)
Class A(2005-6)    AAA(sf)
Class A(2005-7)    AAA(sf)
Class A(2005-9)    AAA(sf)
Class A(2005-10)   AAA(sf)
Class A(2006-1)    AAA(sf)
Class A(2006-3)    AAA(sf)
Class A(2006-5)    AAA(sf)
Class A(2006-8)    AAA(sf)
Class A(2006-11)   AAA(sf)
Class A(2006-12)   AAA(sf)
Class A(2007-1)    AAA(sf)
Class A(2007-2)    AAA(sf)
Class A(2007-4)    AAA(sf)
Class A(2007-5)    AAA(sf)
Class A(2007-7)    AAA(sf)
Class A(2007-8)    AAA(sf)
Class A(2008-3)    AAA(sf)
Class C(2003-3)    BBB(sf)
Class C(2004-2)    BBB(sf)
Class C(2004-3)    BBB(sf)
Class C(2007-1)    BBB(sf)
Class C(2007-4)    BBB(sf)
Class C(2009-A)    BBB(sf)
Class D(2002-1)    BB(sf)

Chase Issuance Trust
ChaseSeries
Class             Rating
A(2003-4)         AAA(sf)
A(2003-8)         AAA(sf)
A(2004-3)         AAA(sf)
A(2004-8)         AAA(sf)
A(2005-2)         AAA(sf)
A(2005-6)         AAA(sf)
A(2005-11)        AAA(sf)
A(2006-2)         AAA(sf)
A(2006-6)         AAA(sf)
A(2006-8)         AAA(sf)
A(2007-2)         AAA(sf)
A(2007-3)         AAA(sf)
A(2007-5)         AAA(sf)
A(2007-7)         AAA(sf)
A(2007-8)         AAA(sf)
A(2007-9)         AAA(sf)
A(2007-10)        AAA(sf)
A(2007-12)        AAA(sf)
A(2007-13)        AAA(sf)
A(2007-16)        AAA(sf)
A(2007-17)        AAA(sf)
A(2007-18)        AAA(sf)
A(2008-2)         AAA(sf)
A(2008-3)         AAA(sf)
A(2008-4)         AAA(sf)
A(2008-6)         AAA(sf)
A(2008-8)         AAA(sf)
A(2008-10)        AAA(sf)
A(2008-11)        AAA(sf)
A(2008-12)        AAA(sf)
A(2008-13)        AAA(sf)
A(2008-14)        AAA(sf)
A(2009-2)         AAA(sf)
A(2011-2)         AAA(sf)
A(2011-3)         AAA(sf)
C(2003-3)         BBB(sf)
C(2004-2)         BBB(sf)
C(2005-2)         BBB(sf)
C(2007-1)         BBB(sf)

Chase Credit Card Owner Trust
Series      Class   Rating
2003-4       A      AAA(sf)
2003-4       C      BBB(sf)

Citibank Credit Card Issuance Trust
Citiseries
Class        Rating
2002-A4      AAA(sf)
2002-A10     AAA(sf)
2003-A7      AAA(sf)
2003-A10     AAA(sf)
2004-A8      AAA(sf)
2005-A1      AAA(sf)
2005-A2      AAA(sf)
2005-A3      AAA(sf)
2005-A4      AAA(sf)
2005-A5      AAA(sf)
2005-A8      AAA(sf)
2005-A9      AAA(sf)
2006-A1      AAA(sf)
2006-A3      AAA(sf)
2006-A7      AAA(sf)
2006-A8      AAA(sf)
2007-A3      AAA(sf)
2007-A4      AAA(sf)
2007-A7      AAA(sf)
2007-A8      AAA(sf)
2007-A9      AAA(sf)
2007-A10     AAA(sf)
2007-A11     AAA(sf)
2008-A1      AAA(sf)
2008-A2      AAA(sf)
2008-A5      AAA(sf)
2008-A6      AAA(sf)
2008-A7      AAA(sf)
2009-A1      AAA(sf)
2009-A2      AAA(sf)
2009-A4      AAA(sf)
2009-A5      AAA(sf)
2007-B5      AA(sf)
2003-C4      BBB+(sf)
2005-C1      BBB+(sf)
2005-C2      BBB+(sf)
2005-C3      BBB+(sf)
2006-C1      BBB+(sf)
2008-C6      BBB+(sf)

Discover Card Master Trust I
Series      Class       Rating
2005-4      Sub2 A      AAA(sf)
2005-4      Sub2 B      AA+(sf)
2006-2      Sub3 A      AAA(sf)
2006-2      Sub3 B      AA+(sf)
2007-2      A           AAA(sf)
2007-2      B           AA+(sf)
2007-3      Sub2-A      AAA(sf)
2007-3      Sub2-B      AA+(sf)

Discover Card Execution Note Trust
Class       Rating
A(2007-1)   AAA(sf)
A(2007-2)   AAA(sf)
A(2008-4)   AAA(sf)
A(2009-1)   AAA(sf)
A(2010-1)   AAA(sf)
A(2010-2)   AAA(sf)
A(2011-2)   AAA(sf)
A(2011-3)   AAA(sf)
A(2011-4)   AAA(sf)
A(2012-1)   AAA(sf)
B(2007-1)   AA+(sf)


CARLYLE BRISTOL: S&P Raises Ratings on 2 Classes of Notes to 'B+'
-----------------------------------------------------------------
Standard & Poor's Ratings Services  raised its ratings on the
class A-2, B-1, B-2, C, and D notes from Carlyle Bristol CLO Ltd.,
a U.S. collateralized loan obligation (CLO) transaction managed by
Carlyle Investment Management LLC. "At the same time, we affirmed
our 'AA+ (sf)' rating on the class A-1 notes," S&P said.

"The upgrades mainly reflect an improvement in the performance of
the transaction's underlying asset portfolio and paydowns to the
class A-1 notes since December 2009, when we downgraded all of the
notes following the application of our September 2009 corporate
collateralized debt obligation (CDO) criteria," S&P said.

"As of the February 2012 trustee report, the transaction had $2.67
million of defaulted assets. This was down from $10.02 million
noted in the November 2009 trustee report, which we referenced for
our December 2009 rating actions. Furthermore, assets from
obligors rated in the 'CCC' category were reported at $17.73
million in February 2012, compared with $37.11 million in November
2009," S&P said.

The upgrades also reflect an improvement in the
overcollateralization (O/C) available to support the notes,
partially due to paydowns to the class A-1 notes since the
December 2009 rating actions. Since that time, the transaction
has paid down the class A-1 notes by approximately $33 million,
reducing their outstanding note balance to 88.67% of its original
balance at issuance. The trustee reported the O/C ratios in the
February 2012 monthly report:

* The class A O/C ratio was 120.35%, compared with a reported
   ratio of 114.61% in November 2009;

* The class B O/C ratio was 112.23%, compared with a reported
   ratio of 107.00% in November 2009;

* The class C O/C ratio was 105.03%, compared with a reported
   ratio of 100.22% in November 2009; and

* The class D O/C ratio was 104.09%, compared with a reported
   ratio of 99.32% in November 2009.

The transaction ended its reinvestment period in November 2011,
and, subsequently, should continue to see further paydowns to the
notes going forward.

"We affirmed our 'AA+ (sf)' rating on the class A-1 notes to
reflect the availability of credit support at the current rating
level," 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 AND CREDITWATCH ACTIONS
Carlyle Bristol CLO Ltd.
                   Rating
Class         To           From
A-2           AA+ (sf)     AA- (sf)
B-1           BBB+ (sf)    BBB (sf)
B-2           BBB+ (sf)    BBB (sf)
C             B+ (sf)      CCC- (sf)
D             B+ (sf)      CCC- (sf)

RATING AFFIRMED
Carlyle Bristol CLO Ltd.
Class                Rating
A-1                  AA+ (sf)

TRANSACTION INFORMATION
Issuer:             Carlyle Bristol CLO Ltd.
Co-issuer:          Stanfield Bristol CLO Corp.
Collateral manager: Carlyle Investment Management LLC
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CDO


CARLYLE GLOBAL 2012-1: Moody's Rates US$22.7MM Class E Notes 'Ba2'
------------------------------------------------------------------
Moody's Investors Service has assigned the following ratings to
notes issued by Carlyle Global Market Strategies CLO 2012-1, Ltd.:

US$320,000,000 Class A Senior Floating Rate Notes due April 2022
(the "Class A Notes"), Definitive Rating Assigned Aaa (sf)

US$22,725,000 Class E Secured Deferrable Floating Rate Notes due
April 2022 (the "Class E Notes"), Definitive Rating Assigned Ba2
(sf)

US$10,000,000 Combination Notes due April 2022 (comprised of $7.2
million of the Combination Note Class B Component, $775,000 of the
Combination Note Class F Component, and $2.025 million of the
Combination Note Subordinated Note Component) (the "Combination
Notes"), Definitive Rating Assigned Baa3 (sf)

Ratings Rationale

Moody's ratings of the Class A Notes and the Class E Notes address
the ultimate cash receipt of all required principal and interest
payments, and are based on the expected loss posed to noteholders
relative to the promise of receiving the present value of such
payments. The ratings reflects the risks due to defaults on the
underlying portfolio of loans, the transaction's legal structure,
and the characteristics of the underlying assets.

Moody's rating of the Combination Notes only addresses the
expected loss posed to the noteholders relative to the promise of
receiving amounts totaling the rated balance of the combination
notes. The rating does not address any interest payments or
additional amounts that a noteholder could receive.

Carlyle 2012-1 is a managed cash flow CLO. The issued notes are
collateralized primarily by broadly syndicated first-lien senior
secured corporate loans. At least 90% of the portfolio must be
invested in senior secured loans or eligible investments and up to
10% of the portfolio may consist of second-lien loans, senior
secured notes and bonds. The underlying portfolio is expected to
be at least 70% ramped up as of the closing date.

In addition to the Class A Notes, Class E Notes and Combination
Notes rated by Moody's, the Issuer will issue five additional
tranches, including subordinated notes. In accordance with the
respective priority of payments, interest and principal will be
paid to the Class A Notes prior to the other classes of notes. The
transaction incorporates interest and par coverage tests which, if
triggered, divert interest and principal proceeds to pay down the
rated notes in order of seniority.

Carlyle Investment Management LLC will direct the selection,
acquisition and disposition of collateral on behalf of the Issuer
and may engage in trading activity during the transaction's four
year reinvestment period, including discretionary trading.
Thereafter, purchases are permitted using principal proceeds from
unscheduled principal payments and proceeds from sales of credit
risk obligations, and are subject to certain restrictions.

For modeling purposes, Moody's used the following base-case
assumptions:

Par amount of $494,177,000

Diversity of 55

WARF of 2550

Weighted Average Spread of 3.75%

Weighted Average Coupon of 7.0%

Weighted Average Recovery Rate of 44.25%

Weighted Average Life of 7.5 years

Together with the set of modeling assumptions above, Moody's
conducted an additional sensitivity analysis which was an
important component in determining the provisional rating assigned
to the Class A Notes, Class E Notes and the Combination Notes.
This sensitivity analysis includes increased default probability
relative to the base case.

Below is a summary of the impact of an increase in default
probability (expressed in terms of WARF level) on the Class A
Notes, Class E Notes and the Combination Notes (shown in terms of
the number of notch difference versus the current model output,
whereby a negative difference corresponds to higher expected
losses), assuming that all other factors are held equal:

Moody's WARF + 15% (2933)

Class A Notes: 0

Class E Notes: -1

Combination Notes: 0

Moody's WARF +30% (3315)

Class A Notes: -1

Class E Notes: -2

Combination Notes: -1

The V Score for this transaction is Medium/High. This V Score has
been assigned in a manner similar to the Medium/High V score
assigned for the global cash flow CLO sector, as described in the
special report titled, "V Scores and Parameter Sensitivities in
the Global Cash Flow CLO Sector," dated July 6, 2009, available on
www.moodys.com.

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.

The principal methodology used in assigning these ratings was
"Moody's Approach to Rating Collateralized Loan Obligations,"
published in June 2011.


CARLYLE GLOBAL 2012-1: S&P Assigns 'BB' Rating on Class E Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Carlyle
Global Market Strategies CLO 2012-1 Ltd./Carlyle Global Market
Strategies CLO 2012-1 LLC's $451.825 million floating-rate notes.

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

The ratings reflect S&P's view of:

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

* The transaction's credit enhancement, which is sufficient to
   withstand the defaults applicable for the supplemental tests
   (not counting excess spread) and cash flow structure, which can
   withstand the default rate projected by Standard & Poor's CDO
   Evaluator model, as assessed by Standard & Poor's using the
   assumptions and methods outlined in its corporate CDO criteria.

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

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

* The collateral manager's experienced management team.

* "Our projections regarding the timely interest and ultimate
   principal payments on the rated notes, which we assessed using
   our cash flow analysis and assumptions commensurate with the
   assigned ratings under various interest-rate scenarios,
   including LIBOR ranging from 0.34%-11.41%," 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 interest diversion 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; subordinated hedge termination payments;
   collateral manager incentive fees; and subordinated note
   payments to 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

RATINGS ASSIGNED
Carlyle Global Market Strategies CLO 2012-1 Ltd./Carlyle Global
Market
Strategies CLO 2012-1 LLC

Class               Rating         Amount
                                 (mil. $)
A                   AAA (sf)      320.000
B                   AA (sf)        50.000
C (deferrable)      A (sf)         35.100
D (deferrable)      BBB (sf)       24.000
E (deferrable)      BB (sf)        22.725
F (deferrable)      NR             15.000
Subordinated notes  NR             43.045

NR - Not rated.


CITIGROUP 2006-FL2: S&P Lowers Ratings on 3 Cert. Classes to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of commercial mortgage pass-through certificates from
Citigroup Commercial Mortgage Trust 2006-FL2, a U.S. commercial
mortgage-backed securities (CMBS) transaction. "Concurrently, we
raised our ratings on two classes and affirmed our ratings on four
other classes from the same transaction," S&P said.

"Our rating actions follow our analysis of the transaction, which
included the revised valuation of the collateral securing the
remaining four floating-rate loans in the pool, all of which are
currently with the special servicers due to imminent maturity
defaults. Our analysis also considered the deal structure, the
liquidity available to the trust, refinancing risks, and losses
that we anticipate will occur upon the eventual resolution of one
($50.0 million, 50.3% of the pooled trust balance) of the four
specially serviced loans ($99.4 million, 100%)," S&P said.

"We downgraded classes L, RAM-1, and RAM-2 to 'D (sf)' because we
believe the accumulated interest shortfalls will remain
outstanding for the foreseeable future. In addition, the
downgrades on the raked class RAM-1 and RAM-2 notes follow our
analysis of the Radisson Ambassador Plaza Hotel & Casino loan,
which we discuss below. These raked certificates derive 100% of
their cash flow from a subordinate nonpooled component of the
loan," S&P said.

The raised ratings on classes G and H also reflect increased
credit enhancement levels due to the deleveraging of the pooled
trust balance.

"The affirmed rating on the class J principal and interest
certificates reflects subordination and liquidity support levels
that are consistent with the outstanding rating. We affirmed our
ratings on the 'DHC' raked certificates based on our revised
valuation of the Doubletree Hospitality & Centre Plaza Office
loan. The raked certificates derive 100% of their cash flow from a
subordinate nonpooled component of the loan," S&P said.

"We based our analysis, in part, on a review of the borrower's
operating statements for the year ended Dec. 31, 2011, the
borrower's available 2012 budget, the borrower's December 2011
rent rolls, and available Smith Travel Research (STR) reports,"
S&P said.

"As of the March 16, 2012, trustee remittance report, the trust
consists of four floating-rate interest-only loans indexed to one-
month LIBOR with a pooled trust balance of $99.4 million and a
trust balance of $110.7 million. The one-month LIBOR rate was
0.2485% per the March trustee remittance report," S&P said.

"The Radisson Ambassador Plaza Hotel & Casino loan, the largest
loan in the trust, is secured by a 233-room, full-service hotel,
which includes a 14,800-sq.-ft. casino, in San Juan, Puerto Rico.
The loan has a trust and whole-loan balance of $54.4 million,
which consists of a $50.0 million senior pooled component (50.3%
of the pooled trust balance) and a $4.4 million subordinate
nonpooled component that supports the class RAM-1 and RAM-2 raked
certificates. In addition, the equity interests in the whole loan
borrower secure $35.6 million of mezzanine debt," S&P said.

"The master servicer, Wells Fargo Bank N.A. (Wells Fargo),
reported an in-trust debt service coverage (DSC) of 0.21x and
occupancy of 78.0% for the 12 months ended Nov. 30, 2011, on the
Radisson Ambassador Plaza Hotel & Casino loan," S&P said.

"Our adjusted valuation, using an 11.53% capitalization rate,
yielded a stressed in-trust loan-to-value (LTV) ratio that
significantly exceeds 100%. Wells Fargo reported declining net
cash flows in the last three years primarily due to deterioration
in casino revenues. According to Wells Fargo, the casino revenue
performance, particularly the slot machine segment that accounts
for a majority of the revenue, has been steadily declining due to
increased competition from newer establishments in Puerto Rico, as
well as the proliferation of illegal slot machine venues.
Consequently, we downgraded the 'RAM' raked certificates to 'D
(sf)' based on our analysis and because we believe the accumulated
interest shortfalls will remain outstanding for the foreseeable
future. Classes RAM-1 and RAM-2 have accumulated interest
shortfalls outstanding for seven consecutive months," S&P said.

"The Radisson Ambassador Plaza Hotel & Casino loan was transferred
to the special servicer on June 3, 2011, due to imminent maturity
default. The loan matured on July 9, 2011. According to the
special servicer, a forbearance agreement was executed on Jan. 13,
2012, which will terminate upon the earlier of another default or
July 2013. The master servicer reported an appraisal reduction
amount (ARA) of $26.4 million on the whole-loan balance based on
an Aug. 1, 2011, appraisal value of $31.2 million. We expect a
significant loss upon the eventual resolution of this loan," S&P
said.

"The CarrAmerica National Pool Portfolio loan, the second-largest
loan in the trust, is currently secured by 26 office properties
totaling 5.4 million sq. ft. in California, Texas, Colorado, and
Washington. The loan has a whole-loan balance of $509.7 million,
consisting of a $335.6 million senior participation that is split
into three pari passu pieces and a $174.1 million junior
participation that is held outside the trust. The senior
participation interests are further divided into two components: a
senior pooled component totaling $296.2 million and a subordinate
nonpooled component totaling $39.4 million. The trust's portion of
the pooled balance is $22.2 million (22.3% of the pooled trust
balance), and its portion of the nonpooled balance is $2.9
million, which is raked to the 'CAN' certificates (not rated by
Standard & Poor's). In addition, the equity interests in the
whole-loan borrower secure four mezzanine loans totaling $128.9
million. It is our understanding that the trustee-reported loan
balances are in the process of being updated due to property
releases in March, which will result in a whole-loan balance of
$509.3 million. Wells Fargo reported an in-trust combined DSC of
11.96x for the 12 months ended Dec. 31, 2011, and the combined
occupancy was 85.9% according to the December 2011 rent rolls. Our
adjusted valuation, using a 9.50% capitalization rate, yielded a
stressed in-trust LTV ratio of 56.3%," S&P said.

The loan was transferred to the special servicer, Bank of America
N.A., on Feb. 1, 2011, due to maturity default. The loan matured
on Aug. 9, 2011. According to the special servicer, the loan was
modified and the maturity was extended to Aug. 9, 2012, with a
one-year extension option.

The Doubletree Hospitality & Centre Plaza Office loan, the third-
largest loan in the trust, is secured by a mixed-use facility in
Modesto, Calif., containing, among other items, 258 full-service
hotel rooms and 58,697 rentable sq. ft. of office space. The loan
has a whole-loan balance of $24.9 million, which consists of a
$15.0 million senior pooled component (15.1% of the pooled trust
balance), a $2.8 million subordinate nonpooled component that
supports the 'DHC' raked certificates, and a $7.0 million nontrust
junior participation interest. Wells Fargo reported a combined DSC
of 5.67x for the nine months ended Sept. 30, 2011, and 65.6%
occupancy for the 12 months ended Dec. 31, 2011, on the hotel
portion and 81.8% occupancy as of July 2011 on the office portion.
S&P's adjusted valuation, using a 10.61% weighted average
capitalization rate, yielded a stressed in-trust LTV ratio of
79.7%. "Based on our analysis of the loan, we affirmed our ratings
on the 'DHC' raked certificate classes. The loan was transferred
to the special servicer on May 10, 2011, due to imminent maturity
default. The loan matured on July 9, 2011. According to the
special servicer, the loan was modified on Dec. 9, 2011. The
modification terms included, but were not limited to, extending
the maturity date to Nov. 9, 2013, with a one-year extension
option, paying down $1.2 million in principal, increasing the
interest rate spread on the whole-loan balance, and the borrower
paying all fees including special servicing and workout fees. The
special servicer indicated that this loan would likely be returned
to the master servicer at some point in March 2012," S&P said.

"The Snake River Lodge & Spa loan, the smallest loan in the trust,
is secured by an 88-room, full-service luxury hotel, which
includes a 17,000-sq.-ft. spa, at the base of the Jackson Hole
mountain range in Teton Village, Wyo. The loan has a whole-loan
balance of $25.2 million that consists of a $12.2 million senior
pooled component (12.3% of the pooled trust balance), a $1.0
million subordinate nonpooled component raked to the SRL
certificate class (not rated by Standard & Poor's), and a $12.8
million subordinate B note. The loan was transferred to the
special servicer on Feb. 11, 2010, after the borrower did not pay
off the loan by its Feb. 9, 2010, maturity date. The special
servicer for this loan, Wells Fargo, reports that it is currently
exploring various liquidation strategies, including a discounted
payoff. The reported DSC for the trust was 4.95x and occupancy was
53.8% for the 12 months ended Oct. 31, 2011. Our adjusted
valuation, which considered the April 20, 2011, appraisal value of
$25.9 million, resulted in a stressed in-trust LTV ratio of
87.3%," 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

Citigroup Commercial Mortgage Trust 2006-FL2
Commercial mortgage pass-through certificates

              Rating
Class     To        From             Credit enhancement (%)
K         CCC- (sf) CCC+ (sf)                         24.00
L         D (sf)    CCC- (sf)                          0.00
RAM-1     D (sf)    CCC- (sf)                           N/A
RAM-2     D (sf)    CCC- (sf)                           N/A

RATINGS RAISED

Citigroup Commercial Mortgage Trust 2006-FL2
Commercial mortgage pass-through certificates

              Rating
Class     To        From             Credit enhancement (%)
G         AA (sf)   A (sf)                            90.01
H         A (sf)    BBB (sf)                          69.01

RATINGS AFFIRMED

Citigroup Commercial Mortgage Trust 2006-FL2
Commercial mortgage pass-through certificates

Class     Rating                     Credit enhancement (%)
J         BB (sf)                                     46.51
DHC-1     B+ (sf)                                       N/A
DHC-2     B- (sf)                                       N/A
DHC-3     CCC (sf)                                      N/A

N/A - Not applicable.


CITIGROUP 2009-1: S&P Lowers Ratings on 2 Classes to 'CCC'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 22
classes from nine residential mortgage-backed securities (RMBS)
resecuritized real estate mortgage investment conduit (re-REMIC)
transactions issued in 2006 through 2010. "In addition, we raised
our rating on class 1A2A from Citigroup Mortgage Loan Trust 2009-
1. We also affirmed our ratings on 90 classes from eight
transactions with lowered ratings and seven other transactions,
and removed one of them from CreditWatch with negative
implications," S&P said.

"Each of the 16 reviewed transactions pays interest on a pro rata
basis, except for GSMSC Pass-Through Trust 2009-5R and RBSSP
Resecuritization Trust 2009-13, which pay interest sequentially,"
S&P said.

"We intend our ratings on the re-REMIC classes to address the
timely payment of interest and ultimate payment of principal. We
reviewed the interest and principal amounts due on the underlying
securities, which are then passed through to the applicable re-
REMIC classes. 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.

"We based our downgrades on our assessment of projected principal
losses and if there were interest shortfalls from the underlying
securities that would impair the re-REMIC classes at the
applicable rating stresses. In reviewing these transactions, we
applied Standard and Poor's criteria as set forth in 'Methodology
For Assessing the Impact of Interest Shortfalls on U.S. RMBS,'
published March 28, 2012. However, none of the downgrades was a
result of interest shortfalls to the re-REMIC classes," S&P said.

"Among other factors, the upgrade reflects our view of a decrease
in delinquencies within the structure associated with this class.
This has caused a decrease to the remaining projected loss for
this class, resulting in the class withstanding more stressful
scenarios. In addition, the upgrade reflects our assessment that
the projected credit enhancement for this class will be more than
sufficient to cover the projected loss at the revised rating
level; however, we are limiting the extent of the upgrade to
reflect our view of the ongoing market risk," S&P said.

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

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

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

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

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

            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

Citigroup Mortgage Loan Trust 2009-1
Series 2009-1
                               Rating
Class      CUSIP       To                   From
3A2B       17314UAV0   CCC (sf)             BB (sf)
1A2C       17314UAG3   CC (sf)              CCC (sf)
1A2A       17314UAE8   BB (sf)              BB- (sf)
1A2        17314UAB4   CC (sf)              CCC (sf)
2A2B       17314UAN8   CCC (sf)             B (sf)

Citigroup Mortgage Loan Trust 2009-7
Series 2009-7
                               Rating
Class      CUSIP       To                   From
4A2        17315MAH8   AA (sf)              AAA (sf)

CSMC Series 2009-9R
Series 2009-9R
                               Rating
Class      CUSIP       To                   From
12-A-2     12642HFF3   A- (sf)              AAA (sf)
12-A-7     12642HLS8   A- (sf)              AAA (sf)
12-A-8     12642HLT6   A- (sf)              AAA (sf)

GSMSC Pass-Through Trust 2009-5R
Series 2009-5R
                               Rating
Class      CUSIP       To                   From
1A-2       36190BAB5   CC (sf)              CCC (sf)

J.P. Morgan Resecuritization Trust Series 2009-1
Series 2009-1
                               Rating
Class      CUSIP       To                   From
A-2        46633CAB7   CC (sf)              CCC (sf)

J.P. Morgan Resecuritization Trust Series 2009-10
Series 2009-10
                               Rating
Class      CUSIP       To                   From
3-A-2      46634AAX2   B- (sf)              BBB+ (sf)

J.P. Morgan Resecuritization Trust Series 2009-2
Series 2009-2
                               Rating
Class      CUSIP       To                   From
A-1        46633FAA2   AAA (sf)             AAA (sf)/Watch Neg


J.P. Morgan Resecuritization Trust Series 2009-3
Series 2009-3
                               Rating
Class      CUSIP       To                   From
1-A-2      46633HAB6   A (sf)               AAA (sf)
2-A-2      46633HAD2   CC (sf)              B (sf)


J.P. Morgan Resecuritization Trust Series 2009-4
Series 2009-4
                               Rating
Class      CUSIP       To                   From
1-A-2      46633JAB2   BBB- (sf)            A- (sf)

JPMorgan MBS Series 2006-R1
Series 2006-R1
                               Rating
Class      CUSIP       To                   From
1-A-1      46628AAA0   CC (sf)              CCC (sf)
1-A-2      46628AAB8   CC (sf)              CCC (sf)
1-A-3      46628AAC6   CC (sf)              CCC (sf)
2-A-1      46628AAD4   CC (sf)              CCC (sf)
3-A-1      46628AAF9   CC (sf)              CCC (sf)
4-A-1      46628AAG7   CC (sf)              CCC (sf)
5-A-1      46628AAH5   BB- (sf)             BBB- (sf)
6-A-1      46628AAK8   D (sf)               CCC (sf)

RATINGS AFFIRMED

Banc of America Funding 2009-R10 Trust
Series 2009-R10
Class      CUSIP       Rating
A-1        05955JAA0   AAA (sf)

BCAP LLC 2009-RR3 Trust
Series 2009-RR3
Class      CUSIP       Rating
II-A-1     05531XAD6   AAA (sf)

Citigroup Mortgage Loan Trust 2009-1
Series 2009-1
Class      CUSIP       Rating
2A2A       17314UAM0   BBB- (sf)
3A2A       17314UAU2   BBB (sf)
1A2B       17314UAF5   BB- (sf)

Citigroup Mortgage Loan Trust 2009-7
Series 2009-7
Class      CUSIP       Rating
4A1        17315MAG0   AAA (sf)

CSMC Series 2009-9R
Series 2009-9R
Class      CUSIP       Rating
1-A-3      12642HAC5   AAA (sf)
12-A-5     12642HLQ2   AAA (sf)
5-A-6      12642HCH2   AAA (sf)
5-A-10     12642HCM1   AAA (sf)
5-A-1      12642HCC3   AAA (sf)
12-A-4     12642HLP4   AAA (sf)
1-A-10     12642HAK7   AAA (sf)
1-A-8      12642HAH4   AAA (sf)
5-A-3      12642HCE9   AAA (sf)
1-A-4      12642HAD3   AAA (sf)
12-A-3     12642HLN9   AAA (sf)
5-A-9      12642HCL3   AAA (sf)
1-A-7      12642HAG6   AAA (sf)
5-A-5      12642HCG4   AAA (sf)
5-A-11     12642HCN9   AAA (sf)
1-A-9      12642HAJ0   AAA (sf)
1-A-1      12642HAA9   AAA (sf)
5-A-8      12642HCK5   AAA (sf)
12-A-1     12642HFE6   AAA (sf)
12-A-6     12642HLR0   AAA (sf)
1-A-5      12642HAE1   AAA (sf)
5-A-4      12642HCF6   AAA (sf)
5-A-7      12642HCJ8   AAA (sf)
5-A-12     12642HCP4   AAA (sf)
1-A-6      12642HAF8   AAA (sf)

CSMC Series 2010-10R
Series 2010-10R
Class      CUSIP       Rating
1-A-1      12644JAA3   A (sf)

GSMSC Pass-Through Trust 2009-5R
Series 2009-5R
Class      CUSIP       Rating
4A-1       36190BAG4   AAA (sf)
1A-1       36190BAA7   AAA (sf)

J.P. Morgan Resecuritization Trust Series 2009-1
Series 2009-1
Class      CUSIP       Rating
A-9        46633CAJ0   AAA (sf)
A-4        46633CAD3   AAA (sf)
A-8        46633CAH4   AAA (sf)
A-5        46633CAE1   AAA (sf)
A-6        46633CAF8   AAA (sf)
A-3        46633CAC5   AAA (sf)
A-1        46633CAA9   AAA (sf)
A-10       46633CAK7   AAA (sf)
A-7        46633CAG6   AAA (sf)

J.P. Morgan Resecuritization Trust Series 2009-10
Series 2009-10
Class      CUSIP       Rating
3-A-6      46634ABB9   AAA (sf)
3-A-5      46634ABA1   AAA (sf)
3-A-3      46634AAY0   AAA (sf)
3-A-8      46634ABD5   AAA (sf)
3-A-10     46634ABF0   AAA (sf)
3-A-1      46634AAW4   AAA (sf)
3-A-4      46634AAZ7   AAA (sf)
3-A-9      46634ABE3   AAA (sf)
3-A-7      46634ABC7   AAA (sf)

J.P. Morgan Resecuritization Trust Series 2009-3
Series 2009-3
Class      CUSIP       Rating
1-A-1      46633HAA8   AAA (sf)
2-A-1      46633HAC4   AAA (sf)

J.P. Morgan Resecuritization Trust Series 2009-4
Series 2009-4
Class      CUSIP       Rating
1-A-1      46633JAA4   AAA (sf)

J.P. Morgan Resecuritization Trust Series 2010-3
Series 2010-3
Class      CUSIP       Rating
2-A-9      46634HAS8   BB (sf)
2-A-8      46634HAR0   BB (sf)
2-A-1      46634HAJ8   AAA (sf)
2-A-12     46634HAV1   BB (sf)
2-A-2      46634HAK5   AA (sf)
1-A-3      46634HAC3   A (sf)
2-A-5      46634HAN9   AA (sf)
1-A-1      46634HAA7   AAA (sf)
2-A-10     46634HAT6   BB (sf)
2-A-11     46634HAU3   BB (sf)
2-A-3      46634HAL3   A (sf)
1-A-6      46634HAF6   A (sf)
1-A-5      46634HAE9   AA (sf)
1-A-2      46634HAB5   AA (sf)
2-A-4      46634HAM1   BB (sf)
2-A-6      46634HAP4   A (sf)

Jefferies Resecuritization Trust 2009-R6
Series 2009-R6
Class      CUSIP       Rating
4-A3       47232YAU0   AAA (sf)
4-A1       47232YAS5   AAA (sf)
4-A2       47232YAT3   AAA (sf)
4-A4       47232YAV8   AAA (sf)

RBSSP Resecuritization Trust 2009-13
Series 2009-13
Class      CUSIP       Rating
9-A1       74928GBB3   AAA (sf)
11-A5      74928GBP2   A (sf)
5-A1       74928GAR9   A (sf)
10-A1      74928GBD9   AA (sf)
4-A4       74928GAQ1   AAA (sf)
4-A3       74928GAP3   AAA (sf)
4-A1       74928GAM0   AAA (sf)
10-A3      74928GBF4   AAA (sf)
9-A2       74928GBC1   B (sf)
8-A1       74928GAZ1   BBB (sf)
4-A2       74928GAN8   CCC (sf)
11-A3      74928GBM9   AAA (sf)
11-A1      74928GBK3   AA (sf)
10-A5      74928GBH0   A (sf)


CITIGROUP MORTGAGE 2009-11: S&P Raises Class 1A2 Rating from 'B+'
-----------------------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on class
1A2 from Citigroup Mortgage Loan Trust 2009-11 by raising it to
'BBB (sf)' from 'B+ (sf)'. "In addition, we affirmed our rating on
class 1A1 from the same transaction and removed it from
CreditWatch with negative implications," S&P said.

"On Dec. 19, 2011, we inadvertently lowered our rating on class
1A2. The correction to the rating reflects our current view that
the projected credit enhancement for this class should be more
than sufficient to cover projected losses at the revised rating
level; the revised rating level also reflects our view of ongoing
market risk," S&P said.

"The affirmation of the rating on class 1A1 reflects our current
view that the projected credit enhancement available for this
class should cover projected losses based on the stress scenario
associated with its 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 CORRECTED

Citigroup Mortgage Loan Trust 2009-11
Series 2009-11
                                Rating
Class   CUSIP        Current    12/19/11     Pre-12/19/11
1A2     17314QAB3    BBB (sf)   B+ (sf)      BBB (sf)

RATING ACTION

Citigroup Mortgage Loan Trust 2009-11
Series 2009-11
                                Rating
Class      CUSIP         To              From
1A1        17314QAA5     AAA (sf)        AAA (sf)/Watch Neg


CLYDESDALE CLO: S&P Raises Rating on Class D Notes to 'BB'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on five
classes of notes from Clydesdale CLO 2005 Ltd., a collateralized
loan obligation (CLO) transaction. "At the same time, we removed
four of these ratings from CreditWatch positive. We also affirmed
our ratings on three classes from the same transaction," S&P said.

"The upgrades reflect positive rating migration of the underlying
portfolio since our December 2009 rating action. As of the
February 2012 trustee report, the balance of defaulted assets
decreased to $8.40 million from $42.21 million in November 2009,
while the balance of 'CCC' rated assets decreased to $12.77
million from $34.37 million. This has led to an increase in class
A overcollateralization (O/C) test to 121.09% from 118.12% during
the same period," S&P said.

"As a result of this improvement, the class C and D notes are no
longer driven by the top obligor test. In addition, the class A-3a
notes, senior with respect to the pro rata sequential relationship
between the class A-1, A-2, and A-3 notes, now pass our 'AAA'
rating stresses," S&P said.

The rating affirmations on the class A-1, A-2, and A-3b notes
reflect the availability of sufficient credit support at their
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 Report
included in this credit rating report is available at

         http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Clydesdale CLO 2005 Ltd.

                   Rating
             To               From
A-3a         AAA (sf)         AA+ (sf)
A-4          AA (sf)          A+ (sf) /Watch Pos
B            A (sf)           BBB+ (sf)/Watch Pos
C            BBB (sf)         BB+ (sf)/Watch Pos
D            BB (sf)          CCC+ (sf)/Watch Pos

RATINGS AFFIRMED

Clydesdale CLO 2005 Ltd.

                             Rating
A-1                          AA+ (sf)
A-2                          AA+ (sf)
A-3b                         AA+ (sf)


COLUMBUSNOVA 2006-II: S&P Affirms 'BB' Rating on Class E Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B and C notes from ColumbusNova CLO Ltd. 2006-II, a U.S.
collateralized loan obligation transaction managed by Columbus
Nova Credit Investment Management LLC. "At the same time, we
affirmed our ratings on class A, D, and E notes, and we removed
our ratings on the class A, B, and C notes from CreditWatch, where
we placed them with positive implications on Feb. 10, 2012," S&P
said.

"ColumbusNova CLO Ltd. 2006-II is currently in its reinvestment
period, which ends Jan. 29, 2013. As of the Feb. 10, 2012, payment
date, the transaction was passing all of its coverage tests and it
retained the $28.73 million in available principal proceeds for
the potential acquisition of additional securities," S&P said.

"The upgrades reflect improved performance we have observed in the
deal's underlying asset portfolio since we lowered our ratings on
the notes on Dec. 29, 2009. The affirmation of the ratings on the
class A, D, and E notes reflect our opinion that the credit
support available is commensurate with their current rating
levels," S&P said.

"As of the Feb. 29, 2012, trustee report, the transaction's asset
portfolio had no defaulted obligations and $17.72 million in
assets with a Standard & Poor's rating in the 'CCC' range,
compared with $13.90 million in defaulted obligations and $39.93
million in obligations in the 'CCC' range noted in the November
2009 trustee report, which we referenced for our December 2009
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 its February 2012 monthly report:

* The senior O/C ratio was 122.24%, compared with a reported
   ratio of 118.40% in November 2009; and

* The mezzanine O/C ratio was 110.69%, compared with a reported
   ratio of 107.22% in November 2009.

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

          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

ColumbusNova CLO Ltd. 2006-II
                       Rating
Class              To          From
A                  AA+ (sf)    AA+ (sf)/Watch Pos
B                  AA (sf)     AA- (sf)/Watch Pos
C                  A (sf)      A- (sf)/Watch Pos

RATINGS AFFIRMED

ColumbusNova CLO Ltd. 2006-II
Class              Rating
D                  BBB (sf)
E                  BB (sf)


COMM 2005-FL11: S&P Affirms 'B-' Rating on Class K Certificates
---------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on 11
classes of commercial mortgage pass-through certificates from COMM
2005-FL11, a U.S. commercial mortgage-backed securities (CMBS)
transaction.

"The affirmations follow our analysis of the transaction, which
included our revaluation of the remaining three floating-rate
loans, one of which is currently with the special servicer, the
deal structure, and the liquidity available to the trust. We also
considered the refinancing risk associated with the two remaining
performing loans (91.3% of the pooled trust balance) that are
scheduled to mature in July 2012 and September 2012. 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-2-DB and X-3-DB interest-only (IO) certificates
based on our current criteria," S&P said.

"We based our analysis, in part, on a review of the borrowers'
December 2011 rent rolls, the borrowers' operating statements for
the year-ended Dec. 31, 2011, and Dec. 31, 2010, and the
borrowers' 2012 budgets, when available," S&P said.

"As of the March 15, 2012, trustee remittance report, the trust
consisted of three floating-rate loans indexed to one-month LIBOR
with a pooled trust balance of $130.7 million and a trust balance
of $236.3 million. The one-month LIBOR rate was 0.2485% according
to the March 2012 trustee remittance report. We discuss the three
remaining floating-rate loans," S&P said.

"The Whitehall/Starwood Golf Portfolio loan, the largest loan
remaining in the trust, has a whole-loan balance of $199.4 million
that is split into a $93.8 million senior pooled component (71.8%
of the pooled trust balance) and a $105.6 million subordinate
nonpooled component that provides 100% of the cash flow to the
'GP' raked certificates. In addition, the equity interests in the
borrower of the whole loan secure mezzanine debt totaling $55.6
million. The loan is currently secured by 92 golf courses with
1,818 holes in 15 states in the U.S. The subservicer for this
loan, GEMSA Loan Services L.P. (GEMSA), reported an in-trust debt
service coverage (DSC) of 2.75x for year-end 2011. Our adjusted
valuation, using a weighted average capitalization rate of 10.88%,
yielded an in-trust stressed loan-to-value (LTV) ratio of 116.2%.
According to GEMSA, the loan was transferred to the special
servicer on May 3, 2010, due to imminent maturity default. GEMSA
stated that the loan, which was returned to the master servicer on
Jan. 3, 2011, is currently performing under a forbearance
agreement that include, among other items, extending the loan's
maturity to July 9, 2012, from July 9, 2010. It is our
understanding from the special servicer for this loan, GE Capital
Realty Group Inc., that the borrower is paying the workout fees,
as part of the loan modification," S&P said.

"The Crossgates Commons loan, the second-largest loan in the
trust, has a trust balance of $25.5 million (19.5%) and a whole-
loan balance of $41.4 million. The loan is secured by 433,014 sq.
ft. of a 693,824-sq.-ft. community shopping center in Albany, N.Y.
The master servicer for this loan, Berkadia Commercial Mortgage
LLC (Berkadia), reported a DSC of 1.54x on the trust balance as of
year-end 2011, and occupancy was 60.1%, according to the December
2011 rent roll. Our adjusted valuation, using an 8.75%
capitalization rate, yielded an in-trust stressed LTV ratio of
114.7%. According to Berkadia, the loan was previously transferred
to the special servicer on June 11, 2010, due to imminent maturity
default because the borrower stated that it was unable to secure
refinancing by the loan's Sept. 9, 2010, maturity date. The loan
was modified on Aug. 4, 2010. As part of the modification, the
loan's maturity date was extended to Sept. 9, 2012. The IO loan
was returned to the master servicer on Nov. 3, 2010. According to
Berkadia, the borrower paid the special servicing and workout fees
as part of the loan modification," S&P said.

"The DDR/Macquarie Mervyn's Portfolio loan, the smallest of the
three remaining loans in the trust, has a whole-loan balance of
$153.4 million that is divided into three pari passu pieces, $11.4
million of which makes up 8.7% of the pooled trust balance. The
$71.0 million pari passu A-1 note is in GE Commercial Mortgage
Corp.'s series 2005-C4 and the $71.0 million pari passu A-2 note
is in GMAC Commercial Mortgage Securities Inc. Series 2006-C1
Trust. The loan is currently secured by 24 retail properties
totaling 829,213 sq. ft. in California, Arizona, Nevada, and
Texas. The loan was transferred to the special servicer on Oct.
22, 2008, after the former sole tenant, Mervyn's, filed for
bankruptcy. The IO loan matured on Oct. 1, 2010. According to the
special servicer for this loan, CWCapital Asset Management LLC
(CWCapital), the overall occupancy for the remaining 24 retail
properties was 34.0% as of February 2012. CWCapital stated that
the retail property in San Antonio, Texas, is real estate owned
and added that it is currently pursuing foreclosure on the
remaining 23 retail properties. Our adjusted valuation,
which considered the July 2011 appraisal values for the remaining
24 retail properties, yielded an in-trust stressed LTV ratio of
170.9%," S&P said.

RATINGS AFFIRMED

COMM 2005-FL11
Commercial mortgage pass-through certificates
Class     Rating       Credit enhancement %
B         AAA (sf)                    88.34
C         AAA (sf)                    75.03
D         AAA (sf)                    65.99
E         AA- (sf)                    54.28
F         A- (sf)                     43.64
G         BBB- (sf)                   34.59
H         BB+ (sf)                    26.61
J         BB (sf)                     17.56
K         B- (sf)                      7.98
X-2-DB    AAA (sf)                      N/A
X-3-DB    AAA (sf)                      N/A

N/A - Not applicable.


COMBINE RE: Moody's Assigns 'Ba3' Rating to Class B Notes
---------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to two
classes of notes issued by Combine Re Ltd. following a review of
final documents. These ratings are consistent with, and replace,
the provisional ratings assigned on March 15, 2012.

The following definitive ratings have been assigned:

US$100,000,000 Class A Principal At-Risk Variable Rate Notes due
January 7, 2015 (the "Class A Notes"), Definitive Rating
Assigned Baa1 (sf) and

US$50,000,000 Class B Principal At-Risk Variable Rate Notes due
January 7, 2015 (the "Class B Notes" and together with the Class
A Notes, the "Notes"), Definitive Rating Assigned Ba3 (sf).

Moody's ratings of the Notes are based primarily on the expected
loss posed to noteholders. The ratings reflect the risks
associated with the two reinsured parties' combined aggregate
ultimate net loss resulting from the U.S. perils of hurricanes,
earthquakes, winter storms and severe thunderstorms, net of
respective franchise deductibles and their catastrophe reinsurance
programs, for the three annual risk periods. The ratings also
reflect the transaction's legal structure, the credit strength of
the reinsured parties, and the collateral. In addition to the
Class A and Class B Notes rated by Moody's, Combine Re issued the
Class C Notes, subordinated to the Notes.

Ratings Rationale

Combine Re is a Cayman Island exempted company sponsored by two
companies, COUNTRY Mutual Insurance Company and North Carolina
Farm Bureau Mutual Insurance, Inc., that provides fully
collateralized, catastrophe aggregate excess of loss
retrocessional protection to Swiss Reinsurance America Corporation
during the three annual risk periods beginning on March 23, 2012
and ending on December 31, 2014. The subject businesses covered in
this transaction are predominantly homeowners policies.

During the Risk Period, Swiss Re provides catastrophe aggregate
excess of loss reinsurance in respect of the subject business of
COUNTRY Mutual and NCFB and cedes those risks to the noteholders
of Combine Re by entering into two separate retrocession
agreements with Combine Re. Proceeds from the offering are placed
in equal amounts into two separate trust accounts, one for COUNTRY
Mutual and the other for NCFB, as collateral for the Issuer's
potential claim obligations to Swiss Re. The permitted investments
of the trust accounts are limited to U.S. domiciled money market
funds that invest in direct U.S. government obligations, short-
term securities of the U.S. government or any agency of the U.S.
government, and/or repurchase and reverse repurchase agreements
collateralized by direct U.S. government obligations, short-term
securities of the U.S. government or any agency of the U.S.
government.

The ratings for the Notes are supported by both quantitative and
qualitative analyses and Moody's used its cash-flow model to
determine the expected loss over the Risk Period are consistent
with the assigned ratings. The most important inputs in the model
were the exceedance probability curves of aggregate net losses to
COUNTRY Mutual and NCFB derived by AIR Worldwide Corp. ("AIR").
Using those probability curves, Moody's simulated the occurrences
of modeled losses for the Reinsured Parties, assuming independence
of the two entities from each other, to determine whether the
losses had exceeded the attachment levels and losses to the notes
had occurred, and calculated the expected loss to noteholders.
Moody's also stressed the exceedance probability curves to reflect
the quality of the data provided by the Reinsured Parties used in
AIR's modeling, the ability to handle claims by the Reinsured
Parties, other non-modeled elements as well as the inherent
uncertainty in the modeling of these perils.

Additional factors that contributed to the expected losses were
the credit strength of the reinsured parties and the credit
quality of the collateral. With respect to the reinsured parties,
Moody's estimated the probability of default of the reinsured
parties and the losses that may result from unpaid early
redemption premiums. With regard to the collateral, the idealized
expected loss of the Aaa collateral exposure for the Risk Period
was added to the modeled expected losses.

V SCORE

The V Score for this transaction is Medium-High, driven by
Performance Variability and Analytic Complexity. While there
exists more than 100 years of hurricane occurrence data and over
60 years of tornado, straight-line windstorm and hail storm
occurrence data, future events or the magnitude of loss caused by
such events are difficult to predict or forecast. It is uncertain
whether historic performance data is a good indicator of future
performance. The analytical complexity of modeling hurricane,
severe thunderstorm, winter storm and earthquake risks also adds
to uncertainty and variability around the modeled parameters.

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.

Parameter Sensitivity

For parameter sensitivity, Moody's analyzed scenarios stressing
the key model input assumption to determine the potential model-
indicated ratings impact. The key model inputs are the exceedance
probability and the associated aggregate net losses. Moody's
increased the aggregate net losses in two scenarios: (i) increased
the losses by 20% for hurricanes and earthquakes, 30% for winter
storms and severe thunderstorms and (ii) increased the losses 30%
for hurricanes and earthquakes, 30% for winter storms and severe
thunderstorms. Using such assumptions, the model output for the
Class A Notes changed to Baa2 (-1) in both scenarios and the model
output for the Class B Notes changed to B1 (-1) in the 30%/20%
scenario and to B2 (-2) in the 30%/30% scenario.

Parameter Sensitivities provide a quantitative, model-indicated
calculation of the number of notches that a Moody's-rated
structured finance security may vary if certain input parameters
used in the initial ratings process differed. The analysis assumes
that the deal has not aged. It is not intended to measure how the
rating of the security might migrate over time, but rather, how
the initial rating of the security might differ as certain key
parameters vary. 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 assigned in each
case could vary from the information presented in the Parameter
Sensitivity analysis below.

Principal Methodology

The principal methodology used in these provisional ratings was
"Moody's Approach to Rating Catastrophe Bonds Updated" published
in January 2004.


COMMERCIAL MORTGAGE 2012-C4: DBRS Rates Class F Certificates 'BB'
-----------------------------------------------------------------
DBRS has assigned final ratings to the following 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.


CORVUS INVESTMENTS: Fitch Withdraws Junk Ratings on 2 Note Classes
------------------------------------------------------------------
Fitch Ratings withdraws the ratings on two classes of notes issued
by Corvus Investments Ltd. as follows:

  -- Class A-1 notes withdrawn from 'Csf';
  -- Class A-2 notes withdrawn from 'Csf'.

This transaction has terminated, but Fitch did not receive any
timely notice of the termination or reports detailing the final
distributions on the notes.  As a result, the ratings have been
withdrawn at their current rating levels.

Corvus was a synthetic collateralized debt obligation (CDO) that
closed on Dec. 7, 2000.  The transaction allowed investors to
achieve leveraged exposure to a diversified portfolio of asset-
backed securities.


CPS AUTO 2012-A: Moody's Assigns 'B3(sf)' Rating to Class D Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to the
notes to be issued by CPS Auto Receivables Trust 2012-A. This is
the first transaction of the year for Consumer Portfolio Services,
Inc. (CPS).

The complete rating actions are as follows:

Issuer: CPS Auto Receivables Trust 2012-A

Class A Notes, rated A2 (sf);

Class B Notes, rated Baa2 (sf);

Class C Notes, rated Ba3 (sf);

Class D Notes, rated B3 (sf);

Ratings Rationale

Moody's said the ratings are based on the quality of the
underlying auto loans and their expected performance, the strength
of the structure, the availability of excess spread over the life
of the transaction, the experience and expertise of CPS as
servicer, and the backup servicing arrangement with Aa3-rated
Wells Fargo Bank, N.A.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. Auto Loan-Backed Securities," published in
May 2011.

Moody's median cumulative net loss expectation for the underlying
pool is 13.0%. The loss expectation was based on an analysis of
CPS' portfolio vintage performance as well as performance of past
securitizations, and current expectations for future economic
conditions.

The Assumption Volatility Score for this transaction is
Medium/High versus a Medium for the sector. This is driven by the
Medium/High assessment for Governance due to the unrated
sponsor/servicer.

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

Moody's Parameter Sensitivities: If the net loss used in
determining the initial rating were changed to 18%, 22% or 27%,
the initial model output for the Class A notes might change from
A2 to A3, Baa3, and Ba3, respectively. If the net loss used in
determining the initial rating were changed to 13.5%, 17% or 18%,
the initial model output for the Class B notes might change from
Baa2 to Baa3, B2, and B3, respectively. If the net loss used in
determining the initial rating were changed to 13.25%, 14.4% or
15.75%, the initial model output for the Class C notes might
change from Ba3 to B1, B3, and Caa1, respectively, and the initial
model output for the Class D notes might change from B3 to all three scenarios.

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


CREDIT SUISSE 1997-C2: Moody's Affirms C Rating on Class I Certs.
-----------------------------------------------------------------
Moody's Investors Service affirmed four classes of Credit Suisse
First Boston Mortgage Securities Corp., Commercial Mortgage Pass-
Through Certificates, Series 1997-C2 as follows:

Cl. E, Affirmed at Aaa (sf); previously on Dec 8, 2006 Upgraded to
Aaa (sf)

Cl. H, Affirmed at Caa2 (sf); previously on May 2, 2005 Downgraded
to Caa2 (sf)

Cl. I, Affirmed at C (sf); previously on May 2, 2005 Downgraded to
C (sf)

Cl. A-X, Affirmed at Caa1 (sf); previously on Feb 22, 2012
Downgraded to Caa1 (sf)

Ratings Rationale

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

The rating of the IO Class, Class A-X, is consistent with the
expected credit performance of its referenced classes and thus is
affirmed.

Moody's rating action reflects a cumulative base expected loss of
10.8% of the current balance. At last review, Moody's cumulative
base expected loss was 3.0%. Moody's provides a current list of
base losses for conduit and fusion CMBS transactions on moodys.com
at:

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

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

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

Primary sources of assumption uncertainty are the 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 "CMBS: Moody's Approach
to Rating Conduit Transactions "published in September 2000,
"Moody's Approach to Rating CMBS Large Loan/Singe Borrower
Transactions" published in July 2000, and "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.60 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

Moody's 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 15, compared to 17 at the Moody's prior review.

In cases where the Herf falls below 20, Moody's employs also the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.2. 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 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 March 19, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 90% to $146.1
million from $1.465 billion at securitization. The Certificates
are collateralized by 46 mortgage loans ranging in size from less
than 1% to 12% of the pool, with the top ten loans representing
58% of the pool. The pool includes a credit tenant lease (CTL)
component, representing 42% of the pool. Five loans, representing
17% of the pool, have defeased and are collateralized with U.S.
Government securities.

Four loans, representing 22% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the
Commercial Mortgage Securities Association's monthly reporting
package. As part of Moody's ongoing monitoring of a transaction,
Moody's reviews the watchlist to assess which loans have material
issues that could impact performance.

Nineteen loans have been liquidated from the pool, resulting in an
aggregate $38.9 million realized loss (23% loss severity on
average). Currently there are four loans, representing 14% of the
pool, in special servicing. The largest loan in special servicing
is the Bannockburn Executive Plaza Loan ($8.4 million --5.8% of
the pool), which is secured by a 131,500 square foot (SF)
industrial building located in Bannockburn, Illinois. The loan was
transferred to special servicing in December 2010 for imminent
default. The property was 54% leased as of June 2011. In April
2011, the property was appraised for $5.2 million. The loan is 90+
days delinquent.

The remaining three specially serviced loans are secured by office
and multifamily properties. Moody's has estimated an aggregate
$8.6 million loss (53% expected loss on average) for three of the
specially serviced loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 100% and 60% of the pool, respectively,
excluding the CTL, specially serviced and defeased loans.
Excluding specially serviced loans and CTL loans, Moody's weighted
average LTV is 72% compared to 74% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 12%
to the most recently available net operating income. Moody's value
reflects a weighted average capitalization rate of 10.3%.

Excluding specially serviced loans and CTL loans, Moody's actual
and stressed DSCRs are 1.44X and 1.58X, respectively, compared to
1.44X and 1.57X 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 25% of the pool
balance. The largest loan is the 78 Corporate Center Loan ($17.9
million -- 12.3% of the pool), which is secured by a 176,700 SF
office building located in Bedminster Township, New Jersey. The
property is 100% leased to Verizon Wireless (Moody's senior
unsecured rating A2 - stable outlook) through November 2021.
Moody's LTV and stressed DSCR are 63% and 1.79X, respectively,
compared to 66% and 1.73X at last review.

The second largest loan is the Kendig Square Shopping Center Loan
($12.1 million -- 8.3% of the pool), which is secured by a 260,200
SF anchored retail center located in West Lampeter Township
(Lancaster County), Pennsylvania. The two largest tenants are K-
Mart (33% of the net rentable area (NRA); lease expiration
September 2016) and Weis Market (23% od the NRA; lease expiration
August 2016). The property was 97% leased as of December 2011, the
same as last review. Performance has been stable. Moody's LTV and
stressed DSCR are 70% and 1.51X, respectively, compared to 71% and
1.48X at last review.

The third largest loan is the Fox Jewelry Plaza and Los Angeles
Theatre Loan ($6.0 million -- 4.1% of the pool), which is secured
by a 91,000 SF retail building located in Los Angeles, California.
The property was 65% leased as of September 2011, essentially the
same as at last review. The loan is on the servicer's watchlist
due to low occupancy. Overall performance has been stable since
last review. Moody's LTV and stressed DSCR are 69% and 1.65X,
respectively, compared to 71% and 1.61X at last review.

The CTL component includes thirty three loans ($61.0 million --
42% of the pool) secured by properties leased to six credit
tenants under bondable leases. The largest exposures are
CVS/Caremark Corp. (31% of the CTL component; Moody's senior
unsecured rating Baa2 - stable outlook) and Sears Holdings Corp.
(30% of the CTL component; Moody's LT Corporate rating B3 -
negative outlook).

The bottom-dollar weighted average rating factor (WARF) for this
pool is 3,152 compared to 2,220 at last review. WARF is a measure
of the overall quality of a pool of diverse credits. The bottom-
dollar WARF is a measure of the default probability within the
pool.


DFR MIDDLE MARKET: Moody's Lifts Rating on Class D Notes From Ba1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by DFR Middle Market CLO Ltd.:

US$28,000,000 Class C Deferrable Mezzanine Floating Rate Notes Due
2019, Upgraded to Aa1 (sf); previously on September 28, 2011
Upgraded to A2 (sf);

US$19,000,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2019, Upgraded to A3 (sf); previously on September 28, 2011
Upgraded to Ba1 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of delevering of the senior notes resulting in
an increase in the transaction's overcollateralization ratios
since the rating action in September 2011. Moody's notes that the
Class A-1A Notes are fully paid down and the Class A-1B Notes have
been paid down by approximately 85% or $34.7 million since the
last rating action. Based on the latest trustee report dated March
9, 2012, the Class B, Class C, and Class D overcollateralization
ratios are reported at 297%, 181.9% and 144.1%, respectively,
versus September 2011 levels of 193.0% , 148.8% and 128.8%,
respectively.

Moody's also notes that the deal has benefited from an improvement
in the credit quality of the underlying portfolio since the last
rating action in September 2011. Based on the March 2012 trustee
report, the weighted average rating factor is currently 3325
compared to 3442 in September 2012.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $128.8 million,
defaulted par of $11.1 million, a weighted average default
probability of 25.4% (implying a WARF of 4221), a weighted average
recovery rate upon default of 37.82%, and a diversity score of 22.
The default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

For securities whose default probabilities are assessed through
credit estimates ("CEs"), Moody's applied a 2-notch equivalent
assumed downgrade (but only on the CEs representing in aggregate
the largest 30% of the pool) for each CE where the related
exposure constitutes more than 3% of the collateral pool, as
described in "Updated Approach to the Usage of Credit Estimates in
Rated Transactions" published in October 2009. Moody's applied
this default probability stress to 15.9% of the performing par.
Notwithstanding the foregoing, in all cases the lowest assumed
rating equivalent is Caa3.

DFR Middle Market CLO issued in July 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011.

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in June 2011. In addition, due to the low
diversity of the collateral pool, CDOROM 2.8 was used to simulate
a default distribution that was then applied as an input in the
cash flow model.

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on all
rated notes of various default probabilities. Below is a summary
of the impact of different default probabilities (expressed in
terms of WARF levels) on all rated notes (shown in terms of the
number of notches' difference versus the current model output,
where a positive difference corresponds to lower expected loss),
assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (3125)

Class C: +1

Class D: +2

Moody's Adjusted WARF + 20% (4687)

Class C: -1

Class D: -2

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2014 and
2016 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are described
below:

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

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

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


DORAL CLO: S&P Assigns Prelim. 'BB' Rating on $21MM Class D Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services  assigned its preliminary
ratings to Doral CLO II Ltd./Doral CLO II Inc.'s $367.5 million
floating-rate notes.

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

The preliminary ratings are based on information as of March 23,
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
    CDO Evaluator model, as assessed by Standard & Poor's using
    the assumptions and methods outlined in its corporate
    collateralized debt obligation (CDO) criteria," S&P said.

    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 asset manager's experienced management team.

    "Our projections regarding the timely interest and ultimate
    principal payments on the preliminary rated notes, which we
    assessed using our cash flow analysis and assumptions
    commensurate with the assigned preliminary ratings under
    various interest-rate scenarios, including LIBOR ranging from
    0.3439% to 12.65%," 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.

           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
Doral CLO II Ltd./Doral CLO II Inc.

Class                  Rating          Amount (mil. $)
A-1                    AAA (sf)                  269.5
A-2                    AA (sf)                    27.0
B (deferrable)         A (sf)                     33.0
C (deferrable)         BBB (sf)                   17.0
D (deferrable)         BB (sf)                    21.0
Subordinated notes     NR                         46.1

NR - Not rated.


DRYDEN XVIII: S&P Raises Rating on Class B Note to 'B+(sf)'
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its rating to 'B+ (sf)'
from 'CCC- (sf)' on the class B note from Dryden XVIII Leveraged
Loan 2007 Ltd., a reinvesting collateralized loan obligation (CLO)
transaction managed by Prudential Investment Management. "At the
same time, we removed the rating from CreditWatch positive, where
we placed it Dec. 20, 2011," S&P said.

"The upgrade reflects positive rating migration within the
underlying asset portfolio since we lowered the rating on the
class in November 2009. As of the February 2012 trustee report,
the balance of collateral rated 'Caa1'/'CCC+' or lower decreased
to $30.45 million from $56.62 million in September 2009. This
increased the class B par value ratio to 105.67% from 100.11%
during the same period," S&P said.

"As a result of this improvement, the rating on the class B note
is no longer driven by the largest obligor default test at the
'CCC' rating level, a supplemental stress test introduced as part
of our 2009 corporate CDO criteria update," S&P said.

"We will continue to review our rating on the note and assess
whether, in our view, it remains 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


DSC 2011-VFN1: S&P Raises Class D Note Rating to 'B+'; Off Watch
----------------------------------------------------------------
DBRS, Inc. has discontinued its ratings on the DSC Floorplan
Master Owner Trust Series 2011-VFN1.  The follow ratings have been
discontinued due to repayment of the noteholders:

-- Class A notes previously rated 'A' (sf) are now rated Disc-
    Repaid

-- Class B notes previously rated BB (sf) are now rated Disc-
    Repaid


EASTLAND CLO: S&P Raises Class D Note Rating to 'B+'; Off Watch
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on six
classes of notes from Eastland CLO Ltd. "We affirmed our rating on
one other class in the transaction. At the same time, we removed
all the ratings from CreditWatch with positive implications, where
we had placed them on Dec. 20, 2011," S&P said.

Eastland CLO Ltd. is a collateralized loan obligation (CLO) backed
by corporate loans and managed by Highland Capital Management L.P.
The transaction is in its reinvestment period, which will last
until May 2014.

"The rating actions reflect a significant decrease in the amount
of defaulted and 'CCC' rated obligations since our January 2010
rating actions. As a result, the class A, B, C, and D
overcollateralization (O/C) ratios have increased. Classes B, C,
and D have also paid back their deferred interest balances since
our January 2010 review. The upgrades reflect the improved
credit quality of the transaction's underlying asset portfolio,
which has benefited the rated notes," S&P said.

"The ratings on the class C and D notes reflect our 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.

The affirmation reflects the availability of sufficient credit
support at its current rating level.

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

Eastland CLO Ltd.
                Rating
Class        To         From
A-1          AA+ (sf)   A+ (sf)/Watch Pos
A-2a         AAA (sf)   AA+ (sf)/Watch Pos
A-2b         AA+ (sf)   A+ (sf)/Watch Pos
A-3          BBB+ (sf)  BBB+ (sf)/Watch Pos
B            BBB (sf)   B+ (sf)/Watch Pos
C            BB+ (sf)   CCC- (sf)/Watch Pos
D            B+ (sf)    CCC- (sf)/Watch Pos


FIRST UNION 1999-C2: Moody's Keeps 'C' Rating on M Certificates
---------------------------------------------------------------
Moody's Investors Service upgraded the ratings of three classes
and affirmed four CMBS classes of First Union National Bank -
Chase Manhattan Bank Commercial Mortgage Trust, Commercial
Mortgage Pass-Through Certificates, Series 1999-C2 as follows:

Cl. G, Affirmed at Aaa (sf); previously on Sep 16, 2010 Upgraded
to Aaa (sf)

Cl. H, Affirmed at Aaa (sf); previously on Apr 22, 2011 Upgraded
to Aaa (sf)

Cl. J, Upgraded to Aa2 (sf); previously on Apr 22, 2011 Upgraded
to A3 (sf)

Cl. K, Upgraded to Ba1 (sf); previously on Apr 22, 2011 Upgraded
to B1 (sf)

Cl. L, Upgraded to B2 (sf); previously on Sep 22, 2004 Downgraded
to Caa1 (sf)

Cl. M, Affirmed at C (sf); previously on Sep 16, 2010 Downgraded
to C (sf)

Cl. IO, Affirmed at Caa1 (sf); previously on Feb 22, 2012
Downgraded to Caa1 (sf)

Ratings Rationale

The upgrades are due primarily to paydowns and amortization, as
well as an increase in the share of defeased loans in the pool.

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

The rating of the IO Class, Class IO, is consistent with the
expected credit performance of its referenced classes and thus is
affirmed..

Moody's rating action reflects a cumulative base expected loss of
approximately 10.3% of the current deal balance. At last review,
Moody's cumulative base expected loss was approximately 6.5%.
Moody's provides a current list of base 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 Conduit U.S. CMBS Transactions" published in September
2000, "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. For deals that include a pool of credit tenant
loans, Moody's uses its credit-tenant lease ("CTL") financing
methodological approach ("CTL" approach). Under Moody's CTL
approach, the rating of a transaction's certificates is primarily
based on the senior unsecured debt rating (or the corporate family
rating) of the tenant, usually an investment grade rated company,
leasing the real estate collateral supporting the bonds. This
tenant's credit rating is the key factor in determining the
probability of default on the underlying lease. The lease
generally is "bondable", which means it is an absolute net lease,
yielding fixed rent paid to the trust through a lock-box,
sufficient under all circumstances to pay in full all interest and
principal of the loan. The leased property should be owned by a
bankruptcy-remote, special purpose borrower, which grants a first
lien mortgage and assignment of rents to the securitization trust.
The dark value of the collateral, which assumes the property is
vacant or "dark", is then examined to determine a recovery rate
upon a loan's default. Moody's also considers the overall
structure and legal integrity of the transaction. For deals that
include a pool of credit tenant loans, Moody's currently uses a
Gaussian copula model, incorporated in its public CDO rating model
CDOROMv2.8 to generate a portfolio loss distribution to assess the
ratings.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.60 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade underlying ratings is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit estimate of the loan which corresponds to a range of credit
enhancement levels. Actual fusion credit enhancement levels are
selected based on loan level diversity, pool leverage and other
concentrations and correlations within the pool. Negative pooling,
or adding credit enhancement at the underlying rating level, is
incorporated for loans with similar credit estimates in the same
transaction.

Moody's 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 5, compared to a Herf of 13 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 8.2 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 April 22, 2011.

DEAL PERFORMANCE

As of the March 16, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 94% to $73 million
from $1.18 billion at securitization. The Certificates are
collateralized by 38 mortgage loans ranging in size from less than
1% to 12% of the pool. The CTL component of the pool includes
thirteen loans, representing approximately 24% of the pool.
Fourteen loans, representing approximately 33% of the pool, are
defeased and are collateralized by U.S. Government securities.

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

Forty-eight loans have liquidated from the pool, resulting in an
aggregate realized loss of $20 million (16% average loan loss
severity). Currently, two loans, representing 9% of the pool, are
in special servicing. The largest specially serviced loan is the
Belmont Crossing Loan ($5 million -- 7% of the pool), which is
secured by a late-1960s era, 192-unit multifamily complex in
Smyrna, Georgia, a suburb of Atlanta. The borrower, unable to pay
off the loan at maturity in March 2009, agreed to a Deed in Lieu
of Foreclosure in December 2010, and the property is now REO. The
property is listed for sale and a purchase and sale agreement is
under negotiation. The servicer has recognized a $3.2 million
appraisal reduction for this loan.

The second specially-serviced loan is the OfficeMax Retail Center
Loan ($2 million -- 3% of the pool). The borrower has requested a
loan modification and extension, which Moody's expects to be
approved in the near term. Moody's estimates an aggregate $3.6
million loss for all specially serviced loans.

Moody's has assumed a high default probability for one poorly-
performing loan representing 2% of the pool. Moody's analysis
attributes to this troubled loan an aggregate $250,000 loss (20%
expected loss severity based on a 50% probability default).

Moody's was provided with full-year 2010 and partial year 2011
operating results for 91% and 68% of the performing pool,
respectively. Excluding troubled loans, Moody's weighted average
LTV is 68%, compared to 70% at last full review. Moody's net cash
flow reflects a weighted average haircut of 17% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 10.7%.

Excluding troubled loans, Moody's actual and stressed DSCRs are
1.11X and 1.87X, respectively, compared to 1.30X and 1.78X 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 30% of the pool.
The largest loan is the Academy Plaza Loan ($9 million -- 12% of
the pool). The loan is secured by a 156,000 square foot grocery-
anchored retail center in Philadelphia, Pennsylvania. The property
was 81% leased as of YE 2011, the same as Moody's last review. The
anchor is Acme Markets, a subsidiary of SuperValu, Inc. (Moody's
senior unsecured rating B2, stable outlook). Moody's current LTV
and stressed DSCR are 74% and 1.38X, respectively, compared to 71%
and 1.43X at last review.

The second-largest loan is a portfolio loan ($8 million -- 12% of
the pool) consisting of four cross-collateralized hotel loans. The
loans are secured by two hotels located in Alexandria, Virginia,
one hotel located in Fredericksburg, Virginia, and one hotel
located in Shreveport, Louisiana. The portfolio originally
included six hotel loans, two of which are now defeased. All four
loans in the portfolio are currently on the watchlist due to poor
performance at the Days Inn -- Fredericksburg and the Days Inn --
Shreveport. Performance at the Fredericksburg hotel has improved
considerably since Moody's last review. The two Alexandria hotels,
a Days Inn and a Comfort Inn, are located in the Washington, DC
regional market and together represent approximately 93% of the
total Net Operating Income across the portfolio. Moody's current
LTV and stressed DSCR are 75% and 1.88X, respectively, compared to
83% and 1.70X at last review.

The third-largest loan is the Whitehall Estates Loan ($5 million -
- 7% of the pool). The loan is secured by a 252-unit multifamily
property in Charlotte, North Carolina. The property was built in
1997, and is 96% leased, similar to the occupancy at Moody's last
review. Moody's current LTV and stressed DSCR are 50% and, 2.07X
respectively, compared to 52% and 1.99X at last review.

The CTL component includes 13 loans secured by properties leased
under bondable leases. Moody's provides ratings for 94% of the CTL
component and has updated its internal credit estimate for the
remainder of the CTL credits. The largest exposures include Rite
Aid Corp. (43% of the CTL component, Moody's Long Term Corporate
Family Rating Caa2 -- stable outlook), Walgreen Co. (30%; Moody's
senior unsecured rating A2 -- stable outlook), and CVS/Caremark
(20%; Moody's senior unsecured rating Baa2 -- stable outlook).


FIRST UNION 2001-C1: Moody's Keeps 'Ca' Rating on Class J Certs.
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of seven CMBS
classes of First Union National Bank -- Bank of America,
Commercial Mortgage Pass-Through Certificates, Series 2001-C1 as
follows:

Cl. E, Affirmed at Aaa (sf); previously on Dec 17, 2010 Upgraded
to Aaa (sf)

Cl. F, Affirmed at Aa2 (sf); previously on Jun 1, 2011 Upgraded to
Aa2 (sf)

Cl. G, Affirmed at Baa1 (sf); previously on Jul 23, 2009 Confirmed
at Baa1 (sf)

Cl. H, Affirmed at B3 (sf); previously on Jun 1, 2011 Downgraded
to B3 (sf)

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

Cl. IO-I, Affirmed at Caa2 (sf); previously on Feb 22, 2012
Downgraded to Caa2 (sf)

Cl. IO-III, Affirmed at Caa2 (sf); previously on Feb 22, 2012
Downgraded to Caa2 (sf)

Ratings Rationale

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

The ratings of the IO Classes, Class IO-I and Class IO-III, are
consistent with the expected credit performance of their
referenced classes and thus are affirmed.

Moody's rating action reflects a cumulative base expected loss of
28.9% of the current balance. At last review, Moody's cumulative
base expected loss was 22.8%. The increase in base expected loss
is larger on a percentage basis due to paydowns since the prior
review. Realized losses have increased from 8.0% of the original
balance to 8.2% since the prior review. Moody's provides a current
list of base 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 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 6 compared to 10 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 8.2 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 xxx.

DEAL PERFORMANCE

As of the March 16, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 93% to $ 97.1
million from $ 1.31 billion at securitization. The Certificates
are collateralized by 12 mortgage loans ranging in size from 2% to
31% of the pool, with the top ten non-defeased loans representing
96% of the pool. There are no defeased loans or loans with
investment grade credit estimates.

One loan, representing 31% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Thirty-eight loans have been liquidated from the pool, resulting
in a realized loss of $79.1 million (31% loss severity). Currently
ten loans, representing 62% of the pool, are in special servicing.
The largest specially serviced loan is the Palisades Apartments
Loan ($13.1 million -- 13.5% of the pool), which is secured by a
280-unit multifamily complex located in Las Vegas, Nevada. The
loan was transferred to special servicing in January 2011 due to
maturity default and has been delinquent since November 2010. The
borrower has been unable to retain refinancing and the servicer
has filed for foreclosure. Property performance has remained
stable with occupancy at 91.4% as of December 2011.

The second largest specially serviced loan is the Tripp Industrial
Loan ($11.0 million -- 11.3% of the pool), which is secured by
nine warehouse buildings ( 836,264 SF) located in Greenville,
North Carolina. The loan was transferred to special servicing in
December 2010 due to maturity default. The borrower was given a 12
month extension till January 2012 but was unable to find
refinancing during the extension period. The special servicer is
proceeding with foreclosure and has taken a $2.35 million
appraisal reduction for this loan.

The third largest specially serviced loans is the Rosewood Care
Center Loan ($8.0 million --8.3% of the pool), which is secured by
a 120 unit assisted living facility located in Swansea, IL outside
of St. Louis. The property suffers from mine subsidence as it was
built on top of an old coal mine. The borrower and operator filed
for bankruptcy protection in February 2012. The special servicer
is moving forward to purse noteholder's rights and remedies and
has taken a $4.8 million appraisal reduction for this loan.

The remaining specially serviced loans are secured by a mix of
property types. The master servicer has recognized appraisal
reductions totaling $12.0 million for eight of the specially
serviced loans. Moody's has estimated an aggregate $19.5 million
loss (37% expected loss on average) for seven of the specially
serviced loans.

Based on the most recent remittance statement, Classes H through Q
have experienced cumulative interest shortfalls totaling $4.4
million, up from $2.9 million at last review. Moody's anticipates
that the pool will continue to experience interest shortfalls
because of the high exposure to specially serviced loans. Interest
shortfalls are caused by special servicing fees, including workout
and liquidation fees, appraisal entitlement reductions (ASERs) and
extraordinary trust expenses.

Moody's was provided with full-year 2010 100% of the pool.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 100%, the same as last review. Moody's net cash
flow reflects a weighted average haircut of 2% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 10.1%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.45X and 1.10X, respectively, compared to
1.31X and 1.11X 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 one performing conduit loan is the EmeryTech loan ($36.9
million -- 30.9% of the pool), which is secured by a 223,720 SF
office building located in Emeryville, California. In February
2010 the loan was returned from special servicing after being
modified. The modification split the loan into a $30 million A
note and a $6.9 million B note. Currently, the loan is on the
master servicer's watchlist due to low DSCR but the loan is
current. The property's performance was impacted by a decline in
occupancy due to lease expirations and several early terminations
due to business failures. Leasing as of October 2010 improved to
92% due to a new lease with Clif Bar and Company for 52% of the
NRA. Moody's analysis of this loan reflects a stabilized
occupancy. Moody's LTV and stressed DSCR are 122% and 1.09X,
respectively, compared to 127% and 1.04X at last review. Moody's
has assumed a high default probability for the B note, estimating
a $5.1 million loss (75% expected loss based on a 75% probability
default) for the B note.


FLATIRON CLO 2011-1: S&P Affirms 'BB' Rating on Class E Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Flatiron CLO 2011-1 Ltd./Flatiron CLO 2011-1 Inc.'s $322.25
million floating-rate notes following the transaction's effective
date as of Jan. 26, 2012.

"Most U.S. cash flow collateralized debt obligations (CLOs) close
before purchasing the full amount of their targeted level of
portfolio collateral. On the closing date, the collateral manager
typically covenants to purchase the remaining collateral within
the guidelines specified in the transaction documents to reach the
target level of portfolio collateral. Typically, the CLO
transaction documents specify a date by which the targeted level
of portfolio collateral must be reached. The 'effective date' for
a CLO transaction is usually the earlier of the date on which the
transaction acquires the target level of portfolio collateral, or
the date defined in the transaction documents. Most transaction
documents contain provisions directing the trustee to request the
rating agencies that have issued ratings upon closing to affirm
the ratings issued on the closing date after reviewing the
effective date portfolio (typically referred to as an 'effective
date rating affirmation')," S&P said.

"An effective date rating affirmation reflects our opinion that
the portfolio collateral purchased by the issuer, as reported to
us by the trustee and collateral manager, in combination with the
transaction's structure, provides sufficient credit support to
maintain the ratings that we assigned on the transaction's closing
date. The effective date reports provide a summary of certain
information that we used in our analysis and the results of our
review based on the information presented to us," S&P said.

"We believe the transaction may see some benefit from allowing a
window of time after the closing date for the collateral manager
to acquire the remaining assets for a CLO transaction. This window
of time is typically referred to as a 'ramp-up period.' Because
some CLO transactions may acquire most of their assets from the
new issue leveraged loan market, the ramp-up period may give
collateral managers the flexibility to acquire a more diverse
portfolio of assets," S&P said.

"For a CLO that has not purchased its full target level of
portfolio collateral by the closing date, our ratings on the
closing date and prior to our effective date review are generally
based on the application of our criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to us by the
collateral manager, and may also reflect our assumptions about the
transaction's investment guidelines. This is because not all
assets in the portfolio have been purchased," S&P said.

"When we receive a request to issue an effective date rating
affirmation, we perform quantitative and qualitative analysis of
the transaction in accordance with our criteria to assess whether
the initial ratings remain consistent with the credit enhancement
based on the effective date collateral portfolio. Our analysis
relies on the use of CDO Evaluator to estimate a scenario default
rate at each rating level based on the effective date portfolio,
full cash flow modeling to determine the appropriate percentile
break-even default rate at each rating level, the application of
our supplemental tests, and the analytical judgment of a rating
committee," S&P said.

"In our published effective date report, we discuss our analysis
of the information provided by the transaction's trustee and
collateral manager in support of their request for effective date
rating affirmation. In most instances, we intend to publish an
effective date report each time we issue an effective date rating
affirmation on a publicly rated U.S. cash flow CLO," S&P said.

"On an ongoing basis after we issue an effective date rating
affirmation, we will periodically review whether, in our view, the
current ratings on the notes remain consistent with the credit
quality of the assets, the credit enhancement available to support
the notes, and other factors, and take rating actions as we deem
necessary," S&P said.

        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
Flatiron CLO 2011-1 Ltd./Flatiron CLO 2011-1 Inc.

Class                Rating      Amount (mil. $)
A                    AAA (sf)             220.00
B                    AA (sf)               53.00
C-1 (deferrable)     A (sf)                 8.25
C-2 (deferrable)     A (sf)                11.00
D (deferrable)       BBB (sf)              16.00
E (deferrable)       BB (sf)               14.00
Subordinated notes   NR                    31.50

NR - Not rated.


G-STAR 2002-1: Moody's Raises Rating on Class C Notes to 'Caa1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of four classes
of Notes issued by G-Star 2002-1, Ltd. due to rapid amortization
of the notes, despite deterioration in the underlying collateral
as evidenced by the Moody's 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
and Re-Remic) transactions.

Class A-2 Floating Rate Notes Due 2017, Upgraded to Aaa (sf);
previously on Jun 29, 2010 Upgraded to A2 (sf)

Class BFL Floating Rate Notes Due 2037, Upgraded to Ba1 (sf);
previously on Jun 29, 2010 Upgraded to Ba3 (sf)

Class BFX 7.075% Notes Due 2037, Upgraded to Ba1 (sf); previously
on Jun 29, 2010 Upgraded to Ba3 (sf)

Class C 8% Notes, Upgraded to Caa1 (sf); previously on Jun 29,
2010 Upgraded to Caa3 (sf)

Ratings Rationale

G-Star 2002-1 Ltd. is static cash CRE CDO transaction backed by a
portfolio of commercial mortgage backed securities (CMBS) (94.5%
of the pool balance), real estate investment trust (REIT) debt
(4.3%) and asset backed securities (1.2%). As of the February 27,
2012 Trustee report, the aggregate Note balance of the
transaction, including preferred shares, amortized to $71.8
million from a par balance of $377.7 million at issuance, with the
current paydown directed to the Class A Notes, due to the failure
of the Class B par value tests which switched the payment priority
from pro-rata to sequential.

There are five assets with a par balance of $29.5 million (29.9%
of the current pool balance) that are considered Defaulted
Securities as of the February 27, 2012 Trustee report. All of
these assets (100.0% of the defaulted balance) are CMBS. Defaulted
Securities are defined as assets which are either three or more
days in default of their debt service payment, bankrupt,
insolvent, in receivership, have been written down, or have been
downgraded to a defaulted rating category.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 2,911 compared to 1,343 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (12.2% compared to 18.7% at last review), A1-A3
(5.4% compared to 4.3% at last review), Baa1-Baa3 (22.2% compared
to 19.8% at last review), Ba1-Ba3 (31.0% compared to 36.1% at last
review), B1-B3 (3.6% compared to 10.4% at last review), and Caa1-C
(25.5% compared to 10.8% 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 3.2 years compared
to 2.8 at last review. The longer WAL is due to the current
profile of the remaining collateral pool since last review and
assumption about underlying collateral extensions.

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
22.7% compared to 31.2% 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 31.6% compared to 30.7% at last review.

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

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

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
28% to 18% or up to 38% would result in average rating movement on
the rated tranches of 0 to 2 notches downward and 0 to 2 notches
upward, respectively.

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, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


GALAXY XII: S&P Gives 'BB' Rating on Class E Deferrable Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Galaxy XII CLO Ltd./Galaxy XII CLO Inc.'s $369.5
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 29,
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
   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 consists primarily
   of broadly syndicated speculative-grade senior secured term
   loans.

* The collateral 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
   0.7482%-13.8391%," 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 interest diversion test, a failure of which
   during the reinvestment period will lead to the
   reclassification of up to 50% of excess interest proceeds that
   are available (before paying subordinated and incentive
   collateral management fees and uncapped administrative expenses
   and fees, topping up the expense reserve account, and paying
   uncapped hedge amounts and subordinated note payments) to
   principal proceeds for the purchase of additional collateral
   assets or, after the noncall period, to pay the notes
   sequentially, at the election of the collateral manager. Also,
   any principal proceeds that were classified as interest
   proceeds prior to the first determination date and unused
   proceeds that were classified as interest proceeds prior to the
   first two determination dates will be reclassified as principal
   proceeds before paying subordinated and incentive collateral
   management fees and uncapped administrative expenses and fees,
   topping up the expense reserve account, and paying uncapped
   hedge amounts and subordinated note payments.

            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


PRELIMINARY RATINGS ASSIGNED
Galaxy XII CLO Ltd./Galaxy XII CLO Inc.

Class                   Rating            Amount
                                        (mil. $)
A                       AAA (sf)          251.50
B                       AA (sf)            55.00
C (deferrable)          A (sf)             28.00
D (deferrable)          BBB (sf)           19.00
E (deferrable)          BB (sf)            16.00
Subordinated notes (i)  NR                 43.00

NR - Not rated.


GALE FORCE 3: S&P Raises Rating on Class E Notes to 'BB'
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B-1, B-2, C, D, and E notes from Gale Force 3 CLO Ltd.,
a collateralized loan obligation (CLO) transaction managed by GSO
Capital Partners L.P. "At the same time, we affirmed the ratings
on the class A notes and raised the rating on the B notes from
Liston Funding 2010-1 Ltd.," S&P said.

"The upgrades reflect the improved performance we have observed in
Gale Force 3 CLO Ltd.'s underlying asset portfolio since we last
downgraded the notes on Jan. 21, 2010. As of the Feb. 2, 2012,
trustee report, the transaction had $5.18 million in defaulted
assets, compared with the $20.58 million noted in the Dec. 2,
2009, trustee report, which we referenced for our January 2010
rating actions. The trustee reported about $32.5 million in 'C'
basket obligations in the Feb. 2, 2012, report with no excess
reported. This number compares with an amount of more than $76
million noted in the December 2009 report and a haircut of about
$1.4 million noted as excess and haircut in the
overcollateralization (O/C) ratios," S&P said.

"The transaction has also maintained the overcollateralization
available to support the rated notes since our review in January
2010," S&P said. The trustee reported the O/C ratios in the Feb.
2, 2012, monthly report:

* The class B-2 O/C ratio was 120.67%, compared with a reported
   ratio of 120.00% in December 2009;

* The class C O/C ratio was 114.54%, compared with a reported
   ratio of 113.91% in December 2009;

* The class D O/C ratio was 108.70%, compared with a reported
   ratio of 108.10% in December 2009; and

* The class E O/C ratio was 104.53%, compared with a reported
   ratio of 103.95% in December 2009.

Liston Funding 2010-1 Ltd. is a retranching of the A-1 and A-2
notes from Gale Force 3 CLO Ltd. The affirmation of the class A
notes reflects sufficient credit support available to support
their current rating of 'AAA (sf)'. The upgrade of the class B
notes reflects the upgrade on the A-1 and A-2 notes from Gale
Force 3 CLO Ltd.

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 Report
included in this credit rating report is available at

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Gale Force 3 CLO Ltd.
                      Rating
Class            To                    From
A-1              AA+ (sf)              AA (sf)
A-2              AA+ (sf)              AA (sf)
B-1              AA- (sf)              A (sf)
B-2              AA- (sf)              A (sf)
C                A (sf)                BBB+ (sf)
D                BBB (sf)              BB+ (sf)
E                BB(sf)                CCC-(sf)

Liston Funding 2010-1 Ltd.
                      Rating
Class            To                    From
B                AA+ (sf)              AA (sf)

RATING AFFIRMED

Liston Funding 2010-1 Ltd.
Class            Rating
A                AAA (sf)

TRANSACTION INFORMATION

Issuer:              Gale Force 3 CLO Ltd.
Coissuer:            Gale Force 3 CLO Corp.
Collateral manager:  GSO Capital Partners L.P.
Trustee:             State Street Bank & Trust Co.
Transaction type:    Cash flow CLO

Issuer:              Liston Funding 2010-1 Ltd.
Trustee:             U.S. Bank N.A.
Transaction type:    Cash flow CDO retranching


GMAC 2000-C1: Moody's Affirms Caa3 Rating on Class X Certificates
-----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of one class and
affirmed two CMBS classes of GMAC Commercial Mortgage Securities,
Inc., Series 2000-C1 Mortgage Pass-Through Certificates as
follows:

Cl. K, Upgraded to Caa3 (sf); previously on Oct 28, 2010
Downgraded to C (sf)

Cl. L, Affirmed at C (sf); previously on Jun 1, 2006 Downgraded to
C (sf)

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

Ratings Rationale

The upgrade affecting the Class K certificates is due primarily to
paydowns and the expectation of future recoveries from the two
loans in special servicing, which together represent 92% of the
total pool balance.

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

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

Moody's rating action reflects a cumulative base expected loss of
approximately 46.4% of the current deal balance. At last review,
Moody's cumulative base expected loss was approximately 50.9%.
Moody's provides a current list of base 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.

Due to the high percentage of loans in special servicing, Moody's
analysis also considered a loss and recovery analysis for
specially serviced loans. Under this approach, Moody's assumes an
expected loss for each loan and determines the impact of losses
and recoveries on the certificates.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.60 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade underlying ratings is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit estimate of the loan which corresponds to a range of credit
enhancement levels. Actual fusion credit enhancement levels are
selected based on loan level diversity, pool leverage and other
concentrations and correlations within the pool. Negative pooling,
or adding credit enhancement at the underlying rating level, is
incorporated for loans with similar credit estimates in the same
transaction.

Moody's 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 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 May 12, 2011.

DEAL PERFORMANCE

As of the March 15, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 99% to $7 million
from $880 million at securitization. The Certificates are
collateralized by 3 mortgage loans ranging in size from less than
9% to 49% of the pool. One loan, representing approximately 9% of
the pool, is defeased and is collateralized by U.S. Government
securities. The pool includes no loans with investment-grade
credit estimates.

Thirty loans have liquidated from the pool, resulting in an
aggregate realized loss of $27.4 million (17% average loan loss
severity). Currently, two loans, representing 91% of the pool, are
in special servicing. The largest specially serviced loan is the
2070 Maple Street Loan ($4 million -- 49% of the pool). The loan
is secured by a 230,000 square foot industrial building in Des
Plains, Illinois, a western suburb of Chicago. The loan matured in
January 2010, and was foreclosed on in January 2011. The property
is now REO and is being marketed by Foresite Realty. The property
was listed for sale for $2.7 million in May 2011. The property
sale is in advanced negotiations.

The second loan in special servicing is the Plum Tree Center Loan
($3 million -- 41% of the pool). The loan is secured by a 42,000
square foot multi-tenant office property in Boca Raton, Florida.
The borrower agreed to a Deed in Lieu of Foreclosure in September
2011. The property is now REO and was listed for sale in January
2012 by Resource Real Estate Group. Several offers have been
received and are under review. The list price for the asset is
$3.4 million.

Moody's estimates an aggregate $3 million loss for the two
specially serviced loans.


GREENS CREEK: S&P Raises Rating on Class D Notes to 'BB+'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, C, and D notes from Greens Creek Funding Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
Silvermine Capital Management LLC. "At the same time, we affirmed
our rating on the class A-1 notes," S&P said.

"The upgrades reflect an increase in the credit support available
to the notes since we last changed our ratings on some of the
notes in February 2010 following the application of our September
2009 corporate collateralized debt obligation (CDO) criteria. The
affirmation of the 'AA+' rating on the class A-1 notes is based on
our opinion that the credit support available to support the class
A-a notes is sufficient to maintain the current rating under our
corporate CDO criteria," S&P said.

"In October 2011, the transaction paid down $20 million of the
class A-1 notes as a special redemption and received a capital
infusion in the form of $17.5 million of income notes in December
2011. The paydown reduced the class A-1 note balance to $302.91
million (88.5% of its original balance) from $322.91 million
(94.42% of its original balance) in January 2010, which we used
for the February 2010 rating actions. The lower balance and the
additional capital increased the credit support available to
support the rated notes," S&P said.

"In addition, the transaction resumed its reinvestment activities
in January 2012 following the removal of a restriction in its
reinvestment activities. The principal cash balance declined from
$241 million in January 2012 to $117 million in February 2012; the
balance was $48 million as per the March 7, 2012, trustee report,
which was released earlier this week. Our analysis assumed that
the transaction would reinvest the remaining principal proceeds
in additional collateral," S&P said.

The transaction was passing all of its coverage tests as of the
March trustee report, and the portfolio has fewer defaulted assets
and improved credit quality than in January 2010.

"Standard & Poor's notes that the transaction has paid down the
class D note balance to 82.14% of its original balance because it
was previously failing its class D coverage tests; the transaction
is structured such that it applies any interest proceeds used to
cure the class D coverage failure to pay down the class D notes.
The transaction has not paid down the class D note balance since
our January 2010 rating actions," 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

Greens Creek Funding Ltd.
                        Rating
Class              To           From
A-2                AA (sf)      A+ (sf)
B                  A (sf)       BBB+ (sf)
C                  BBB (sf)     BBB- (sf)
D                  BB+ (sf)     BB (sf)

RATING AFFIRMED

Greens Creek FundingLtd.
Class              Rating
A-1                AA+ (sf)


GREENWICH CAPITAL 2005-GG5: Moody's Reviews 'Ca' Ratings
--------------------------------------------------------
Moody's Investors Service placed 10 classes of Greenwich Capital
Commercial Funding Corp. Commercial Mortgage Trust, Series 2005-
GG5 on review for possible downgrade as follows:

Cl. A-5, Aaa (sf) Placed Under Review for Possible Downgrade;
previously on Jan 17, 2006 Definitive Rating Assigned Aaa (sf)

Cl. A-M, Aa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2011 Confirmed at Aa2 (sf)

Cl. A-J, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2011 Confirmed at A3 (sf)

Cl. B, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2011 Downgraded to B1 (sf)

Cl. C, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2011 Downgraded to B3 (sf)

Cl. D, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2011 Downgraded to Caa1 (sf)

Cl. E, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2011 Downgraded to Caa2 (sf)

Cl. F, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2011 Downgraded to Ca (sf)

Cl. G, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 28, 2011 Confirmed at Ca (sf)

Cl. XP, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Feb 22, 2012 Downgraded to Baa1 (sf)

Ratings Rationale

The classes were placed on review for possible downgrade due to
higher expected losses for the pool resulting from actual and
anticipated losses from specially serviced and troubled loans
along with the possibility of interest shortfalls affecting
investment grade classes.

The IO Class, Class XP, was placed on review for possible
downgrade due to its reference classes being placed on review for
possible downgrade.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated April 28, 2011.

DEAL AND PERFORMANCE SUMMARY

As of the March 12, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 15% to $3.65
billion from $4.30 billion at securitization. The Certificates are
collateralized by 150 mortgage loans ranging in size from less
than 1% to 9% of the pool, with the top ten loans representing 46%
of the pool.

Thirty-eight loans, representing 14% of the pool, are on the
master servicer's watchlist. The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the CRE Finance Council (CREFC) monthly reporting package. As part
of Moody's ongoing monitoring of a transaction, Moody's reviews
the watchlist to assess which loans have material issues that
could impact performance.

Twenty-one loans have been liquidated from the pool, resulting in
an aggregate realized loss of $103.8 million (30% loss severity).
Twenty-four loans, representing 23% of the pool, are currently in
special servicing. The specially serviced loans are secured by a
mix of multifamily, retail, office, industrial, and hotel property
types. The master servicer has recognized appraisal reductions
totaling $318.7 million for twenty loans in the pool.

Moody's review will focus on potential losses from specially
serviced and troubled loans, specifically the Schron Industrial
Portfolio ($317.5 million, 8.7% of the pool), performance of the
overall pool, and the potential impact of interest shortfalls on
class AJ.

The principal methodology used in this rating was "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.


GS MORTGAGE 2010-C1: Moody's Affirms 'B2' Rating on Class F Notes
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of eight classes of
GS Mortgage Securities Corporation II Commercial Mortgage Pass-
Through Certificates 2010-C1.

Cl. A-1, Affirmed at Aaa (sf); previously on Aug 17, 2010
Definitive Rating Assigned Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Aug 17, 2010
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Aug 17, 2010 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed at A2 (sf); previously on Aug 17, 2010 Definitive
Rating Assigned A2 (sf)

Cl. D, Affirmed at Baa3 (sf); previously on Aug 17, 2010
Definitive Rating Assigned Baa3 (sf)

Cl. E, Affirmed at Ba2 (sf); previously on Aug 17, 2010 Definitive
Rating Assigned Ba2 (sf)

Cl. F, Affirmed at B2 (sf); previously on Aug 17, 2010 Definitive
Rating Assigned B2 (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.

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

Primary sources of assumption uncertainty are the 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 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 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.

Also used was the CMBS IO calculator ver1.0, which incorporates
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 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 May 20, 2011.

DEAL PERFORMANCE

As of the March 12, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 3% to
$768.3 million from $788.5 million at securitization due to
amortization. The Certificates are collateralized by 23 mortgage
loans. The top five loans represent 50% of the pooled balance. All
loans are fixed rate loans. The trust has not experienced losses
or interest shortfalls since securitization.

Moody's weighted average LTV for the pooled trust mortgage balance
is 68.8% compared to 70.2% at last review and 70.8% at
securitization. Moody's stressed debt service coverage ratio
(DSCR) for the pooled trust mortgage balance is 1.53X compared to
1.47X at last review and 1.45X at securitization.

The largest loan in the pool is collateralized by 660 Madison
Avenue ($97 million, 13% of the pool), a 264,000 square foot
retail property 100% leased to Barneys NY in Manhattan's Plaza
District submarket. The property is located on Madison Avenue
between East 60th Street and East 61st Street, a premier shopping
destination notable for high end retailers. The property serves as
Barneys flagship store with the tenant on a lease until 2019.
Moody's current pooled LTV is 65% and stressed DSCR is 1.38X.
Moody's current credit estimate is Baa2, the same as last review.

The second largest loan in the pool is the Mall at Partridge Creek
loan ($81 million, 10.5%) secured by a lifestyle center in
Clinton, Michigan. The mall is 600,000 square feet and located 33
miles north of downtown Detroit. Anchor tenants, Nordstrom and
Parisian, are not part of the loan collateral. The center is
managed by Taubman Centers. As of December 2011, the center was
90% occupied. Comparable in-line sales for 2011 were $390 per
square foot, up 5% from 2010 sales figures. Moody's current pooled
LTV is 79% and stressed DSCR is 1.38X. Moody's current credit
estimate is B1, the same as at last review.

The Burnsville Center loan ($80 million, 10.5%) is the third
largest loan in the pool. Located in Burnsville, Minnesota, the
center was built in 1977 and comprises 1.1 million square foot
regional mall, 523,692 square feet of which is collateral for the
loan. Mall anchors include Macy's, Sears, JC Penney, Dicks
Sporting Goods and Gordmans. The improvements for Macy's, Sears,
and JC Penney are not part of the collateral. As of December 31,
2011, the mall was 99% occupied. The mall is managed by CBL &
Associates and is not the dominant mall in the area. In-line sales
reported at securitization for the trailing twelve month period
ending March 2010 were $337 per square foot. Moody's current
pooled LTV is 68% and stressed DSCR is 1.43X. Moody's current
credit estimate is Baa3, the same as at last review.


GS MORTGAGE 2006-CC1: Moody's Cuts Rating on Cl. A Notes to 'Ca'
----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of one class
of Certificates issued by GS Mortgage Securities Corporation II,
Series 2006-CC1 due to an increase in realized losses combined
with increased and continuing interest shortfalls on the
underlying collateral. 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, Downgraded to Ca (sf); previously on May 20, 2011
Downgraded to Caa2 (sf)

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

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

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

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

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

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

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

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

Ratings Rationale

GS Mortgage Securities Corporation II, Series 2006-CC1 is a static
cash CRE CDO transaction backed by a portfolio of commercial
mortgage backed securities (CMBS) (100% of the pool balance). As
of the March 21, 2012 Trustee report, the aggregate Certificate
balance of the transaction has decreased to $366.1 million from
$406.2 million at issuance, with the paydown directed to the Class
A Certificates as a result of amortization of the underlying
collateral. Classes K, L and M have sustained full realized losses
while Class J has sustained partial 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.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 5,351 compared to 5,111 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (2.5% compared to 2.9% at last review), A1-A3
(1.4% compared to 3.4% at last review), Baa1-Baa3 (12.9% compared
to 11.6% at last review), Ba1-Ba3 (16.9% compared to 18.3% at last
review), B1-B3 (13.0% compared to 13.7% at last review), and Caa1-
C (53.3% compared to 50.1% 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 4.1 years compared
to 4.4 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
6.5% compared to 9.5% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 13.9% compared to 13.4% 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.

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

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
6.5% to 0% or up to 16.5% would result in average rating movement
on the rated tranches of 0 to 1 notch downward and 0 to 1 notch
upward, respectively.

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

Primary sources of assumption uncertainty are the 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, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


HARCH CLO III: S&P Affirms 'CCC+' Rating on Class E Notes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, and C notes from Harch CLO III Ltd., a U.S. collateralized
loan obligation (CLO) transaction managed by Harch Capital
Management LLC. "At the same time, we affirmed our ratings on
the class A-1, D, and E notes. Concurrently, we removed our
ratings on the class A-2, B, C, D, and E notes from CreditWatch,
where we placed them with positive implications on Feb. 10, 2012,"
S&P said.

"The upgrades reflect an improvement in the performance of the
transaction's underlying asset portfolio and paydowns to the class
A-1 notes since December 2009. At that time,  we downgraded most
of the notes following the application of our September 2009
corporate collateralized debt obligation (CDO) criteria," S&P
said.

"As of the February 2012 trustee report, the transaction had $0.55
million of defaulted assets. This was down from $6.03 million
noted in the November 2009 trustee report, which we referenced for
our December 2009 rating actions. Furthermore, assets from
obligors rated in the 'CCC' category were reported at $6.73
million in February 2012, down from $13.12 million in November
2009," S&P said.

"The upgrades also reflect an improvement in the
overcollateralization (O/C) available to support the notes,
primarily due to paydowns to the class A-1 notes since the
December 2009 rating actions. Since that time, the transaction has
paid down the class A-1 notes by approximately $150 million,
reducing their outstanding note balance to 39.15% of its original
balance at issuance," S&P said. The trustee reported the O/C
ratios in the February 2012 monthly report:

* The class A/B O/C ratio was 136.66%, compared with a reported
   ratio of 119.78% in November 2009;

* The class C O/C ratio was 121.96%, compared with a reported
   ratio of 112.65% in November 2009;

* The class D O/C ratio was 110.66%, compared with a reported
   ratio of 106.62% in November 2009; and

* The class E O/C ratio was 103.11%, compared with a reported
   ratio of 102.30% in November 2009.

"We affirmed our ratings on the class A-1, D, and E notes to
reflect the availability of credit support at the 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 AND CREDITWATCH ACTIONS

Harch CLO III Ltd.
                   Rating
Class         To           From
A-2           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             CCC+ (sf)    CCC+ (sf)/Watch Pos

RATING AFFIRMED

Harch CLO III Ltd.
Class                Rating
A-1                  AAA (sf)

TRANSACTION INFORMATION
Issuer:             Harch CLO III Ltd.
Coissuer:           Harch CLO III Inc.
Collateral manager: Harch Capital Management LLC
Underwriter:        Goldman Sachs & Co.
Trustee:            Deutsche Bank Trust Co. Americas
Transaction type:   Cash flow CDO


ICE GLOBAL: S&P Assigns 'BB' Rating on $20MM Class E Notes
----------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to ICE Global Credit CLO Ltd./ICE Global Credit CLO Inc.'s
$416.0 million fixed- and floating-rate notes.

The note issuance is a cash flow emerging market collateralized
loan obligation securitization backed by a revolving pool
consisting of U.S. dollar-denominated senior secured loans, senior
notes, or bonds issued by borrowers located primarily in emerging
markets.

The preliminary ratings are based on information as of March 22,
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
   (excluding 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 consists primarily
   of speculative-grade senior secured term loans, senior notes,
   or bonds issued by borrowers located primarily in emerging
   countries.

* 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
   0.36%-13.63%," 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 interest
proceeds to principal proceeds for the purchase of additional
collateral assets during the reinvestment period. The amount of
interest proceeds that will be reclassified will be limited to 50%
of the remaining interest proceeds available after the payment of
the class E coverage tests but prior to the payment of the
subordinated management fees, uncapped administrative expenses and
fees, subordinated hedge termination payments, portfolio manager
incentive fees, and subordinated note payments.

           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
ICE Global Credit CLO Ltd./ICE Global Credit CLO Inc.

Class                  Rating          Amount (mil. $)
A                      AAA (sf)                  295.0
B                      AA (sf)                    35.0
C-1 (deferrable)       A (sf)                     16.0
C-2 (deferrable)       A (sf)                     17.0
D (deferrable)         BBB (sf)                   33.0
E (deferrable)         BB (sf)                    20.0
Subordinated notes     NR                         84.0

NR - Not rated.


JPMC 2004-CIBC8: Moody's Affirms 'C' Ratings on Four CMBS Classes
-----------------------------------------------------------------
Moody's Investors Service downgraded three and affirmed the
ratings of 13 CMBS classes of J.P. Morgan Commercial Mortgage
Finance Corp., Series 2004-CIBC8 as follows:

Cl. A-3, Affirmed at Aaa (sf); previously on Apr 12, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Apr 12, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Apr 12, 2004
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Apr 12, 2004 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed at Aa3 (sf); previously on Apr 12, 2004 Definitive
Rating Assigned Aa3 (sf)

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

Cl. E, Downgraded to Ba1 (sf); previously on Sep 29, 2010
Downgraded to Baa2 (sf)

Cl. F, Downgraded to Ba3 (sf); previously on Sep 29, 2010
Downgraded to Ba1 (sf)

Cl. G, Downgraded to B3 (sf); previously on Sep 29, 2010
Downgraded to B1 (sf)

Cl. H, Affirmed at Caa3 (sf); previously on Sep 29, 2010
Downgraded to Caa3 (sf)

Cl. J, Affirmed at Ca (sf); previously on Sep 29, 2010 Downgraded
to Ca (sf)

Cl. K, Affirmed at C (sf); previously on Sep 29, 2010 Downgraded
to C (sf)

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

Cl. M, Affirmed at C (sf); previously on Sep 16, 2010 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Sep 16, 2010 Downgraded
to C (sf)

Cl. X-1, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

Ratings Rationale

The downgrades are due to lower credit support from actual and
anticipated losses from loans in special servicing and the
prospect for future interest shortfalls. The affirmations of the
principal classes are due to key parameters, including Moody's
loan to value (LTV) ratio, Moody's stressed DSCR and the
Herfindahl Index (Herf), remaining within acceptable ranges. Based
on Moody's current base expected loss, the credit enhancement
levels for the affirmed classes are sufficient to maintain their
current ratings.

The rating of the IO Class, Class X-1, is consistent with the
expected credit performance of its reference classes and thus is
affirmed.

Moody's rating action reflects a cumulative base expected loss of
6.2% of the current balance. At last full review, Moody's
cumulative base expected loss was 4.4%. The combined cumulative
base expected plus realized losses totals 7.9% compared to 5.5% at
last 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.

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

Primary sources of assumption uncertainty are the 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 pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

Moody's review also incorporated the CMBS IO calculator version
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 the 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
version 1.0 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 27, the same as at last review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through 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 May 4, 2011.

DEAL PERFORMANCE

As of the March 15, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 40% to $748.1
million from $1.254 billion at securitization. The Certificates
are collateralized by 81 mortgage loans ranging in size from less
than 1% to 10% of the pool, with the top ten loans, excluding
defeased loans, representing 41% of the pool. Eight loans,
representing 14% of the pool, have defeased and are collateralized
with U.S. Government securities compared to six defeased loans at
last review. The pool includes one loan with an investment grade
credit estimate, representing 4.6% of the pool, the same as at
last review.

Twenty-four loans, representing 19% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Seven loans have been liquidated from the pool since
securitization resulting in an aggregate $21.5 million loss (31.9%
loss severity on average). There are presently four loans,
representing 12.5% of the pool, in special servicing. The master
servicer has recognized an aggregate $5.6 million appraisal
reduction for one of the specially serviced loans. The largest
specially serviced loan is the Harbor Plaza Loan ($76.6 million -
10.2% of the pool) which was transferred to special servicing in
November 2011 due to an insufficient mortgage payment and
mezzanine lender UCC foreclosure action. Moody's has estimated an
aggregate $23.1 million loss (25% expected loss on average) for
the specially serviced loans.

Moody's has assumed a high default probability for seven poorly
performing loans representing 6% of the pool and has estimated a
$10.6 million loss (23% expected loss based on a 50% probability
of default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 100% and 97% of the non-defeased performing
pool, respectively. Excluding specially serviced and troubled
loans, Moody's weighted average LTV is 85%, compared to 88% at
last full review. Moody's net cash flow reflects a weighted
average haircut of 12.4% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 9.0%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.36X and 1.26X, respectively, compared to
1.35X and 1.19X, respectively, at last full review. Moody's actual
DSCR is based on Moody's net cash flow (NCF) and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stressed rate applied to the loan balance.

The loan with a credit estimate is the Northpark Mall loan ($34.7
million - 4.6% of the pool) which is secured by an 809,166 square
foot (SF) enclosed regional mall located Joplin, Missouri. Overall
occupancy as of December 2011 was 93% compared to 97% at last
review. JC Penney, Sears and Macy's are the anchor tenants and the
former Shopko anchor tenant space serves as the temporary home of
the Joplin High School which was destroyed during the May 2011
tornado. Moody's credit estimate is Aa2, the same as at last
review and the stressed DSCR is 2.2X compared to 2.0X at last
review.

The top three performing conduit loans represent 15% of the pool
balance. The largest loan is the Santee Trolley Square Loan ($49.2
million - 6.6% of the pool), which is secured by a 311,430 SF
retail power center located in Santee, California. Occupancy as of
December 2011 was 98%, the same as at last review. Although
excluded from the collateral, a 127,000 SF Target shadow anchors
this shopping center. Property performance declined slightly since
last review. Moody's LTV and stressed DSCR are 96% and 1.23X,
respectively, compared to 93% and 1.01X at last review.

The second largest loan is the 554 Third Avenue Loan ($31.7
million -- 4.2% of the pool), which is secured by a 126-unit
Execustay property in Manhattan's Murray Hill neighborhood. The
property's financial performance has declined slightly since last
review due to higher real estate taxes. The loan has also
amortized 11% since securitization. Moody's LTV and stressed DSCR
are 79% and 1.06X, respectively, compared to 79% and 1.05X at last
review.

The third largest loan is the PHH Vehicle Management Services Loan
($27.3 million -- 3.6% of the pool), which is secured by a 210,000
SF office building that serves as the world headquarters for PHH
(Moody's senior unsecured rating Ba2, negative outlook) through
February 2014. PHH, which leases 100% of this build-to-suit
building, has several lease renewal options that must be exercised
prior to September 2012. Otherwise, the lender will sweep all
excess cash flow through loan maturity. Moody's stressed the cash
flow with a lit/dark analysis given the single tenant occupancy
and lease renewal uncertainty at this time. Moody's LTV and
stressed DSCR are 133% and 0.77X, respectively, compared to 92%
and 1.11X at last review.


JPMCC 2006-FL1: S&P Affirms 'CCC' Rating on Class K Certificates
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on four
classes of commercial mortgage pass-through certificates from
JPMorgan Chase Commercial Mortgage Securities Corp.'s series 2006-
FL1, a U.S. commercial mortgage-backed securities (CMBS)
transaction. "Concurrently, we affirmed our ratings on seven other
classes from the same transaction," S&P said.

"The rating actions follow our analysis of the transaction, which
included our revaluation of the remaining two floating-rate
amortizing loans, deal structure, and liquidity available to the
trust. Our raised ratings also considered that we expect the
larger of the two remaining loans (70.5% of the trust balance),
based on information from the master servicer, to most likely
be refinanced and repay in full by its June 9, 2012, maturity
date," 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 also considered the
refinancing risk on the Independence Mall loan. We affirmed our
'AAA (sf)' rating on the class X-2 interest-only certificates
based on our current criteria," S&P said.

"We based our analysis, in part, on a review of the borrower's
operating statements for the year-ended Dec. 31, 2011, the year-
ended Dec. 31, 2010, the borrower's 2012 operating expenses
budgets, and the borrower's December 2011 rent rolls," S&P said.

As of the March 15, 2012, trustee remittance report, the trust
consisted of two floating-rate amortizing loans indexed to one-
month LIBOR totaling $251.0 million. The one-month LIBOR rate was
0.2485% according to the March 2012 trustee remittance report.

"The Crossgates Mall loan, the larger of the two remaining loans
in the trust, has a trust and whole-loan balance of $176.9 million
(70.5%). The loan is secured by 1.24 million sq. ft. of a 1.68
million-sq.-ft. regional mall in Albany, N.Y. The master servicer,
Wells Fargo Bank N.A. (Wells Fargo), reported a debt service
coverage (DSC) of 5.00x for year-end 2011, and occupancy was
79.1%, according to the Dec. 31, 2011, rent roll. Anchor tenants
include J.C. Penney Co. Inc. (179,964 sq. ft.), Burlington Coat
Factory Warehouse Corp. (64,582 sq. ft.), and Forever 21 Inc.
(62,858 sq. ft.), according to the December 2011 rent roll. Our
adjusted valuation, using an 8.25% capitalization rate, yielded an
in-trust stressed loan-to-value (LTV) ratio of 60.5%. The loan
amortizes on a 30-year schedule and matures on June 9, 2012. Wells
Fargo indicated that the borrower has requested a payoff quote
effective April 9, 2012," S&P said.

"The Independence Mall loan, the smaller of the two remaining
loans in the trust, has a trust and whole-loan balance of $74.1
million (29.5%). The loan is secured by 679,705 sq. ft. of an
830,158-sq.-ft. regional mall in Kingston, Mass. Wells Fargo
reported a 1.66x DSC for year-end 2011, and occupancy was 67.5%,
according to the Dec. 31, 2011, rent roll. Anchor tenants include
Target Corp. (126,000 sq. ft.), Sears holding Corp. (79,441 sq.
ft.), and H&M Group (34,000 sq. ft.), according to the December
2011 rent roll. Our adjusted valuation, using an 9.0%
capitalization rate, yielded an in-trust stressed LTV ratio of
108.1%. The loan amortizes on a 20-year schedule and matures on
Feb. 9, 2013," 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 RAISED

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2006-FL1
              Rating
Class     To          From           Credit enhancement (%)
D         AAA (sf)    AA+ (sf)                        41.32
E         AAA (sf)    AA (sf)                         34.34
F         AAA (sf)    A+ (sf)                         28.75
G         AA- (sf)    A                               22.88

RATINGS AFFIRMED

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2006-FL1
Class     Rating       Credit enhancement %
A-2       AAA (sf)                    75.96
B         AAA (sf)                    61.16
C         AAA (sf)                    48.58
H         A- (sf)                     15.90
J         BB (sf)                     10.03
K         CCC (sf)                     3.33
X-2       AAA (sf)                      N/A

N/A - Not applicable.


KENNECOTT FUNDING: S&P Affirms 'BB-' Ratings on 2 Classes of Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1 and A-2B notes from Kennecott Funding Ltd., a collateralized
loan obligation (CLO) transaction with an APEX revolver feature
managed by Guggenheim Investment Management LLC. "We also affirmed
our ratings on the class A-2A, B, C, D-1, and D-2 notes," S&P
said.

The APEX revolver was available during the reinvestment period to
absorb principal losses. Wells Fargo Bank N.A. is the APEX
revolver provider.

"This transaction has a pro rata sequential pay feature in which
two classes receive payments pro rata, but within the two notes,
subclasses receive payments in a sequential manner. As a result,
some classes can be paid down in full ahead of the other classes
and hence can support higher ratings. In this transaction, the
class A-1 and A-2 notes receive payments pro rata. Within the
class A-2 notes, classes A-2A and A-2B are paid sequentially. As a
result, class A-2A could potentially pay off in full prior to
class A-2B," 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 Feb. 17, 2012, trustee report, the
transaction's asset portfolio held about $10 million in defaulted
assets, down from the $30 million noted in the February 2010
trustee report. Additionally, the collateral pool consisted of
approximately $64 million in assets from obligors rated in the
'CCC' category according to the February 2012 trustee report, down
from $90 million noted in February 2010," S&P said.

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

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

Kennecott Funding Ltd
                         Rating
Class                To           From
A-1                  AA+ (sf)     AA (sf)
A-2B                 AA+ (sf)     AA (sf)

RATINGS AFFIRMED

Kennecott Funding Ltd
Class                Rating
A-2A                 AA+ (sf)
B                    A+ (sf)
C                    BBB+ (sf)
D-1                  BB- (sf)
D-2                  BB- (sf)


LNR CDO III: Moody's Cuts Rating on Class B Notes to 'Ca(sf)'
-------------------------------------------------------------
Moody's Investors Service has downgraded two and affirmed the
ratings of seven classes of Notes issued by LNR CDO III Ltd. The
downgrade is due to the deterioration in the credit quality of the
portfolio as evidenced by a decrease in the weighted average
recovery rate (WARR), additional realized losses since last
review, and an Event of Default (EOD) which occurred on December
29, 2011. 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 and Re-Remic) transactions.

Cl. A, Downgraded to Caa3 (sf); previously on May 4, 2011
Downgraded to B3 (sf)

Cl. B, Downgraded to Ca (sf); previously on May 4, 2011 Downgraded
to Caa3 (sf)

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

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

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

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

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

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

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

Ratings Rationale

LNR CDO III Ltd. is a static CRE CDO transaction backed by a
portfolio of 100% commercial mortgage backed securities (CMBS). As
of the February 23, 2012 trustee report, the aggregate Note
balance of the transaction, including Preferred Shares, excluding
deferred interest, has decreased to $900.5 million from $1.1
billion at issuance, with the paydown directed to the Senior Notes
(Class A to Class G-FL Notes). The paydown was mainly due to full
amortization of underlying B-notes, Mezzanine loans, and certain
CMBS collateral. The current collateral par amount is $651.7
million; which resulted from $198.6 million in full amortization
of collateral assets and $248.8 million in realized losses to the
collateral pool since securitization, of which $98.1 million is
due to additional realized losses since last review.

The transaction entered into EOD on December 29, 2011 due to the
occurrence of a default in the payment of interest due and payable
on the Class A Notes and Class B Notes.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has updated credit estimates for the non-Moody's rated
collateral. The bottom-dollar WARF is a measure of the default
probability within a collateral pool. Moody's modeled a bottom-
dollar WARF of 7,484 compared to 7,390 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (2.1% compared to 1.8% at last review), A1-A3
(0.7% compared to 1.6% at last review), Baa1-Baa3 (5.1% compared
to 2.5% at last review), Ba1-Ba3 (8.3% compared to 10.2% at last
review), B1-B3 (8.6% compared to 10.5% at last review), and Caa1-C
(75.2% compared to 73.4% 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 4.0 years compared
to 4.5 at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
3.9% compared to 6.8% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 100.0%, the same as last review.

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

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

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. In general, the rated notes are particularly
sensitive to changes in recovery rate assumptions. Holding all
other key parameters static, changing the recovery rate assumption
down from 3.9% to 2.0% or up to 9.0% would result in average
rating movement on the rated tranches 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 methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in November 2010, and "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


MERRILL LYNCH 2001-C5: DBRS Rates Class E Certificates 'B(sf)'
---------------------------------------------------------------
DBRS has confirmed the following classes of Merrill Lynch
Financial Assets Inc., Series 2001-Canada 5 as follows:

-- Class A-2 at AAA (sf)
-- Class B at AAA (sf)
-- Class X at AAA (sf)
-- Class D at BBB (sf)
-- Class E at B (sf)

In addition, DBRS has upgraded Class C to AA (high) (sf) from AA
(low) (sf).  The trends on all classes are Stable.

There are five loans left in the pool, and all are scheduled to
mature by May 2013.

The pool is concentrated in one loan, York Mills Gardens
(Prospectus ID#1), which represents more than half of the current
pool balance, with an outstanding principal balance of $16.6
million as of the March 2012 remittance.  This loan is secured by
part of an anchored retail property in Toronto.  The property's
largest tenant is Longo's, representing 37.5% of the net rentable
area (NRA), and is part of the collateral.  This loan is scheduled
to mature in December 2012 with an exit debt yield in excess of
17%.

DBRS considers the Plaza Group Rollup (Prospectus ID#7,33,53,
29.4% of the current pool balance) to be of some concern because
of occupancy issues at one of the three collateral properties.
Lansdowne Place is located in Saint John, New Brunswick, and began
suffering from increased vacancy when its two largest tenants,
Zellers and Eddie Bauer, vacated the property in 2010 and 2011.
Based on historical rent rolls, these tenants accounted for almost
half of the property's base rental income.  This asset represents
68.6% of the allocated loan balance between the three Plaza Group
properties and 44.1% of their combined net cash flow when taking
into account the loss of Zellers and Eddie Bauer.  The remaining
two assets have continued to exhibit stable performance.  These
three loans are cross-defaulted and cross-collateralized, with
full recourse to the borrower, and have no history of delinquency.

The constraining metrics DBRS used in the sizing of this pool were
conservative as a result of the status of the Lansdowne Place
loan.  Although DBRS views the cross-collateralization of the
three Plaza Group properties favourably and does not foresee an
immediate risk of monetary default, Lansdowne Place's dark anchor
space obscures the chances of a timely refinance.


MJH EDUCATION: Moody's Keeps 'Ca' Rating on Housing Revenue Bonds
-----------------------------------------------------------------
Moody's Investors Service has affirmed the Ca rating for MJH
Education Assistance Illinois IV LLC's $57.4 million outstanding
Student Housing Revenue Bonds (Fullerton Village Project), Series
2004A (Senior Bonds) and $14.8 million outstanding Series 2004B
(Subordinate Bonds) issued through the Illinois Finance Authority.
The recommendation to affirm the Ca and C ratings on the Series A
and B are based on expected loss estimates over the next 12 to 24
months. The outlook on the Senior Bonds has been revised to stable
from negative.

Outlook

The change in outlook to stable from negative reflects the
improved operational performance of the project, the university
affiliation with DePaul, and the project's payments of missed
interest payments from December 1, 2008 through June 1, 2011.

What would change the ratings - UP

- A significant improvement in cash flow to the project,
   stemming primarily from increased and stable occupancy and
  rents for the next several years

What would change the ratings - DOWN

- For the 2004A bonds, a decline in occupancy or revenue
   resulting in lower recoveries upon liquidation.

PRINCIPAL METHODOLOGY

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


ML-CFC 2006-2: S&P Lowers Rating on Class F Certificates to 'D'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of commercial mortgage pass-through certificates from ML-
CFC Commercial Mortgage Trust 2006-2, a U.S. commercial mortgage-
backed securities (CMBS) transaction. "Concurrently, we affirmed
our ratings on seven other classes from the same transaction," S&P
said.

"Our rating actions primarily reflect our analysis of the
transaction using our U.S. CMBS conduit/fusion criteria, which
included a review of the credit characteristics of all of the
remaining assets in the pool, the transaction structure, and the
liquidity available to the trust. Furthermore, our downgrades
reflect credit support erosion that we anticipate will occur upon
the eventual resolution of 19 ($227.0 million, 13.6%) of the
transaction's 23 ($254.5 million, 15.2%) assets with the special
servicer. We also considered the monthly interest shortfalls that
are affecting the trust. We lowered our rating on class F to 'D
(sf)' because we expect the interest shortfalls to continue and
believe the accumulated interest shortfalls will remain
outstanding for the foreseeable future," S&P said.

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

"Using servicer-provided financial information, we calculated an
adjusted debt service coverage (DSC) of 1.58x and a loan-to-value
(LTV) ratio of 92.3%. We further stressed the loans' cash flows
under our 'AAA' scenario to yield a weighted average DSC of 1.11x
and an LTV ratio of 123.3%. The implied defaults and loss severity
under the 'AAA' scenario were 66.5% and 33.9%. The DSC and LTV
calculations noted above exclude 19 ($227.0 million, 13.6%) of the
transaction's 23 ($254.5 million, 15.2%) specially serviced assets
and three cross collateralized and cross defaulted loans that
defeased ($7.3 million, 0.4%). We separately estimated losses for
the 19 specially serviced assets and included them in our 'AAA'
scenario implied default and loss figures," S&P said.

"As of the March 12, 2012, trustee remittance report, the trust
experienced monthly interest shortfalls totaling $509,523,
primarily related to appraisal subordinate entitlement reduction
(ASER) amounts of $367,758, special servicing and workout fees
totaling $56,120, interest shortfalls due to rate modifications of
$40,879 and a nonrecoverable interest determination of $39,741.
The interest shortfalls affected all classes subordinate to and
including class E. We expect these interest shortfalls to continue
for the foreseeable future and consequently, we lowered our rating
on class F to 'D (sf)'," S&P said.

                   CREDIT CONSIDERATIONS

"As of the March 12, 2012, trustee remittance report, 23 ($254.5
million, 15.2%) assets in the pool were with the special servicer,
CWCapital Asset Management LLC (CWCapital). The payment status of
the specially serviced assets is: 11 are real estate owned (REO;
$62.8 million, 3.8%), five ($127.6 million, 7.6%) have foreclosed,
four ($48.9 million, 2.9%) are 90-plus-days delinquent, one ($1.9
million, 0.1%) is 60 days delinquent, one ($1.9 million, 0.1%) is
30-plus-days delinquent, and one ($11.4 million, 0.7%) is less
than 30 days delinquent. Appraisal reduction amounts (ARAs)
totaling $82.6 million are in effect for 19 of 23 the specially
serviced assets. Details of the two largest specially serviced
assets, both of which are top 10 loans, are as set forth," S&P
said.

"The Penn Mutual Towers & Washington Square Garage loan ($101.7
million, 6.1%), is the largest asset with the special servicer and
the second-largest loan in the pool. The loan has a total trust
exposure of $108.5 million. The loan is secured by three class A
office towers totaling 853,840 sq. ft. in the Philadelphia central
business district. The loan was transferred to the special
servicer on Feb. 17, 2011, due to imminent monetary default. The
loan is currently in foreclosure. The reported occupancy was 78.0%
as of February 2012. An ARA of $22.5 million is in effect against
this loan. Based on the most recent appraisal value, we expect a
moderate loss upon the eventual resolution of this loan," S&P
said.

"The Blairstone Office Building loan ($34.6 million, 2.1%) is the
second-largest asset with the special servicer and is the fifth-
largest loan in the pool. The loan is secured by a 263,163-sq.-ft.
office property built in 1990 in Tallahassee, Fla. The loan
transferred to the special servicer on July 26, 2011, after the
sole tenant notified the borrower that it planned to vacate the
building. According to the special servicer, a receiver was
appointed in September 2011 and the property remains vacant.
CWCapital indicated that the property is currently being marketed
for lease. An ARA of $20.1 million is in effect against this loan.
Based on the most recent appraisal value, we expect a significant
loss upon the eventual resolution of this loan," S&P said.

"The remaining 21 specially serviced assets have balances that
individually represent less than 0.85% of the total pool balance.
ARAs totaling $40.0 million are in effect against 17 of these
assets. We estimated losses for 17 of the remaining assets,
arriving at a weighted average loss severity of 45.8%. Of the
remaining four assets, two are pending return to the master
servicer as performing loans and the special servicer is
evaluating the remaining two loans for potential modification,"
S&P said.

                       TRANSACTION SUMMARY

"As of the March 12, 2012, trustee remittance report, the total
pool balance was $1.67 billion, which is 90.9% of the pool balance
at issuance. The pool includes 170 loans and 11 REO assets, down
from 191 loans at issuance. The master servicers, Wells Fargo Bank
N.A. (Wells Fargo) and KeyBank Real Estate Capital (KeyBank),
combined provided financial information for 97.0% of the loans in
the pool, the majority of which was full-year 2011 data (43.8%),
with the remainder reflecting partial- or full-year 2009, 2010, or
2011 data," S&P said.

"We calculated a weighted average DSC of 1.63x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.58x and 92.3%. Our adjusted DSC and LTV
figures excluded 19 ($227.0 million, 13.6%) of the transaction's
23 ($254.5 million, 15.2%) specially serviced assets and three
cross collateralized and cross defaulted loans that defeased ($7.3
million, 0.4%). To date, the transaction has experienced $27.2
million in principal losses in connection with nine assets. Forty-
six loans ($287.1 million, 17.2%) in the pool are on the master
servicers' combined watchlist and 47 loans ($302.7 million, 18.1%)
have a reported DSC of less than 1.10x, 39 of which ($213.1
million, 12.7%) 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 balance of $576.3
million (34.4%). Our adjusted DSC and LTV ratio for eight of the
top 10 loans were 2.06x and 76.9%. These figures exclude two of
the top 10 loans with the special servicer. Two ($58.1 million,
3.5%) of the top 10 loans appear on the master servicers' combined
watchlist," S&P said.

"The BTR Capital Portfolio loan ($29.4 million, 1.8%) is the
sixth-largest loan in the pool and the largest loan on the master
servicers' combined watchlist. The loan is secured by a mixed-used
portfolio, which consists of four industrial properties, one
office property, and one retail property totaling 782,624 sq. ft.,
as well as a fee interest in 1.09 sq. ft. of usable industrial
space. All of the collateral is located in the Baltimore
metropolitan statistical area (MSA). The loan was returned to the
master servicer on Feb. 13, 2012, as a modified and corrected loan
and remains on the watchlist due to its low reported DSC. The
modification terms included, but are not limited to, a change in
the note rate to 5.24% from 6.24% and an extension of the loan's
maturity date to July 31, 2015. The servicer reported a 0.94x DSC
for the year ending Dec. 31, 2010. Overall occupancy was 58.9%
according to the Dec. 31, 2010, rent rolls," S&P said.

"The Jefferson Block Apartments loan ($28.7 million, 1.7%) is the
eighth-largest loan in the pool and the second-largest loan on the
master servicers' combined watchlist. The loan, which is secured
by a 217-unit apartment complex in Milwaukee, Wis., appears on the
watchlist due to a low reported DSC. According to the master
servicer, the borrower indicated that the decrease in DSC was due
to a one-time expense incurred in 2010 and reported in its 2011
financial statement. The servicer reported a 1.04x DSC for the
nine months ending Sept. 30, 2011. Occupancy was 91.2%, according
to the December 2011 rent roll," S&P said.

"Standard & Poor's stressed the collateral in the pool according
to our current criteria. The resultant credit enhancement levels
are consistent with our rating actions," 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

ML-CFC Commercial Mortgage Trust 2006-2
Commercial mortgage pass-through certificates
                Rating
Class      To           From        Credit enhancement (%)
AJ         BBB (sf)     BBB+ (sf)                    12.12
B          BB (sf)      BBB (sf)                      9.92
C          BB- (sf)     BBB- (sf)                     8.96
D          CCC+ (sf)    BB+ (sf)                      7.04
E          CCC- (sf)    CCC (sf)                      5.94
F          D (sf)       CCC- (sf)                     4.15

RATINGS AFFIRMED

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

Class    Rating                      Credit enhancement (%)
A-2      AAA (sf)                                     31.37
A-3      AAA (sf)                                     31.37
A-SB     AAA (sf)                                     31.37
A-4      AAA (sf)                                     31.37
A-1A     AAA (sf)                                     31.37
AM       A+ (sf)                                      20.37
X        AAA (sf)                                       N/A

N/A - Not applicable.


MORGAN STANLEY 2003-1Q5: Moody's Affirms Caa1 Rating on N Certs.
----------------------------------------------------------------
Moody's Investors Service upgraded four classes and affirmed the
ratings of 10 CMBS classes of Morgan Stanley Capital I, Inc.
Commercial Mortgage Pass-Through Certificates, Series 2003-IQ5 as
follows:

Cl. A-4, Affirmed at Aaa (sf); previously on Oct 15, 2003
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Mar 19, 2007 Upgraded
to Aaa (sf)

Cl. C, Upgraded to Aa2 (sf); previously on Jun 9, 2010 Upgraded to
Aa3 (sf)

Cl. D, Upgraded to A1 (sf); previously on Mar 19, 2007 Upgraded to
A2 (sf)

Cl. E, Upgraded to A3 (sf); previously on Oct 15, 2003 Definitive
Rating Assigned Baa1 (sf)

Cl. F, Upgraded to Baa1 (sf); previously on Oct 15, 2003
Definitive Rating Assigned Baa2 (sf)

Cl. G, Affirmed at Baa3 (sf); previously on Oct 15, 2003
Definitive Rating Assigned Baa3 (sf)

Cl. H, Affirmed at Ba1 (sf); previously on Oct 15, 2003 Definitive
Rating Assigned Ba1 (sf)

Cl. J, Affirmed at Ba2 (sf); previously on Oct 15, 2003 Definitive
Rating Assigned Ba2 (sf)

Cl. K, Affirmed at Ba3 (sf); previously on Oct 15, 2003 Definitive
Rating Assigned Ba3 (sf)

Cl. L, Affirmed at B1 (sf); previously on Oct 15, 2003 Definitive
Rating Assigned B1 (sf)

Cl. M, Affirmed at B2 (sf); previously on Oct 15, 2003 Definitive
Rating Assigned B2 (sf)

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

Cl. X-1, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

Ratings Rationale

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

The rating of the IO Class, Class X-1, is consistent with the
expected credit performance of its reference classes and thus is
affirmed.

Moody's rating action reflects a cumulative base expected loss of
1.6% of the current balance. At last full review, Moody's
cumulative base expected loss was 1.7%. 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.

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

Primary sources of assumption uncertainty are the 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 pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

Moody's review also incorporated the CMBS IO calculator version
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 the 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
version 1.0 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 16, up from 15 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 May 4, 2011.

DEAL PERFORMANCE

As of the March 15, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 51% to $384 million
from $779 million at securitization. The Certificates are
collateralized by 53 mortgage loans ranging in size from less than
1% to 14% of the pool, with the top ten loans, excluding defeased
loans, representing 58% of the pool. Five loans, representing 13%
of the pool, have defeased and are collateralized with U.S.
Government securities, the same as at last review. The pool
includes one loan with an investment grade credit estimate,
representing 6.3% of the pool, the same as at last review.

Seventeen loans, representing 9% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

No loans have been liquidated from the pool since securitization
and there are also no loans currently in special servicing.

Moody's has assumed no default probability for any poorly
performing loans and has estimated no losses from these troubled
loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 86% and 43% of the non-defeased performing
pool, respectively. Excluding specially serviced and troubled
loans, Moody's weighted average LTV is 70%, compared to 74% at
last full review. Moody's net cash flow reflects a weighted
average haircut of 10.75% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 9.5%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.70X and 1.71X, respectively, compared to
1.52X and 1.51X, respectively, at last full review. Moody's actual
DSCR is based on Moody's net cash flow (NCF) and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stressed rate applied to the loan balance.

The loan with a credit estimate is the Three Times Square Loan
($24.0 million -- 6.3% of the pool), which represents a 21% pari
passu interest in a $115 million loan. The property is also
encumbered by a subordinate B note totaling $94.8 million which is
held outside the trust. The loan is secured by an 884,000 square
foot (SF) Class A office building located in the Times Square
office submarket of midtown Manhattan. The property remains 99%
leased, the same as at last review. The building's largest tenants
are Reuters Group (79% of the net rentable area (NRA) and lease
expiration September 2021) and Bank of Montreal (12% of NRA and
lease expiration November 2021). The loan is fully amortizing and
has amortized 31% since securitization. The loan matures on
November 15, 2021. Moody's current credit estimate and stressed
DSCR are Aaa and 3.42X, respectively, compared to Aaa and 3.08X at
Moody's last review.

The top three performing conduit loans represent 30% of the pool
balance. The largest conduit loan is the Two Commerce Square Loan
($53.5 million -- 13.9% of the pool), which represents a 50% pari
passu interest in a $107 million loan. The property is also
encumbered by a $77 million subordinate B note held outside of the
trust. The loan is secured by a 40-story, 953,000 square foot (SF)
Class A office building located in the Center City office
submarket of Philadelphia, Pennsylvania. The property was 86%
leased as of September 2011 compared to 85% leased at last review.
Property performance has declined due to new tenant leases signed
at market terms, including concession packages, and lower
operating expense recoveries. The largest tenants are Price
Waterhouse Coopers LLP (23% of NRA and lease expiration April
2015) and Reliance Standard Life Insurance (13% of NRA and lease
expiration December 2015). The loan matures Mary 15, 2013. Moody's
LTV and stressed DSCR are 85% and 1.15X, respectively, compared to
79% and 1.23x at last review.

The second largest performing conduit loan is the Plaza America
Office Towers III & IV ($37.2 million - 9.7% of the pool), which
represents a 50% pari passu interest in a $74.4 million loan. The
loan is secured by two Class A office buildings located in Reston,
Virginia totaling 473,000 SF. The property was 100% leased as of
October 2011 compared to 91% leased at last review. This loan has
amortized 12% since securitization. Moody's LTV and stressed DSCR
are 71% and 1.45X, respectively, compared to 74% and 1.39X, at
last review.

The third largest performing conduit loan is the Quail Springs
Marketplace Loan ($25.1 million - 6.5% of the pool), which is
secured by a 295,700 SF retail center located in Oklahoma City,
Oklahoma. The largest tenants are Ultimate Electronics (11% of NRA
and lease expiration January 2014) and Ross Dress for Less (10% of
the NRA and lease expiration January 2014). The property was 98%
leased, the same as at last review. The loan matures May 15, 2013
and has amortized 13% securitization. Moody's LTV and stressed
DSCR are 80% and 1.28X, respectively, compared to 76% and 1.35X at
last review.


MORGAN STANLEY 2004-TOP15: Moody's Affirms C Ratings on 2 Certs.
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 16 CMBS classes
of Morgan Stanley Capital I Inc., Commercial Mortgage Pass-Through
Certificates, Series 2004-TOP15 as follows:

Cl. A-3, Affirmed at Aaa (sf); previously on Aug 4, 2004
Definitive Rating Assigned Aaa (sf)

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

Cl. B, Affirmed at Aa2 (sf); previously on Jun 9, 2010 Confirmed
at Aa2 (sf)

Cl. C, Affirmed at A3 (sf); previously on Jun 9, 2010 Downgraded
to A3 (sf)

Cl. D, Affirmed at Baa1 (sf); previously on Jun 9, 2010 Downgraded
to Baa1 (sf)

Cl. E, Affirmed at Baa3 (sf); previously on Jun 9, 2010 Downgraded
to Baa3 (sf)

Cl. F, Affirmed at Ba1 (sf); previously on Jun 9, 2010 Downgraded
to Ba1 (sf)

Cl. G, Affirmed at Ba3 (sf); previously on Jun 9, 2010 Downgraded
to Ba3 (sf)

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

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

Cl. K, Affirmed at Caa2 (sf); previously on Jun 9, 2010 Downgraded
to Caa2 (sf)

Cl. L, Affirmed at Caa3 (sf); previously on Jun 9, 2010 Downgraded
to Caa3 (sf)

Cl. M, Affirmed at C (sf); previously on Jun 9, 2010 Downgraded to
C (sf)

Cl. N, Affirmed at C (sf); previously on Jun 9, 2010 Downgraded to
C (sf)

Cl. X-1, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on Aug 4, 2004
Definitive Rating Assigned Aaa (sf)

Ratings Rationale

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

The ratings of the IO Classes, Class X-1 and Class X-2, are
consistent with the expected credit performance of their
referenced classes and thus are affirmed.

Moody's rating action reflects a cumulative base expected loss of
2.4% of the current balance. At last review, Moody's cumulative
base expected loss was 2.2%. Realized losses are in line with the
prior review at 0.2% of the original pooled balance. Moody's
provides a current list of base 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 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 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 17 compared to 21 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 8.2 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 April 28, 2011.

DEAL PERFORMANCE

As of the March 13, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 31% to $610.9
million from $889.8 million at securitization. The Certificates
are collateralized by 96 mortgage loans ranging in size from less
than 1% to 18% of the pool, with the top ten non-defeased loans
representing 47% of the pool. Seven loans, representing 7% of the
pool, have defeased and are secured by U.S. Government securities.
Defeasance at last review represented 5% of the pool. The pool
contains two loans with investment grade credit estimates,
representing 28% 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
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Four loans have been liquidated from the pool, resulting in a
realized loss of $1.5 million (6% loss severity on average).
Currently three loans, representing 2% of the pool, are in special
servicing. The specially serviced loans are secured by a mix of
retail, multifamily, and industrial property types. Moody's
estimates an aggregate $5.4 million loss for the specially
serviced loans (43% expected loss on average).

Moody's has assumed a high default probability for four poorly
performing loans representing 4% of the pool and has estimated an
aggregate $3.2 million loss (15% expected loss based on a 30%
probability of default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 91%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 67% compared to 73% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 9% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.1%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.73X and 1.66X, respectively, compared to
1.72X and 1.53X 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 Grace Building Loan
($109.4 million -- 17.9% of the pool), which is secured by a 1.5
million square foot (SF) office building located in the Midtown
submarket of New York City. The loan represents a 33% pari-passu
interest in a $328.2 million loan. There is also a subordinate B
Note of $28.1 million that is held outside of the trust.
Brookfield Office Properties and Swig Equities are the loan
sponsors. The property was 96% leased as of December 2011 compared
to 90% at the last review. NOI is expected to increase after the
rent concessions and free rent periods for the new tenants burn
off. Moody's current credit estimate and stressed DSCR are A3 and
1.44X compared to Baa2 and 1.34X at last full review.

The second loan with a credit estimate is the GIC Office Portfolio
Loan ($62.4 million -- 10.2% of the pool), which is secured by 12
office buildings located in seven states and totaling 6.4 million
SF. The loan represents a 9.3% pari-passu interest in a $672.1
million loan. There is also a subordinate B Note of $121.5 million
that is held outside of the trust. The portfolio was 87% leased as
of December 2010 compared to 71% at the prior review. The borrower
was able to release a majority of the space that AT&T vacated in
March 2009. Moody's current credit estimate and stressed DSCR are
Baa3 and 1.44X, respectively, compared to Baa3 and 1.43X at last
full review.

The top three performing conduit loans represent 9% of the pool
balance. The largest loan is the Village at Newtown Loan ($25.0
million -- 4.1% of the pool), which is secured by a 177,000 SF
retail center located in Newtown Township, Pennsylvania. The
submarket is mature with very strong demographics as average
household income in the county is above $100,000 per year. The
property was 89% leased as of June 2011 compared to 92% at the
last review. Property performance has been relatively stable.
Moody's LTV and stressed DSCR are 73% and 1.29X, respectively,
compared to 82% and 1.15X at last full review.

The second largest loan is the Port Sacramento Industrial Loan
($14.1 million -- 2.3% of the pool), which is secured by a 610,000
SF industrial complex located in West Sacramento, California. The
complex is 100% leased to C&S Logistics through June 2017. Moody's
LTV and stressed DSCR are 80% and 1.36X, respectively, compared to
82% and 1.32X at last review.

The third largest loan is the Third & Main Portfolio Loan ($17.8
million -- 2.6% of the pool), which is secured by four separate
retail buildings built in the 1920's located in Santa Monica,
California. The portfolio is 100% leased which is the same as at
the prior review. Overall, the property is stable and the loan is
benefitting from amortization. Moody's LTV and stressed DSCR are
47% and 1.95X, respectively, compared to 49% and 1.91X at last
full review.


MORGAN STANLEY 2006-TOP21: S&P Cuts Class M Cert Rating to 'D'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
classes of commercial mortgage pass-through certificates from
Morgan Stanley Capital I Trust 2006-TOP21, a U.S. commercial
mortgage-backed securities (CMBS) transaction. "Concurrently, we
affirmed our ratings on 10 other classes from the same
transaction," S&P said.

"The downgrades reflect deterioration in the credit
characteristics of the pool collateral, which under our 'AAA'
scenario, yielded debt service coverage (DSC) of 0.95x and a
(loan-to-value) ratio 168.7%. The downgrades further reflect our
review of the transaction structure, credit support erosion that
we anticipate will occur upon the eventual resolution of one ($4.2
million, 0.4%) of the transaction's two ($5.1 million, 0.5%)
specially serviced loans, and a reduction in the liquidity support
available to the trust due to interest shortfalls. As of the
revised March 12, 2012, trustee remittance report, the trust
experienced monthly interest shortfalls of $15,365, primarily due
to appraisal subordinate entitlement reduction (ASER) amounts
($11,938) and special servicing fees ($1,036). The interest
shortfalls affected all classes subordinate to and including class
M. Our analysis indicated that the total anticipated recurring
monthly interest shortfalls will cause continued interest
shortfalls for class M and the classes subordinate to it for the
foreseeable future and lead to a reduction in the liquidity
support available to the classes senior to it. As a result of our
analysis, we lowered our rating on class M to 'D (sf)'," S&P said.

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

"Using servicer-provided financial information, we calculated
adjusted debt service coverage (DSC) of 1.56x and a loan-to-value
(LTV) ratio of 119.8%. We further stressed the loans' cash flows
under our 'AAA' scenario to yield a weighted average DSC of 0.95x
and an LTV ratio of 168.7%. The implied defaults and loss severity
under the 'AAA' scenario were 73.7% and 39.1%. The DSC and LTV
calculations noted above exclude one ($4.2 million, 0.4%) of
the transaction's two ($5.1 million, 0.5%) specially serviced
loans and three ($36.5 million, 3.3%) loans secured by cooperative
housing (co-op) properties. We separately estimated a loss for the
excluded specially serviced loan and included it in our 'AAA'
scenario implied default and loss severity figures. The co-op
loans did not default under our 'AAA' scenario due to extremely
low leverage," S&P said.

                     CREDIT CONSIDERATIONS

"As of the revised March 12, 2012, trustee remittance report, two
($5.1 million, 0.5%) loans in the pool were with the special
servicer, C-III Asset Management LLC (C-III). Both specially
serviced loans were reported as being 90-plus days delinquent.
Appraisal reduction amounts (ARAs) totaling $2.7 million are in
effect for the specially serviced loans," S&P said.

"The Harrisonburg & Charlottesville Retail loan ($4.1 million,
0.4%) is the largest specially serviced loan. The loan is secured
by two retail shopping centers totaling 57,712 sq. ft. in
Virginia. The loan was transferred to the special servicer on May
4, 2009, due to payment default. According to C-III, a note sale
is under consideration. An ARA of $2.5 million is in effect
against the loan. We expect a moderate loss upon the eventual
resolution of this loan," S&P said.

"The Virginia Plaza Shopping Center ($978,122, 0.1%) is the
second-largest specially serviced loan and is collateralized by an
unanchored retail center totaling 10,748 sq. ft. in McKinney,
Texas. The loan was transferred to the special servicer on Dec.
13, 2011, due to payment default. According to C-III, no workout
strategy has been determined at this time. As of year-end 2010,
the reported DSC was 1.55x. An ARA of $240,843 is in effect
against this loan," S&P said.

                      TRANSACTION SUMMARY

"As of the revised March 12, 2012, trustee remittance report, the
trust balance was $1.12 billion, which is 79.8% of the trust
balance at issuance. The pool includes 109 loans, down from 121
loans at issuance. The master servicer, Wells Fargo Commercial
Mortgage Servicing, provided financial information for 87.1% of
the loans in the pool (by balance), the majority of which was
full-year 2010 data, interim 2011, or full-year 2011 data," S&P
said.

"We calculated a weighted average DSC of 1.57x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.56x and 119.8%. To date, the transaction has
experienced $10.9 million in principal losses in connection with
four assets. Forty-three loans ($388.4 million, 34.7%) in the pool
are on the master servicer's watchlist. Sixteen assets ($187.5
million, 16.7%) have a reported DSC of less than 1.10x, 12 of
which ($135.9 million, 12.1%) 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 pooled balance of
$599.2 million (55.9%). Using servicer-reported numbers, we
calculated a weighted average DSC of 1.43x for the top 10 loans.
Our adjusted DSC and LTV ratio for the top 10 loans were 1.36x and
119.6%. Four of the top 10 loans ($208.7 million, 18.6%) are on
the master servicer's watchlist and are discussed below. The
Monmouth Mall loan ($134.3 million, 14.4%), which is the largest
loan in the pool," S&P said.

"The SBC - Hoffman Estates loan ($94.5 million, 8.4%) is the
second-largest loan in the pool and the largest loan on the master
servicer's watchlist. The loan is secured by a 1,690,214 sq.-ft.
retail shopping center in Eatontown, N.J. The loan is on the
master servicer's watchlist due to the borrower's inability to pay
off the loan on its anticipated repayment date of Dec. 1, 2010.
The master servicer is now capturing excess cash in a lockbox, and
principal is being paid down at hyper-amortization rate. The final
loan maturity date is Dec. 1, 2035. As of year-end 2010, the
reported DSC was 2.25x, while the most recent reported occupancy
was 100%," S&P said.

"The Mervyn's loan ($59.5 million, 5.3%) is the fifth-largest loan
in the pool and the second-largest loan on the master servicer's
watchlist. The loan is secured by a 25-single-tenant retail
property portfolio totaling 1,896,968 sq. ft. located in
California and Texas. The loan is on the master servicer's
watchlist due to low DSC. As of year-end 2010, reported income was
insufficient to cover reported operating expenses. The reported
occupancy was 48% as of the same period," S&P said.

"The West Palm Beach Marriot loan ($29.4 million, 2.6%) is the
eighth-largest loan in the pool and the third-largest loan on the
master servicer's watchlist. The loan is secured by a 352-room
hotel property in Florida. The loan is on the master servicer's
watchlist due to low DSC. As of September 2011, the reported
occupancy was 77%. As of year-end 2011, the reported DSC was
0.39x," S&P said.

"The Southridge Shopping Center loan ($25.4 million, 2.3%) is the
10th-largest loan in the pool and the fourth-largest loan on the
master servicer's watchlist. The loan is secured by a 229,540-sq.-
ft. retail shopping center in Arden, N.C. The loan is on the
master servicer's watchlist due to low DSC. As of year-end 2010,
the reported DSC was 1.09x, while the most recent reported
occupancy, as of June 2011, was 88.0%," S&P said.

"The Monmouth Mall loan ($134.3 million pool balance, 14.4%,
$161.8 million whole-loan balance) is the largest loan in the
pool. The loan is secured by a 980,487-sq.-ft. mall in Eatontown,
N.J. Recent reported DSC information was not available. The
September 2011 rent roll indicated the property was 94.9%
occupied. Our adjusted valuation yielded a whole-loan stressed LTV
ratio of 94.0%," S&P said.

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

           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-TOP21
Commercial mortgage pass-through certificates

                Rating
Class      To           From        Credit enhancement (%)
C          BB+ (sf)     BBB- (sf)                      8.14
D          BB (sf)      BB+ (sf)                       6.25
E          BB- (sf)     BB (sf)                        5.30
F          B+ (sf)      BB- (sf)                       4.04
G          B (sf)       B+ (sf)                        3.10
H          CCC+ (sf)    B (sf)                         2.00
J          CCC- (sf)    CCC (sf)                       1.21
M          D (sf)       CCC- (sf)                      0.27

RATINGS AFFIRMED

Morgan Stanley Capital I Trust 2006-TOP21
Commercial mortgage pass-through certificates

Class    Rating                      Credit enhancement (%)
A-2      AAA (sf)                                     33.00
A-3      AAA (sf)                                     33.00
A-AB     AAA (sf)                                     33.00
A-4      AAA (sf)                                     33.00
A-M      AA-(sf)                                      20.41
A-J      BBB+ (sf)                                    11.91
B        BBB (sf)                                     9.55
K        CCC- (sf)                                     0.90
L        CCC- (sf)                                     0.42
X        AAA (sf)                                       N/A

N/A - Not applicable.


MORGAN STANLEY 2007-TOP27: DBRS Cuts Rating on N/O Certs. to 'D'
----------------------------------------------------------------
DBRS has downgraded the following classes of Morgan Stanley
Capital I Trust, Series 2007-TOP27 as follows:

-- Class N to D (sf) from C (sf)
-- Class O to D (sf) from C (sf)

The downgrades follow realized losses to the above mentioned
classes, which resulted from the liquidation of one loan with the
March 2012 remittance.

Comfort Suites Chesapeake (Prospectus ID#69) was secured by a 129-
key limited-service hotel in Chesapeake, Virginia.  This loan
originally transferred to special servicing in March 2010 for
monetary default.  The lender took title of the asset shortly
after a foreclosure sale, which occurred in May 2011.  A September
2011 appraisal valued the property at $3.9 million, down from
$14.7 million at issuance.  As of the March 2012 remittance, this
loan has incurred a realized trust loss of $9.0 million,
representative of an 82% loss severity.

The cumulative losses for this transaction, to date, have resulted
in the full principal losses to Class P and Class O and have
reduced the balance of Class N to $5.4 million.

A number of non-performing loans remain in special servicing,
which DBRS considers of particular concern, including Comfort
Suites BWI Airport (Prospectus ID#51), Empire Towers (Prospectus
ID#52), Grand Mart Chicago Portfolio (Prospectus ID#50),
TownePlace Suites (Prospectus ID#73) and Country Inn and Suites -
Ft. Meyers Airport (Prospectus ID#125).  These loans cumulatively
comprise 2.4% of the pool balance, as of the March 2012
remittance.  DBRS continues to monitor this transaction on a
monthly basis, with increased focus on these pivotal loans and the
other loans currently in special servicing.


MSC 2006-SRR1: Moody's Affirms 'C' Ratings on 16 Note Classes
-------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of all classes
of Notes issued by MSC 2006-SRR1. 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.

Cl. A2, Affirmed at Ca (sf); previously on May 27, 2010 Downgraded
to Ca (sf)

Cl. A2-S, Affirmed at Ca (sf); previously on May 27, 2010
Downgraded to Ca (sf)

Cl. B, Affirmed at Ca (sf); previously on May 27, 2010 Downgraded
to Ca (sf)

Cl. B-S, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. C, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. C-S, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. D, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. D-S, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. E, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. E-S, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. F, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. F-S, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. H, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. J, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. K, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. L, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Cl. M, Affirmed at C (sf); previously on May 27, 2010 Downgraded
to C (sf)

Ratings Rationale

MSC 2006-SRR1 is synthetic CRE CDO transaction backed by a
portfolio of commercial mortgage backed securities (CMBS)
reference obligations (100.0% of the pool balance) issued between
2004 and 2006. As of the February 24, 2012 Trustee report, the
aggregate Note balance of the transaction was reduced due to
protection payments as a result of writedowns in the reference
obligations; as detailed below.

There are eleven reference obligations with an original par
balance of $110.0 million (17.7% of the current pool balance) that
have experienced credit events via writedowns. As of the February
24, 2012 Trustee Report, Classes F-S, G, H, J, K, L, M and the
Subordinated Notes have experienced full losses, and Class F has
experienced a partial loss. There has been a corresponding
reduction in the term assets account.

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
reference pool. Moody's has completed updated credit estimates for
the non-Moody's rated collateral. The bottom-dollar WARF is a
measure of the default probability within a collateral pool.
Moody's modeled a bottom-dollar WARF of 8,869 compared to 8,774 at
last review. The distribution of current ratings and credit
estimates is as follows: Ba1-Ba3 (0.0% compared to 1.7% at last
review), B1-B3 (11.6% compared to 6.9% at last review), and Caa1-C
(88.4% compared to 91.4% at last review).

WAL acts to adjust the probability of default of the reference
pool for time. Moody's modeled to a WAL of 3.1 years compared to
3.8 at last review.

WARR is the par-weighted average of the mean recovery values for
the reference pool. Moody's modeled a fixed WARR of 28.4% compared
to 27.6% 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 pool (i.e. the measure of diversity). Moody's
modeled a MAC of 31.6% compared to 30.7% at last review.

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

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. Synthetic notes are particularly sensitive
to changes in ratings assumptions. Holding all other key
parameters static, changing the ratings down one notch or up one
notch would result in average rating movement on the rated
tranches of 0 to 0.2 notches downward and 0 to 0.2 notches upward,
respectively.

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.


MUZINICH II: S&P Raises Ratings on 2 Classes of Notes to 'CC'
------------------------------------------------------------
Standard & Poor's Ratings Services lowered and removed from
CreditWatch negative its ratings on the class B-1 and B-2 notes
from Muzinich CBO II Ltd., a cash flow collateralized bond
obligation (CBO) transaction.

"We previously lowered the ratings on the class B notes in May
2010. The transaction has since paid down the class A-1 and A-2
notes in full and is paying down the class B notes. Despite the
pay downs to the notes, the class B overcollateralization ratio
fell to 77.65% as of the March 2012 trustee report from 102.28% in
March 2010. We based 's downgrades on the reduction in credit
support available to the class B notes and the higher likelihood
that the notes will not get back their full principal," 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

Muzinich CBO II Ltd.

                   Rating
             To               From
B-1          CC (sf)          CCC- (sf)/Watch Neg
B-2          CC (sf)          CCC- (sf)/Watch Neg


N-STAR VII: S&P Lowers Ratings on 3 Classes of Notes to 'CC'
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A-1, A-2, A-3, B, C, D-FL, D-FX, and E notes from N-Star
Real Estate CDO VII Ltd., a collateralized debt obligation (CDO)
transaction backed by commercial mortgage-backed securities (CMBS)
assets, managed by NS Advisors LLC. "At the same time, we removed
these ratings from CreditWatch, where we placed them with negative
implications on Dec. 27, 2011," S&P said.

The downgrades are primarily on account of the release of new
criteria.

"The transaction has also had significant deterioration in the
credit quality of the underlying assets since we last downgraded
the notes on May 31, 2011. As of the Feb. 21, 2012, trustee report
the transaction held over $206.7 million in defaulted assets
compared with about $110.1 million noted in the April 18, 2011,
report, which we used for the May 2011 rating action," S&P said.

"The senior A/B overcollateralization (O/C) ratio was passing its
trigger as of the February 2012 trustee report. However, all the
other O/C tests in the transaction were failing their trigger
values and diverting the interest proceeds to pay down the senior
notes. As a result, the class D and E notes are not receiving
timely interest payments and are accruing interest," S&P said.

The weakening performance of the transaction is also evident in
the decreased support available to the rated notes. The trustee
reported the O/C ratios in the Feb. 21, 2012, monthly report:

* The class A/B O/C ratio was 108.65%, compared with a reported
   ratio of 116.6% in April 2011;

* The class C O/C ratio was 102.91%, compared with a reported
   ratio of 111.42% in April 2011;

* The class D O/C ratio was 99.11%, compared with a reported
   ratio of 107.93% in April 2011; and

* The class E O/C ratio was 95.50%, compared with a reported
   ratio of 104.61% in April 2011.

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 Report
included in this credit rating report is available at

         http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

N-Star Real Estate CDO VII Ltd.
                      Rating
Class            To              From
A-1              BB- (sf)        AA- (sf)/Watch Neg
A-2              B (sf)          A- (sf)/Watch Neg
A-3              CCC+ (sf)       BBB- (sf)/Watch Neg
B                CCC- (sf)       BB+ (sf)/Watch Neg
C                CCC- (sf)       BB (sf)/Watch Neg
D-FL             CC (sf)         B (sf)/Watch Neg
D-FX             CC (sf)         B (sf)/Watch Neg
E                CC (sf)         CCC+ (sf)/Watch Neg

TRANSACTION INFORMATION

Issuer:              N-Star Real Estate CDO VII Ltd.
Collateral manager:  NS Advisors LLC
Trustee:             Bank of America N.A.
Transaction type:    Cash flow CLO


NATIONAL COLLEGIATE 2007-2: S&P Lowers Class C Notes Rating to 'D'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
C notes from National Collegiate Student Loan Trust 2007-2 to 'D
(sf)' from 'B (sf)' and removed it from CreditWatch with negative
implications, where S&P placed it on Nov. 11, 2011.

"We lowered our rating to 'D (sf)' because the affected class did
not receive any interest payment on the March 26, 2012, the
distribution date. The series 2007-2 transaction breached its
class C note interest trigger because it failed its cumulative
default and parity tests. The transaction failed the cumulative
default test because cumulative defaults of 24.86%, as of March
26, 2012, are above the current required threshold of 7%. The
transaction failed the parity test because the aggregate
outstanding balance of the class A and B notes exceeded the sum of
the collateral balance plus the amounts on deposit in the reserve
account. The aforementioned parity test was 99.88% as of March
26, 2012. The increase in defaults and declines in parity reflect
the effect of the continuing poor collateral performance on this
transaction," S&P said.

"The class C note breached its interest trigger because it failed
its cumulative default and parity tests, which prompted the
interest shortfall. The class C note interest trigger is tested
monthly, and the transaction can cure the breach if it passes the
appropriate performance tests on subsequent distribution dates. We
placed our rating on the class C notes on CreditWatch negative on
Nov. 11, 2012, because adverse collateral performance was reducing
the transaction's parity," S&P said.

"We believe this transaction will continue to breach its class C
note interest trigger for the foreseeable future due to the
continued adverse performance trends of the underlying pool of
private student loans, including the accelerated pace at which the
transaction has been realizing defaults. The breach of the class C
note interest trigger, as well as the resulting reprioritization
of interest to pay down senior bonds, caused an interest shortfall
to the class C notes on the March 26, 2012, distribution date. The
transaction may draw on its reserve account to cover fees to the
servicer, trustee, paying agent, and administrator, as well as
backup administrator fees and expenses, and class A, B, and C note
interest when no triggers are in effect. However, when a class C
note interest trigger is in effect, the reserve account cannot be
drawn on to cover interest payments to the class C notes," S&P
said.

"Standard & Poor's will continue to monitor the performance of the
student loan receivables backing this trust relative to our
cumulative default expectations and available credit enhancement,"
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


NERVA LTD: Fitch Withdraws Junk Rating on Class A Notes
-------------------------------------------------------
Fitch Ratings withdraws the rating on one class of notes issued by
Nerva Ltd. Series I as follows:

-- Class A notes withdrawn from 'Csf'.

This transaction has terminated, but Fitch did not receive any
timely notice of the termination or reports detailing the final
distributions on the notes.  As a result, the rating has been
withdrawn at its current rating level.

Nerva was a synthetic collateralized debt obligation (CDO) that
closed on June 30, 2000.  The transaction allowed investors to
achieve leveraged exposure to a diversified portfolio of asset-
backed securities.



NEXTSTUDENT MASTER: Moody's Withdraws 'C' Ratings on 25 Notes
-------------------------------------------------------------
Moody's Investors Service has withdrawn the ratings of 25 notes
issued by NextStudent Master Trust I. In July 2010 Moody's
downgraded the ratings to C following the occurrence of several
events of default under the trust Indenture and the subsequent
liquidation of the trust assets. Moody's is currently withdrawing
the credit ratings because it has insufficient information to
support the maintenance of the ratings.

The complete rating actions are as follows:

Issuer: NextStudent Master Trust I

    2006A-1, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2006A-2, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2006A-3, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2006A-4, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2006A-5, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2006A-6, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2006A-7, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2006A-8, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2006B-1, Withdrawn (sf); previously on Jul 9, 2010 Downgraded
to C (sf)

    2007A-1, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-2, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-3, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-4, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-5, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-6, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-7, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-8, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-9, Withdrawn (sf); previously on Sep 14, 2010 Downgraded
to C (sf)

    2007A-10, Withdrawn (sf); previously on Sep 14, 2010
Downgraded to C (sf)

    2007A-11, Withdrawn (sf); previously on Sep 14, 2010
Downgraded to C (sf)

    2007A-12, Withdrawn (sf); previously on Sep 14, 2010
Downgraded to C (sf)

    2007A-13, Withdrawn (sf); previously on Sep 14, 2010
Downgraded to C (sf)

    2007A-14, Withdrawn (sf); previously on Sep 14, 2010
Downgraded to C (sf)

    2007A-15, Withdrawn (sf); previously on Sep 14, 2010
Downgraded to C (sf)

    2007B-1, Withdrawn (sf); previously on Jul 9, 2010 Downgraded
to C (sf)


NOMURA ASSET 1998-D6: Moody's Affirms Ba3 Rating on PS-1 Notes
--------------------------------------------------------------
Moody's Investors Service affirmed six CMBS classes of Nomura
Asset Securities Corporation, Commercial Mortgage Pass-Through
Certificates, Series 1998-D6 as follows:

Cl. A-1C, Affirmed at Aaa (sf); previously on Mar 30, 1998
Assigned Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Sep 8, 2005 Upgraded
to Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Sep 8, 2005 Upgraded
to Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Dec 8, 2006 Upgraded
to Aaa (sf)

Cl. A-5, Affirmed at Aaa (sf); previously on Sep 11, 2008 Upgraded
to Aaa (sf)

Cl. PS-1, 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.

The rating of the IO Class, Class PS-1, is consistent with the
expected credit performance of its referenced classes and thus is
affirmed.

Moody's rating action reflects a cumulative base expected loss of
2.3% of the current balance compared to 2.2% at last 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, for deals that include a pool of credit tenant loans,
Moody's also used its credit-tenant lease ("CTL") financing
methodological approach ("CTL" approach). Under Moody's CTL
approach, the rating of a transaction's certificates is primarily
based on the senior unsecured debt rating (or the corporate family
rating) of the tenant, usually an investment grade rated company,
leasing the real estate collateral supporting the bonds. This
tenant's credit rating is the key factor in determining the
probability of default on the underlying lease. The lease
generally is "bondable", which means it is an absolute net lease,
yielding fixed rent paid to the trust through a lock-box,
sufficient under all circumstances to pay in full all interest and
principal of the loan. The leased property should be owned by a
bankruptcy-remote, special purpose borrower, which grants a first
lien mortgage and assignment of rents to the securitization trust.
The dark value of the collateral, which assumes the property is
vacant or "dark", is then examined to determine a recovery rate
upon a loan's default. Moody's also considers the overall
structure and legal integrity of the transaction. For deals that
include a pool of credit tenant loans, Moody's currently uses a
Gaussian copula model, incorporated in its public CDO rating model
CDOROMv2.8 to generate a portfolio loss distribution to assess the
ratings, 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 pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

Moody's 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 21, down from 22 at last review.

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 March 16, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 68% to $1.05
million from $3.72 billion at securitization. The Certificates are
collateralized by 109 mortgage loans which range in size from less
than 1% to 5% of the pool, with the top ten loans representing 22%
of the pool. Thirty-six loans representing 60% of the deal have
defeased and are collateralized with U.S. Government securities.
Seven loans representing 3% of the pool are secured by credit
tenant lease (CTL) loans.

There are 12 loans, representing 8% of the pool on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Twenty-seven loans have been liquidated from the pool since
securitization, resulting in approximately an $82.5 million loss
(40% average loss severity) compared to $81.2 million at last
review. There is currently one loan representing less than 1% of
the pool in special servicing. Moody's anticipates a loss on this
loan.

Moody's has assumed a high default probability for three poorly
performing loan representing less than 1% of the pool and has
estimated a $6.5 million loss (25% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 financials for 67%, and
partial year 2011 financials for 85% of the pool's non-defeased
and non-specially serviced loans. Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 62% compared to
68% at Moody's prior review. Moody's net cash flow reflects a
weighted average haircut of 12% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 10.1%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.47X and 2.01X, respectively, compared to
1.44X and 1.88X 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 13% of the pool
balance. The largest loan is the FAC Realty II Loan ($57.5 million
-- 4.8% of the pool), which is secured by 11 retail outlet stores
located throughout the United States. The properties are located
in North Carolina, Missouri, Florida, Nebraska, Alabama, Texas and
Iowa. The loan matures in March, 2013. Moody's LTV and stressed
DSCR are 57% and 1.91X, respectively, compared to 60% and 1.81X at
last review.

The second largest loan is the Forest City Atlantic Loan ($49.6
million -- 4.1% of the pool), which is secured by a 395,000 square
foot (SF) retail center located in Brooklyn, New York. Tenants
include Macy's, Pathmark and Best Buy. The property was 95% leased
as of December 2011 compared to 98% at last review. Moody's LTV
and stressed DSCR are 82% and 1.26X, respectively, compared to 77%
and 1.34X at last review.

The third largest loan is the HQ Plaza Loan ($43.8 million -- 3.6%
of the pool), which is secured by a mixed use complex consisting
of office (733,000 SF) and hotel (256 keys) located in Morristown,
New Jersey. Performance has improved since last review due to an
increase in occupancy for both the office and hotel portions.
Moody's LTV and stressed DSCR are 48% and 2.35X, respectively,
compared to 50% and 2.26X at last review.


NORTH STREET: Moody's Cuts Ratings on Two Note Classes to 'Caa2'
----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of two
classes of notes issued by North Street Referenced Linked Notes,
2003-5 Ltd. The classes of notes affected by the rating action are
as follows:

US$50,000,000 Class A-1 Floating Rate Notes, Downgraded to Caa3
(sf); previously on May 21, 2010 Downgraded to Caa2 (sf);

US$50,000,000 Class A-2 Floating Rate Notes, Downgraded to Caa3
(sf); previously on May 21, 2010 Downgraded to Caa2 (sf).

Ratings Rationale

According to Moody's, the rating downgrade action is the result of
deterioration in the credit quality of the reference obligations.
Credit deterioration is observed through an increase in the
Moody's Weighted Average Rating Factor (WARF) and an increase in
assets rated Caa1 or below. Based on the February 2012 trustee
report, the Moody's WARF of the reference portfolio has increased
to 1073 from 313 in May 2010 and reference obligations rated Caa1
or below increased to approximately 10.7% from 2.1% during the
same period.

North Street Reference Linked Notes, 2003-5 Ltd. is a synthetic
collateralized debt obligation issuance that references a
portfolio of primarily Residential Mortgage Backed Securities
(RMBS) with the majority originated in 2003 and 2004.

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

Moody's analysis for this transaction is based on CDOROM v2.8.

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

Moody's 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-rated assets notched up by 2 rating notches:

Class A-1: 0

Class A-2: 0

Moody's Caa-rated assets notched down by 2 rating notches:

Class A-1: 0

Class A-2: 0


NYLIM FLATIRON: Moody's Raises Rating to Class D Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by NYLIM Flatiron CLO 2004-1 LTD.:

US$21,000,000 Class C Deferrable Floating Rate Notes Due 2016,
Upgraded to Aa1 (sf), previously on July 14, 2011 Upgraded to Aa3
(sf);

US$26,250,000 Class D Deferrable Floating Rate Notes Due 2016
(current outstanding balance of $24,501,068), Upgraded to Ba1
(sf), previously on July 14, 2011 Upgraded to Ba2 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of delevering of the senior notes, which led to
an increase in the transaction's overcollateralization ratios
since the last rating action in July 2011. Moody's notes that the
Class A Notes have been paid down by approximately 40% or $60.4
million since the last rating action. Based on the latest trustee
report dated February 29, 2012, the Class A/B, Class C, and Class
D overcollateralization ratios are reported at 179.8%, 138.2% and
108.8%, respectively, versus July 2011 levels of 144.07%, 124.05%
and 106.75%, respectively.

Notwithstanding benefits of the delevering, Moody's notes that the
credit quality of the underlying portfolio has deteriorated since
the last rating action. Based on the February 2012 trustee report,
the weighted average rating factor is currently 2603 compared to
2470 in July 2011.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $127.2 million,
no defaulted par, a weighted average default probability of 15.1%
(implying a WARF of 2872), a weighted average recovery rate upon
default of 49.45%, and a diversity score of 33. The default and
recovery properties of the collateral pool are incorporated in
cash flow model analysis where they are subject to stresses as a
function of the target rating of each CLO liability being
reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

NYLIM FLATIRON CLO 2004-1 LTD., issued in October 2004, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011.

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in June 2011.

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on all
rated notes of various default probabilities. Below is a summary
of the impact of different default probabilities (expressed in
terms of WARF levels) on all rated notes (shown in terms of the
number of notches' difference versus the current model output,
where a positive difference corresponds to lower expected loss),
assuming that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2298)

Class A: 0

Class B: 0

Class C: +1

Class D: +1

Moody's Adjusted WARF + 20% (3446)

Class A: 0

Class B: 0

Class C: -1

Class D: 0

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2014 and
2016 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are described
below:

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


PACIFIC COAST: Moody's Raises Rating on US$450MM Notes to 'Caa1'
----------------------------------------------------------------
Moody's Investors Service has upgraded the rating of the following
notes issued by Pacific Coast CDO Ltd.:

US$450,000,000 Class A First Priority Senior Secured Floating
Rate Notes due 2036 (current outstanding balance of
$52,623,446), Upgraded to Caa1 (sf); previously on March 26,
2009 Downgraded to Caa2 (sf).

Ratings Rationale

According to Moody's, the rating action taken on the notes is
primarily a result of de-leveraging of the senior notes since the
rating action in March 2009. Moody's notes that the Class A Notes
have been paid down by approximately 53.2% or $59.8 million since
the last rating action.

Pacific Coast CDO Ltd, Limited, issued in February 2001, is a
collateral debt obligation backed by a portfolio of ABS, MBS, and
CMBS originated from 2001 to 2004.

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

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.8 to model the loss distribution for SF CDOs. Within this
framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference.
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 rated assets notched up by 2 rating notches:

Class A: +3

Moody's Caa rated assets notched down by 2 rating notches:

Class A: 0


SANTANDER DRIVE: Moody's Assigns 'Ba1' Rating to Class E Notes
--------------------------------------------------------------
Moody's Investors Service has assigned definitive ratings to the
notes issued by Santander Drive Auto Receivables Trust 2012-2
(SDART 2012-2). This is the second public subprime transaction of
the year for Santander Consumer USA Inc. (SCUSA).

The complete rating actions are as follows:

Issuer: Santander Drive Auto Receivables Trust 2012-2

Cl. A-1, Rated P-1 (sf)

Cl. A-2, Rated Aaa (sf)

Cl. A-3, Rated Aaa (sf)

Cl. B, Rated Aa1 (sf)

Cl. C, Rated Aa3 (sf)

Cl. D, Rated Baa1 (sf)

Cl. E, Rated Ba1 (sf)

Ratings Rationale

Moody's said the ratings are based on the quality of the
underlying auto loans and their expected performance, the strength
of the structure, the availability of excess spread over the life
of the transaction, and the experience and expertise of SCUSA as
servicer.

The principal methodology used in rating the transaction is
"Moody's Approach to Rating U.S. Auto Loan-Backed Securities,"
published in May 2011.

Moody's median cumulative net loss expectation for the SDART 2012-
2 pool is 15.0% and the Aaa level is 46%. The loss expectation was
based on an analysis of SCUSA's portfolio vintage performance as
well as performance of past securitizations, and current
expectations for future economic conditions.

The Assumption Volatility Score for this transaction is Low/Medium
versus a Medium for the sector. This is driven by the a Low/Medium
assessment for Governance due to the presence of a highly rated
parent, Banco Santander (Aa3 RUR for possible downgrade/P-1), in
addition to the size and strength of SCUSA's servicing platform.

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

Moody's Parameter Sensitivities: If the net loss used in
determining the initial rating were changed to 19.5%, 26% or 29%,
the initial model output for the Class A notes might change from
Aaa to Aa1, A1, and Baa1, respectively. If the net loss used in
determining the initial rating were changed to 16.0%, 19.5% or
23.0%, the initial model output for the Class B notes might change
from Aa1 to Aa2, A2, and Baa2, respectively. If the net loss used
in determining the initial rating were changed to 15.25%, 17.0% or
20%, the initial model output for the Class C notes might change
from Aa3 to A1, Baa1, and Ba1, respectively. If the net loss used
in determining the initial rating were changed to 15.25%, 17.0% or
20.0%, the initial model output for the Class D notes might change
from Baa1 to Baa2, Ba2, and B2, respectively. If the net loss used
in determining the initial rating were changed to 15.25%, 16.5% or
18.5%, the initial model output for the Class E notes might change
from Ba1 to Ba2, B2, and
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.


SECURITY NAT'L 2005-A: Moody's Cuts Rating on B Notes to 'Caa3'
---------------------------------------------------------------
Moody's Investors Service has downgraded one tranche issued by
Security National Mortgage Loan Trust 2005-A. Security National
Servicing Corporation is the servicer. A pool of miscellaneous
loans, including residential and commercial mortgages, back the
notes. As of the February 2012 distribution date, most of the
residential mortgages had paid off or defaulted, and 43.7% of the
pool balance consisted of commercial real estate mortgages.
Commercial loans including those backed by accounts receivable,
inventory, and furniture, fixtures and equipment, comprised
approximately 33.8% of the outstanding pool balance.

The complete rating action is as follows:

Issuer: Security National Mortgage Loan Trust 2005-A

Cl. B, Downgraded to Caa3 (sf); previously on Aug 3, 2011
Downgraded to Caa1 (sf)

Ratings Rationale

Higher than expected net losses and reduced credit enhancement
available to support the affected notes caused the downgrade
actions. Since the last rating action in August 2011, cumulative
net losses increased to approximately 38.2% from approximately
29.6% as a percent of the original pool balance. Consequently, the
total credit enhancement provided by a reserve account and
overcollateralization decreased to 6.0% from 25.2% of the
outstanding pool balance.

The methodology used in these rating actions included projecting
losses using a loan-by-loan analysis for approximately 96% of the
pool. Moody's assessed the likelihood of each loan to default
based on the levels of current delinquencies, business types,
property locations, past payment histories, borrower's
creditworthiness, and either appraisals or estimates of property
market values. For the remaining portion of the pool, Moody's
applied market recovery rates for each different collateral type
to arrive at projected losses.

Moody's current remaining expected net loss for the transaction is
24%-28% of the current pool balance. The expected loss on the pool
was then examined in relation to available credit enhancement,
including a reserve account and overcollateralization.

Primary sources of uncertainty for this transaction are the
general economic environment, commercial property and other
underlying asset values, and the ability of the industries of the
underlying collateral to recover from the recession. If the
remaining expected net loss used in determining the ratings were
increased to 40% of the current pool balance, the Class B notes
may be downgraded.

Other methodologies and factors that may have been considered in
the process of rating these transactions can also be found on
Moody's Web site.


STRATA 2006-34: S&P Withdraws 'CCC-' Rating on Notes
----------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on the
notes issued by Strata 2006-34 Ltd. and Strata 2007-1 Ltd.

The rating withdrawals follow the receipt of termination and
redemption agreement notices dated Feb. 4, 2012.

             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

Strata 2006-34 Ltd.
              Rating
           To          From
Nts        NR          CCC- (sf)

Strata 2007-1 Ltd.
              Rating
           To          From
Nts        NR          B- (sf)

NR - Not rated.


WICKER PARK: S&P Raises Rating on Class B Notes to 'B+'
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on three
classes of notes from Wicker Park CDO I Ltd., a hybrid
collateralized debt obligation (CDO) backed by a reference
portfolio of corporate bonds and managed by Nueberger Berman Group
LLC. "We affirmed our rating on one other class in the
transaction," S&P said.

"The rating actions reflect a decreased amount of 'CCC' rated
obligations in the transaction to $12.5 million according to the
February 2012 trustee report, from $30.0 million according to the
May 2010 trustee report, which we used in our July 2010 rating
action. In addition, the class A-1 note balance declined by $9.50
million to $864.84 million since the July 2010 rating action after
the class failed its overcollateralization (O/C) tests. The O/C
failures were mainly due to a 'B par reduction' amount which
haircuts the ratio value based on the amount of 'B' rated assets
in the portfolio. The upgrades reflect the overall improved credit
quality of the transactions underlying asset portfolio, which has
benefited the rated notes," S&P said.

"The rating on the class C note is driven by the application of
the largest obligor default test, a supplemental stress test we
introduced as part of our 2009 corporate CDO criteria update. The
affirmation reflects credit quality commensurate with class C's
current rating level," 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

RATING AND CREDITWATCH ACTIONS
Wicker Park CDO I Ltd.
                Rating
Class        To         From
A-1          A- (sf)    BBB- (sf)
A-2          BB (sf)    B+ (sf)
B            B+ (sf)    B- (sf)

RATINGS AFFIRMED
Wicker Park CDO I Ltd.
Class          Rating
C              CCC- (sf)


* S&P Lowers Ratings on 427 Classes of Certificates to 'D'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 427
classes of mortgage pass-through certificates from 254 U.S.
residential mortgage-backed securities (RMBS) transactions to 'D
(sf)'. The transactions within this review were issued between
2001 and 2008.

The complete rating list is available for free at:

        http://bankrupt.com/misc/S&P_RMBS_03222012.pdf

"The downgrades reflect our assessment of the impact that
principal write-downs had on the affected classes during recent
remittance periods. Prior to 's rating actions, we rated all of
the downgraded classes in this review 'CCC (sf)' or 'CC (sf)',"
S&P said.

Approximately 79.16% of the defaulted classes were from
transactions backed by Alternative-A (Alt-A) or prime jumbo
mortgage loan collateral. The 427 defaulted classes consist of:

* 194 classes from Alt-A transactions (45.43% of all
   defaults);

* 144 from prime jumbo transactions (33.72%);

* 72 from subprime transactions (16.86%);

* Three from resecuritized real estate mortgage investment
   conduit (re-REMIC) transactions;

* Three from RMBS reperforming transactions;

* Three from RMBS prime second lien transactions;

* Three from small balance commercial loan transactions;

* Two from RMBS risk transfer transactions;

* One from an RMBS document deficient transaction;

* One from an RMBS home equity line of credit (HELOC)
   transaction; and

* One from an RMBS Federal Housing Administration/Veterans
   Affairs transaction.

A combination of subordination, excess spread, and
overcollateralization (where applicable) provide credit
enhancement for all of the transactions in this review.

Standard & Poor's will continue to monitor its ratings on
securities that experience principal write-downs, and it will
adjust its ratings as it considers appropriate in accordance with
its criteria.

           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


* DBRS Takes Action on 44 U.S. RMBS Securities
----------------------------------------------
DBRS, Inc. has taken rating actions on 44 classes from 19 U.S.
Residential Mortgage-Backed Securities (RMBS) transactions.  Of
the classes reviewed, 35 classes from 11 transactions were
confirmed and removed from Under Review with Developing
Implications (see "DBRS Places 6,566 Classes from 576 U.S. RMBS
Transactions Under Review", published on January 23, 2012).  All
44 classes from 19 transactions reviewed were then set to
Discontinued - Repaid due to repayment of the bonds.

Rating Action taken on March 23, 2012:

Issuer                  Debt Rated                Rating Action
-------                 -----------               -------------
Accredited Mortgage
Loan Trust 2005-3        Asset-Backed Notes,    Disc. -Repaid
                         Series 2005-3,
                         Class A-2C

Aegis Asset Backed
Securities Trust 2005-2  Mortgage-Backed Notes, Disc. -Repaid
                         Series 2005-2,
                         Class IA3

ASG Resecuritization
Trust 2009-5             REMIC Notes,           Confirmed AAA(sf)
                         Series 2009-5,
                         Class A30

ASG Resecuritization
Trust 2009-5             REMIC Notes,           Disc. -Repaid
                         Series 2009-5,
                         Class A30

ASG Resecuritization
Trust 2009-5             REMIC Notes,           Confirmed AAA(sf)
                         Series 2009-5,
                         Class G30

ASG Resecuritization
Trust 2009-5             REMIC Notes,           Disc. -Repaid
                         Series 2009-5,
                         Class G30

Banc of America Funding
2010-R5 Trust            Mortgage               Confirmed AAA(sf)
                         Security-Backed
                         Certificates,
                         Class 5-A-1

Banc of America Funding
2010-R5 Trust            Mortgage               Disc.-Repaid
                         Security-Backed
                         Certificates,
                         Class 5-A-1

Banc of America Funding
2010-R5 Trust            Mortgage               Confirmed AA(sf)
                         Security-Backed
                         Certificates,
                         Class 5-A-2

Banc of America Funding
2010-R5 Trust            Mortgage               Disc. -Repaid
                         Security-Backed
                         Certificates,
                         Class 5-A-2

Banc of America Funding
2010-R5 Trust            Mortgage               Confirmed A(sf)
                         Security-Backed
                         Certificates,
                         Class 5-A-3

Banc of America Funding
2010-R5 Trust            Mortgage               Disc. -Repaid
                         Security-Backed
                         Certificates,
                         Class 5-A-3

Banc of America Funding
2010-R5 Trust            Mortgage               Confirmed AA (sf)
                         Security-Backed
                         Certificates,
                            Class 5-A-5

Banc of America Funding
2010-R5 Trust            Mortgage               Disc. - Repaid
                         Security-Backed
                         Certificates,
                         Class 5-A-5

Banc of America Funding
2010-R5 Trust            Mortgage               Confirmed A (sf)
                         Security-Backed
                         Certificates,
                         Class 5-A-6

Banc of America Funding
2010-R5 Trust            Mortgage               Disc.-Repaid
                         Security-Backed
                         Certificates,
                         Class 5-A-6

BCAP LLC 2010-RR11 Trust Resecuritization Trust Confirmed AA(sf)
                         Securities,
                         Class 2A4

BCAP LLC 2010-RR11 Trust Resecuritization Trust Disc. - Repaid
                         Securities,
                         Class 2A4

BCAP LLC 2010-RR11 Trust Resecuritization Trust Confirmed A(sf)
                         Securities, Class 2A6

BCAP LLC 2010-RR11 Trust Resecuritization Trust Disc. - Repaid
                         Securities,
                         Class 2A6

BCAP LLC 2010-RR4-I Trust Resecuritization      Confirmed A(sf)
                          Trust Securities,
                          Class IV-A1

BCAP LLC 2010-RR4-I Trust Resecuritization      Disc. - Repaid
                          Trust Securities,
                          Class IV-A1

BCAP LLC 2010-RR9 Trust  Resecuritization       Confirmed A(sf)
                         Trust Securities,
                         Class 2A3

BCAP LLC 2010-RR9 Trust  Resecuritization       Disc. - Repaid
                         Trust Securities,
                         Class 2A3

BCAP LLC 2010-RR9 Trust  Resecuritization
                         Trust Securities,
                         Class 2A5              Confirmed A (sf)

BCAP LLC 2010-RR9 Trust  Resecuritization
                         Trust Securities,
                         Class 2A5              Disc.-Repaid

BCAP LLC 2010-RR9 Trust  Resecuritization
                         Trust Securities,
                         Class 2A6              Confirmed A (sf)

BCAP LLC 2010-RR9 Trust  Resecuritization
                         Trust Securities,
                         Class 2A6              Disc. - Repaid

BNC Mortgage Loan Trust  2007-4 Mortgage
                         Pass-Through
                         Certificates,
                         Series 2007-4,
                         Class M6B              Disc. - Repaid

Citigroup Mortgage Loan
Trust 2010-4             Resecuritization
                         Trust Certificates,
                         Series 2010-4,
                         Class 1A3              Confirmed AA (sf)

Citigroup Mortgage Loan
Trust 2010-4             Resecuritization
                         Trust Certificates,
                         Series 2010-4,
                         Class 1A3              Disc. -Repaid

Citigroup Mortgage Loan
Trust 2010-4             Resecuritization
                         Trust Certificates,
                         Series 2010-4,
                         Class 1A4              Confirmed A (sf)

Citigroup Mortgage Loan
Trust 2010-4             Resecuritization
                         Trust Certificates,
                         Series 2010-4,
                         Class 1A4              Disc. - Repaid

DSLA Mortgage Loan Trust
2005-AR6                 Mortgage Pass-Through
                         Certificates,
                         Series 2005 AR6,
                         Class 1A-1B            Disc. - Repaid

GMAC GSAP 2011-1         Series 2011-1,
                         Class A Notes          Disc. - Repaid

GMACM Mortgage Loan
Trust 2010-1             Mortgage Loan-Backed
                         Notes, Series 2010-1,
                         Class A                Confirmed A (sf)

GMACM Mortgage Loan
Trust 2010-1             Mortgage Loan-Backed
                         Notes, Series 2010-1,
                         Class A                Disc. - Repaid

J.P. Morgan Mortgage
Trust 2006-S1            Mortgage Pass-Through
                         Certificates,
                         Series 2006-S1,
                         Class 3-A-5            Confirmed BB (sf)

J.P. Morgan Mortgage
Trust 2006-S1            Mortgage Pass-Through
                         Certificates,
                         Series 2006-S1,
                         Class 3-A-5            Disc. - Repaid

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 13-A2            Confirmed BBB(sf)

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 13-A2            Disc. - Repaid

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 14-A1            Confirmed A (sf)

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 14-A1            Disc. - Repaid

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 14-AZ            Confirmed A (sf)

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 14-AZ            Disc. - Repaid

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 3-A1            Confirmed A (sf)

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 3-A1            Disc. - Repaid

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 3-AZ            Confirmed A (sf)

Jefferies
Resecuritization
Trust 2009-R8            Jefferies
                         Resecuritization
                         Trust 2009-R8,
                         Class 3-AZ            Disc. - Repaid

MASTR Asset Backed
Securities Trust
2005-WMC1                Mortgage
                         Pass-Through
                         Certificates,
                         Series 2005-WMC1,
                         Class M-1         Confirmed AA(high)(sf)

MASTR Asset Backed
Securities Trust
2005-WMC1                Mortgage
                         Pass-Through
                         Certificates,
                         Series 2005-WMC1,
                         Class M-1              Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 15-B             Confirmed B (sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 15-B              Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 19-B         Confirmed BB(low)(sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 19-B             Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 23-B            Confirmed CCC (sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 23-B             Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 24-B            Confirmed CCC (sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 24-B             Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 25-B            Confirmed CCC (sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 25-B             Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4
                         RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 29-B            Confirmed CCC (sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 29-B             Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 31-B           Confirmed CCC (sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 31-B             Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 36-B             Confirmed CCC(sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 36-B             Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 3-B          Confirmed B(high)(sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 3-B              Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 5-B            Confirmed CCC(sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4
                         Certificates,
                         Class 5-B              Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4 Notes,
                         Class 23-A            Confirmed AAA(sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4 Notes,
                         Class 23-A             Disc.-Repaid

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4 Notes,
                         Class 25-A             Confirmed AAA(sf)

RBSSP Resecuritization
Trust 2009-4             RBSSP Resecuritization
                         Trust 2009-4 Notes,
                         Class 25-A             Disc. - Repaid

SG Mortgage Securities
Trust 2006-OPT2          Asset-Backed
                         Certificates,
                         Series 2006-OPT2,
                         Class A-3A             Disc.-Repaid

Soundview Home Loan
Trust 2007-OPT1          Potential Interest
                         Rate Swap Termination
                         Payment                Disc. - Repaid

Supplemental Interest
Trust, Lehman XS Trust
Mortgage Pass-Through
Certificates,
Series 2007-3            Group 1 Potential
                         Interest Rate Swap
                         Termination Payment    Disc. - Repaid

Supplemental Interest
Trust, Lehman XS Trust
Mortgage Pass-Through
Certificates,
Series 2007-3            Group 2 Potential
                         Interest Rate Swap
                         Termination Payment    Disc. - Repaid


* S&P Raises Ratings on 22 Tranches From 16 U.S. Synthetic CDOs
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 22
tranches from 16 corporate-backed synthetic collateralized debt
obligation (CDO) transactions and removed them from CreditWatch
with positive implications.  "In addition, we lowered one rating
from one synthetic CDO transaction backed by residential mortgage-
backed securities (RMBS) and removed it from CreditWatch with
negative implications and lowered 23 ratings from 15 corporate-
backed synthetic CDO transactions and removed one from CreditWatch
with negative implications. Furthermore, we affirmed five ratings
from five synthetic CDO transactions and removed one from
CreditWatch with negative implications and withdrew one rating
from one corporate-backed synthetic CDO transaction after
receiving a termination notice," S&P said.

"The upgrades are from 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 March review and at our projection of the SROC ratios in 90
days assuming no credit migration. The downgrades were from
synthetic CDOs that had experienced negative rating migration in
their underlying reference portfolios or had reductions to the
credit enhancement available to them. Cloverie PLC Series 2005-56
and ABSpoke 2005-VIA Ltd.'s rating actions took into account
our updated criteria for structured finance-backed CDOs. The
affirmations are from synthetic CDOs that had appropriate credit
support at their current rating levels," 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

ABSpoke 2005-VIA Ltd.
                              Rating
Class                    To             From
VFRN                     CCC- (sf)      CCC- (sf)/Watch Neg

ARLO IX Ltd.
PASCAL SERIES 2007
                              Rating
Class                    To              From
PS 2007                  BB+ (sf)        BB- (sf)/Watch Pos

Bank of Nova Scotia
EUR30 mil 6.42% Managed Portfolio Credit Linked Note (ISIN NO.
XS0308238004);
6.42% Managed Portfolio Credit Linked Note (ISIN NO. XS0308238004)
                              Rating
Class                    To                  From
CLN                      CCC- (sf)           CCC- (sf)
CLN                      CC (sf)             CCC- (sf)

Cloverie PLC
Series 2005-55
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Cloverie PLC
Series 2005-56
                              Rating
Class                    To              From
A                        BB+ (sf)        A- (sf)/Watch Neg

Corsair (Jersey) No. 4 Ltd.
Series 13
                              Rating
Class                    To                  From
Notes                    CCC- (sf)           CCC- (sf)

Credit Default Swap
US$10 mil Swap Risk Rating  Portfolio - CDS Reference # C1304925M
                              Rating
Class                    To                  From
Swap                     CCsrp (sf)          CCC-srp (sf)

Credit Default Swap
US$10 mil Swap Risk Rating Portfolio - CDS Reference # C1315268M
                              Rating
Class                    To                  From
Swap                     CCsrp (sf)          CCC-srp (sf)

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

Credit Default Swap
US$50 mil Swap Risk Rating Portfolio - CDS Reference # C1355189M
                              Rating
Class                    To                  From
Swap                     CCsrp (sf)          CCC-srp (sf)

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

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

Credit Sail Ltd.
Series 2006-1
                              Rating
Class                    To                  From
                         Dp (sf)             CCp (sf)

Credit-Linked Trust Certificates
Series 2005-I
                              Rating
Class                    To            From
2005-I-H                 AA- (sf)      A+ (sf)/Watch Pos
2005-I-I                 A+ (sf)       A- (sf)/Watch Pos
2005-I-J                 A- (sf)       BBB+ (sf)/Watch Pos

Greylock Synthetic CDO 2006
Series 1
                              Rating
Class                    To              From
A1A-$LS                  BBB- (sf)       BB+ (sf)/Watch Pos
A3-$LMS                  BB+ (sf)        BB (sf)/Watch Pos

Greylock Synthetic CDO 2006
Series 4
                              Rating
Class                    To              From
A1¯LS                    BBB- (sf)       BB+ (sf)/Watch Pos

Infiniti SPC Ltd.
EUR16.4 mil, US$178 mil Kenmore Street Synthetic CDO 2006-2
Segregated
Portfolio
                              Rating
Class                    To                  From
7A-1                     D (sf)              CCC- (sf)

Lorally CDO Limited Series 2007-3
                              Rating
Class                    To              From
2007-3                   A (sf)          A- (sf)/Watch Pos

Momentum CDO (Europe) Ltd.
Series 2006-16
                              Rating
Class                    To                  From
                         D (sf)              CC (sf)

Morgan Stanley ACES SPC
Series 2006-9
                              Rating
Class                    To             From
IA                       B+ (sf)        CCC- (sf)/Watch Pos

Morgan Stanley ACES SPC
Series 2007-22
                              Rating
Class                    To             From
IA                       AAA (sf)        AA+ (sf)/Watch Pos

Morgan Stanley ACES SPC
Series 2008-3
                              Rating
Class                    To             From
Notes                    AA+ (sf)       BBB+ (sf)/Watch Pos

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

Morgan Stanley Managed ACES SPC
Series 2005-1
                              Rating
Class                    To               From
I A                      A+ (sf)          A (sf)/Watch Pos

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

PARCS Master Trust
US$5 mil Parcs Master Trust, Class 2007-18 Piedmont Units, Due
2017
                              Rating
Class                    To                  From
Trust Unit               CCC- (sf)           CCC- (sf)

PARCS-R Master Trust
Series 2008-3
                              Rating
Class                    To                  From
Trust Unit               D (sf)              CCC- (sf)

Primoris SPC Ltd.
Series C3-7
                                 Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd.
Series A1-7
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd.
Series A2-7
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd.
Series A5-7
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd.
Series A6-7
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd.
Series B1-7
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd.
Series D3-10
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd.
Series E3-7
                                 Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd
Series F1-10
                                 Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd
Series A1-7-2
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd
Series B2-10-2
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

Primoris SPC Ltd
Series D1-7-2
                              Rating
Class                    To                  From
Notes                    CC (sf)             CCC- (sf)

REVE SPC
EUR15 mil, ¯3 bil, US$81 mil REVE SPC Segregated Portfolio of
Dryden XVII
Notes
Series 34, 36, 37, 38, 39, & 40
                              Rating
Class                    To              From
Series 37                CCC+ (sf)       B- (sf)/Watch Neg

Rutland Rated Investments
US$25 mil Rutland Rated Investments Rumson 2007-2 Series 42
                              Rating
Class                    To             From
A1-L1                    B (sf)         CCC- (sf)/Watch Pos

STEERS Credit Linked Trust Minoa Tranche Series 2006-1
                              Rating
Class                    To                  From
Trust Cert               CCC- (sf)           CCC- (sf)

STEERS Credit Linked Trust, Bespoke Credit Tranche Series 2005-6
                              Rating
Class                    To               From
Trust Cert               B+ (sf)          B (sf)/Watch Pos

TIERS Derby Synthetic CDO Floating Rate Credit Linked Trust
2007-12
                              Rating
Class                    To                  From
Certs                    NR (sf)             CCC- (sf)


* S&P Cuts 51 Classes Ratings From 52 US RMBS Transactions to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 148
classes, including 51 lowered to 'D (sf)', from 43 U.S.
residential mortgage-backed securities (RMBS) transactions
issued between 1991 and 2008 and removed 82 of them from
CreditWatch with negative implications. "Concurrently, we affirmed
our ratings on 182 classes from 33 of the transactions with
lowered ratings as well as seven other transactions and removed 32
of those ratings from CreditWatch negative. We also lowered our
ratings on three classes from two other transactions and
subsequently withdrew the ratings due to the small number of loans
remaining and the potential for performance volatility.
Additionally, we withdrew our ratings on nine classes under our
interest-only criteria and on two classes because they have been
paid in full. Each of the transactions in this review has had at
least one class that has experienced interest shortfalls," S&P
said.

"Over the past several years, interest shortfalls have become more
prevalent within U.S. RMBS. Standard & Poor's attributes this to
several factors that can affect cash flows including: (i) the
reimbursement by servicers of prior advances deemed
nonrecoverable; (ii) the cessation of servicer advances on
delinquent loans; (iii) reimbursements for prior advances when
loans are modified and amounts are capitalized on the loan
balance; and (iv) significant deterioration in credit quality and
the resulting impact on structures that become undercollateralized
and unable to generate sufficient interest to make the applicable
security payments," S&P said.

"We applied the recently updated criteria as set forth in
'Methodology For Assessing the Impact of Interest Shortfalls on
U.S. RMBS,' published March 28, 2012. The updated criteria
continue to impose a maximum rating threshold on classes that have
incurred interest shortfalls. As a result, we lowered 91 ratings
by an average of six notches. However, for certain classes with
delayed reimbursement provisions, the updates to the criteria
limited the impact of interest shortfalls on the rating. For other
classes that do not have delayed reimbursement provisions, large
rating movements nevertheless occurred because those classes had
experienced interest shortfalls that were outstanding for longer
than 12 months. We also applied the applicable criteria listed
under 'Related Criteria And Research' contingent on the type of
RMBS," S&P said.

"In applying the criteria mentioned above, we looked to
reimbursement provisions within each payment waterfall for the
applicable RMBS in order to determine if the reimbursement
provisions were more immediate, or delayed. In instances where the
RMBS had immediate reimbursement provisions, we used the length of
time a shortfall remained unpaid, and the amount of the shortfall
as part of our analysis. In instances where the RMBS did not have
immediate reimbursement provisions, or delayed reimbursement, we
did not factor into our analysis the length of time a shortfall
was outstanding but rather the number of times a shortfall
occurred if certain conditions were met (interest accrues on the
outstanding amount, the collateral performance would have provided
for reimbursement had immediate reimbursement provisions existed,
and our projections show reimbursement)," S&P said.

S&P lowered its ratings on the transactions, which contain
immediate reimbursement provisions, due to interest shortfalls:

American Home Mortgage Investment Trust 2004-1, Series 2004-1
Bayview Commercial Asset Trust 2007-2, Series 2007-2
Bayview Commercial Asset Trust 2007-4, Series 2007-4
Bayview Commercial Asset Trust 2007-5, Series 2007-5
Bayview Commercial Asset Trust 2007-6, Series 2007-6
Bayview Commercial Asset Trust 2008-1, Series 2008-1
Bayview Commercial Asset Trust 2008-2, Series 2008-2
Bayview Commercial Asset Trust 2008-3, Series 2008-3
Bayview Commercial Asset Trust 2008-4, Series 2008-4
Bayview Financial Mortgage Pass-Through Trust 2007-B, Series 2007-
B
Carrington Mortgage Loan Trust, Series 2005-FRE1, Series 2005-FRE1
Credit Suisse First Boston Mortgage Securities Corp., Series 2003-
27 Merrill Lynch Mortgage Investors Trust Series MLCC 2006-2,
Series 2006-2 Option One Mortgage Loan Trust 2007-FXD1, Series
2007-FXD1 Ryland Mortgage Securities Corp., Series 1991-15
Structured Asset Securities Corp., Series 2003-26A

"We lowered our ratings on certain securities from Bayview
Commercial Asset Trust 2007-5, 2007-6, and 2008-2 to 'D (sf)' from
'AAA (sf)'," S&P said.

"For these transactions, cash available to pay interest has been
depleted because of poor collateral performance. Additionally,
these transactions generally have a decreased amount of cash
available to pay current bond interest because of swap agreements
and interest only certificates that have a higher priority within
the waterfall. As a result, certain securities within these
transactions have experienced ongoing interest shortfalls that
exceed the tolerance levels set forth in the applicable criteria,"
S&P said.

Conversely, S&P lowered its ratings on these transactions, which
contain delayed reimbursement provisions, due to interest
shortfalls:

Aames Mortgage Trust 2001-1, Series 2001-1
Bear Stearns Asset Backed Securities I Trust 2005-HE11, Series
2005-HE11 Bear Stearns Asset Backed Securities I Trust 2006-HE1,
Series 2006-HE1 GSAMP Trust 2004-SD1, Series 2004-SD1
MASTR Asset Backed Securities Trust 2004-FRE1, Series 2004-FRE1
Merrill Lynch Mortgage Investors Inc., Series 2002-NC1
Merrill Lynch Mortgage Investors Trust, Series 2004-WMC3, Series
2004-WMC3 Quest Trust 2003-X2, Series 2003-X2 Quest Trust 2003-X3,
Series 2003-X3 Quest Trust 2004-X2, Series 2004-X2

"We lowered our ratings on certain mezzanine securities from Bear
Stearns Asset Backed Securities I Trust 2005-HE11 and 2006-HE1 to
'D (sf)' due to interest shortfalls that occurred in January 2011
and have yet to be reimbursed. Our cash flow analysis indicates
that these classes could have been reimbursed but this would only
have occurred after the certificate balances were paid in full.
However, the documents for these transactions have specific
language prohibiting any distributions of prior shortfalls to a
certificate once that certificate's balance has been reduced to
zero," S&P said.

"In some instances, the classes with lowered ratings have not
experienced ongoing interest shortfalls for several months.
However, due to the inability of such transactions to repay prior
shortfalls and the uncertainty about whether they will ever be
repaid, the lowered ratings reflect our view of the current
creditworthiness of each security. If interest shortfalls are
temporary and not expected to recur, Standard & Poor's may raise
the rating once interest shortfalls have been fully reimbursed and
the appropriate credit characteristics are evident," S&P said.

"In addition to applying the appropriate rating threshold based on
our interest shortfall criteria, in order to assess the
creditworthiness of each class, we compared our lifetime loss
projections against each class' projected credit support and its
ability to withstand additional credit deterioration. Therefore,
to the extent that interest shortfalls did not contribute to the
lowered rating, the lowered ratings reflect our belief that
projected credit enhancement for the affected classes will be
insufficient to cover the projected losses we applied at the
previous rating levels. Conversely, the rating affirmations
reflect our belief that projected credit enhancement for these
classes will be sufficient to cover our projected losses at these
rating levels," 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 ACTIONS


C-BASS Mortgage Loan Asset Backed Certificates, Series 2002-CB5
Series      2002-CB5
                               Rating
Class      CUSIP       To                   From
M-1        12489WFS8   BB- (sf)             AA- (sf)/Watch Neg
M-2        12489WFT6   CCC (sf)             B- (sf)/Watch Neg

Aames Mortgage Trust 2001-1
Series      2001-1
                               Rating
Class      CUSIP       To                   From
A-2        00253CGM3   NR                   AAA (sf)
M-2        00253CGQ4   BB+ (sf)             A (sf)/Watch Neg

ACE Securities Corp. Home Equity Loan Trust, Series 2005-RM2
Series      2005-RM2
                               Rating
Class      CUSIP       To                   From
M-2        004421NU3   AA (sf)              AA (sf)/Watch Neg
M-3        004421NV1   AA (sf)              AA (sf)/Watch Neg
M-4        004421NW9   BB+ (sf)             BB+ (sf)/Watch Neg
M-6        004421NY5   CC (sf)              CCC (sf)

ACE Securities Corp. Home Equity Loan Trust, Series 2005-SD2
Series      2005-SD2
                               Rating
Class      CUSIP       To                   From
M-1        004421QE6   AA (sf)              AA (sf)/Watch Neg
M-2        004421QF3   A (sf)               A (sf)/Watch Neg
M-3        004421QG1   B- (sf)              B (sf)/Watch Neg

American Home Mortgage Investment Trust 2004-1
Series      2004-1
                               Rating
Class      CUSIP       To                   From
IV-A       02660TAR4   AA+ (sf)             AAA (sf)/Watch Neg
III-M-1    02660TAP8   BB+ (sf)             AA (sf)
IV-M-1     02660TAS2   B- (sf)              BB- (sf)/Watch Neg
I-M-2      02660TAG8   BB+ (sf)             A (sf)
IV-M-2     02660TAT0   CCC (sf)             B- (sf)/Watch Neg

Ameriquest Mortgage Securities Inc.
Series      2003-AR3
                               Rating
Class      CUSIP       To                   From
M-5        03072SHK4   B- (sf)              B+ (sf)/Watch Neg

Ameriquest Mortgage Securities Inc.
Series      2004-IA1
                               Rating
Class      CUSIP       To                   From
M-2        03072SVC6   BBB- (sf)            AA- (sf)/Watch Neg
M-3        03072SVD4   B- (sf)              BB+ (sf)/Watch Neg

Argent Securities Inc.
Series      2004-W11
                               Rating
Class      CUSIP       To                   From
M-2        040104MF5   AA+ (sf)             AA+ (sf)/Watch Neg
M-3        040104MG3   BBB+ (sf)            BBB+ (sf)/Watch Neg
M-4        040104MJ7   B (sf)               B (sf)/Watch Neg

Bayview Commercial Asset Trust 2004-3
Series      2004-3
                               Rating
Class      CUSIP       To                   From
M-2        07324SBA9   A (sf)               A (sf)/Watch Neg
B-1        07324SBB7   BBB+ (sf)            BBB+ (sf)/Watch Neg
B-2        07324SBC5   BBB- (sf)            BBB+ (sf)/Watch Neg

Bayview Commercial Asset Trust 2007-2
Series      2007-2
                               Rating
Class      CUSIP       To                   From
IO         07325XAN0   NR                   AAA (sf)/Watch Neg
A-1        07325XAA8   BB+ (sf)             AAA (sf)/Watch Neg
B-1        07325XAJ9   CC (sf)              CCC (sf)

Bayview Commercial Asset Trust 2007-4
Series      2007-4
                               Rating
Class      CUSIP       To                   From
IO         07326BAM9   NR                   AA (sf)/Watch Neg
A-1        07326BAA5   D (sf)               AA (sf)/Watch Neg

Bayview Commercial Asset Trust 2007-5
Series      2007-5
                               Rating
Class      CUSIP       To                   From
IO         07325WAA0   NR                   AAA (sf)/Watch Neg
A-2        07325WAC6   D (sf)               AAA (sf)/Watch Neg
A-3        07325WAD4   D (sf)               AAA (sf)/Watch Neg
A-4        07325WAE2   D (sf)               B (sf)/Watch Neg
M-1        07325WAF9   D (sf)               CCC (sf)
M-2        07325WAG7   D (sf)               CCC (sf)
M-3        07325WAH5   D (sf)               CCC (sf)
M-4        07325WAJ1   D (sf)               CCC (sf)

Bayview Commercial Asset Trust 2007-6
Series      2007-6
                               Rating
Class      CUSIP       To                   From
IO         07326FAA6   NR                   AAA (sf)/Watch Neg
A-2        07326FAC2   D (sf)               AAA (sf)/Watch Neg
A-3A       07326FAD0   D (sf)               AAA (sf)/Watch Neg
A-3B       07326FAT5   D (sf)               AAA (sf)/Watch Neg
A-4A       07326FAE8   D (sf)               AA (sf)/Watch Neg
A-4B       07326FAU2   D (sf)               AA (sf)/Watch Neg
M-1        07326FAF5   D (sf)               CCC (sf)
M-2        07326FAG3   D (sf)               CCC (sf)
M-3        07326FAH1   D (sf)               CCC (sf)
M-4        07326FAJ7   D (sf)               CCC (sf)
M-5        07326FAK4   D (sf)               CCC (sf)

Bayview Commercial Asset Trust 2008-1
Series      2008-1
                               Rating
Class      CUSIP       To                   From
IO         07324AAA9   AA+ (sf)             AAA (sf)/Watch Neg
A-2A       07324AAC5   AA+ (sf)             AAA (sf)/Watch Neg
A-2B       07324AAD3   AA+ (sf)             AAA (sf)/Watch Neg
A-3        07324AAE1   AA+ (sf)             AAA (sf)/Watch Neg
A-4        07324AAF8   AA (sf)              AAA (sf)/Watch Neg
M-1        07324AAG6   CCC (sf)             BB (sf)/Watch Neg
M-2        07324AAH4   CCC (sf)             B (sf)/Watch Neg
M-6        07324AAM3   CC (sf)              CCC (sf)

Bayview Commercial Asset Trust 2008-2
Series      2008-2
                               Rating
Class      CUSIP       To                   From
IO         07326HAA2   NR                   AAA (sf)/Watch Neg
SIO        07326HAB0   NR                   AAA (sf)/Watch Neg
A-1        07326HAC8   D (sf)               AAA (sf)/Watch Neg
A-2        07326HAE4   D (sf)               BBB (sf)/Watch Neg
A-3        07326HAH7   D (sf)               BBB (sf)/Watch Neg
A-4A       07326HAJ3   D (sf)               BBB (sf)/Watch Neg
A-4B       07326HAK0   D (sf)               BBB (sf)/Watch Neg
M-1        07326HAL8   D (sf)               CCC (sf)
M-2        07326HAM6   D (sf)               CCC (sf)
M-3        07326HAN4   D (sf)               CCC (sf)
M-4        07326HAP9   D (sf)               CCC (sf)
M-5        07326HAQ7   D (sf)               CCC (sf)
M-6        07326HAR5   D (sf)               CCC (sf)
B-1        07326HAS3   CC (sf)              CCC (sf)
B-2        07326HAT1   CC (sf)              CCC (sf)

Bayview Commercial Asset Trust 2008-3
Series      2008-3
                               Rating
Class      CUSIP       To                   From
IO         07326JAA8   NR                   AAA (sf)/Watch Neg
SIO        07326JAB6   NR                   AAA (sf)/Watch Neg
A-1        07326JAC4   BB+ (sf)             AAA (sf)/Watch Neg
A-2        07326JAD2   CCC (sf)             A (sf)/Watch Neg
A-3        07326JAE0   CCC (sf)             BBB (sf)/Watch Neg
A-4        07326JAF7   CCC (sf)             BBB (sf)/Watch Neg
M-4        07326JAK6   D (sf)               CCC (sf)
M-5        07326JAL4   D (sf)               CCC (sf)
M-6        07326JAM2   D (sf)               CCC (sf)
B-1        07326JAN0   CC (sf)              CCC (sf)
B-2        07326JAP5   CC (sf)              CCC (sf)

Bayview Commercial Asset Trust 2008-4
Series      2008-4
                               Rating
Class      CUSIP       To                   From
SIO        07326KAA5   NR                   AAA (sf)
A-1        07326KAB3   NR                   AAA (sf)/Watch Neg
A-2        07326KAC1   BBB+ (sf)            AAA (sf)/Watch Neg
A-3        07326KAD9   BBB+ (sf)            AAA (sf)/Watch Neg
A-4        07326KAE7   BBB+ (sf)            AAA (sf)/Watch Neg
M-1        07326KAF4   BB (sf)              AA (sf)/Watch Neg
M-2        07326KAG2   CCC (sf)             BBB (sf)/Watch Neg
M-3        07326KAH0   CCC (sf)             BBB (sf)/Watch Neg
M-4        07326KAJ6   CCC (sf)             B (sf)

Bayview Financial Mortgage Pass-Through Trust 2007-B
Series      2007-B
                               Rating
Class      CUSIP       To                   From
1-A1       07324FAB6   B+ (sf)              AAA (sf)/Watch Neg
2-A1       07324FAG5   B+ (sf)              AAA (sf)/Watch Neg
2-A2       07324FAH3   B- (sf)              B- (sf)/Watch Neg

Bear Stearns Asset Backed Securities I Trust 2005-HE11
Series      2005-HE11
                               Rating
Class      CUSIP       To                   From
M-1        0738793N6   D (sf)               AA+ (sf)/Watch Neg
M-2        0738793P1   D (sf)               AA (sf)/Watch Neg
M-3        0738793Q9   D (sf)               CCC (sf)
M-4        0738793R7   D (sf)               CC (sf)
M-5        0738793S5   D (sf)               CCC (sf)

Bear Stearns Asset Backed Securities I Trust 2006-HE1
Series      2006-HE1
                               Rating
Class      CUSIP       To                   From
II-M-1     07387UBR1   D (sf)               AA+ (sf)/Watch Neg
II-M-2     07387UBS9   D (sf)               AA+ (sf)/Watch Neg
II-M-3     07387UBT7   D (sf)               CCC (sf)
II-M-4     07387UBU4   D (sf)               CC (sf)
II-M-5     07387UBV2   D (sf)               CCC (sf)

Carrington Mortgage Loan Trust, Series 2004-NC2
Series      2004-NC2
                               Rating
Class      CUSIP       To                   From
M-3        144531AS9   CC (sf)              CCC (sf)
M-1        144531AQ3   AA (sf)              AA (sf)/Watch Neg

Carrington Mortgage Loan Trust, Series 2005-FRE1
Series      2005-FRE1
                               Rating
Class      CUSIP       To                   From
A-3        144531EB2   AA+ (sf)             AAA (sf)
A-4        144531EC0   AA+ (sf)             AAA (sf)
A-5        144531ED8   AA+ (sf)             AAA (sf)
A-6        144531EE6   AA+ (sf)             AAA (sf)
M-1        144531EF3   BBB+ (sf)            AA (sf)/Watch Neg
M-2        144531EG1   B- (sf)              BBB (sf)/Watch Neg
M-4        144531EJ5   CC (sf)              CCC (sf)
M-5        144531EK2   CC (sf)              CCC (sf)
M-6        144531EL0   CC (sf)              CCC (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Series      2003-27
                               Rating
Class      CUSIP       To                   From
VIII-A-1   22541QQ39   AA+ (sf)             AAA (sf)/Watch Neg
IX-A-1     22541QQ47   AA+ (sf)             AAA (sf)/Watch Neg
C-B-1      22541QR79   BB (sf)              BB+ (sf)
D-B-1      22541QS29   B (sf)               B+ (sf)
C-B-2      22541QR87   CCC (sf)             B- (sf)
D-B-2      22541QS37   CC (sf)              CCC (sf)

EMC Mortgage Loan Trust 2004-A
Series      2004-A
                               Rating
Class      CUSIP       To                   From
A-3        268668DC1   A- (sf)              A (sf)
M-1        268668DD9   CCC (sf)             B (sf)/Watch Neg
M-2        268668DE7   CC (sf)              CCC (sf)

Fieldstone Mortgage Investment Trust Series 2005-1
Series      2005-1
                               Rating
Class      CUSIP       To                   From
M4         31659TDD4   A+ (sf)              A+ (sf)/Watch Neg
M5         31659TDE2   A (sf)               A (sf)/Watch Neg

GSAMP Trust 2004-SD1
Series      2004-SD1
                               Rating
Class      CUSIP       To                   From
M-1        36242DAX1   AA (sf)              AA (sf)/Watch Neg
M-2        36242DAY9   BB+ (sf)             A (sf)/Watch Neg
B-1        36242DAZ6   CC (sf)              CCC (sf)
B-2        36242DBA0   CC (sf)              CCC (sf)

GSAMP Trust 2005-HE2
Series      2005-HE2
                               Rating
Class      CUSIP       To                   From
M-1        36242DA52   A (sf)               A (sf)/Watch Neg

GSRPM Mortgage Loan Trust 2003-2
Series      2003-2
                               Rating
Class      CUSIP       To                   From
M-2        36228FWK8   B (sf)               B (sf)/Watch Neg

Home Equity Mortgage Loan Asset-Backed Trust, Series INABS 2005-A
Series      2005-A
                               Rating
Class      CUSIP       To                   From
M-6        43708AAW2   B- (sf)              BB- (sf)/Watch Neg
M-8        43708AAY8   CC (sf)              CCC (sf)

Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2003-A
Series      SPMD2003-A
                               Rating
Class      CUSIP       To                   From
MV-1       456606EC2   B- (sf)              B- (sf)/Watch Neg
MV-2       456606ED0   CC (sf)              CCC (sf)

Homeside Mortgage Securities, Inc.
Series      1998-2
Class      CUSIP       To       Interim     From
IA-1       437609AV2   NR       BB (sf)     BB (sf)
IIA-1      437609BE9   NR       BB (sf)     BB (sf)

HSI Asset Securitization Corporation Trust 2005-OPT1
Series      2005-OPT1
                               Rating
Class      CUSIP       To                   From
M-1        40430HCA4   B- (sf)              B- (sf)/Watch Neg
M-2        40430HCB2   CC (sf)              CCC (sf)

MASTR Adjustable Rate Mortgages Trust 2002-3
Series      2002-3
                               Rating
Class      CUSIP       To                   From
B-1        576433BQ8   B (sf)               B (sf)/Watch Neg

MASTR Adjustable Rate Mortgages Trust 2004-14
Series      2004-14
                               Rating
Class      CUSIP       To                   From
B-1        576433VD5   BB+ (sf)             BBB (sf)

MASTR Asset Backed Securities Trust 2004-FRE1
Series      2004-FRE1
                               Rating
Class      CUSIP       To                   From
M-4        57643LDX1   BB+ (sf)             A+ (sf)/Watch Neg
M-5        57643LDY9   B+ (sf)              A (sf)/Watch Neg
M-6        57643LDZ6   CCC (sf)             A- (sf)/Watch Neg
M-7        57643LEA0   CCC (sf)             BBB (sf)/Watch Neg
M-8        57643LEB8   D (sf)               CC (sf)

Meritage Mortgage Loan Trust 2005-2
Series      2005-2
                               Rating
Class      CUSIP       To                   From
M-2        59001FCS8   B- (sf)              B- (sf)/Watch Neg

Merrill Lynch Mortgage Investors Inc.
Series      2002-NC1
                               Rating
Class      CUSIP       To                   From
M-1        589929ZE1   BBB+ (sf)            AA (sf)/Watch Neg
M-2        589929ZF8   B- (sf)              B- (sf)/Watch Neg

Merrill Lynch Mortgage Investors Trust Series MLCC 2006-2
Series      2006-2
                               Rating
Class      CUSIP       To                   From
III-A      590219AF8   AA+ (sf)             AAA (sf)/Watch Neg
IV-A       590219AG6   AA+ (sf)             AAA (sf)/Watch Neg
M-2        590219AK7   CC (sf)              CCC (sf)

Merrill Lynch Mortgage Investors Trust, Series 2004-WMC3
Series      2004-WMC3
                               Rating
Class      CUSIP       To                   From
M-3        59020UCQ6   BB+ (sf)             A+ (sf)/Watch Neg

Morgan Stanley Home Equity Loan Trust 2005-4
Series      2005-4
                               Rating
Class      CUSIP       To                   From
M-1        61744CVJ2   BB (sf)              A- (sf)/Watch Neg

Option One Mortgage Loan Trust 2007-FXD1
Series      2007-FXD1
                               Rating
Class      CUSIP       To                   From
I-A-1      68402VAA0   D (sf)               CC (sf)
II-A-1     68402VAB8   D (sf)               CC (sf)
III-A-2    68402VAD4   D (sf)               CCC (sf)
III-A-3    68402VAE2   D (sf)               CCC (sf)
III-A-4    68402VAF9   D (sf)               CCC (sf)
III-A-5    68402VAG7   D (sf)               CCC (sf)
III-A-6    68402VAH5   D (sf)               CC (sf)

Quest Trust 2003-X2
Series      2003-X2
                               Rating
Class      CUSIP       To                   From
M-2        03072SHP3   CCC (sf)             AA (sf)/Watch Neg

Quest Trust 2003-X3
Series      2003-X3
                               Rating
Class      CUSIP       To                   From
M-2        03072SKE4   BB+ (sf)             AA (sf)/Watch Neg
M-3        03072SKF1   B+ (sf)              BBB (sf)/Watch Neg

Quest Trust 2003-X4
Series      2003-X4
                               Rating
Class      CUSIP       To                   From
M-1        03072SMH5   AA- (sf)             AA- (sf)/Watch Neg

Quest Trust 2004-X2
Series      2004-X2
                               Rating
Class      CUSIP       To                   From
M-2        03072SSX4   BBB+ (sf)            A (sf)/Watch Neg
M-3        03072SSY2   CCC (sf)             B- (sf)/Watch Neg

Quest Trust 2004-X3
Series      2004-X3
                               Rating
Class      CUSIP       To                   From
M-1        03072SWC5   AA (sf)              AA (sf)/Watch Neg
M-2        03072SWD3   A (sf)               A (sf)/Watch Neg
M-3        03072SWE1   CCC (sf)             B (sf)/Watch Neg

Quest Trust 2005-X1
Series      2005-X1
                               Rating
Class      CUSIP       To                   From
M-2        03072SZK4   A (sf)               A (sf)/Watch Neg
M-3        03072SZL2   A- (sf)              A- (sf)/Watch Neg
M-4        03072SZM0   BB (sf)              BBB- (sf)/Watch Neg

Ryland Mortgage Securities Corp.
Series      1991-15
                               Rating
Class      CUSIP       To                   From
B          783766GV4   D (sf)               B (sf)/Watch Neg

Soundview Home Equity Loan Trust 2005-2
Series      2005-2
                               Rating
Class      CUSIP       To                   From
M-2        83611MER5   AA (sf)              AA (sf)/Watch Neg
M-3        83611MES3   AA- (sf)             AA- (sf)/Watch Neg
M-4        83611MET1   A+ (sf)              A+ (sf)/Watch Neg
M-5        83611MEU8   A (sf)               A (sf)/Watch Neg
M-6        83611MEV6   BB (sf)              BBB- (sf)/Watch Neg
M-8        83611MEX2   CC (sf)              CCC (sf)

Structured Asset Mortgage Investments Trust 2002-3
Series      2002-3
                               Rating
Class      CUSIP       To       Interim     From
CC         86358HNF2   NR       BB (sf)     AAA (sf)/Watch Neg

Structured Asset Securities Corp.
Series      2003-26A
                               Rating
Class      CUSIP       To                   From
1A         86359AS20   A+ (sf)              AAA (sf)/Watch Neg
2-A        86359AS46   BBB+ (sf)            AAA (sf)/Watch Neg
3-A1       86359AS53   A+ (sf)              AAA (sf)/Watch Neg
3-A5       86359AS95   A+ (sf)              AAA (sf)/Watch Neg
4-A        86359AT52   AA+ (sf)             AAA (sf)/Watch Neg
5-A        86359AT78   AA+ (sf)             AAA (sf)/Watch Neg
6-A        86359AT86   A+ (sf)              AAA (sf)/Watch Neg
7-A        86359AU35   AA+ (sf)             AAA (sf)/Watch Neg
B1-II      86359AU84   CC (sf)              CCC (sf)

Wachovia Mortgage Loan Trust, LLC
Series      2005-WMC1
                               Rating
Class      CUSIP       To                   From
M-1        92977YAX9   A+ (sf)              A+ (sf)/Watch Neg
M-2        92977YAY7   CC (sf)              CCC (sf)

RATINGS AFFIRMED

C-BASS Mortgage Loan Asset Backed Certificates, Series 2002-CB5
Series  2002-CB5
Class      CUSIP       Rating
AF-3       12489WFP4   AAA (sf)
B-1        12489WFU3   CC (sf)

Aames Mortgage Trust 2001-1
Series      2001-1
Class      CUSIP       Rating
M-1        00253CGP6   AA+ (sf)

ACE Securities Corp. Home Equity Loan Trust, Series 2005-RM2
Series      2005-RM2
Class      CUSIP       Rating
M-5        004421NX7   CCC (sf)

ACE Securities Corp. Home Equity Loan Trust, Series 2005-SD2
Series      2005-SD2
Class      CUSIP       Rating
M-4        004421QH9   CCC (sf)
M-5        004421QJ5   CC (sf)

American Home Mortgage Investment Trust 2004-1
Series      2004-1
Class      CUSIP       Rating
I-A        02660TAE3   AAA (sf)
II-A       02660TAJ2   AAA (sf)
III-A      02660TAN3   AAA (sf)
I-M-1      02660TAF0   AA (sf)
II-M-1     02660TAK9   BB (sf)
II-M-2     02660TAL7   CCC (sf)
III-M-2    02660TAQ6   CCC (sf)
I-M-3      02660TAH6   CCC (sf)
II-M-3     02660TAM5   CCC (sf)
IV-M-3     02660TAU7   CCC (sf)

Ameriquest Mortgage Securities Inc.
Series      2003-AR3
Class      CUSIP       Rating
M-2        03072SHG3   A+ (sf)
M-3        03072SHH1   A (sf)
M-4        03072SHJ7   BBB+ (sf)

Ameriquest Mortgage Securities Inc.
Series      2004-IA1
Class      CUSIP       Rating
M-1        03072SVB8   AAA (sf)

Argent Securities Inc.
Series      2004-W11
Class      CUSIP       Rating
M-1        040104ME8   AA+ (sf)
M-5        040104MK4   CCC (sf)
M-6        040104ML2   CC (sf)
M-7        040104MM0   CC (sf)

Bayview Commercial Asset Trust 2004-3
Series      2004-3
Class      CUSIP       Rating
A-1        07324SAX0   AAA (sf)
M-1        07324SAZ5   AA (sf)

Bayview Commercial Asset Trust 2008-1
Series      2008-1
Class      CUSIP       Rating
M-3        07324AAJ0   CCC (sf)
M-4        07324AAK7   CCC (sf)
M-5        07324AAL5   CCC (sf)

Bayview Commercial Asset Trust 2008-3
Series      2008-3
Class      CUSIP       Rating
M-1        07326JAG5   CCC (sf)
M-2        07326JAH3   CCC (sf)
M-3        07326JAJ9   CCC (sf)

Bayview Commercial Asset Trust 2008-4
Series      2008-4
Class      CUSIP       Rating
M-5        07326KAK3   CCC (sf)
M-6        07326KAL1   CCC (sf)
B-1        07326KAM9   CCC (sf)
B-2        07326KAN7   CCC (sf)

Bayview Financial Mortgage Pass-Through Trust 2007-B
Series      2007-B
Class      CUSIP       Rating
1-A2       07324FAC4   CCC (sf)
1-A3       07324FAD2   CCC (sf)
1-A4       07324FAE0   CCC (sf)
1-A5       07324FAF7   CCC (sf)
2-A3       07324FAJ9   CCC (sf)
2-A4       07324FAK6   CCC (sf)

Bear Stearns Asset Backed Securities I Trust 2005-HE11
Series      2005-HE11
Class      CUSIP       Rating
A-2        0738793L0   AAA (sf)
A-3        0738793M8   AAA (sf)

Bear Stearns Asset Backed Securities I Trust 2006-HE1
Series      2006-HE1
Class      CUSIP       Rating
I-A-2      0738796M5   AAA (sf)
I-A-3      0738796N3   AAA (sf)
I-M-1      0738796P8   BBB+ (sf)
I-M-2      0738796Q6   B- (sf)
I-M-3      0738796R4   CCC (sf)
I-M-4      0738796S2   CC (sf)
I-M-5      0738796T0   CC (sf)
I-M-6      0738796U7   CC (sf)
II-A-2     07387UBP5   AAA (sf)
II-A-3     07387UBQ3   AAA (sf)

Carrington Mortgage Loan Trust, Series 2004-NC2
Series      2004-NC2
Class      CUSIP       Rating
M-2        144531AR1   CCC (sf)
M-4        144531AT7   CC (sf)

Carrington Mortgage Loan Trust, Series 2005-FRE1
Series      2005-FRE1
Class      CUSIP       Rating
M-3        144531EH9   CCC (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Series      2003-27
Class      CUSIP       Rating
I-A-2      22541QK68   AAA (sf)
I-A-3      22541QK76   AAA (sf)
I-A-4      22541QK84   AAA (sf)
II-A-1     22541QK92   AAA (sf)
III-A-1    22541QL26   AAA (sf)
III-A-2    22541QL34   AAA (sf)
V-A-2      22541QP63   AAA (sf)
V-A-3      22541QP71   AAA (sf)
V-A-4      22541QP89   AAA (sf)
II-X       22541QQ54   AAA (sf)
C-X        22541QQ88   AAA (sf)
II-P       22541QR20   AAA (sf)
A-P        22541QR53   AAA (sf)
IV-A-3     22541QL67   AAA (sf)
IV-A-4     22541QL75   AAA (sf)
IV-A-5     22541QL83   AAA (sf)
IV-A-6     22541QL91   AAA (sf)
IV-A-7     22541QM25   AAA (sf)
IV-A-8     22541QM33   AAA (sf)
IV-A-9     22541QM41   AAA (sf)
IV-A-15    22541QN24   AAA (sf)
IV-A-16    22541QN32   AAA (sf)
IV-A-17    22541QN40   AAA (sf)
VI-A-1     22541QP97   AAA (sf)
VII-A-1    22541QQ21   AAA (sf)
IV-X       22541QQ62   AAA (sf)
VI-X       22541QQ70   AAA (sf)
D-X        22541QQ96   AAA (sf)
IV-P       22541QR38   AAA (sf)
VI-P       22541QR46   AAA (sf)
D-P        22541QR61   AAA (sf)
D-B-3      22541QS45   CC (sf)
C-B-3      22541QR95   CC (sf)
C-B-4      22541QJ78   CC (sf)
C-B-5      22541QJ86   CC (sf)

EMC Mortgage Loan Trust 2004-A
Series      2004-A
Class      CUSIP       Rating
B          268668DS6   CC (sf)

Fieldstone Mortgage Investment Trust Series 2005-1
Series      2005-1
Class      CUSIP       Rating
M6         31659TDF9   CCC (sf)
M7         31659TDG7   CC (sf)

GSAMP Trust 2005-HE2
Series      2005-HE2
Class      CUSIP       Rating
M-2        36242DA60   CC (sf)
M-3        36242DA78   CC (sf)
B-1        36242DA86   CC (sf)

GSRPM Mortgage Loan Trust 2003-2
Series      2003-2
Class      CUSIP       Rating
A-1        36228FWH5   AAA (sf)
M-1        36228FWJ1   AA (sf)
B-1        36228FWL6   CC (sf)

Home Equity Mortgage Loan Asset-Backed Trust, Series INABS 2005-A
Series      2005-A
Class      CUSIP       Rating
M-1        43708AAR3   AA+ (sf)
M-2        43708AAS1   AA (sf)
M-3        43708AAT9   AA (sf)
M-4        43708AAU6   AA- (sf)
M-5        43708AAV4   BBB+ (sf)
M-7        43708AAX0   CC (sf)
M-9        43708AAZ5   CC (sf)

Home Equity Mortgage Loan Asset-Backed Trust, Series SPMD 2003-A
Series      SPMD2003-A
Class      CUSIP       Rating
AF-4       456606DV1   A- (sf)
AF-5       456606DW9   AA- (sf)
AV-2       456606EB4   AAA (sf)
MV-3       456606EE8   CC (sf)
MV-5       456606EG3   CC (sf)
BV         456606EH1   CC (sf)

HSI Asset Securitization Corporation Trust 2005-OPT1
Series      2005-OPT1
Class      CUSIP       Rating
A-3        40430HBY3   AAA (sf)
A-4        40430HBZ0   AAA (sf)
M-3        40430HCC0   CC (sf)
M-4        40430HCD8   CC (sf)
M-5        40430HCE6   CC (sf)

MASTR Adjustable Rate Mortgages Trust 2002-3
Series      2002-3
Class      CUSIP       Rating
1-A-1      576433BH8   BB (sf)
3-A-1      576433BL9   BB (sf)
4-A-1      576433BM7   BB (sf)
B-2        576433BR6   CCC (sf)

MASTR Adjustable Rate Mortgages Trust 2004-14
Series      2004-14
Class      CUSIP       Rating
M-1        576433VB9   AA (sf)
M-2        576433VC7   A (sf)
B-2        576433VE3   CC (sf)

Meritage Mortgage Loan Trust 2005-2
Series      2005-2
Class      CUSIP       Rating
M-3        59001FCT6   CCC (sf)
M-4        59001FCU3   CC (sf)

Merrill Lynch Mortgage Investors Inc.
Series      2002-NC1
Class      CUSIP       Rating
B-1        589929ZC5   CC (sf)

Merrill Lynch Mortgage Investors Trust Series MLCC 2006-2
Series      2006-2
Class      CUSIP       Rating
I-A        590219AD3   AA (sf)
II-A       590219AE1   AA (sf)
M-1        590219AJ0   B+ (sf)
M-3        590219AL5   CC (sf)

Merrill Lynch Mortgage Investors Trust, Series 2004-WMC3
Series      2004-WMC3
Class      CUSIP       Rating
M-2        59020UCP8   AA (sf)
B-1        59020UCR4   CC (sf)

Morgan Stanley Home Equity Loan Trust 2005-4
Series      2005-4
Class      CUSIP       Rating
A-1        61744CVE3   AAA (sf)
A-2c       61744CVH6   AAA (sf)
M-2        61744CVK9   CC (sf)

Quest Trust 2003-X4
Series      2003-X4
Class      CUSIP       Rating
M-2        03072SMJ1   CC (sf)

Quest Trust 2004-X2
Series      2004-X2
Class      CUSIP       Rating
M-4        03072SSZ9   CC (sf)

Quest Trust 2004-X3
Series      2004-X3
Class      CUSIP       Rating
M-4        03072SWF8   CC (sf)

Quest Trust 2005-X1
Series      2005-X1
Class      CUSIP       Rating
M-1        03072SZJ7   AA (sf)
M-5        03072SZN8   CCC (sf)
M-6        03072SZP3   CC (sf)

Soundview Home Equity Loan Trust 2005-2
Series      2005-2
Class      CUSIP       Rating
M-7        83611MEW4   CCC (sf)

Structured Asset Securities Corp.
Series      2003-26A
Class      CUSIP       Rating
B1-I       86359AU43   CCC (sf)
B2-1       86359AU68   CC (sf)
B2-II      86359AU92   CC (sf)
B3         86359AV26   CC (sf)

Wachovia Mortgage Loan Trust, LLC
Series      2005-WMC1
Class      CUSIP       Rating
A-4        92977YAW1   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, Ivy B. Magdadaro, 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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