TCR_Public/121014.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, October 14, 2012, Vol. 16, No. 286

                            Headlines

ALM VII: S&P Gives 'B' Rating on Class E Deferrable Notes
AMAC CDO: Moody's Affirms 'C' Rating on Class F Notes
AMRESCO COMMERCIAL: Moody's Cuts Rating on Class B Notes to 'B3'
ANTHRACITE CDO: Fitch Affirms Junk Rating on Nine Note Classes
BANC OF AMERICA 2003-3: Moody's Cuts Rating on A-4 Tranche to Ba1

BANC OF AMERICA 2006-BIXI: S&P Cuts Rating on Cl. K Certs to 'D'
BEAR STEARNS: Moody's Lowers Ratings on Three Tranches to 'Ca'
BEAR STEARNS 2007-PWR18: S&P Lowers Ratings on 11 Classes
CITICORP MORTGAGE 2007-1: Moody's Cuts IIA-IO Sec. Rating to Caa3
COUNTRYWIDE: Moody's Junks Ratings on Two RMBS Transactions

CROWN POINT: S&P Gives 'BB-' Rating on Class B-2L Deferrable Notes
CSFB MORTGAGE 2001-26: Moody's Cuts Rating on D-B-2 Notes to 'Ca'
CT CDO IV: Fitch Affirms Junk Ratings on 15 Note Classes
DAWN CDO I: S&P Withdraws 'CC' Rating on Class B Notes on Paydown
FAIRBANKS CAPITAL: Moody's Cuts Rating on Cl. B Tranche to Caa1

FALCON AUTO: Moody's Cuts Rating on Class A-2 Certs. to 'Caa2'
GOLDMAN SACHS 2011-GC5: Fitch Affirms 'B' Rating on $23.9MM Certs
GMAC COMMERCIAL: S&P Lowers Rating on Class F Certs. to 'D'
GMAC MORTGAGE: Fitch Keeps Rating Watch Neg. on 140 RMBS Classes
GRANITE VENTURES II: S&P Affirms 'CCC+' Rating on Class D Notes

GS MORTGAGE: Fitch Affirms Junk Rating on 9 Security Classes
GULF STREAM-COMPASS 2005-II: S&P Affirms 'B+' Rating on Class D
HEWETT'S ISLAND V: Moody's Lifts Rating on Class D Notes to 'Ba1'
INDEPENDENCE III: S&P Lowers Rating on Class A-1 Notes to 'D'
LAFAYETTE SQUARE: Moody's Lifts Rating on Cl. Q-5 Notes From Ba1

MASTR ALTERNATIVE: Moody's Cuts Ratings on 9 Tranches to 'Caa3'
MORGAN STANLEY 2003-HE2: Moody's Cuts Rating on M-2 Tranche to B3
MORGAN STANLEY 2007-XLC1: Moody's Keeps 'C' Ratings on 2 Notes
NATIONAL COLLEGIATE: Fitch Keeps 'CC' Rating on Sub. Class B Notes
OCP CLO 2012-1: S&P Affirms 'BB' Rating on Class D Def Notes

PREFERRED TERM X: Moody's Cuts Ratings on 3 Note Classes to 'Ca'
PREFERRED TERM XXV: Moody's Lifts Rating on A-2 Notes to 'Ba2'
RALI SERIES: Moody's Confirms 'Caa3' Ratings on 14 RMBS Tranches
RESIDENTIAL REINSURANCE: S&P Keeps 'B' Cl. 5 Note Rating on Watch
SANTANDER DRIVE 2012-6: Fitch Rates $50-Mil. Class E Notes 'BBsf'

SECURITIZED ASSET 2007-BR4: Moody's Cuts Ratings on 3 Secs. to Ca
SOLOSO CDO: Moody's Upgrades Rating on Cl. A-1LB Notes to 'Caa2'
SOUND POINT I: S&P Gives 'BB' Rating on Class E Deferrable Notes
UNITED AIR: Moody's Affirms Ba3 Rating to Series 2009-2B Tranche
TIAA REAL: Fitch Affirms Junk Rating on Two Note Classes

WAMU 2004-AR1: Moody's Cuts Rating on Class B-1 Certs to 'Caa2'
WELLS FARGO 2004-Z: Moody's Cuts Rating on I-A-2 Secs. to 'B3'
WFRBS COMMERCIAL: Fitch Issues Presale Report on Certificates
ZAIS INVESTMENT: Moody's Lifts Rating on Cl. A-2 Notes to 'Ba1'

* Fitch Takes Rating Actions on Eight TruPs CDOs
* S&P Lowers Ratings on 241 Classes From 79 US RMBS Transactions
* S&P Lowers Ratings on 514 Classes From 99 US RMBS Transactions
* S&P Lowers Ratings on 19 Classes From 2 Canadian CMBS Deals
* S&P Withdraws Ratings on 61 Classes From 30 CMBS, CDO Deals

* S&P Withdraws Ratings on 13 Classes From 2 CMBS Transactions
* S&P Withdraws Ratings on 13 Classes From 4 CDOs, 3 CBO Deals
* S&P Raises Ratings on 10 Classes From 3 CMBS Transactions


                            *********


ALM VII: S&P Gives 'B' Rating on Class E Deferrable Notes
---------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to ALM VII Ltd./ALM VII LLC's $669.4 million floating-rate
notes.

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

The preliminary ratings are based on information as of Oct. 8,
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 asset manager's experienced management team.

    "The timely interest and ultimate principal payments on the
    preliminary rated notes, which we assessed using our cash-flow
    analysis and assumptions commensurate with the assigned
    preliminary ratings under various interest-rate scenarios,
    including LIBOR ranging from 0.34% to 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 uncapped
    administrative expenses and fees, subordinated hedge and
    synthetic security termination payments, portfolio manager
    subordinated and incentive fees, and subordinated note
    payments to principal proceeds for the purchase of additional
    collateral assets during the reinvestment period.

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

     http://standardandpoorsdisclosure-17g7.com/1026.pdf

PRELIMINARY RATINGS ASSIGNED

ALM VII Ltd./ALM VII LLC

Class          Rating         Interest                   Amount
                              rate                     (Mil. $)

X              AAA (sf)       Three-month LIBOR           2.625
                              plus 1.00%
A-1            AAA (sf)       Three-month LIBOR          446.25
                              plus 1.42%
A-2            AA (sf)        Three-month LIBOR           78.75
                              plus 2.30%
B (deferrable) A (sf)         Three-month LIBOR          58.625
                              plus 3.15%
C (deferrable) BBB (sf)       Three-month LIBOR          34.125
                              plus 4.50%
D (deferrable) BB (sf)        Three-month LIBOR           29.75
                              plus 5.00%
E (deferrable) B (sf)         Three-month LIBOR           19.25
                              plus 6.50%
Subordinated
notes         NR             N/A                         52.50


AMAC CDO: Moody's Affirms 'C' Rating on Class F Notes
-----------------------------------------------------
Moody's Investors Service has affirmed the ratings of all classes
of Notes issued by AMAC CDO Funding I due to key transaction
parameters performing within levels commensurate with the existing
ratings levels. The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation and collateralized loan obligation (CRE CDO CLO)
transactions.

Moody's rating action is as follows:

Cl. A-1, Affirmed at A2 (sf); previously on Nov 17, 2010
Downgraded to A2 (sf)

Cl. A-2, Affirmed at Ba3 (sf); previously on Nov 17, 2010
Downgraded to Ba3 (sf)

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

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

Cl. D-1, Affirmed at Ca (sf); previously on Nov 17, 2010
Downgraded to Ca (sf)

Cl. D-2, Affirmed at Ca (sf); previously on Nov 17, 2010
Downgraded to Ca (sf)

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

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

Ratings Rationale

AMAC CDO Funding I is a static (the reinvestment period ended in
November 2011) cash CRE CDO transaction backed by a portfolio of
whole loans or senior participations in whole loans (95.2% of the
pool balance), B-Notes (3.2%), and mezzanine loans (1.6%). As of
the September 19, 2012 Trustee report, the aggregate Note balance
of the transaction, including preferred shares, has decreased to
$353.0 million from $400 million at issuance, with the principal
paydown directed to the Class A-1 Notes. The paydowns are a result
of principal repayment of collateral and the failure of the par
value tests.

There are no assets that are considered impaired interests as of
the September 19, 2012 Trustee report, compared to one asset with
a par balance of $4.7 million (1.5% of the pool balance) at last
review.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments 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 8,151, compared to 7,130 at last review. The
current distribution of Moody's rated collateral and assessments
for non-Moody's rated collateral is as follows: Aaa- Aa3 (0.9%
compared to 0.9% at last review), Baa1-Baa3 (0.0% compared to 0.7%
at last review), Ba1-Ba3 (0.7% compared to 6.0% at last review),
B1-B3 (15.2% compared to 14.6% at last review), and Caa1-C (83.2%
compared to 77.8% at last review).

WAL acts to adjust the probability of default of the reference
obligations in the pool for time. Moody's modeled to a WAL of 3.4
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
54.4% compared to 54.3% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 29.1% compared to 25.1% at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on March 22, 2012.

The cash flow model, CDOEdge(R) v3.2.1.2, 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
54.4% to 44.4% or up to 64.4% would result in modeled rating
movements on the rated Notes of 0 to 3 notches downward and 0 to 5
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 growth
in the current macroeconomic environment and commercial real
estate property markets. Commercial real estate property values
are continuing to move in a positive direction along with a rise
in investment activity and stabilization in core property type
performance. Limited new construction and moderate job growth have
aided this improvement. However, a consistent upward trend will
not be evident until the volume of investment activity steadily
increases for a significant period, non-performing properties are
cleared from the pipeline, and fears of a Euro area recession are
abated.

The hotel sector is performing strongly with eight straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Slow recovery in the office sector continues with
minimal additions to supply. However, office demand is closely
tied to employment, where growth remains slow and employers are
considering decreases in the leased space per employee. Also,
primary urban markets are outperforming secondary suburban
markets. Performance in the retail sector continues to be mixed
with retail rents declining for the past four years, weak demand
for new space and lackluster sales driven by discounting and
promotions. However, rising wages and reduced unemployment, along
with increased consumer confidence, is helping to spur consumer
spending resulting in increased sales. Across all property
sectors, the availability of debt capital continues to improve
with robust securitization activity of commercial real estate
loans supported by a monetary policy of low interest rates.

Moody's central global macroeconomic scenario maintains its
forecast of relatively robust growth in the US and an expectation
of a mild recession in the euro area for 2012. Downside risks
remain significant, and elevated downside risks and their
materialization could pose a serious threat to the outlook. Major
downside risks include: a deeper than expected recession in the
euro area; the potential for a hard landing in major emerging
markets; an oil supply shock; and material fiscal tightening in
the US given recent political gridlock. Healthy but below-trend
growth in GDP is expected through the rest of this year and next
with risks trending to the downside.

The methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in May 2012, and "Moody's Approach to
Rating Commercial Real Estate CDOs" published in July 2011.


AMRESCO COMMERCIAL: Moody's Cuts Rating on Class B Notes to 'B3'
----------------------------------------------------------------
Moody's Investors Service has downgraded the Class B notes from
AMRESCO Commercial Finance Inc.'s 1998-2 franchise loan
securitization from B2 (sf) to B3 (sf). The notes are backed by
franchise loans made to fast-food restaurants, casual dining
restaurants, and quick service convenience stores.

The complete rating action is as follows:

Issuer: ACLC Business Loan Receivables Trust 1998-2

Class B, Downgraded to B3 (sf); previously on Jul 18, 2006
Confirmed at B2 (sf)

Ratings Rationale

ACLC 1998-2 has a high percentage of defaulted loans and
significant obligor concentrations risks having only 17 loans in
the current pool. The largest obligor in ACLC 1998-2 comprises 46%
of the current pool balance, and the top 3 obligors comprise 81%
of the current pool balance. As of the September 17th payment
date, 88% of the current pool balance is defaulted and has been
accelerated. Two of the loans in default status, which were cash-
flowing earlier in the year, have experienced deteriorating to no
payments in recent months.

The Class B notes do not benefit from any credit enhancement
excluding all defaulted loans. The junior subordinate notes have
been completely written down from pool losses, leaving the Class B
exposed to any future writedowns on the defaulted loans. Moody's
has assumed that all the currently defaulted loans will not be
cured and that future cash flows from the underlying pool will
remain weak as the defaulted borrowers continue to face suppressed
revenues. The new rating reflects the underlying risks in the
transaction as well as Moody's view on future performance of the
collateral properties.

The primary source of uncertainty in the performance of this
transaction is the outcome of workout strategies for loans
requiring special servicing, as well as the current macroeconomic
environment and its impact on fast food restaurants and
convenience stores.

Parameter Sensivitivies:

If Moody's kept default assumptions constant and assumed recovery
rates ranged from 10% to 50%, versus Moody's actual assumption
range of 10% to 75%, resulting projected losses on the Class B
notes would increase and may result in a further downgrade.

Methodology:

The Methodology is as follows: In order to estimate losses on the
collateral pool, Moody's calculates the expected loss given
default of the obligors that have become nonperforming, and also
estimates future losses on the performing portion of the pool, all
as a percentage of the outstanding pool. In evaluating the
nonperforming loans, key factors include collateral valuations and
expected recovery rates, volatility around those recovery rates,
historical obligor performance, time until recovery or liquidation
on defaulted obligors, concessions due to restructuring which may
negatively impact the overall cash flow of the trust and/or the
collateral, and future industry expectations. Net losses are then
evaluated against the available credit enhancement provided by any
available overcollateralization, subordination, and excess spread.
Sufficiency of coverage is considered in light of remaining
borrower concentrations and concepts, remaining bond maturities,
and economic outlook.


ANTHRACITE CDO: Fitch Affirms Junk Rating on Nine Note Classes
--------------------------------------------------------------
Fitch Ratings has downgraded two and affirmed 10 classes of
Anthracite CDO III Ltd./Corp. (Anthracite CDO III).

Since the last rating action in November 2011, approximately 14.5%
of the collateral has been downgraded while 2.6% has been
upgraded. Currently, 61% of the portfolio has a Fitch derived
rating below investment grade and 36.2% has a rating in the 'CCC'
category and below, compared to 58.1% and 32.6%, respectively, at
the last rating action.  Over this period, the class A notes have
received $13.2 million principal paydowns.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model (PCM) for projecting future default
levels for the underlying portfolio.  The default levels were then
compared to the breakeven levels generated by Fitch's cash flow
model of the CDO under the various default timing and interest
rate stress scenarios, as described in the report 'Global Criteria
for Cash Flow Analysis in CDOs'.  Fitch also analyzed the
structure's sensitivity to the assets that are distressed,
experiencing interest shortfalls, and those with near-term
maturities.  Based on this analysis, the class A through C notes'
breakeven rates are generally consistent with the ratings assigned
below.

For the class D through H notes, Fitch analyzed the class'
sensitivity to the default of the distressed assets ('CCC' and
below).  Given the high probability of default of these assets and
expected limited recovery prospects upon default, the class D
notes have been affirmed at 'CCsf', indicating that default is
probable.  Similarly, the class E notes have been downgraded and
the class F through H notes affirmed at 'Csf', indicating that
default is inevitable.

The Evolving Outlook on the class A notes is driven by the near
term risk of interest shortfalls due to the significant hedge
payment which is senior to the interest on the notes; should the
interest continue to pay timely the class may be upgraded in the
future as it further delevers.  The risk of interest shortfalls is
mitigated by the expectation that the hedge payment will likely
decrease as the hedge notional is scheduled to step down over the
next few payment dates.  The Stable Outlook on the class B notes
reflects the cushion in the passing ratings and the expectation
that the transaction will continue to delever.

Anthracite CDO III is a collateralized debt obligation (CDO) that
closed on March 30, 2004.  Currently, the portfolio is composed of
62 securities from 34 issuers of which 73.9% are commercial
mortgage backed securities (CMBS), 18% CMBS rake bonds or credit
tenant leases (CTL) classified as commercial real estate loans
(CREL), and 8.1% real estate investment trusts (REITs).

Fitch has taken the following actions as indicated below:

  -- $109,727,717 class A notes affirmed at 'BBsf'; Outlook to
     Evolving from Positive;
  -- $27,000,000 class B-FL notes affirmed at 'Bsf'; Outlook
     Stable;
  -- $14,384,000 class B-FX notes affirmed at 'Bsf'; Outlook
     Stable;
  -- $24,727,000 class C-FL notes affirmed at 'CCCsf';
  -- $2,500,000 class C-FX notes affirmed at 'CCCsf';
  -- $14,222,649 class D-FL notes affirmed at 'CCsf';
  -- $10,786,825 class D-FX notes affirmed at 'CCsf';
  -- $10,988,037 class E-FL notes downgraded to 'Csf' from 'CCsf';
  -- $29,089,072 class E-FX notes downgraded to 'Csf' from 'CCsf';
  -- $25,378,299 class F notes affirmed at 'Csf';
  -- $8,067,861 class G notes affirmed at 'Csf';
  -- $14,753,960 class H notes affirmed at 'Csf'.


BANC OF AMERICA 2003-3: Moody's Cuts Rating on A-4 Tranche to Ba1
-----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of six
tranches from Banc of America Alternation Loan Trust 2003-3,
backed by Alt-A loans, issued by Banc of America.

Ratings Rationale

The actions are a result of the recent performance of the
underlying pool and reflect Moody's updated loss expectations on
the pool. The performance of the underlying pool has deteriorated
steadily over the past two years with serious delinquencies
currently at 6.2% as a percentage of current balanceand loss
severities averaging over 50%. The downgrades are further driven
by structural features resulting in higher expected losses for the
bonds than previously anticipated. For shifting interest
structures, back-ended liquidations could expose the seniors to
tail-end losses. In its current approach, Moody's captures this
risk by running each individual pool through a variety of loss and
prepayment scenarios in the Structured Finance
Workstation(R)(SFW), the cash flow model developed by Moody's Wall
Street Analytics. This individual pool level analysis incorporates
performance variances across the different pools and the
structural nuances of the transaction

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

Moody's adjusts the methodologies noted above for 1) Moody's
current view on loan modifications 2) small pool volatility.

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

For pools with loans less than 100, Moody's adjusts its
projections of loss to account for the higher loss volatility of
such pools. For small pools, a few loans becoming delinquent would
greatly increase the pools' delinquency rate.

To project losses on Alt-A pools with fewer than 100 loans,
Moody's first calculates an annualized delinquency rate based on
vintage, number of loans remaining in the pool and the level of
current delinquencies in the pool. For Alt-A and Option Arm pools,
Moody's first applies a baseline delinquency rate of 10% for 2004,
5% for 2003 and 3% for 2002 and prior. Once the loan count in a
pool falls below 76, this rate of delinquency is increased by 1%
for every loan fewer than 76. For example, for a 2004 pool with 75
loans, the adjusted rate of new delinquency is 10.1%. Further, to
account for the actual rate of delinquencies in a small pool,
Moody's multiplies the rate calculated above by a factor ranging
from 0.50 to 2.0 for current delinquencies that range from less
than 2.5% to greater than 30% respectively. Moody's then uses this
final adjusted rate of new delinquency to project delinquencies
and losses for the remaining life of the pool under the approach
described in the methodology publication.

When assigning the final ratings to senior bonds, in addition to
the methodologies described above, Moody's considered the
volatility of the projected losses and timeline of the expected
defaults. For bonds backed by small pools, Moody's also considered
the current pipeline composition as well as any specific loss
allocation rules that could preserve or deplete the
overcollateralization available for the senior bonds at different
pace.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in April 2011 to 8.1% in August 2012. Moody's forecasts a
further drop to 7.8% for 2013. Moody's expects house prices to
drop another 1% from their 4Q2011 levels before gradually rising
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can
impact the performance of these transactions.

Complete rating actions are as follows:

Issuer: Banc of America Alternative Loan Trust 2003-3

Cl. A-1, Downgraded to Baa3 (sf); previously on Mar 15, 2011
Downgraded to A2 (sf)

Cl. A-2, Downgraded to Baa3 (sf); previously on Mar 15, 2011
Downgraded to A2 (sf)

Cl. A-3, Downgraded to Baa3 (sf); previously on Mar 15, 2011
Downgraded to A2 (sf)

Cl. A-4, Downgraded to Ba1 (sf); previously on Mar 15, 2011
Downgraded to A3 (sf)

Cl. A-5, Downgraded to Baa3 (sf); previously on Mar 15, 2011
Downgraded to A2 (sf)

Cl. A-PO, Downgraded to Baa3 (sf); previously on Mar 15, 2011
Downgraded to A2 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF299714

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

http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237256


BANC OF AMERICA 2006-BIXI: S&P Cuts Rating on Cl. K Certs to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
from 'CCC- (sf)' on the class K commercial mortgage pass-through
certificates from Banc of America Large Loan Inc.'s series 2006-
BIX1, a U.S. commercial mortgage-backed securities (CMBS)
transaction.

"As of the Sept. 17, 2012, trustee remittance report, the pooled
trust has three loans remaining totaling $172.3 million. The
pooled trust had experienced monthly interest shortfalls totaling
$80,780 due primarily to an interest rate modification for the
Ballantyne Village loan. The interest shortfalls have affected all
of classes subordinate to and including class K. Class K has
experienced interest shortfalls for 10 consecutive months," S&P
said.

"The Ballantyne Village loan, the smallest loan in the pool, has a
trust balance of $31.5 million (18.3%) and a whole-loan balance of
$50.0 million. The loan is secured by a 166,041-sq.-ft. class A
lifestyle center in Charlotte, N.C. The loan was transferred to
the special servicer, Bank of America N.A. (BofA), on July 9,
2009, after the borrower submitted a request to restructure the
loan due to a decline in cash flow at the property because two of
the largest tenants stopped paying rent. According to BofA, the
loan was performing under a forbearance agreement effective March
15, 2011. Among other things, the forbearance agreement stipulates
that the borrower will contribute cash under certain conditions
and pay interest on $14.0 million of the $31.5 million trust
balance. In addition, the agreement allowed interest on the
remaining $17.5 million trust balance to be deferred, and the
borrower had until Oct. 1, 2012 (end of forbearance period) to
make the release payment as defined in the forbearance agreement
or turn over title of the property to the trust. The borrower has
agreed to release the title via a deed in lieu. The trust is
scheduled to take title on Nov. 1, 2012. As a result, we expect
the accumulated interest shortfalls to remain outstanding for the
foreseeable future," 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


BEAR STEARNS: Moody's Lowers Ratings on Three Tranches to 'Ca'
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 23
tranches from four RMBS transactions, backed by Alt-A loans,
issued by Bear Stearns.

Rating Rationale

The actions are a result of the recent performance of Alt-A pools
originated before 2005 and reflect Moody's updated loss
expectations on these pools.

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

The rating action constitutes of a number of downgrades. The
downgrades are a result of deteriorating performance and/or
structural features resulting in higher expected losses for
certain bonds than previously anticipated. For e.g., for shifting
interest structures, back-ended liquidations could expose the
seniors to tail-end losses. The subordinate bonds in the majority
of these deals are currently receiving 100% of their principal
payments, and thereby depleting the dollar enhancement available
to the senior bonds. In its current approach, Moody's captures
this risk by running each individual pool through a variety of
loss and prepayment scenarios in the Structured Finance
Workstation(R)(SFW), the cash flow model developed by Moody's Wall
Street Analytics. This individual pool level analysis incorporates
performance variances across the different pools and the
structural nuances of the transaction

Moody's adjusts the methodologies noted above for 1) Moody's
current view on loan modifications 2) small pool volatility.

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

For pools with loans less than 100, Moody's adjusts its
projections of loss to account for the higher loss volatility of
such pools. For small pools, a few loans becoming delinquent would
greatly increase the pools' delinquency rate.

To project losses on Alt-A pools with fewer than 100 loans,
Moody's first calculates an annualized delinquency rate based on
vintage, number of loans remaining in the pool and the level of
current delinquencies in the pool. For Alt-A and Option Arm pools,
Moody's first applies a baseline delinquency rate of 10% for 2004,
5% for 2003 and 3% for 2002 and prior. Once the loan count in a
pool falls below 76, this rate of delinquency is increased by 1%
for every loan fewer than 76. For example, for a 2004 pool with 75
loans, the adjusted rate of new delinquency is 10.1%. Further, to
account for the actual rate of delinquencies in a small pool,
Moody's multiplies the rate calculated above by a factor ranging
from 0.50 to 2.0 for current delinquencies that range from less
than 2.5% to greater than 30% respectively. Moody's then uses this
final adjusted rate of new delinquency to project delinquencies
and losses for the remaining life of the pool under the approach
described in the methodology publication.

When assigning the final ratings to senior bonds, in addition to
the methodologies described above, Moody's considered the
volatility of the projected losses and timeline of the expected
defaults. For bonds backed by small pools, Moody's also considered
the current pipeline composition as well as any specific loss
allocation rules that could preserve or deplete the
overcollateralization available for the senior bonds at different
pace.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in April 2011 to 8.1% in August 2012. Moody's forecasts a
further drop to 7.8% for 2013. Moody's expects house prices to
drop another 1% from their 4Q2011 levels before gradually rising
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can
impact the performance of these transactions.

Complete rating actions are as follows:

Issuer: Bear Stearns ARM Trust 2004-3

Cl. I-A-1, Downgraded to Caa1 (sf); previously on May 13, 2011
Downgraded to B2 (sf)

Cl. I-A-2, Downgraded to B3 (sf); previously on May 13, 2011
Downgraded to B1 (sf)

Cl. I-A-3, Downgraded to Caa3 (sf); previously on May 13, 2011
Downgraded to Caa2 (sf)

Cl. II-A, Downgraded to B3 (sf); previously on May 13, 2011
Downgraded to B2 (sf)

Issuer: Bear Stearns Asset-Backed Securities Trust 2003-AC5

Cl. A-1, Downgraded to Ba1 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. A-2, Downgraded to Ba1 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. A-3, Downgraded to Ba1 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. A-4, Downgraded to Ba1 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. A-5, Downgraded to Ba1 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. M-1, Downgraded to B3 (sf); previously on Mar 24, 2011
Downgraded to Ba3 (sf)

Cl. M-2, Downgraded to Ca (sf); previously on Mar 24, 2011
Downgraded to Caa3 (sf)

Issuer: Bear Stearns ARM Trust 2004-11

Cl. I-A-1, Downgraded to Baa3 (sf); previously on May 13, 2011
Downgraded to Baa1 (sf)

Cl. II-A-1, Downgraded to Baa3 (sf); previously on May 13, 2011
Downgraded to Baa1 (sf)

Cl. III-A-1, Downgraded to Baa3 (sf); previously on May 13, 2011
Downgraded to Baa1 (sf)

Cl. IV-A-1, Downgraded to Baa3 (sf); previously on May 13, 2011
Downgraded to Baa1 (sf)

Cl. M-1, Downgraded to B3 (sf); previously on May 13, 2011
Downgraded to Ba2 (sf)

Cl. B-1, Downgraded to Ca (sf); previously on May 13, 2011
Downgraded to Caa3 (sf)

Issuer: Bear Stearns Asset-Backed Securities Trust 2003-AC7

Cl. A-1, Downgraded to Ba2 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. A-2, Downgraded to Ba2 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. A-3, Downgraded to Ba2 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. A-4, Downgraded to Ba2 (sf); previously on Mar 24, 2011
Downgraded to Baa2 (sf)

Cl. M-1, Downgraded to Caa2 (sf); previously on Mar 24, 2011
Downgraded to Ba3 (sf)

Cl. M-2, Downgraded to Ca (sf); previously on Mar 24, 2011
Downgraded to Caa3 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF299722

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

http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237256


BEAR STEARNS 2007-PWR18: S&P Lowers Ratings on 11 Classes
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 11
classes from Bear Sterns Commercial Mortgage Securities Trust
2007-PWR18 and 13 classes from CD 2007-CD5 Mortgage Trust, two
commercial mortgage-backed securities (CMBS) transactions and
removed 10 of the ratings from CreditWatch with negative
implications. "Concurrently, we raised our ratings on two classes
from the Bear Sterns Commercial Mortgage Securities Trust 2007-
PWR18 transaction. We also affirmed our ratings on 10 classes from
the two CMBS transactions. The CreditWatch resolutions are related
to CreditWatch placements that occurred on Sept. 5, 2012," S&P
said.

"Our rating actions on the interest-only (IO) certificates reflect
our current criteria for rating IO securities," S&P said.

"The downgrades reflect our expected available credit enhancement
for the affected tranches, which we believe is less than our most
recent estimate of necessary credit enhancement for the most
recent rating levels. The downgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions, which include the current
and potential interest shortfalls both transactions are
experiencing resulting in reduced liquidity support available to
the lowered classes," S&P said.

"According to the Sept. 13, 2012, trustee report, the Bear Stearns
Commercial Mortgage Securities Trust 2007-PWR18 transaction
experienced $155,995 in interest shortfalls affecting the classes
subordinate to and including class H. According to the Sept. 17,
2012, trustee report, the CD 2007-CD5 Mortgage Trust transaction
experienced $346,380 in interest shortfalls affecting the classes
subordinate to and including class H," S&P said.

"The upgrades reflect Standard & Poor's expected available credit
enhancement for the affected tranches, which we believe is greater
than our most recent estimate of necessary credit enhancement for
the most recent rating levels. The upgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions," S&P said.

"The rating actions follow a detailed review of the performance of
the collateral supporting the relevant securities and transaction
structures. This review was similar to the review we conducted
before placing 744 U.S. and Canadian CMBS ratings on CreditWatch
following the release of our updated ratings criteria for U.S. and
Canadian CMBS transactions, but was more detailed with respect to
collateral and transaction performance. For more information on
the analytic process we used for those CreditWatch placements,
refer to 'The Application Of Standard & Poor's Revised U.S. And
Canadian CMBS Criteria For The Sept. 5, 2012, CreditWatch
Actions,' published Sept. 5, 2012," 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 AND CREDITWATCH ACTIONS

Bear Sterns Commercial Mortgage Securities Trust 2007-PWR18
Commercial mortgage pass-through certificates
           Rating
Class  To         From          Credit enhancement (%)
A-2    AAA (sf)   AAA (sf)                 29.51
A-3    AAA (sf)   AAA (sf)                 29.51
A-AB   AAA (sf)   AAA (sf)                 29.51
A-4    AA (sf)    AA- (sf)                 29.51
A-1A   AA (sf)    AA- (sf)                 29.51
A-M    BBB (sf)   BBB+ (sf)                18.13
AM-A   BBB (sf)   BBB+ (sf)                18.13
AJ     B- (sf)    BB- (sf)/Watch Neg        8.32
AJ-A   B- (sf)    BB- (sf)/Watch Neg        8.32
B      CCC(sf)    B+(sf)/Watch Neg          7.18
C      CCC (sf)   B (sf)/Watch Neg          6.04
D      CCC(sf)    B (sf)/Watch Neg          5.19
E      CCC-(sf)   B- (sf)                   4.05
F      CCC- (sf)  CCC+ (sf)                 3.20
G      CCC-(sf)   CCC (sf)                  2.06
H      D (sf)     CCC- (sf)                 1.06
X-1    AAA (sf)   AAA (sf)                   N/A
X-2    AAA (sf)   AAA (sf)                   N/A

CD 2007-CD5 Mortgage Trust
Commercial mortgage pass-through certificates
           Rating
Class  To         From        Credit enhancement (%)
A-AB   AAA (sf)   AAA (sf)                 30.51
A-4    AAA (sf)   AAA (sf)                 30.51
A-1A   AAA (sf)   AAA (sf)                 30.51
A-M    BBB (sf)   BBB+ (sf)                18.80
A-MA   BBB (sf)   BBB+ (sf)                18.80
AJ     B+ (sf)    BB (sf)/Watch Neg        11.04
AJA    B+ (sf)    BB (sf)/Watch Neg        11.04
B      B (sf)     BB- (sf)/Watch Neg        9.87
C      B- (sf)    B+ (sf)/Watch Neg         8.70
D      B- (sf)    B+ (sf)/Watch Neg         7.53
E      CCC (sf)   B+ (sf)/Watch Neg         6.50
F      CCC (sf)   B (sf)/Watch Neg          5.48
G      CCC- (sf)  B- (sf)                   4.31
H      CCC- (sf)  CCC+ (sf)                 2.99
J      CCC- (sf)  CCC  (sf)                 1.67
K      D (sf)     CCC- (sf)                 0.50
XP     AAA (sf)   AAA (sf)                   N/A
XS     AAA (sf)   AAA (sf)                   N/A


CITICORP MORTGAGE 2007-1: Moody's Cuts IIA-IO Sec. Rating to Caa3
-----------------------------------------------------------------
Moody's Investors Service has downgraded eight tranches, upgraded
four tranches and confirmed the rating on one tranche from two
RMBS transactions issued by Citicorp Mortgage Securities. The
collateral backing these deals primarily consists of first-lien,
fixed-rate prime Jumbo residential mortgages. The actions impact
approximately $85.3 million of RMBS issued from 2005 and 2007.

Complete rating actions are as follows:

Issuer: Citicorp Mortgage Securities Trust, Series 2007-1

Cl. IIA-1, Downgraded to Ba3 (sf); previously on May 30, 2012 Ba1
(sf) Placed Under Review for Possible Downgrade

Cl. IIA-PO, Downgraded to Caa1 (sf); previously on Jun 4, 2010
Downgraded to B3 (sf)

Cl. IIA-IO, Downgraded to B3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

Issuer: Citicorp Mortgage Securities, Inc. 2005-4

Cl. IA-1, Upgraded to Baa2 (sf); previously on May 30, 2012 Ba3
(sf) Placed Under Review for Possible Upgrade

Cl. IA-2, Upgraded to Baa2 (sf); previously on May 30, 2012 Ba3
(sf) Placed Under Review for Possible Upgrade

Cl. IA-3, Upgraded to Ba2 (sf); previously on May 30, 2012 B1 (sf)
Placed Under Review for Possible Upgrade

Cl. IA-6, Confirmed at Ba3 (sf); previously on May 30, 2012 Ba3
(sf) Placed Under Review for Possible Upgrade

Cl. IA-8, Upgraded to Ba3 (sf); previously on May 30, 2012 B2 (sf)
Placed Under Review for Possible Upgrade

Cl. IIA-1, Downgraded to Ba2 (sf); previously on Jul 15, 2011
Downgraded to Baa3 (sf)

Cl. IIIA-1, Downgraded to Ba3 (sf); previously on Jul 15, 2011
Downgraded to Baa3 (sf)

Cl. IIIA-2, Downgraded to Ba3 (sf); previously on Jul 15, 2011
Downgraded to Baa3 (sf)

Cl. IIIA-3, Downgraded to B1 (sf); previously on May 30, 2012 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. IIIA-4, Downgraded to Caa3 (sf); previously on Jul 15, 2011
Downgraded to Ba3 (sf)

Rating Rationale

The actions are a result of the recent performance of Prime jumbo
pools originated on or after 2005 and reflect Moody's updated loss
expectations on these pools.

The rating action consists of a number of upgrades, downgrades,
and confirmations. The upgrades are due to significant improvement
in collateral performance, and rapid build-up in credit
enhancement due to high prepayments.

The downgrades are a result of deteriorating performance and
structural features resulting in higher expected losses for
certain bonds than previously anticipated.

The methodologies used in these ratings were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, and "2005 -- 2008 US RMBS Surveillance Methodology"
published in July 2011. The methodology used in rating Interest-
Only Securities was "Moody's Approach to Rating Structured Finance
Interest-Only Securities" published in February 2012.

Moody's adjusts the methodologies noted above for 1) Moody's
current view on loan modifications 2) small pool volatility and 3)
bonds that financial guarantors insure.

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

The above RMBS approach only applies to structures with at least
40 loans and pool factor of greater than 5%. Moody's can withdraw
its rating when the pool factor drops below 5% and the number of
loans in the deal declines to 40 loans or lower. If, however, a
transaction has a specific structural feature, such as a credit
enhancement floor, that mitigates the risks of small pool size,
Moody's can choose to continue to rate the transaction.

For pools with loans less than 100, Moody's adjusts its
projections of loss to account for the higher loss volatility of
such pools. For small pools, a few loans becoming delinquent would
greatly increase the pools' delinquency rate.

To project losses on prime jumbo pools with fewer than 100 loans,
Moody's first calculates an annualized delinquency rate based on
vintage, number of loans remaining in the pool and the level of
current delinquencies in the pool. For prime jumbo pools, Moody's
first applies a baseline delinquency rate of 3.5% for 2005, 6.5%
for 2006 and 7.5% for 2007. Once the loan count in a pool falls
below 76, this rate of delinquency is increased by 1% for every
loan fewer than 76. For example, for a 2005 pool with 75 loans,
the adjusted rate of new delinquency is 3.54%. Further, to account
for the actual rate of delinquencies in a small pool, Moody's
multiplies the rate calculated above by a factor ranging from 0.20
to 2.0 for current delinquencies that range from less than 2.5% to
greater than 50% respectively. Moody's then uses this final
adjusted rate of new delinquency to project delinquencies and
losses for the remaining life of the pool under the approach
described in the methodology publication.

When assigning the final ratings to bonds, in addition to the
approach described above, Moody's considered the volatility of the
projected losses and timeline of the expected defaults.

Bonds Insured by Financial Guarantors

The credit quality of RMBS that a financial guarantor insures
reflect the higher of the credit quality of the guarantor or the
RMBS without the benefit of the guarantee. As a result, the rating
on the security is the higher of 1) the guarantor's financial
strength rating and 2) the current underlying rating, which is
what the rating of the security would be absent consideration of
the guaranty. The principal methodology Moody's uses in
determining the underlying rating is the same methodology for
rating securities that do not have financial guaranty, described
earlier.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in April 2011 to 8.1% in August 2012. Moody's forecasts a
further drop to 7.8% for 2013. Moody's expects house prices to
drop another 1% from their 4Q2011 levels before gradually rising
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can
impact the performance of these transactions.

A list of these actions including CUSIP identifiers may be found
at http://moodys.com/viewresearchdoc.aspx?docid=PBS_SF299885

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

http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF196023


COUNTRYWIDE: Moody's Junks Ratings on Two RMBS Transactions
-----------------------------------------------------------
Rating Action: Moody's downgrades $73.9 Million of US Alt-A RMBS
issued by Countrywide from 2003 and 2004

Moody's Investors Service has downgraded the ratings of two
tranches from two RMBS transactions, backed by Alt-A loans, issued
by Countrywide.

Ratings Rationale

The actions are a result of the recent performance of the
underlying pools and reflects Moody's updated loss expectations on
the pools. The performance of the pools has deteriorated over the
past year, resulting in higher expected losses for the bonds than
previously anticipated.

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

Moody's adjusts the methodologies noted above for 1) Moody's
current view on loan modifications 2) Small pool volatility.

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

For pools with loans less than 100, Moody's adjusts its
projections of loss to account for the higher loss volatility of
such pools. For small pools, a few loans becoming delinquent would
greatly increase the pools' delinquency rate.

To project losses on Alt-A pools with fewer than 100 loans,
Moody's first calculates an annualized delinquency rate based on
vintage, number of loans remaining in the pool and the level of
current delinquencies in the pool. For Alt-A and Option Arm pools,
Moody's first applies a baseline delinquency rate of 10% for 2004,
5% for 2003 and 3% for 2002 and prior. Once the loan count in a
pool falls below 76, this rate of delinquency is increased by 1%
for every loan fewer than 76. For example, for a 2004 pool with 75
loans, the adjusted rate of new delinquency is 10.1%. Further, to
account for the actual rate of delinquencies in a small pool,
Moody's multiplies the rate calculated above by a factor ranging
from 0.50 to 2.0 for current delinquencies that range from less
than 2.5% to greater than 30% respectively. Moody's then uses this
final adjusted rate of new delinquency to project delinquencies
and losses for the remaining life of the pool under the approach
described in the methodology publication.

When assigning the final ratings to senior bonds, in addition to
the methodologies described above, Moody's considered the
volatility of the projected losses and timeline of the expected
defaults. For bonds backed by small pools, Moody's also considered
the current pipeline composition as well as any specific loss
allocation rules that could preserve or deplete the
overcollateralization available for the senior bonds at different
pace.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in April 2011 to 8.1% in August 2012. Moody's forecasts a
further drop to 7.8% for 2013. Moody's expects house prices to
drop another 1% from their 4Q2011 levels before gradually rising
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can
impact the performance of these transactions.

Complete rating actions are as follows:

Issuer: CHL Mortgage Pass-Through Trust 2003-53

Cl. A-1, Downgraded to Caa1 (sf); previously on Mar 3, 2011
Downgraded to B3 (sf)

Issuer: CWALT, Inc. Mortgage Pass-Through Certificates, Series
2004-17CB

Cl. 1-A-1, Downgraded to Caa2 (sf); previously on Mar 28, 2011
Downgraded to Caa1 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF299673

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

  http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237256


CROWN POINT: S&P Gives 'BB-' Rating on Class B-2L Deferrable Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Crown
Point CLO Ltd./Crown Point CLO LLC's $344.929 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 (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.

    S&P's projections regarding the timely interest and ultimate
    principal payments on the rated notes, which S&P assessed
    using its cash flow analysis and assumptions commensurate with
    the assigned ratings under various interest rate scenarios,
    including LIBOR ranging from 0.30% to 11.19%.

    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 management fees, collateral
    manager incentive fees, and subordinated note payments to
    principal proceeds for the purchase of additional collateral
    assets during the reinvestment period.

    The transaction's principal proceeds recapture feature, which
    requires reclassifying excess interest proceeds as principal
    proceeds in an amount equal to the principal proceeds used to
    make interest payments on the deferrable 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 Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at:

    http://standardandpoorsdisclosure-17g7.com/1028.pdf.

RATINGS ASSIGNED
Crown Point CLO Ltd./Crown Point CLO LLC

Class                Rating       Interest             Amount
                                  rate               (mil. $)

A-1La                AAA (sf)     Three-month LIBOR     93.00
                                  plus 0.75%
A-1Lb                AAA (sf)     Three-month LIBOR     73.00
                                  plus 1.50%
A-2L (deferrable)    AA (sf)      Three-month LIBOR     21.25
                                  plus 2.71%
A-3L (deferrable)    A (sf)       Three-month LIBOR     17.00
                                  plus 3.96%
B-1L (deferrable)    BBB (sf)     Three-month LIBOR     15.00
                                  plus 5.00%
B-2L (deferrable)    BB- (sf)     Three-month LIBOR     11.25
                                  plus 6.50%
Combination notes    A (sf)       Three-month LIBOR   114.429
(deferrable)                     plus 1.22%


CSFB MORTGAGE 2001-26: Moody's Cuts Rating on D-B-2 Notes to 'Ca'
-----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of Class D-B-
2, and upgraded the ratings of Class V-A-1 and Class V-A-2 from
CSFB Mortgage-Backed Pass-Through Certificates, Series 2001-26,
backed by Alt-A loans, issued by Credit Suisse.

Ratings Rationale

The actions are a result of the recent performance of the
underlying pool and reflect Moody's updated loss expectations on
the pool. The upgrade on the Class V-A-1 is a result of
reestablishment of principal and interest payments on the on the
tranche post a litigation settlement by the trustee and the high
credit enhancement available to the bond. The downgrade on Class
D-B-2 is a result of deteriorating performance of the pool
resulting in higher expected losses for Class D-B-2 than
previously anticipated.

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

Moody's adjusts the methodologies noted above for 1) Moody's
current view on loan modifications 2) small pool volatility.

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

For pools with loans less than 100, Moody's adjusts its
projections of loss to account for the higher loss volatility of
such pools. For small pools, a few loans becoming delinquent would
greatly increase the pools' delinquency rate.

To project losses on Alt-A pools with fewer than 100 loans,
Moody's first calculates an annualized delinquency rate based on
vintage, number of loans remaining in the pool and the level of
current delinquencies in the pool. For Alt-A and Option Arm pools,
Moody's first applies a baseline delinquency rate of 10% for 2004,
5% for 2003 and 3% for 2002 and prior. Once the loan count in a
pool falls below 76, this rate of delinquency is increased by 1%
for every loan fewer than 76. For example, for a 2004 pool with 75
loans, the adjusted rate of new delinquency is 10.1%. Further, to
account for the actual rate of delinquencies in a small pool,
Moody's multiplies the rate calculated above by a factor ranging
from 0.50 to 2.0 for current delinquencies that range from less
than 2.5% to greater than 30% respectively. Moody's then uses this
final adjusted rate of new delinquency to project delinquencies
and losses for the remaining life of the pool under the approach
described in the methodology publication.

When assigning the final ratings to senior bonds, in addition to
the methodologies described above, Moody's considered the
volatility of the projected losses and timeline of the expected
defaults. For bonds backed by small pools, Moody's also considered
the current pipeline composition as well as any specific loss
allocation rules that could preserve or deplete the
overcollateralization available for the senior bonds at different
pace.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in April 2011 to 7.8% in September 2012. Moody's forecasts a
further drop to 7.5% by 2014. Moody's expects house prices to drop
another 1% from their 4Q2011 levels before gradually rising
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can
impact the performance of these transactions.

Complete rating actions are as follows:

Issuer: CSFB Mortgage-Backed Pass-Through Certificates, Series
2001-26

Cl. D-B-2, Downgraded to Ca (sf); previously on Mar 18, 2011
Downgraded to Caa3 (sf)

Cl. V-A-1, Upgraded to Baa1 (sf); previously on Nov 9, 2011
Downgraded to Ba1 (sf)

Cl. V-A-2, Upgraded to B2 (sf); previously on Feb 22, 2012
Downgraded to Caa1 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF299729

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

http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF237256


CT CDO IV: Fitch Affirms Junk Ratings on 15 Note Classes
--------------------------------------------------------
Fitch Ratings has affirmed 15 classes issued by CT CDO IV Ltd. (CT
CDO IV).

Since Fitch's last rating action in November 2011, approximately
29.5% of the underlying collateral has been downgraded and 6.4%
upgraded.  Currently, 78.4% of the portfolio has a Fitch derived
rating below investment grade and 51.2% has a rating in the 'CCC'
category and below, compared to 70.3% and 46.4% at the last rating
action.  Over this time, the class A-1 notes have received $30.3
million for a total of $207.8 million in principal paydowns since
issuance.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model (PCM) for projecting future default
levels for the underlying portfolio.  The Rating Loss Rates (RLR)
were then compared to the credit enhancement of the classes.
Fitch also analyzed the structure's sensitivity to the assets that
are distressed, experiencing interest shortfalls, and those with
near-term maturities.  Based on this analysis, the credit
enhancement for the class A-1 notes is consistent with the current
rating of the notes.

For the classes C through M notes, Fitch analyzed the class'
sensitivity to the default of the distressed assets ('CCC' and
below).  Given the high probability of default of the underlying
assets and the expected limited recovery prospects upon default,
the class C through M notes have been affirmed at 'Csf',
indicating that default is inevitable.

The transaction entered an Event of Default on Nov. 29, 2010, due
to non-payment of the full and timely accrued interest on the
class A-2 and B notes.  The class A-2 and B notes are non-
deferrable classes.  Currently, the class A-1 notes are receiving
interest through the use of principal proceeds due to the hedge
counterparty payment while the class A-2 and B notes continue to
be in default on their entire interest payment.  On Jan. 14, 2011
the controlling class declared the principal of all notes
immediately due and payable.

CT CDO IV is backed by 33 tranches from 24 obligors, the majority
of which is commercial mortgage backed securities (CMBS, 59.2%).
The remainder of the pool consists of commercial real estate (CRE)
loans (23.4%), and structured finance CDOs (17.4%).  The
transaction is considered a CMBS B-piece resecuritization (also
referred to as first loss CRE CDO) as it primarily includes junior
bonds of CMBS transactions. The transaction closed in March 2006.

Fitch has affirmed the following classes:

  -- $128,195,126 class A-1 notes at 'CCCsf';
  -- $17,691,336 class A-2 notes at 'Dsf';
  -- $17,711,304 class B notes at 'Dsf';
  -- $12,408,966 class C notes at 'Csf';
  -- $5,684,108 class D-FL notes at 'Csf';
  -- $3,631,090 class D-FX notes at 'Csf';
  -- $4,905,782 class E notes at 'Csf';
  -- $2,234,871 class F-FL notes at 'Csf';
  -- $3,680,088 class F-FX notes at 'Csf';
  -- $7,402,648 class G notes at 'Csf';
  -- $3,866,950 class H notes at 'Csf';
  -- $2,440,512 class J notes at 'Csf';
  -- $5,369,286 class K notes at 'Csf';
  -- $4,899,424 class L notes at 'Csf';
  -- $3,429,115 class M notes at 'Csf'.


DAWN CDO I: S&P Withdraws 'CC' Rating on Class B Notes on Paydown
-----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'CC (sf)' rating
on the class B notes from Dawn CDO I Ltd., a cash flow CDO backed
by mezzanine structured finance assets.

The withdrawal follows the complete paydown of the notes on their
most recent payment date.

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

SEC Rule 17g-7 requires an NRSRO, for any report accompanying a
credit rating relating to an asset-backed security as defined in
the Rule, to include a description of the representations,
warranties and enforcement mechanisms available to investors and a
description of how they differ from the representations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

           http://standardandpoorsdisclosure-17g7.com


FAIRBANKS CAPITAL: Moody's Cuts Rating on Cl. B Tranche to Caa1
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of four
tranches from one RMBS transaction backed by Subprime loans issued
by Fairbanks Capital Mortgage Loan Trust 1999-1.

Rating Rationale

The actions are a result of the recent performance review of
Subprime pools originated before 2005 and reflect Moody's updated
loss expectations on these pools.

The methodologies used in this rating were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, and "Pre-2005 US RMBS Surveillance Methodology"
published in January 2012.

The approach "Pre-2005 US RMBS Surveillance Methodology" is
adjusted slightly when estimating losses on pools left with a
small number of loans to account for the volatile nature of small
pools. Even if a few loans in a small pool become delinquent,
there could be a large increase in the overall pool delinquency
level due to the concentration risk. To project losses on pools
with fewer than 100 loans, Moody's first estimates a "baseline"
average rate of new delinquencies for the pool that is dependent
on the vintage of loan origination (11% for all vintages 2004 and
prior). The baseline rates are higher than the average rate of new
delinquencies for larger pools for the respective vintages.

Once the baseline rate is set, further adjustments are made based
on 1) the number of loans remaining in the pool and 2) the level
of current delinquencies in the pool. The volatility of pool
performance increases as the number of loans remaining in the pool
decreases. Once the loan count in a pool falls below 75, the rate
of delinquency is increased by 1% for every loan less than 75. For
example, for a pool with 74 loans from the 2004 vintage, the
adjusted rate of new delinquency would be 11.11%. In addition, if
current delinquency levels in a small pool is low, future
delinquencies are expected to reflect this trend. To account for
that, the rate calculated above is multiplied by a factor ranging
from 0.85 to 2.25 for current delinquencies ranging from less than
10% to greater than 50% respectively. Delinquencies for subsequent
years and ultimate expected losses are projected using the
approach described in the methodology publication listed above.

When assigning the final ratings to senior bonds, in addition to
the methodologies described above, Moody's considered the
volatility of the projected losses and timeline of the expected
defaults. For bonds backed by small pools, Moody's also considered
the current pipeline composition as well as any specific loss
allocation rules that could preserve or deplete the
overcollateralization available for the senior bonds at different
pace.

The above methodology only applies to pools with at least 40 loans
and a pool factor of greater than 5%. Moody's may withdraw its
rating when the pool factor drops below 5% and the number of loans
in the pool declines to 40 loans or lower unless specific
structural features allow for a monitoring of the transaction
(such as a credit enhancement floor).

The primary sources of assumption uncertainty are Moody's central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 9.1% in August 2011 to 8.1% in August 2012. Moody's
forecasts a further drop to 7.8% by the end of 2Q 2013. Moody's
expects housing prices to remain stable through the remainder of
2012 before gradually rising towards the end of 2013. Performance
of RMBS continues to remain highly dependent on servicer activity
such as modification-related principal forgiveness and interest
rate reductions. Any change resulting from servicing transfers or
other policy or regulatory change can also impact the performance
of these transactions.

Complete rating actions are as follows:

Issuer: Fairbanks Capital Mortgage Loan Trust 1999-1

A, Downgraded to A3 (sf); previously on Mar 23, 2011 Downgraded to
Aa2 (sf)

M-1, Downgraded to Baa3 (sf); previously on Mar 23, 2011
Downgraded to A2 (sf)

M-2, Downgraded to Ba3 (sf); previously on Mar 23, 2011 Downgraded
to Baa2 (sf)

B, Downgraded to Caa1 (sf); previously on Mar 23, 2011 Downgraded
to B1 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF299844

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

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


FALCON AUTO: Moody's Cuts Rating on Class A-2 Certs. to 'Caa2'
--------------------------------------------------------------
Moody's Investors Service has downgraded the Class A-2
certificates originated by Falcon Auto Dealership, LLC's 2003-1
securitization from B3 (sf) to Caa2 (sf). The certificates are
backed by franchise loans made to automobile dealerships. The
complete rating action is as follows:

Issuer: Falcon Auto Dealership LLC, Series 2003-1

Class A-2, Downgraded to Caa2 (sf); previously on Mar 30, 2012
Downgraded to B3 (sf)

Ratings Rationale

The rating action is prompted by deteriorating performance of the
borrowers as well as insufficient levels of credit enhancement
available to protect certificateholders from future losses.

The percentage of loans in special servicing due to borrower
defaults increased in the last year from 30% to 42% as of the
October 5th payment date. The Class A-2 certificates have only
2.3% credit enhancement of the outstanding loan balance. Moody's
has assumed that all the currently defaulted loans will not be
cured and that future cash flows from the underlying pool will
remain weak as the defaulted borrowers continue to face suppressed
revenues. The new rating reflects the underlying risks in the
transaction as well as Moody's view on future performance of the
collateral properties.

The primary source of uncertainty for the transaction is the
current macroeconomic environment and its impact on the automobile
industry.

Parameter Sensivitivies:

If Moody's kept default assumptions constant and assumed recovery
rates ranged from 25% to 65%, versus Moody's actual assumption
range of 35% to 90%, resulting projected losses on the Class A-2
certificates would be greater and result in a further downgrade.

Methodology:

The Methodology is as follows: In order to estimate losses on the
collateral pool, Moody's calculates the expected loss given
default of the obligors that have become nonperforming, and also
estimates future losses on the performing portion of the pool, all
as a percentage of the outstanding pool. In evaluating the
nonperforming loans, key factors include collateral valuations and
expected recovery rates, volatility around those recovery rates,
historical obligor performance, time until recovery or liquidation
on defaulted obligors, concessions due to restructuring which may
negatively impact the overall cash flow of the trust and/or the
collateral, and future industry expectations. Net losses are then
evaluated against the available credit enhancement provided by any
available overcollateralization, subordination, and excess spread.
Sufficiency of coverage is considered in light of remaining
borrower concentrations and concepts, remaining bond maturities,
and economic outlook.


GOLDMAN SACHS 2011-GC5: Fitch Affirms 'B' Rating on $23.9MM Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed all classes of Goldman Sachs Commercial
Mortgage Capital, L.P., series 2011-GC5 commercial mortgage pass-
through certificates as follows:

  -- $73.6 million class A-1 at 'AAAsf'; Outlook Stable;
  -- $476.5 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $86.4 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $568.2 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $1.385 billion class X-A at 'AAAsf'; Outlook Stable;
  -- $181 million class A-S at 'AAAsf'; Outlook Stable;
  -- $95.9 million class B at 'AA-sf'; Outlook Stable;
  -- $69.8 million class C at 'A-sf'; Outlook Stable;
  -- $74.1 million class D at 'BBB-sf'; Outlook Stable;
  -- $28.3 million class E at 'BBsf'; Outlook Stable;
  -- $23.9 million class F at 'Bsf'; Outlook Stable;

The affirmations are due to stable pool performance.  There have
been no delinquent or specially serviced loans since issuance.
Fitch identified one (1.43%) Loan of Concern, which experienced a
decline in property cash flows and a low debt service coverage
ratio.

As of the September 2012 distribution date, the pool's certificate
balance has paid down 0.96% to $1.728 billion from $1.745 billion.

The largest loan of the pool (11.36%) is secured by 478,028 square
feet of in-line and major tenant retail space within a 1.1 million
square foot (sf) regional mall in Tucson, AZ.  The property is
anchored by Sears, Dillard's, Macy's (non-collateral) and Century
Theaters (collateral).  As of second-quarter 2012, the occupancy
and debt service coverage ratio (DSCR) was similar to that from
issuance at 93% and 1.45x.  The former Borders Books & Music
(5.6%) space, vacant since year-end 2011, has been recently leased
to Total Wine & More.  The Total Wine & More lease commenced on
Aug. 1, 2012 and is pursuant to a 15-year term.


GMAC COMMERCIAL: S&P Lowers Rating on Class F Certs. to 'D'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on three
classes of commercial mortgage pass-through certificates from GMAC
Commercial Mortgage Securities Inc.'s series 2001-C1 due to
current and potential interest shortfalls.

"We downgraded class F to 'D (sf)' to reflect accumulated interest
shortfalls outstanding four months, primarily due to ASER amounts
($50,957) related to one ($10.0 million, 13.0%) of the seven
assets ($73.5 million; 95.4%) that are currently with the special
servicer, Berkadia Commercial Mortgage LLC (Berkadia); interest
not advanced of $294,950 associated with the Bridgewater Place and
the Providence Office Center assets, which have been deemed
nonrecoverable by Berkadia; and special servicing fees ($15,415).
The master servicer, Berkadia, has informed us that it intends to
recover a total of $1.1 million in outstanding advances from the
trust related to property protection advances (PPA) made on behalf
of the Bridgewater Place specially service asset. Berkadia expects
to recover the $1.1 million over the next six months, which will
potentially cause interest shortfalls up to and including the
class D certificate," S&P said.

"We lowered our ratings on class D and E because we expect these
classes to be susceptible to future interest shortfalls, resulting
primarily from the recovery of the previous PPA made by Berkadia.
Class E has already experienced an interest shortfall in the prior
month," S&P said.

"As of the Sept. 17, 2012, trustee remittance report, ARAs
totaling $31.2 million were in effect for four of the seven
specially serviced assets. The reported monthly interest
shortfalls totaled $378,976 and affected all bonds subordinate to
and including the class E certificates. Including the recoveries
by Berkadia, we estimated the potential interest shortfalls for
the next six months to be approximately $439,908, which will
likely affect all bonds subordinate to and including class D," 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

GMAC Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2001-C1
                                             Reported
           Rating             Credit     interest shortfalls
Class  To          From     enhcmt(%)    Current  Accumulated
D      CCC- (sf)   BBB+ (sf)    98.98          0            0
E      CCC- (sf)   B+ (sf)      76.56     46,734        46,734
F      D (sf)      CCC- (sf)    59.74     80,948       146,382


GMAC MORTGAGE: Fitch Keeps Rating Watch Neg. on 140 RMBS Classes
----------------------------------------------------------------
Fitch Ratings has maintained the Rating Watch Negative on 140 RMBS
classes serviced by GMAC Mortgage.  GMAC is a subsidiary of
Residential Capital LLC (ResCap).  The affected classes were
originally placed on Rating Watch Negative on April 19, 2012,
following Fitch's downgrade of ResCap's Issuer Default Rating to
'C' from 'CCC' on April 18 and Fitch's assignment of Rating Watch
Negative to GMAC's servicer ratings on April 19.

A spreadsheet listing the transactions reviewed can be found at
'www.fitchratings.com' by performing a title search for 'Fitch
Maintains Rating Watch Negative on GMAC-Serviced RMBS Oct. 10,
2012'.

The classes were originally placed on Rating Watch Negative to
reflect the increased uncertainty for the servicing portfolio due
to the growing possibility of a bankruptcy or debt restructuring
for ResCap.

Since April 19, ResCap filed for bankruptcy and the bankruptcy
court began seeking bids for the servicing assets.  Final bids are
due in October and a bankruptcy court ruling on the sale is
scheduled for November.

Fitch believes that although a servicing disruption is still not
expected in the most-likely scenario, the increased risk of a
disruption should be considered in stressed rating scenarios.
Therefore, Fitch will maintain the Rating Watch Negative on all
investment grade rated classes in subprime transactions and the
'AAsf' and 'AAAsf' rated classes in certain prime and Alt-A
transactions that were identified as being most impacted by a
servicing disruption.

Fitch will continue to monitor ResCap's ability and willingness to
meet its financial obligations and the implications for GMAC's
servicing portfolio.


GRANITE VENTURES II: S&P Affirms 'CCC+' Rating on Class D Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B and C notes from Granite Ventures II Ltd., a U.S. collateralized
loan obligation (CLO) managed by Stone Tower Debt Advisors LLC.
"In addition, we affirmed our ratings on the class A-1, A-2, and D
notes, and we removed our ratings on the class B, C, and D notes
from CreditWatch, where we placed them with positive implications
on Aug. 17, 2012," S&P said.

"The upgrades of the class B and C notes reflect improved
overcollateralization levels coupled with an improvement in the
credit quality of the underlying assets since our December 2011
rating actions. The affirmed ratings on the class A-1, A-2, and D
notes reflect our belief that the credit support available to
these tranches is commensurate with their current rating levels,"
S&P said.

"The amount of 'CCC' rated collateral held in the transaction's
asset portfolio declined since the time of our last rating action.
According to the Sept. 5, 2012, trustee report, the transaction
held $4.27 million in 'CCC' rated collateral, down from $8.09
million noted in the Nov. 7, 2011 trustee report, which we used
for our December 2011 rating actions. When calculating the
overcollateralization (O/C) ratios, the trustee haircuts a portion
of the 'CCC' rated collateral that exceeds the threshold specified
in the transaction documents. This threshold has not breached in
the time since our last rating action. The level of the 'CCC'
rated collateral in the September 2012 trustee report was 4.23%,
compared with a threshold of 7.50%," S&P said.

"The class A-1 notes have been paid down by $60.07 million over
the same time period, primarily due to post reinvestment period
amortization of the underlying collateral. The pay downs have
resulted in an increase in the transaction's class A, B, C, and D
overcollateralization ratio tests (by 44.57%, 17.22%, 5.57%, and
2.41%). Additionally, the deal has benefit from an increase in the
weighted average spread of 0.37%," S&P said.

"We note that the transaction has significant exposure to long-
dated assets, (i.e. assets maturing after the stated maturity of
the CLO). According to the September 2012, trustee report, the
balance of collateral with a maturity date after the stated
maturity of the transaction represented 7.08% of the portfolio, or
$6.83 million in par. Our analysis took into account the potential
market value and/or settlement related risk arising from the
potential liquidation of the remaining securities on the legal
final maturity date of the transaction," S&P said.

Standard & Poor's notes that the ratings on the class C and D
notes are constrained at 'BB+ (sf)' and 'CCC+ (sf)'  by the
application of the largest obligor default test, a supplemental
stress test we introduced as part of its 2009 corporate criteria
update.

"The transaction has a redemption feature that takes effect
following the January 2013 payment date, if certain provisions are
met. The feature allows the collateral manager to redeem the notes
from the proceeds generated from an auction of the underlying
collateral," S&P said.

"Our review of this transaction included a cash flow analysis,
based on the portfolio and transaction as reflected in the
aforementioned trustee report, to estimate future performance. In
line with our criteria, our cash flow scenarios applied forward-
looking assumptions on the expected timing and pattern of
defaults, and recoveries upon default, under various interest rate
and macroeconomic scenarios. In addition, our analysis considered
the transaction's ability to pay timely interest and/or ultimate
principal to each of the rated tranches. The results of the cash
flow analysis demonstrated, in our view, that all of the rated
outstanding classes have adequate credit enhancement available at
the rating levels associated with this rating action," 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," 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

Granite Ventures II Ltd.
                       Rating
Class              To           From
B                  AAA (sf)     A+ (sf)/Watch Pos
C                  BB+ (sf)     BB (sf)/Watch Pos
D                  CCC+ (sf)    CCC+ (sf)/Watch Pos

RATINGS AFFIRMED

Granite Ventures II Ltd.

Class              Rating
A-1                AAA (sf)
A-2                AAA (sf)


GS MORTGAGE: Fitch Affirms Junk Rating on 9 Security Classes
------------------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed 19 classes
of GS Mortgage Securities Corporation II (GCCFC) commercial
mortgage pass-through certificates series 2006-GG6 due to an
increase in expected losses form the specially serviced loans.

Fitch modeled losses of 12.7% of the remaining pool; expected
losses on the original pool balance total 11.9%, including losses
already incurred.  The pool has experienced $101.8 million (2.6%
of the original pool balance) in realized losses to date.  Fitch
has designated 59 loans (34.2%) as Fitch Loans of Concern, which
includes 16 specially serviced assets (19.9%).

As of the September 2012 distribution date, the pool's aggregate
principal balance has been reduced by 14.8% to $3.32 billion from
$3.9 billion at issuance.  No loans have defeased since issuance.

The largest contributor to expected losses is the specially-
serviced Windsor Capital Portfolio (6% of the pool), which is
secured by secured by eight full-service Embassy Suites hotels
containing a total of 1,906 rooms.  The hotels are primarily
located in secondary markets across six states, Washington
(Bellevue and Lynwood), Oregon (Tigard), Ohio (Blue Ash), Michigan
(Livonia), Colorado (Colorado Springs and Denver), and Texas (El
Paso).  The loan transferred to the special servicer in October
2010 due to imminent maturity default.  The special servicer
commenced foreclosure proceedings and was granted receivership,
but before the receiver could take possession the borrower filed
for bankruptcy.  The special servicer is trying to come to terms
with the borrower on a modification.

The next largest contributor to expected losses is the specially
serviced Silver Creek Portfolio Phase I loan which is secured by
37 cross-collateralized and cross-defaulted retail strip shopping
centers totaling 636,166 sf located across 17 states primarily in
the mid-west.  Thirty of the properties (87.7% NRA) are shadow-
anchored by Super Wal-Marts, while the remaining seven are
unanchored.  The loan transferred to the special servicer in
January 2010 for monetary default.  Decreasing occupancy levels
and continued pressure on rental rates are the primary causes of
the performance decline.  The special servicer continues to
negotiate with the borrower while dual tracking foreclosure.

The third largest contributor to expected losses is the modified
Market Street at DC Ranch loan (1.7%) which is secured by a
184,548 sf grocery-anchored retail center located in the
northeastern quadrant of Scottsdale, Arizona.  The property
contains 98.735 sf of retail space and 85,813 sf of office space
along with a ground lease to Safeway, which operates a 53,000 sf
grocery store.  Property performance has decreased dramatically
from underwriting due to the economic conditions of the retail
market in Scottsdale, AZ which have caused both occupancies and
rental rates to drop.  This loan was modified by the special
servicer in December 2010 and returned to the master servicer in
May 2011.  The loan was split into an A Note of $22.5 million and
a B Note of $27.5 million.

Fitch downgrades the following classes and assigns Recovery
Estimates (REs) as indicated:

  -- $292.6 million class A-J to 'BBsf' from 'BBB-sf'; Outlook
     Negative;
  -- $19.5 million class B to 'Bsf' from 'BBsf'; Outlook Negative;
  -- $48.8 million class C to 'CCCsf' from 'Bsf'; RE 10%.

Fitch affirms the following classes as indicated:

  -- $432.4 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $75.6 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $187.8 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $1 billion class A-4 at 'AAAsf'; Outlook Stable;
  -- $138.8 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $390.1 million class A-M at 'AAAsf'; Outlook Stable;
  -- $39 million class D at 'CCCsf'; RE 0%;
  -- $29.3 million class E at 'CCCsf'; RE 0%;
  -- $43.9 million class F at 'CCsf'; RE 0%;
  -- $39 million class G at 'CCsf'; RE 0%;
  -- $39 million class H at 'Csf'; RE 0%;
  -- $43.9 million class J at 'Csf'; RE 0%;
  -- $43.9 million class K at 'Csf'; RE 0%;
  -- $24.4 million class L at 'Csf'; RE 0%;
  -- $14.6 million class M at 'Csf'; RE 0%.

Class A-1 has paid in full. Classes N through Q have realized
losses and remain at 'Dsf'; RE 0%.  Fitch does not rate the class
S certificates.  Fitch previously withdrew the ratings on the
interest-only class X-P and X-C certificates.


GULF STREAM-COMPASS 2005-II: S&P Affirms 'B+' Rating on Class D
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, and C notes from Gulf Stream-Compass CLO 2005-II
Ltd., a U.S. collateralized loan obligation (CLO) managed by GSAM
Apollo Holdings LLC. "In addition, we affirmed our rating on the
class D notes, and we removed our ratings on the class A-1, A-2,
B, C, and D notes from CreditWatch, where we placed them with
positive implications on July 17, 2012," S&P said.

"The upgrades reflect a $113.98 million paydown to the class A-1
and A-2 notes and improvement in the credit quality of the
transaction's underlying assets since our October 2011 rating
actions. The affirmed rating reflects our belief that the credit
support available is commensurate with the current rating level,"
S&P said.

"According to the Sept. 17, 2012, trustee report, the transaction
held $2.81 million in defaulted assets, down from $3.54 million
noted in the Aug. 15, 2011, trustee report, which we used for our
October 2011 rating actions," S&P said.

"The amount of 'CCC' rated collateral held in the transaction's
asset portfolio also declined since the time of our last rating
action. According to the September 2012 trustee report, the
transaction held $17.07 million in 'CCC' rated collateral, down
from $22.15 million noted in the August 2011 trustee report. When
calculating the overcollateralization (O/C) ratios, the trustee
haircuts a portion of the 'CCC' rated collateral that exceeds the
threshold specified in the transaction documents. The transaction
has not breached this threshold since our last rating action. The
level of the 'CCC' rated collateral in the September 2012 trustee
report was 4.72%, compared with a threshold of 7.50%," S&P said.

"Also, the transaction has paid down the class A-1 and A-2 notes
by $10.36 million and $103.62 million since the transaction exited
its reinvestment period after the January 2012 payment date," S&P
said.

"Over the same time period, the transaction's class A/B, C, and D
overcollateralization ratio tests have improved 7.65%, 3.26%, and
0.99%, and the weighted average spread has also increased by
0.65%," S&P said.

"The transaction has exposure to long-dated assets (i.e., assets
mature after the stated maturity of the CLO). According to the
September 2012 trustee report, the balance of collateral with a
maturity date after the stated maturity of the transaction
represented 1.90% of the portfolio (alternatively, $6.31 million
in par). Our analysis took into account the potential market
value and/or settlement related risk arising from the potential
liquidation of the remaining securities on the legal final
maturity date of the transaction," S&P said.

"Our review of this transaction included a cash flow analysis,
based on the portfolio and transaction as reflected in the trustee
report, to estimate future performance. In line with our criteria,
our cash flow scenarios applied forward-looking assumptions on the
expected timing and pattern of defaults, and recoveries upon
default, under various interest rate and macroeconomic scenarios.
In addition, our analysis considered the transaction's ability to
pay timely interest and/or ultimate principal to each of the rated
tranches. The results of the cash flow analysis demonstrated, in
our view, that all of the rated outstanding classes have adequate
credit enhancement available at the rating levels associated with
this rating action," 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

Gulf Stream-Compass CLO 2005-II Ltd.
                       Rating
Class              To           From
A-1                AAA (sf)     AA+ (sf)/Watch Pos
A-2                AAA (sf)     AA+ (sf)/Watch Pos
B                  AA+ (sf)     AA- (sf)/Watch Pos
C                  A+ (sf)      BBB+ (sf)/Watch Pos
D                  B+ (sf)      B+ (sf)/Watch Pos


HEWETT'S ISLAND V: Moody's Lifts Rating on Class D Notes to 'Ba1'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Hewett's Island CLO V, Ltd.:

U.S.$27,500,000 Class B Second Priority Senior Secured Floating
Rate Notes Due 2018, Upgraded to Aa1 (sf); previously on August
24, 2011 Upgraded to A1 (sf)

U.S.$15,500,000 Class C Third Priority Senior Secured Deferrable
Floating Rate Notes Due 2018, Upgraded to A2 (sf); previously on
August 24, 2011 Upgraded to Baa2 (sf)

U.S.$15,500,000 Class D Fourth Priority Mezzanine Secured
Deferrable Floating Rate Notes Due 2018, Upgraded to Ba1 (sf);
previously on August 24, 2011 Upgraded to Ba2 (sf)

Ratings Rationale

According to Moody's, the rating actions taken on the notes
reflect the benefit of the short period of time remaining before
the end of the deal's reinvestment period in December 2012. In
consideration of the reinvestment restrictions applicable during
the amortization period, and therefore limited ability to effect
significant changes to the current collateral pool, Moody's
analyzed the deal assuming a higher likelihood that the collateral
pool characteristics will continue to maintain a positive buffer
relative to certain covenant requirements. In particular, the deal
is assumed to benefit from lower WARF, higher diversity and spread
levels compared to the levels assumed at the last rating action in
August 2011. Moody's assumed diversity score, WARF and spread of
70, 2,551, and 3.14% compared to 60, 2,670 and 2.55%,
respectively, at the time of the last rating action. Moody's also
notes that the transaction's reported collateral quality and
overcollateralization ratios are stable since the last rating
action.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $350.8 million,
defaulted par of $17.7 million, a weighted average default
probability of 15.24% (implying a WARF of 2,551), a weighted
average recovery rate upon default of 49.16%, and a diversity
score of 70. Moody's generally analyzes deals in their
reinvestment period by assuming the worse of reported and
covenanted values for all collateral quality tests. The default
and recovery properties of the collateral pool are incorporated in
cash flow model analysis where they are subject to stresses as a
function of the target rating of each CLO liability being
reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Hewett's Island CLO V, Ltd., issued in December 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 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% (WARF = 2,151)

Class A-T: 0
Class A-R: 0
Class B: +1
Class C: +3
Class D: +2
Class E: +1

Moody's Adjusted WARF + 20% (WARF = 3,227)

Class A-T: 0
Class A-R: 0
Class B: -2
Class C: -2
Class D: -1
Class E: -1

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

Sources of additional performance uncertainties are described
below (choose the ones that are applicable):

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

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


INDEPENDENCE III: S&P Lowers Rating on Class A-1 Notes to 'D'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
from 'CCC (sf)' for the class A-1 notes from Independence III CDO
Ltd., a collateralized debt obligation (CDO) transaction backed by
mezzanine structured finance assets. "We also affirmed our rating
on the class B notes," S&P said.

"According a liquidation and suspension of payments notice dated
Sept. 28, 2012, the appropriate noteholders in the transaction
voted to liquidate the remaining assets in the portfolio. We
lowered our rating on the class A-1 notes to 'D (sf)' due to the
nonpayment of interest due to the class A-1 notes on the Oct. 3,
2012, scheduled distribution date," S&P said.

"The affirmed rating reflects our belief that the credit support
available is commensurate with the current rating level," S&P
said.

"We may take additional rating actions after completion of the
liquidation and receipt of the final trustee report. Under our
criteria, we would likely lower to 'D (sf)' any rated note that
realizes a loss upon completion of the liquidation process," 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 LOWERED

Independence III CDO Ltd.
                            Rating
Class               To                  From
A-1                 D(sf)              CCC(sf)

RATING AFFIRMED

Independence III CDO Ltd.
Class              Rating
B                  CC (sf)

OTHER OUTSTANDING RATINGS

Independence III CDO Ltd.
Class              Rating
C-1                D (sf)
C-2                D (sf)


LAFAYETTE SQUARE: Moody's Lifts Rating on Cl. Q-5 Notes From Ba1
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Lafayette Square CDO Ltd.

U.S.$52,000,000 Class A-3 Third Priority Secured Floating Rate
Term Notes Due 2019; Upgraded to Aaa (sf); previously on July 18,
2011 Confirmed at Aa2 (sf);

U.S.$13,000,000 Class B-1 Fourth Priority Secured Deferrable
Floating Rate Term Notes Due 2019, Upgraded to Aa3 (sf);
previously on July 18, 2011 Upgraded to A3 (sf);

U.S.$31,000,000 Class B-2 Fourth Priority Secured Deferrable Fixed
Rate Term Notes Due 2019, Upgraded to Aa3 (sf); previously on July
18, 2011 Upgraded to A3 (sf);

U.S.$35,000,000 Class C-1 Fifth Priority Secured Deferrable
Floating Rate Term Notes Due 2019, Upgraded to A3 (sf); previously
on July 18, 2011 Upgraded to Baa2 (sf);

U.S.$10,000,000 Class C-2 Fifth Priority Secured Deferrable Fixed
Rate Term Notes Due 2019, Upgraded to A3 (sf); previously on July
18, 2011 Upgraded to Baa2 (sf);

U.S.$5,000,000 Class Q-1 Notes Due 2019 (current rated balance of
$3,381,030.98), Upgraded to Aa1 (sf); previously on July 18, 2011
Upgraded to A1 (sf);

U.S.$10,000,000 Class Q-2 Notes Due 2019 (current rated balance of
$3,725,201.81), Upgraded to Aa3 (sf); previously on July 18, 2011
Upgraded to Baa1 (sf);

U.S.$6,000,000 Class Q-4 Notes Due 2019 (current rated balance of
$3,499,779.74), Upgraded to Aa1 (sf); previously on July 18, 2011
Upgraded to A1 (sf);

U.S.$5,000,000 Class Q-5 Notes Due 2019 (current rated balance of
$2,253,512.76), Upgraded to A2 (sf); previously on July 18, 2011
Upgraded to Ba1 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the senior notes and an
increase in the transaction's overcollateralization ratios since
the rating action in July 2011. Moody's notes that the Class A-1
Notes have been paid down by approximately 34% or $101 million
since the last rating action. Based on the latest trustee report
dated September 7, 2012, the Class A, Class B and Class C
Principal Coverage Tests are reported at 158.19%, 138.57% and
122.98%, respectively versus 146.31%, 131.99% and 119.99% as of
the trustee report dated June 7, 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 $491 million,
defaulted par of $11 million, a weighted average default
probability of 22.20% (implying a WARF of 3194), a weighted
average recovery rate upon default of 47.18%, and a diversity
score of 59. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Lafayette Square CDO Ltd., issued in November 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

The methodologies used in this rating were "Moody's Approach to
Rating Collateralized Loan Obligations" published in June 2011 and
"Using the Structured Note Methodology to Rate CDO Combo-Notes"
published in February 2004.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 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 the
Class A, B, and C notes of various default probabilities. Below is
a summary of the impact of different default probabilities
(expressed in terms of WARF levels) on the Class A, B, and C 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% (2555)

Class A-1A: 0
Class A-1B: 0
Class A-2: 0
Class A-3: 0
Class B-1: +2
Class B-2: +2
Class C-1: +3
Class C-2: +3

Moody's Adjusted WARF + 20% (3833)

Class A-1A: 0
Class A-1B: 0
Class A-2: 0
Class A-3: 0
Class B-1: -2
Class B-2: -2
Class C-1: -2
Class C-2: -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 upcoming speculative-grade debt maturities which
may create challenges for issuers to refinance. CLO notes'
performance may also be impacted by 1) the manager's investment
strategy and behavior and 2) divergence in legal interpretation of
CLO documentation by different transactional parties due to
embedded ambiguities.

Sources of additional performance uncertainties are described
below:

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

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


MASTR ALTERNATIVE: Moody's Cuts Ratings on 9 Tranches to 'Caa3'
---------------------------------------------------------------
Moody's Investors Service has downgraded 19 tranches, upgraded six
tranches, and confirmed the ratings on two tranches from MASTR
Alternative Loan Trust 2005-5 and MASTR Alternative Loan Trust
2007-1. The collateral backing these deals primarily consists of
first-lien, fixed and adjustable-rate Alt-A residential mortgages.

Complete rating actions are as follows:

Issuer: MASTR Alternative Loan Trust 2005-5

Cl. 1-A-1, Downgraded to B2 (sf); previously on Apr 15, 2010
Downgraded to B1 (sf)

Cl. 2-A-1, Downgraded to Caa1 (sf); previously on May 30, 2012 Ba3
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-2, Upgraded to Caa1 (sf); previously on Apr 15, 2010
Downgraded to Ca (sf)

Cl. 2-A-3, Downgraded to Caa1 (sf); previously on Apr 15, 2010
Downgraded to B2 (sf)

Cl. 3-A-1, Downgraded to Caa3 (sf); previously on Apr 15, 2010
Downgraded to Caa1 (sf)

Cl. 3-A-2, Upgraded to Caa3 (sf); previously on Apr 15, 2010
Downgraded to C (sf)

Cl. 4-A-1, Downgraded to Caa2 (sf); previously on Apr 15, 2010
Downgraded to Caa1 (sf)

Cl. 5-A-1, Downgraded to Caa3 (sf); previously on Apr 15, 2010
Downgraded to Caa1 (sf)

Cl. 5-A-2, Upgraded to Caa3 (sf); previously on Apr 15, 2010
Downgraded to C (sf)

Cl. 15-A-X, Downgraded to B2 (sf); previously on Apr 15, 2010
Downgraded to B1 (sf)

Cl. 15-PO, Downgraded to Caa2 (sf); previously on Apr 15, 2010
Downgraded to B3 (sf)

Cl. 20-A-X, Downgraded to Caa1 (sf); previously on Apr 15, 2010
Downgraded to Ba3 (sf)

Cl. 30-A-X, Downgraded to Caa3 (sf); previously on Apr 15, 2010
Downgraded to Caa1 (sf)

Cl. 30-PO, Downgraded to Caa3 (sf); previously on Apr 15, 2010
Downgraded to Caa2 (sf)

Issuer: MASTR Alternative Loan Trust 2007-1

Cl. 1-A-1, Confirmed at Baa2 (sf); previously on May 30, 2012 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A-2, Confirmed at Baa2 (sf); previously on May 30, 2012 Baa2
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A-3, Downgraded to B3 (sf); previously on May 30, 2012 B1
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-2, Downgraded to Caa3 (sf); previously on Aug 6, 2010
Downgraded to Caa2 (sf)

Cl. 2-A-5, Upgraded to Caa3 (sf); previously on Feb 22, 2012
Downgraded to Ca (sf)

Cl. 2-A-7, Downgraded to Caa3 (sf); previously on Aug 6, 2010
Downgraded to Caa2 (sf)

Cl. 2-A-14, Upgraded to Caa3 (sf); previously on Aug 6, 2010
Downgraded to C (sf)

Cl. 3-A-1, Downgraded to Caa3 (sf); previously on Aug 6, 2010
Downgraded to Caa2 (sf)

Cl. 3-A-2, Upgraded to Caa3 (sf); previously on Aug 6, 2010
Downgraded to C (sf)

Cl. 15-AX, Downgraded to Caa3 (sf); previously on Aug 6, 2010
Downgraded to Caa2 (sf)

Cl. 15-PO, Downgraded to Caa3 (sf); previously on Aug 6, 2010
Downgraded to Caa2 (sf)

Cl. 30-A-X, Downgraded to Caa3 (sf); previously on Aug 6, 2010
Downgraded to Caa2 (sf)

Cl. 30-PO, Downgraded to Caa2 (sf); previously on Aug 6, 2010
Downgraded to Caa1 (sf)

Ratings Rationale

The actions are a result of the recent performance of Alt-A pools
originated on or after 2005 and reflect Moody's updated loss
expectations on these pools.

The rating action consists of a number of upgrades and downgrades.
The downgrades are a result of deteriorating performance and
structural features resulting in higher expected losses for
certain bonds than previously anticipated.

In addition, the rating actions reflect a change in the analysis
of how the losses are allocated between certain classes. Series
2005-5's prospectus supplement states that classes 2-A-2, 3-A-2,
and 5-A-2 support classes 2-A-1, 3-A-1, and 5-A-1, respectively,
after subordinate classes are depleted, and series 2007-1's
prospectus supplement states that classes 2-A-14 and 3-A-2 support
classes 2-A-4 and 3-A-1. However, the Pooling and Servicing
Agreements (PSAs) for both transactions state that losses after
subordinate depletion are applied pro-rata between these bonds.
Moody's previously considered the loss allocation rules as defined
in the prospectus supplement. However, the securities
administrator has confirmed that they are following the loss
allocation rules described in the PSAs. As a result, Moody's has
adjusted the ratings accordingly.

The methodologies used in these ratings were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, and "2005 -- 2008 US RMBS Surveillance Methodology"
published in July 2011. The methodology used in rating Interest-
Only Securities was "Moody's Approach to Rating Structured Finance
Interest-Only Securities" published in February 2012.

Moody's adjusts the methodologies noted above for 1) Moody's
current view on loan modifications and 2) small pool volatility.

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

For pools with loans less than 100, Moody's adjusts its
projections of loss to account for the higher loss volatility of
such pools. For small pools, a few loans becoming delinquent would
greatly increase the pools' delinquency rate.

To project losses on Alt-A pools with fewer than 100 loans,
Moody's first calculates an annualized delinquency rate based on
vintage, number of loans remaining in the pool and the level of
current delinquencies in the pool. For Alt-A pools, Moody's first
applies a baseline delinquency rate of 10% for 2005, 19% for 2006
and 21% for 2007. Once the loan count in a pool falls below 76,
this rate of delinquency is increased by 1% for every loan fewer
than 76. For example, for a 2005 pool with 75 loans, the adjusted
rate of new delinquency is 10.1%. Further, to account for the
actual rate of delinquencies in a small pool, Moody's multiplies
the rate calculated above by a factor ranging from 0.20 to 1.8 for
current delinquencies that range from less than 2.5% to greater
than 50% respectively. Moody's then uses this final adjusted rate
of new delinquency to project delinquencies and losses for the
remaining life of the pool under the approach described in the
methodology publication.

When assigning the final ratings to bonds, in addition to the
approach described above, Moody's considered the volatility of the
projected losses and timeline of the expected defaults.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in April 2011 to 8.1% in August 2012. Moody's forecasts a
further drop to 7.8% for 2013. Moody's expects house prices to
drop another 1% from their 4Q2011 levels before gradually rising
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can
impact the performance of these transactions.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF281318

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

http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF191874


MORGAN STANLEY 2003-HE2: Moody's Cuts Rating on M-2 Tranche to B3
-----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches from two RMBS transactions backed by Subprime loans
issued by Morgan Stanley.

Rating Rationale

The actions are a result of the recent performance review of
Subprime pools originated before 2005 and reflect Moody's updated
loss expectations on these pools.

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

The rating actions reflect recent collateral performance, Moody's
updated loss timing curves and detailed analysis of timing and
amount of credit enhancement released due to step-down. Moody's
captures structural nuances by running each individual pool
through a variety of loss and prepayment scenarios in the
Structured Finance Workstation(R)(SFW), the cash flow model
developed by Moody's Wall Street Analytics. This individual pool
level analysis incorporates performance variations across the
different pools and the structure of the transaction.

The approach "Pre-2005 US RMBS Surveillance Methodology" is
adjusted slightly when estimating losses on pools left with a
small number of loans to account for the volatile nature of small
pools. Even if a few loans in a small pool become delinquent,
there could be a large increase in the overall pool delinquency
level due to the concentration risk. To project losses on pools
with fewer than 100 loans, Moody's first estimates a "baseline"
average rate of new delinquencies for the pool that is dependent
on the vintage of loan origination (11% for all vintages 2004 and
prior). The baseline rates are higher than the average rate of new
delinquencies for larger pools for the respective vintages.

Once the baseline rate is set, further adjustments are made based
on 1) the number of loans remaining in the pool and 2) the level
of current delinquencies in the pool. The volatility of pool
performance increases as the number of loans remaining in the pool
decreases. Once the loan count in a pool falls below 75, the rate
of delinquency is increased by 1% for every loan less than 75. For
example, for a pool with 74 loans from the 2004 vintage, the
adjusted rate of new delinquency would be 11.11%. In addition, if
current delinquency levels in a small pool is low, future
delinquencies are expected to reflect this trend. To account for
that, the rate calculated above is multiplied by a factor ranging
from 0.85 to 2.25 for current delinquencies ranging from less than
10% to greater than 50% respectively. Delinquencies for subsequent
years and ultimate expected losses are projected using the
approach described in the methodology publication listed above.

When assigning the final ratings to senior bonds, in addition to
the methodologies described above, Moody's considered the
volatility of the projected losses and timeline of the expected
defaults. For bonds backed by small pools, Moody's also considered
the current pipeline composition as well as any specific loss
allocation rules that could preserve or deplete the
overcollateralization available for the senior bonds at different
pace.

The above methodology only applies to pools with at least 40 loans
and a pool factor of greater than 5%. Moody's may withdraw its
rating when the pool factor drops below 5% and the number of loans
in the pool declines to 40 loans or lower unless specific
structural features allow for a monitoring of the transaction
(such as a credit enhancement floor).

The primary sources of assumption uncertainty are Moody's central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 9.1% in August 2011 to 8.1% in August 2012. Moody's
forecasts a further drop to 7.8% by the end of 2Q 2013. Moody's
expects housing prices to remain stable through the remainder of
2012 before gradually rising towards the end of 2013. Performance
of RMBS continues to remain highly dependent on servicer activity
such as modification-related principal forgiveness and interest
rate reductions. Any change resulting from servicing transfers or
other policy or regulatory change can also impact the performance
of these transactions.

Complete rating actions are as follows:

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2003-HE2

Cl. M-1, Downgraded to Baa3 (sf); previously on Mar 15, 2011
Downgraded to Baa1 (sf)

Cl. M-2, Downgraded to B3 (sf); previously on Mar 15, 2011
Downgraded to B2 (sf)

Issuer: Morgan Stanley ABS Capital I Inc. Trust 2004-HE6

Cl. M-1, Downgraded to A3 (sf); previously on Mar 15, 2011
Downgraded to A1 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF299879

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

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


MORGAN STANLEY 2007-XLC1: Moody's Keeps 'C' Ratings on 2 Notes
--------------------------------------------------------------
Moody's has affirmed the ratings of ten classes of Notes issued by
Morgan Stanley 2007-XLC1, Ltd. 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 and collateralized loan obligation
(CRE CDO CLO) transactions.

Moody's rating action is as follows:

Cl. A-2, Affirmed at Ba2 (sf); previously on Nov 23, 2011 Upgraded
to Ba2 (sf)

Cl. B, Affirmed at B3 (sf); previously on Nov 23, 2011 Upgraded to
B3 (sf)

Cl. C, Affirmed at Caa1 (sf); previously on Nov 23, 2011 Upgraded
to Caa1 (sf)

Cl. D, Affirmed at Caa2 (sf); previously on Nov 23, 2011 Upgraded
to Caa2 (sf)

Cl. E, Affirmed at Caa3 (sf); previously on Nov 23, 2011 Upgraded
to Caa3 (sf)

Cl. F, Affirmed at Caa3 (sf); previously on Nov 23, 2011 Upgraded
to Caa3 (sf)

Cl. G, Affirmed at Caa3 (sf); previously on Nov 23, 2011 Upgraded
to Caa3 (sf)

Cl. H, Affirmed at Caa3 (sf); previously on Nov 23, 2011 Upgraded
to Caa3 (sf)

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

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

Ratings Rationale

Morgan Stanley 2007-XLC1, Ltd. is a static cash CRE CDO
transaction backed by a portfolio of mezzanine debt (65.5% of the
pool balance), whole loans (22.5%), and B-Note debt (12.0%).

As of the September 17, 2012 Trustee report, the aggregate Note
balance of the transaction, including preferred shares, has
declined to $330.0 million from $826.8 million at issuance with
the paydown directed to Class A-1 through Class J Notes, as a
result of the combination of principal repayment of collateral,
resolution and sales of defaulted collateral and credit risk
collateral, and failure of the par value tests. The class A-1
Notes have been retired.

There are three whole loan assets with a par balance of $61.3
million (22.5% of the current pool balance) that are considered
defaulted securities as of the September 17, 2012 Trustee report.
Moody's expects moderate losses from the defaulted securities to
occur once they are realized. As of the September 17, 2012 Trustee
report, the deal is undercollateralized by $70.7 million due to
realized losses and the restructuring of collateral assets.

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 assessments 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 7,925 compared to 6,520 at last review. The
current distribution of Moody's rated collateral and assessments
for non-Moody's rated collateral is as follows: Aaa-Aa3 (0.4%
compared to 0.5% at last review), Baa1-Baa3 (3.7% compared to 4.3%
at last review) and Caa1-Ca/C (95.9% compared to 95.2% at last
review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled a WAL of 2.5 years compared to
2.3 years at last review. The current modeled WAL incorporates
updated assumptions about extensions on the loan collateral.

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
9.5% compared to 8.0% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 100.0% compared to 41.0% at last review.
The high MAC is due to higher default probability collateral
concentrated within a small number of collateral names.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on March 22, 2012.

The cash flow model, CDOEdge(R) v3.2.1.2, 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 9.5% to 0% or up to 19.5% would result in the modeled
rating movement on the notes of 0 to 2 notches downward and 0 to 3
notches upward, respectively.

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment and commercial real
estate property markets. Commercial real estate property values
are continuing to move in a positive direction along with a rise
in investment activity and stabilization in core property type
performance. Limited new construction and moderate job growth have
aided this improvement. However, a consistent upward trend will
not be evident until the volume of investment activity steadily
increases for a significant period, non-performing properties are
cleared from the pipeline, and fears of a Euro area recession are
abated.

The hotel sector is performing strongly with eight straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Slow recovery in the office sector continues with
minimal additions to supply. However, office demand is closely
tied to employment, where growth remains slow and employers are
considering decreases in the leased space per employee. Also,
primary urban markets are outperforming secondary suburban
markets. Performance in the retail sector continues to be mixed
with retail rents declining for the past four years, weak demand
for new space and lackluster sales driven by discounting and
promotions. However, rising wages and reduced unemployment, along
with increased consumer confidence, is helping to spur consumer
spending resulting in increased sales. Across all property
sectors, the availability of debt capital continues to improve
with robust securitization activity of commercial real estate
loans supported by a monetary policy of low interest rates.

Moody's central global macroeconomic scenario maintains its
forecast of relatively robust growth in the US and an expectation
of a mild recession in the euro area for 2012. Downside risks
remain significant, and elevated downside risks and their
materialization could pose a serious threat to the outlook. Major
downside risks include: a deeper than expected recession in the
euro area; the potential for a hard landing in major emerging
markets; an oil supply shock; and material fiscal tightening in
the US given recent political gridlock. Healthy but below-trend
growth in GDP is expected through the rest of this year and next
with risks trending to the downside.

The methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in May 2012, and "Moody's Approach to
Rating Commercial Real Estate CDOs" published in July 2011.


NATIONAL COLLEGIATE: Fitch Keeps 'CC' Rating on Sub. Class B Notes
------------------------------------------------------------------
Fitch Ratings affirms the ratings on the National Collegiate Trust
2006-A student loan asset-backed notes (NCT 2006-A).  The Rating
Outlook is Stable for the senior notes.  Fitch's Global Structured
Finance Rating Criteria and Private Student Loan Asset-Backed
Securities (ABS) Criteria were used to review the transaction.

The calculated loss coverage multiple for the NCT 2006-A notes is
sufficient to support an 'A-sf' rating on the senior notes and
'CCsf' rating on the subordinate notes, which was calculated using
collateral performance data as of May 30, 2012.  The collateral
performance data reported senior parity to be 127.59% and total
parity 95.72%.  A Stable Outlook has been assigned to the senior
notes as senior parity continues to rise and excess spread is
positive.

A loss coverage multiple was determined by comparing a projected
net loss amount to available credit enhancement.  Fitch used
historical vintage loss data provided by First Marblehead
Corporation to form a loss timing curve.  After giving credit for
seasoning of loans in repayment, Fitch applied the trust's current
cumulative gross loss level to this loss timing curve to derive
the expected gross losses over the projected remaining life.  A
recovery rate was applied, which was determined to be appropriate
based on the latest data provided by the issuer.  The guarantee
provided by the Bank of America on loans originated pursuant to
the GATE Program was given credit in Fitch's analysis.  Credit
enhancement consists of excess spread and a general reserve
account, while the senior notes benefit from subordination
provided by the class B notes.  Fitch derived excess spread from
the most recent information provided by First Marblehead
Corporation and applied that same rate over the stressed
projection of remaining life.

As the subordinate class B notes' current rating classifies these
notes as a distressed structured finance security, Fitch has
calculated a Recovery Estimate (RE), which represents Fitch's
calculation of expected principal recoveries, as a percentage of
current note principal outstanding.  The RE for the subordinate
class B notes was calculated to be approximately 60.00% given
Fitch's calculation of expected net recoveries and principal
balance of the notes as of the latest reporting period.

Credit enhancement consists of excess spread and a general reserve
fund for the senior and subordinate notes, while the senior notes
also benefit from overcollateralization and subordination provided
by the subordinate class B notes.  The subordinate notes are
under-collateralized. Their credit enhancement is purely derived
from future excess spread.

The collateral supporting NCT 2006-A notes consists entirely of
private student loans, of which, the loans under the GATE program
were originated by the Bank of America (rated 'Asf/F1' Outlook
Stable by Fitch), and the remaining loans were originated by
Chela, which is not rated by Fitch,.  Loan proceeds are used by
students to assist in financing the cost of attending
undergraduate, law school, business school, medical school, dental
school, and other graduate programs.

Fitch has taken the following rating actions:

National Collegiate Trust 2006-A Student Loan Asset-Backed Notes:

  -- Senior class A-2 affirmed at 'A-sf'; Outlook Stable;
  -- Subordinate class B affirmed at 'CCsf'/ RE 60%.


OCP CLO 2012-1: S&P Affirms 'BB' Rating on Class D Def Notes
------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on OCP CLO
2012-1 Ltd./OCP CLO 2012-1 Corp.'s $294.6 million floating-rate
notes following the transaction's effective date as of June 12,
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 reliminary 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
OCP CLO 2012-1 Ltd./OCP CLO 2012-1 Corp.

Class                    Rating         Amount (mil. $)
A-1                      AAA (sf)                217.50
A-2                      AA (sf)                  16.50
B (deferrable)           A (sf)                   26.50
C (deferrable)           BBB (sf)                 17.30
D (deferrable)           BB (sf)                  16.80
Preference shares        NR                       32.20

NR-Not rated.


PREFERRED TERM X: Moody's Cuts Ratings on 3 Note Classes to 'Ca'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Preferred Term Securities X, Ltd.:

U.S. $287,000,000 Floating Rate Class A-1 Senior Notes Due July 3,
2033 (current balance of $116,876,265), Upgraded to Aa2 (sf);
previously on December 11, 2011 Upgraded to Baa1 (sf);

U.S. $67,000,000 Floating Rate Class A-2 Senior Notes Due July 3,
2033, Upgraded to A2 (sf); previously on December 11, 2011
Upgraded to Ba1 (sf);

U.S. $2,000,000 Fixed/Floating Rate Class A-3 Senior Notes Due
July 3, 2033, Upgraded to A2 (sf); previously on December 11, 2011
Upgraded to Ba1 (sf);

U.S. $88,000,000 Floating Rate Class B1 Mezzanine Notes Due July
3, 2033 (current balance of $91,978,041.22), Upgraded to Ca (sf);
previously on June 24, 2010 Downgraded to C (sf);

U.S. $19,000,000 Fixed/Floating Rate Class B2 Mezzanine Notes Due
July 3, 2033, (current balance of $19,858,895.26), Upgraded to Ca
(sf); previously on June 24, 2010 Downgraded to C (sf);

U.S. $70,500,000 Fixed/Floating Rate Class B3 Mezzanine Notes Due
July 3, 2033, (current balance of $73,686,953.45), Upgraded to Ca
(sf); previously on June 24, 2010 Downgraded to C (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the Class A-1 Notes and an
increase in the transaction's overcollateralization ratios since
the last rating action in December 2011.

Moody's notes that the Class A-1 notes have been paid down by
approximately $57.86 million or 33.1% since the last rating
action, due to diversion of excess interest proceeds and
disbursement of principal proceeds from redemptions of underlying
assets. In addition, the total par amount that Moody's treated as
defaulted or deferring declined to $168.8 million compared to
$233.6 million as of the last rating action date. As a result, the
Class A-1 notes' par coverage improved to 216.2% from 136.5% since
the last rating action, as calculated by Moody's. Based on the
latest trustee report dated September 28, 2012, the Senior
Principal Coverage Ratio is reported at 135.93% (limit 128.0%)
versus September 2011 level of 97.83%.

Due to the impact of revised and updated key assumptions
referenced in Moody's rating methodology, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers. In its
base case, Moody's analyzed the underlying collateral pool to have
a performing par of $252.7 million (including the accreted value
of the Reserve Account Strip), defaulted/deferring par of $168.8
million, a weighted average default probability of 19.43%
(implying a WARF of 952), Moody's Asset Correlation of 20.34%, and
a weighted average recovery rate upon default of 10%. In addition
to the quantitative factors that are explicitly modeled,
qualitative factors are part of rating committee considerations.
Moody's considers the structural protections in the transaction,
the risk of triggering an Event of Default, recent deal
performance under current market conditions, the legal
environment, and specific documentation features. All information
available to rating committees, including macroeconomic forecasts,
inputs from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, may influence the final rating decision.

Preferred Term Securities X, Ltd., issued on June 26, 2003, is a
collateralized debt obligation backed by a portfolio of bank trust
preferred securities (TruPS).

The portfolio of this CDO is mainly comprised of trust preferred
securities issued by small to medium sized U.S. community banks
that are generally not publicly rated by Moody's. To evaluate the
credit quality of bank TruPS without public ratings, Moody's uses
RiskCalc model, an econometric model developed by Moody's KMV, to
derive their credit scores. Moody's evaluation of the credit risk
for a majority of bank obligors in the pool relies on FDIC
financial data reported as of Q2-2012.

Moody's also evaluates the sensitivity of the rated transaction to
the volatility of the credit estimates, as described in Moody's
Rating Implementation Guidance "Updated Approach to the Usage of
Credit Estimates in Rated Transactions" published in October 2009.

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

The transaction's portfolio was modeled using CDOROM v.2.8-5 to
develop the default distribution from which the Moody's Asset
Correlation parameter was obtained. This parameter was then used
as an input in a cash flow model using CDOEdge. CDOROM v.2.8-5 is
available on moodys.com under Products and Solutions -- Analytical
models, upon return of a signed free license agreement.

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. Moody's analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased by 190 points from the
base case of 952, the model-implied rating of the Class A-1 notes
is one notch worse than the base case result. Similarly, if the
WARF is decreased by 310 points, the model-implied rating of the
Class A-1 notes is one notch better than the base case result.

In addition, Moody's also performed two additional sensitivity
analyses as described in the Special Comment "Sensitivity Analyses
on Deferral Cures and Default Timing for Monitoring TruPS CDOs"
published in August 2012. In the first, Moody's gave par credit to
banks that are deferring interest on their TruPS but satisfy
specific credit criteria and thus have a strong likelihood of
resuming interest payments. Under this sensitivity analysis,
Moody's gave par credit to $42.5 million of bank TruPS. In the
second sensitivity analysis, Moody's ran alternative default-
timing profile scenarios to reflect the lower likelihood of a
large spike in defaults. Below is a summary of the impact 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:

Sensitivity Analysis 1:

Class A-1: 0
Class A-2: +1
Class A-3: +1
Class B-1: +3
Class B-2: +3
Class B-3: +3

Sensitivity Analysis 2:

Class A-1: 0
Class A-2: 0
Class A-3: 0
Class B-1: 0
Class B-2: 0
Class B-3: 0

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as Moody's outlook on the banking
sector remains negative, although there have been some recent
signs of stabilization. The pace of FDIC bank failures continues
to decline in 2012 compared to 2011, 2010 and 2009, and some of
the previously deferring banks have resumed interest payment on
their trust preferred securities.


PREFERRED TERM XXV: Moody's Lifts Rating on A-2 Notes to 'Ba2'
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Preferred Term Securities XXV, Ltd.:

U.S.$482,600,000 Floating Rate Class A-1 Senior Notes Due June 22,
2037 (current balance of $350,408,751), Upgraded to Baa1 (sf);
previously on June 24, 2010 Downgraded to Ba3 (sf);

U.S.$129,400,000 Floating Rate Class A-2 Senior Notes Due June 22,
2037 (current balance of $127,091,526), Upgraded to Ba2 (sf);
previously on June 24, 2010 Downgraded to B3 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the Class A-1 Notes and an
increase in the transaction's overcollateralization ratios as well
as the improvement in the credit quality of the underlying
portfolio since the last rating action in June 2010.

Moody's notes that the Class A-1 Notes have been paid down by
approximately 23.7% or $109 million since the last rating action,
as a result of diversion of excess interest proceeds and
disbursement of principal proceeds from redemptions of underlying
assets. As a result of this deleveraging, the Class A-1 notes' par
coverage improved to 143.9% from 120.74% since the last rating
action, as calculated by Moody's. Based on the latest trustee
report dated September 24, 2012, the Senior Principal Coverage
Ratio is reported at 109.49% (limit 128%) versus March 26, 2010
levels of 103.64%. Going forward, the Class A-1 notes will
continue to benefit from the diversion of excess interest and the
proceeds from future redemptions of any assets in the collateral
pool .

Moody's also notes that the deal benefited from an improvement in
the credit quality of the underlying portfolio. Based on Moody's
calculation, the weighted average rating factor (WARF) improved to
953 compared to 1552 as of the last rating action date. The total
par amount that Moody's treated as defaulted or deferring declined
to $286.1 million compared to $325.6 million as of the last rating
action date.

Due to the impact of revised and updated key assumptions
referenced in Moody's rating methodology, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers. In its
base case, Moody's analyzed the underlying collateral pool to have
a performing par of $508.3 million (including the accreted value
of the Reserve Account Strips), defaulted/deferring par of $286.1
million, a weighted average default probability of 23.26%
(implying a WARF of 953), Moody's Asset Correlation of 15.86%, and
a weighted average recovery rate upon default of 8.79%. In
addition to the quantitative factors that are explicitly modeled,
qualitative factors are part of rating committee considerations.
Moody's considers the structural protections in the transaction,
the risk of triggering an Event of Default, recent deal
performance under current market conditions, the legal
environment, and specific documentation features. All information
available to rating committees, including macroeconomic forecasts,
inputs from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, may influence the final rating decision.

Preferred Term Securities XXV, Ltd., issued on March 22, 2007, is
a collateralized debt obligation backed by a portfolio of bank and
insurance trust preferred securities.

The portfolio of this CDO is mainly comprised of trust preferred
securities (TruPS) issued by small to medium sized U.S. community
banks and insurance companies that are generally not publicly
rated by Moody's. To evaluate the credit quality of bank TruPS
without public ratings, Moody's uses RiskCalc model, an
econometric model developed by Moody's KMV, to derive their credit
scores. Moody's evaluation of the credit risk for a majority of
bank obligors in the pool relies on FDIC financial data reported
as of Q2-2012. For insurance TruPS without public ratings, Moody's
relies on the assessment of Moody's Insurance team based on the
credit analysis of the underlying insurance firms' annual
statutory financial reports.

Moody's also evaluates the sensitivity of the rated transaction to
the volatility of the credit estimates, as described in Moody's
Rating Implementation Guidance "Updated Approach to the Usage of
Credit Estimates in Rated Transactions" published in October 2009.

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

The transaction's portfolio was modeled using CDOROM v.2.8-5 to
develop the default distribution from which the Moody's Asset
Correlation parameter was obtained. This parameter was then used
as an input in a cash flow model using CDOEdge. CDOROM v.2.8-5 is
available on moodys.com under Products and Solutions -- Analytical
models, upon return of a signed free license agreement.

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. Moody's analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased by 137 points from the
base case of 953, the model-implied rating of the Class A-1 notes
is one notch worse than the base case result. Similarly, if the
WARF is decreased by 78 points, the model-implied rating of the
Class A-1 notes is one notch better than the base case result.

In addition, Moody's also performed two additional sensitivity
analyses as described in the Special Comment "Sensitivity Analyses
on Deferral Cures and Default Timing for Monitoring TruPS CDOs"
published in August 2012. In the first, Moody's gave par credit to
banks that are deferring interest on their TruPS but satisfy
specific credit criteria and thus have a strong likelihood of
resuming interest payments. Under this sensitivity analysis,
Moody's gave par credit to $53.1 million of bank TruPS. In the
second sensitivity analysis, Moody's ran alternative default-
timing profile scenarios to reflect the lower likelihood of a
large spike in defaults. Below is a summary of the impact 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:

Sensitivity Analysis 1:

Class A-1: +2
Class A-2: +2
Class B-1: +3
Class B-2: +3
Class C-1: 0
Class C-2: 0

Sensitivity Analysis 2:

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as Moody's outlook on the banking
sector remains negative, although there have been some recent
signs of stabilization. The pace of FDIC bank failures continues
to decline in 2012 compared to 2011, 2010 and 2009, and some of
the previously deferring banks have resumed interest payment on
their trust preferred securities. Moody's continues to have a
stable outlook on the insurance sector, other than the negative
outlook on the U.S. life insurance industry.


RALI SERIES: Moody's Confirms 'Caa3' Ratings on 14 RMBS Tranches
----------------------------------------------------------------
Moody's Investors Service has confirmed the ratings on 17 tranches
from four RMBS transactions issued by RALI. The collateral backing
these deals primarily consists of first-lien, fixed and
adjustable-rate Alt-A residential mortgages.

Complete rating actions are as follows:

Issuer: RALI Series 2005-QS15

Cl. III-A, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. A-V, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Issuer: RALI Series 2006-QS3 Trust

Cl. I-A-1, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. I-A-2, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. I-A-3, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. I-A-5, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. I-A-6, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. I-A-7, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. I-A-8, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. I-A-9, Confirmed at Caa3 (sf); previously on May 31, 2012 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. I-A-10, Confirmed at Caa3 (sf); previously on May 31, 2012
Caa3 (sf) Placed Under Review Direction Uncertain

Cl. I-A-11, Confirmed at Caa3 (sf); previously on May 31, 2012
Caa3 (sf) Placed Under Review Direction Uncertain

Cl. I-A-12, Confirmed at Caa3 (sf); previously on May 31, 2012
Caa3 (sf) Placed Under Review Direction Uncertain

Cl. I-A-14, Confirmed at Caa3 (sf); previously on May 31, 2012
Caa3 (sf) Placed Under Review Direction Uncertain

Issuer: RALI Series 2007-QA5 Trust

Cl. III-A-1, Confirmed at Caa2 (sf); previously on May 31, 2012
Upgraded to Caa2 (sf) and Placed Under Review Direction Uncertain

Issuer: RALI Series 2007-QS4 Trust

Cl. V-A-1, Confirmed at B3 (sf); previously on May 31, 2012
Upgraded to B3 (sf) and Placed Under Review Direction Uncertain

Cl. V-A-2, Confirmed at B3 (sf); previously on May 31, 2012
Upgraded to B3 (sf) and Placed Under Review Direction Uncertain

Ratings Rationale

These bonds were previously placed on watch pending completion of
their balance correction by the Trustee. Losses have been
allocated to these bonds after the credit support depletion date,
despite having overcollateralization with respect to their related
groups. These losses were allocated without regard to any loss
allocation limit. However, the Pooling and Servicing Agreement
states that losses will not be allocated to the certificates if by
such allocation the balance of these certificates becomes lower
than the balance of the related loan group.The Trustee has
reversed some of these losses and the balances of some bonds have
been written up by the magnitude of incorrect losses previously
allocated. While Moody's has not received confirmation from the
Trustee regarding completion of the write up process, the ratings
of these bonds have been confirmed taking into account, the
current overcollateralization available and the expected
recoveries on the bonds.

The methodologies used in these ratings were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, and "2005 -- 2008 US RMBS Surveillance Methodology"
published in July 2011.

Moody's adjusts the methodologies noted above for 1) Moody's
current view on loan modifications and 2) small pool volatility.

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

For pools with loans less than 100, Moody's adjusts its
projections of loss to account for the higher loss volatility of
such pools. For small pools, a few loans becoming delinquent would
greatly increase the pools' delinquency rate.

To project losses on Alt-A pools with fewer than 100 loans,
Moody's first calculates an annualized delinquency rate based on
vintage, number of loans remaining in the pool and the level of
current delinquencies in the pool. For Alt-A pools, Moody's first
applies a baseline delinquency rate of 10% for 2005, 19% for 2006
and 21% for 2007. Once the loan count in a pool falls below 76,
this rate of delinquency is increased by 1% for every loan fewer
than 76. For example, for a 2005 pool with 75 loans, the adjusted
rate of new delinquency is 10.1%. Further, to account for the
actual rate of delinquencies in a small pool, Moody's multiplies
the rate calculated above by a factor ranging from 0.20 to 2.0 for
current delinquencies that range from less than 2.5% to greater
than 50% respectively. Moody's then uses this final adjusted rate
of new delinquency to project delinquencies and losses for the
remaining life of the pool under the approach described in the
methodology publication.

When assigning the final ratings to bonds, in addition to the
approach described above, Moody's considered the volatility of the
projected losses and timeline of the expected defaults.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in September 2011 to 7.8% in September 2012. Moody's
forecasts a further drop to 7.5% for 2014. Moody's expects house
prices to drop another 1% from their 4Q2011 levels before
gradually rising towards the end of 2013. Performance of RMBS
continues to remain highly dependent on servicer procedures. Any
change resulting from servicing transfers or other policy or
regulatory change can impact the performance of these
transactions.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF299873

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

http://v3.moodys.com/page/viewresearchdoc.aspx?docid=PBS_SF198174


RESIDENTIAL REINSURANCE: S&P Keeps 'B' Cl. 5 Note Rating on Watch
-----------------------------------------------------------------
Standard & Poor's Ratings Services said its 'B(sf)' rating on the
Residential Reinsurance 2011 Ltd. Series 2011-1 (Res Re 2011)
Class 5 notes and its 'BB-(sf)' rating on the Residential
Reinsurance 2012 Ltd. Series 2012-1 (Res Re 2012) Class 5 notes
remain on CreditWatch with negative implications, where they were
initially placed July 18, 2012.

Residential Reinsurance is an ongoing natural peril catastrophe
bond program (since 1997) sponsored by United Services Automobile
Association (USAA; AA+/Negative/--). Each class of notes covers
losses from hurricane, earthquake, severe thunderstorm, winter
storm, and wildfire on an annual aggregate basis for the Class 5
notes. The current risk period began on June 1, 2012, and ends on
May 31, 2013.

"We placed the notes on CreditWatch Negative on July 18, 2012. By
that date, there had been two reported covered events--Catastrophe
Series 77 and 78--that resulted in ultimate net loss estimates of
$95 million and $45 million. An additional event--Catastrophe
Series 83--was expected to become a covered event. Since the date
of the rating action, the loss estimate related to Cat 78 was
lowered to less than the franchise deductible amount, so it will
not be included in the aggregate loss calculation for either class
of notes. The ultimate loss estimate for Cat 83 was set at $92
million and losses from Hurricane Isaac were less than the
franchise deductible. The current estimated ultimate net loss
total is $187 million," S&P said.

"The attachment points are $1.365 billion for the Res Re 2011
notes and $1.571 billion for the Res Re 2012 notes during the
current annual risk period," S&P said.

"When we initially placed the notes on CreditWatch, we indicated
the potential for an upgrade. Due to seasonality of the covered
perils--particularly hurricane, because this peril contributes the
most to the probability of attachment and the passage of time--
barring additional covered events, we could raise the ratings,
though not higher than the initial ratings. We have requested an
updated probability of attachment from AIR Worldwide Corp., the
modeling agent. Once we receive this information, we will resolve
the CreditWatch status on the notes," S&P said.

RATINGS LIST
Ratings Remain On CreditWatch Negative
Residential Reinsurance 2011 Ltd.
  Series 2011-1 Class 5 Notes              B(sf)/Watch Neg

Residential Reinsurance 2012 Ltd.
  Series 2012-1 Class 5 Notes              BB-(sf)/Watch Neg


SANTANDER DRIVE 2012-6: Fitch Rates $50-Mil. Class E Notes 'BBsf'
-----------------------------------------------------------------
Fitch Ratings assigns ratings and Rating Outlooks to the Santander
Drive Auto Receivables Trust 2012-6 as detailed below:

  -- $429,500,000 class A-1 notes 'F1+sf';
  -- $390,850,000 class A-2 notes 'AAAsf'; Outlook Stable;
  -- $162,700,000 class A-3 notes 'AAAsf'; Outlook Stable;
  -- $182,210,000 class B notes 'AAsf'; Outlook Stable;
  -- $203,390,000 class C notes 'Asf'; Outlook Stable;
  -- $131,350,000 class D notes 'BBBsf'; Outlook Stable;
  -- $50,850,000 class E notes 'BBsf'; Outlook Stable.


SECURITIZED ASSET 2007-BR4: Moody's Cuts Ratings on 3 Secs. to Ca
-----------------------------------------------------------------
Moody's Investors Service (Moody's) has downgraded the ratings of
three tranches from two deals issued by SABR LLC trusts. The
collateral backing the transactions are subprime residential
mortgages.

Complete rating actions are as follows:

Issuer: Securitized Asset Backed Receivables LLC Trust 2007-BR4

Cl. A-1, Downgraded to Ca (sf); previously on Jul 8, 2010
Downgraded to Caa3 (sf)

Cl. A-2A, Downgraded to Ca (sf); previously on Jul 8, 2010
Downgraded to Caa2 (sf)

Issuer: Securitized Asset Backed Receivables LLC Trust 2007-NC1

Cl. A-2A, Downgraded to Ca (sf); previously on Jul 15, 2011
Downgraded to Caa2 (sf)

Rating Rationale

The actions are a result of the recent performance of Subprime
pools originated after 2005 and reflect Moody's updated loss
expectations on these pools. The downgrades in the rating action
are a result of deteriorating performance and/or structural
features resulting in higher expected losses for certain bonds
than previously anticipated.

The methodologies used in these ratings were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, and "2005 -- 2008 US RMBS Surveillance Methodology"
published in July 2011.

Moody's adjusts the methodologies noted above for Moody's current
view on loan modifications As a result of an extension of the Home
Affordable Modification Program (HAMP) to 2013 and an increased
use of private modifications, Moody's is extending its previous
view that loan modifications will only occur through the end of
2012. It is now assuming that the loan modifications will continue
at current levels until the end of 2013.

To assess the rating implications of the updated loss levels on
subprime RMBS, each individual pool was run through a variety of
scenarios in the Structured Finance Workstation(R)(SFW), the cash
flow model developed by Moody's Wall Street Analytics. This
individual pool level analysis incorporates performance variances
across the different pools and the structural features of the
transaction including priorities of payment distribution among the
different tranches, average life of the tranches, current balances
of the tranches and future cash flows under expected and stressed
scenarios. The scenarios include ninety-six different combinations
comprising of six loss levels, four loss timing curves and four
prepayment curves. The volatility in losses experienced by a
tranche due to extended foreclosure timelines by servicers is
taken into consideration when assigning ratings.

The above RMBS approach only applies to structures with at least
40 loans and a pool factor of greater than 5%. Moody's can
withdraw its rating when the pool factor drops below 5% and the
number of loans in the deal declines to 40 loans or lower. If,
however, a transaction has a specific structural feature, such as
a credit enhancement floor, that mitigates the risks of small pool
size, Moody's can choose to continue to rate the transaction.

The primary sources of assumption uncertainty are Moody's central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 9.1% in August 2011 to 8.1% in August 2012. Moody's
forecasts a further drop to 7.8% by the end of 2Q 2013. Moody's
expects housing prices to remain stable through the remainder of
2012 before gradually rising towards the end of 2013. Performance
of RMBS continues to remain highly dependent on servicer activity
such as modification-related principal forgiveness and interest
rate reductions. Any change resulting from servicing transfers or
other policy or regulatory change can also impact the performance
of these transactions.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF299845

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

http://www.moodys.com/researchdocumentcontentpage.aspx?docid=PBS_SF198689


SOLOSO CDO: Moody's Upgrades Rating on Cl. A-1LB Notes to 'Caa2'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Soloso CDO 2007-1, Ltd.:

U.S. $263,000,000 Class A-1LA Floating Rate Notes Due October 2037
(current balance $234,402,686.3), Upgraded to B1 (sf); previously
on April 8, 2011 Downgraded to Caa2 (sf)

U.S. $83,000,000 Class A-1LB Floating Rate Notes Due October 2037,
Upgraded to Caa2 (sf); previously on April 8, 2011 Downgraded to
Ca (sf)

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the Class A-1LA Notes as
well as the improvement in the credit quality of the underlying
portfolio since the last rating action in April 2011.

Moody's notes that the Class A-1LA Notes notes have been paid down
by approximately 7.8% or $19.7 million since the last rating
action, as a result of disbursement of principal proceeds from
redemptions of underlying assets. As a result of this
deleveraging, the Class A-1LA notes' par coverage improved to
116.6% from 111.7% since the last rating action, as calculated by
Moody's. Going forward, the Class A-1LA Notes notes will continue
to benefit from the diversion of excess interest and the proceeds
from future redemptions of any assets in the collateral pool.

Moody's also notes that the deal benefited from an improvement in
the credit quality of the underlying portfolio. Based on Moody's
calculation, the weighted average rating factor (WARF) improved to
713 compared to 916 as of the last rating action date. In
addition, payments to the swap counterparty are expected to step
down as the interest rate hedge with a notional amount of $184
million will step down to $75 million in October 2012. As a
result, additional excess interest will be available and disbursed
according to the transaction's priority of payments. The Moody's
cumulative assumed defaulted amount has declined to $231.75
million from $242 million as of the last rating action date. The
decline is partly due to the sale of assets that were assumed to
be defaulted in the last rating action.

Due to the impact of revised and updated key assumptions
referenced in Moody's rating methodology, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers. In its
base case, Moody's analyzed the underlying collateral pool to have
a performing par of $273 million, defaulted/deferring par of $231
million, a weighted average default probability of 19.56%
(implying a WARF of 713), Moody's Asset Correlation of 25.22%, and
a weighted average recovery rate upon default of 10%. In addition
to the quantitative factors that are explicitly modeled,
qualitative factors are part of rating committee considerations.
Moody's considers the structural protections in the transaction,
the risk of triggering an Event of Default, recent deal
performance under current market conditions, the legal
environment, and specific documentation features. All information
available to rating committees, including macroeconomic forecasts,
inputs from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, may influence the final rating decision.

Soloso CDO 2007-1, Ltd. issued on June 28, 2007, is a collateral
debt obligation backed by a portfolio of bank trust preferred
securities (TruPS).

The portfolio of this CDO is mainly comprised of trust preferred
securities issued by small to medium sized U.S. community banks
that are generally not publicly rated by Moody's. To evaluate the
credit quality of bank TruPS without public ratings, Moody's uses
RiskCalc model, an econometric model developed by Moody's KMV, to
derive their credit scores. Moody's evaluation of the credit risk
for a majority of bank obligors in the pool relies on FDIC
financial data received as of Q2-2012.

Moody's also evaluates the sensitivity of the rated transaction to
the volatility of the credit scores, as described in Moody's
Rating Implementation Guidance "Updated Approach to the Usage of
Credit Estimates in Rated Transactions" published in October 2009.

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

The transaction's portfolio was modeled using CDOROM v.2.8-5 to
develop the default distribution from which the Moody's Asset
Correlation parameter was obtained. This parameter was then used
as an input in a cash flow model using CDOEdge. CDOROM v.2.8-5 is
available on moodys.com under Products and Solutions -- Analytical
models, upon return of a signed free license agreement.

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. Moody's analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased by 162 points from the
base case of 713, the model-implied rating of the Class A-1LA
notes is one notch worse than the base case result. Similarly, if
the WARF is decreased by 63 points, the model-implied rating of
the Class A-1LA notes is one notch better than the base case
result.

In addition, Moody's also performed two additional sensitivity
analyses as described in the Special Comment "Sensitivity Analyses
on Deferral Cures and Default Timing for Monitoring TruPS CDOs"
published in August 2012. In the first, Moody's gave par credit to
banks that are deferring interest on their TruPS but satisfy
specific credit criteria and thus have a strong likelihood of
resuming interest payments. Under this sensitivity analysis,
Moody's gave par credit to $30.75 million of bank TruPS. In the
second sensitivity analysis, Moody's ran alternative default-
timing profile scenarios to reflect the lower likelihood of a
large spike in defaults. Below is a summary of the impact 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:

Sensitivity Analysis 1:

Class A-1LA: +3
Class A-1LB: +7
Class A-2L: 0
Class A-3F: 0
Class A-3L: 0
Class B-1: 0

Sensitivity Analysis 2:

Class A-1LA: +1
Class A-1LB: +0
Class A-2L: 0
Class A-3F: 0
Class A-3L: 0
Class B-1: 0

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as Moody's outlook on the banking
sector remains negative, although there have been some recent
signs of stabilization. The pace of FDIC bank failures continues
to decline in 2012 compared to 2011, 2010 and 2009, and some of
the previously deferring banks have resumed interest payment on
their trust preferred securities.


SOUND POINT I: S&P Gives 'BB' Rating on Class E Deferrable Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Sound
Point CLO I Ltd./Sound Point CLO I Inc.'s $359.25 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 including excess spread).

    The 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.

    S&P's projections of the timely interest and ultimate
    principal payments on the rated notes, which S&P assessed
    using its cash flow analysis and assumptions commensurate with
    the assigned ratings under various interest-rate scenarios,
    including LIBOR ranging from 0.34%-12.6%.

    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 available excess interest
    proceeds (before paying uncapped administrative expenses,
    subordinate and incentive management fees, expenses for
    refinancing and additional securities issued, expense reserve
    account top-up, hedge amounts, and subordinated note payments)
    to principal proceeds for the purchase of additional
    collateral assets or to pay principal on the notes
    sequentially, at the option of the collateral manager.

         STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

    http://standardandpoorsdisclosure-17g7.com/982.pdf

RATINGS ASSIGNED
Sound Point CLO I Ltd./Sound Point CLO I Inc.

Class               Rating                    Amount
                                            (mil. $)
X                   AAA (sf)                    2.75
A                   AAA (sf)                  250.25
B                   AA (sf)                    36.75
C (deferrable)      A (sf)                     34.00
D (deferrable)      BBB (sf)                   19.00
E (deferrable)      BB (sf)                    16.50
Subordinated notes  NR                         40.75

NR-Not rated.


UNITED AIR: Moody's Affirms Ba3 Rating to Series 2009-2B Tranche
----------------------------------------------------------------
Moody's Investors Service affirmed its ratings on the Series 2009-
2A and 2009-2B Enhanced Equipment Trust Certificates ("EETC") of
United Air Lines, Inc. upon the replacement of the Liquidity
Provider for these financings. Sumitomo Mitsui Banking
Corporation, acting through its New York Branch ("SMBC") has
replaced Goldman Sachs Bank USA as the provider of the separate
liquidity facilities that support each of these EETC tranches.
Moody's short-term rating of SMBC is P-1, which meets the
Threshold Rating Requirement of this EETC financing's terms.

The following EETC Tranche ratings have been affirmed and remain
in force:

  United Air Lines, Inc.

Series 2009-2A, at Baa3

Series 2009-2B, at Ba3

The principal methodology used in rating United Air Lines, Inc.
was the Global Passenger Airlines Industry Methodology published
in May 2012 and Enhanced Equipment Trust And Equipment Trust
Certificates Industry Methodology published in December 2010.
Other methodologies used include Loss Given Default for
Speculative-Grade Non-Financial Companies in the U.S., Canada and
EMEA published in June 2009.

United Continental Holdings, Inc. (NYSE: UAL) is the holding
company for both United Airlines and Continental Airlines.
Together with United Express, Continental Express and Continental
Connection, these airlines operate an average of 5,574 flights a
day to 377 airports on six continents from their hubs in Chicago,
Cleveland, Denver, Guam, Houston, Los Angeles, New York/Newark
Liberty, San Francisco, Tokyo and Washington, D.C.


TIAA REAL: Fitch Affirms Junk Rating on Two Note Classes
--------------------------------------------------------
Fitch Ratings has affirmed seven classes of TIAA Real Estate CDO
2003-1, Ltd. (TIAA 2003-1) as a result of increased credit
enhancement to the notes from principal paydowns.

Since Fitch's last rating action in November 2011, approximately
11.2% of the underlying collateral has been downgraded and 4.4%
upgraded.  Currently, 38.7% of the portfolio has a Fitch derived
rating below investment grade and 23.8% has a rating in the 'CCC'
category and below, compared to 32% and 17.6% at the last rating
action.  Over this time, the class A-1MM notes have received $45.5
million for a total of $150.7 million in principal paydowns since
issuance.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model (PCM) for projecting future default
levels for the underlying portfolio.  The default levels were then
compared to the breakeven levels generated by Fitch's cash flow
model of the CDO under the various default timing and interest
rate stress scenarios, as described in the report 'Global Criteria
for Cash Flow Analysis in CDOs'.  Fitch also analyzed the
structure's sensitivity to the assets that are distressed,
experiencing interest shortfalls, and those with near-term
maturities.  Based on this analysis, the class A through C notes'
breakeven rates are generally consistent with the ratings assigned
below.

For the class D and E notes, Fitch analyzed the class' sensitivity
to the default of the distressed assets ('CCC' and below).  Given
the high probability of default of these assets and expected
limited recovery prospects upon default, the class D notes have
been affirmed at 'CCCsf', indicating that default is possible.
Similarly, the class E notes have been affirmed at 'Csf',
indicating that default is inevitable.

The Stable Outlook on the class A-1MM and B notes reflects Fitch's
view that the transaction will continue to delever.  The Negative
Outlook on the class C notes reflects the potential for adverse
selection as the portfolio continues to amortize.

TIAA 2003-1 is a static collateralized debt obligation (CDO) that
closed on Nov. 6, 2003.  The current portfolio consists of 49
bonds from 43 obligors, of which 78.5% are commercial mortgage
backed securities (CMBS), 19.4% are real estate investment trust
(REIT) debt securities, and 2.1% are structured finance CDOs.

Fitch has affirmed the following classes as indicated:

  -- $71,342,070 class A-1MM notes at 'Asf'; Outlook Stable;
  -- $10,000,000 class B-1 notes at 'BBBsf'; Outlook to Stable
     from Negative;
  -- $2,000,000 class B-2 notes at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $16,000,000 class C-1 notes at 'Bsf'; Outlook Negative;
  -- $14,000,000 class C-2 notes at 'Bsf'; Outlook Negative;
  -- $13,500,000 class D notes at 'CCCsf';
  -- $13,901,132 class E notes at 'Csf'.


WAMU 2004-AR1: Moody's Cuts Rating on Class B-1 Certs to 'Caa2'
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of two
tranches issued by WaMu Mortgage Pass-Through Certificates Series
2004-AR1 Trust.

Complete rating actions are as follows:

Issuer: WaMu Mortgage Pass-Through Certificates Series 2004-AR1
Trust

Cl. A, Downgraded to Ba2 (sf); previously on Apr 20, 2011
Downgraded to Baa3 (sf)

Cl. B-1, Downgraded to Caa2 (sf); previously on Apr 20, 2011
Downgraded to B3 (sf)

Ratings Rationale

The actions are a result of the recent performance of the pool and
reflect Moody's updated loss expectations on the pool. The
downgrades are a result of deteriorating performance of the pool
and structural features resulting in higher expected losses for
the bonds than previously anticipated.

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

Moody's adjusts the methodologies noted above for (1) Moody's
current view on loan modifications (2) small pool volatility

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

To project losses on pools with fewer than 100 loans, Moody's
first estimates a "baseline" average rate of new delinquencies for
the pool that is set at 3% for Jumbo and which is typically higher
than the average rate of new delinquencies for larger pools. Once
the baseline rate is set, further adjustments are made based on 1)
the number of loans remaining in the pool and 2) the level of
current delinquencies in the pool. The fewer the number of loans
remaining in the pool, the higher the volatility in performance.
Once the loan count in a pool falls below 76, the rate of
delinquency is increased by 1% for every loan less than 76. For
example, for a pool with 75 loans, the adjusted rate of new
delinquency would be 3.03%. In addition, if current delinquency
levels in a small pool is low, future delinquencies are expected
to reflect this trend. To account for that, the rate calculated
above is multiplied by a factor ranging from 0.75 to 2.5 for
current delinquencies ranging from less than 2.5% to greater than
10% respectively. Delinquencies for subsequent years and ultimate
expected losses are projected using the approach described in the
methodology publication listed above.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in April 2011 to 7.8% in September 2012. Moody's forecasts a
further drop to 7.5% by 2014. Moody's expects house prices to drop
another 1% from their 4Q2011 levels before gradually rising
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can
impact the performance of these transactions.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF301750

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

http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF243269


WELLS FARGO 2004-Z: Moody's Cuts Rating on I-A-2 Secs. to 'B3'
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of four
tranches issued by Wells Fargo Mortgage Backed Securities 2004-Z
Trust.

Complete rating actions are as follows:

Issuer: Wells Fargo Mortgage Backed Securities 2004-Z Trust

Cl. I-A-1, Downgraded to Ba3 (sf); previously on Apr 18, 2011
Downgraded to Ba2 (sf)

Cl. I-A-2, Downgraded to B3 (sf); previously on Apr 18, 2011
Downgraded to B1 (sf)

Cl. II-A-1, Downgraded to Ba1 (sf); previously on Apr 18, 2011
Downgraded to Baa3 (sf)

Cl. II-A-2, Downgraded to Ba1 (sf); previously on Apr 18, 2011
Downgraded to Baa3 (sf)

Ratings Rationale

The actions are a result of the recent performance of the
underlying pools and reflect Moody's updated loss expectations on
the pool. The downgrades are a result of structural features
resulting in declining credit enhancement and as a result, higher
expected losses for the bonds than previously anticipated.

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

Moody's adjusts the methodologies noted above for 1) Moody's
current view on loan modifications 2) small pool volatility

Loan Modifications

As a result of an extension of the Home Affordable Modification
Program (HAMP) to 2013 and an increased use of private
modifications, Moody's is extending its previous view that loan
modifications will only occur through the end of 2012. It is now
assuming that the loan modifications will continue at current
levels until the end of 2013.

Small Pool Volatility

To project losses on pools with fewer than 100 loans, Moody's
first estimates a "baseline" average rate of new delinquencies for
the pool that is set at 3% for Jumbo and which is typically higher
than the average rate of new delinquencies for larger pools. Once
the baseline rate is set, further adjustments are made based on 1)
the number of loans remaining in the pool and 2) the level of
current delinquencies in the pool. The fewer the number of loans
remaining in the pool, the higher the volatility in performance.
Once the loan count in a pool falls below 76, the rate of
delinquency is increased by 1% for every loan less than 76. For
example, for a pool with 75 loans, the adjusted rate of new
delinquency would be 3.03%. In addition, if current delinquency
levels in a small pool is low, future delinquencies are expected
to reflect this trend. To account for that, the rate calculated
above is multiplied by a factor ranging from 0.75 to 2.5 for
current delinquencies ranging from less than 2.5% to greater than
10% respectively. Delinquencies for subsequent years and ultimate
expected losses are projected using the approach described in the
methodology publication listed above.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
9.0% in April 2011 to 7.8% in September 2012. Moody's forecasts a
further drop to 7.5% by 2014. Moody's expects house prices to drop
another 1% from their 4Q2011 levels before gradually rising
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer procedures. Any change resulting from
servicing transfers or other policy or regulatory change can
impact the performance of these transactions.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF301749

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

http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF243269


WFRBS COMMERCIAL: Fitch Issues Presale Report on Certificates
-------------------------------------------------------------
Fitch Ratings has issued a presale report on WFRBS Commercial
Mortgage Trust 2012-C9 pass-through certificates.

Fitch expects to rate the transaction and assign Rating Outlooks
as follows:

  -- $86,171,000 class A-1 'AAAsf'; Outlook Stable;
  -- $110,387,000 class A-2 'AAAsf'; Outlook Stable;
  -- $444,199,000 class A-3 'AAAsf'; Outlook Stable;
  -- $96,213,000 class A-SB 'AAAsf'; Outlook Stable;
  -- $93,437,000 class A-S 'AAAsf'; Outlook Stable;
  -- $830,407,000*a class X-A 'AAAsf'; Outlook Stable;
  -- $101,334,000*a class X-B 'A-sf'; Outlook Stable;
  -- $64,485,000 class B 'AA-sf'; Outlook Stable;
  -- $36,849,000 class C 'A-sf'; Outlook Stable;
  -- $42,112,000a class D 'BBB-sf'; Outlook Stable;
  -- $21,057,000a class E 'BBsf'; Outlook Stable;
  -- $19,740,000 class F 'Bsf'; Outlook Stable.

* Notional amount and interest only.
a Privately placed pursuant to Rule 144A.

The expected ratings are based on information provided by the
issuer as of Oct. 5, 2012.  Fitch does not expect to rate the
$38,165,081 class G.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 73 loans secured by 100 commercial
properties having an aggregate principal balance of approximately
$1.053 billion as of the cutoff date.  The loans were contributed
to the trust by: Wells Fargo Bank, National Association; The Royal
Bank of Scotland plc; C-III Commercial Mortgage LLC; Liberty
Island Group I, LLC; and Basis Real Estate Capital II, LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 72.6% of the properties
by balance, cash flow analysis of 82.0%, and asset summary reviews
on 87.3% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.18x, a Fitch stressed loan-to-value (LTV) of 103.1%,
and a Fitch debt yield of 9.4%.  Fitch's aggregate net cash flow
represents a variance of 7.9% to issuer cash flows.

The Master Servicer and Special Servicer will be Wells Fargo Bank,
National Association, and Midland Loan Services, Inc., rated
'CMS2' and 'CSS1', respectively, by Fitch.


ZAIS INVESTMENT: Moody's Lifts Rating on Cl. A-2 Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by ZAIS Investment Grade Limited X, Ltd.:

U.S. $152,000,000 Class A-1a Senior Secured Floating Rate Notes
Due 2057 (current outstanding balance of $135,884,039), Upgraded
to A3 (sf); previously on November 29, 2011 Upgraded to Baa3 (sf);

U.S. $120,000,000 Class A-1b Senior Secured Floating Rate Notes
Due 2057 (current outstanding balance of $107,276,873), Upgraded
to A3 (sf); previously on November 29, 2011 Upgraded to Baa3 (sf);

U.S. $59,500,000 Class A-2 Senior Secured Floating Rate Notes Due
2057, Upgraded to Ba1 (sf); previously on November 29, 2011
Upgraded to Ba2 (sf).

Ratings Rationale

According to Moody's, the rating upgrade is the result of
improvement in the credit quality of the underlying portfolio.
Such credit improvement is observed through numerous factors,
including a decrease in the WARF and an increase in the
transaction's overcollateralization ratios. Based on the latest
trustee report dated August 2012, the WARF of the portfolio has
decreased to 949 from 1123 since the last rating action in
November 2011. Additionally, the Class A overcollateralization
ratio test is reported at 97.9% versus a November 2011 level of
93.5%. Finally, the Class A-1a Notes and Class A-1b Notes are
benefitting from the diversion of excess interest proceeds as a
result of a continued Class A Overcollateralization Test failure.

ZAIS Investment Grade Limited X, Ltd., issued in July 2007, is a
collateralized debt obligation backed primarily by a portfolio of
CLOs originated from 2001 to 2010.

The principal methodology used in this rating was "Moody's
Approach to Rating SF CDOs" published in May 2012.

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 backed by
CLOs, there exist a number of sources of uncertainty, operating
both on a macro level and on a transaction-specific level. These
uncertainties are evidenced by: 1) uncertainties of credit
conditions in the general economy and 2) the large concentration
of upcoming speculative-grade debt maturities which may create
challenges for issuers to refinance. CLO notes' performance may
also be impacted by 1) the manager's investment strategy and
behavior and 2) divergence in legal interpretation of CLO
documentation by different transactional parties due to embedded
ambiguities.

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 Ba1 and below rated assets notched up by 2 rating notches:

Class A-1a: +3
Class A-1b: +3
Class A-2: +4
Class A-3: +3
Class A-4: +3
Class B: +3
Class C: 0
Class D: 0

Moody's Ba1 and below rated assets notched down by 2 rating
notches:

Class A-1a: -3
Class A-1b: -3
Class A-2: -2
Class A-3: -3
Class A-4: -3
Class B: 0
Class C: 0
Class D: 0


* Fitch Takes Rating Actions on Eight TruPs CDOs
------------------------------------------------
Fitch Ratings has affirmed 49 tranches and downgraded two tranches
from eight Trust Preferred (TruPS) Collateralized Debt Obligations
(CDOs) backed by insurance collateral as outlined in a new report.
In addition, Fitch has marked one note as paid in full and
maintained Stable Outlooks on 27 tranches rated 'Bsf' and higher.

The rating action report, titled 'Fitch Takes Various Rating
Actions on Eight TruPS CDOs', dated Oct. 10, 2012, details the
individual rating actions and portfolio characteristics for each
rated CDO.  It can be found on Fitch's Web site at
www.fitchratings.com' by performing a title search.

The key rating drivers for the rating actions are the relative
stability of the underlying credit, deleveraging of the
transactions, and the concentrated nature of the portfolios.

Trust preferred securities (TruPS), surplus notes, and other debt
issued by these U.S Property and Casualty (P&C) and Life and
Health (L&H) insurance companies represent the main credit
exposure across these transactions.

Credit quality of the underlying portfolios remained relatively
stable. This reflects stabilization in the key rating drivers for
many underlying insurance issuers.  Over this past year,
underwriting trends for P&C insurers have improved.  In addition,
for many insurers, investment portfolios recovered relatively
quickly after the recent financial crisis.  Fitch's current
outlook for the U.S. P&C and L&H insurance industry is stable.

The combined default and deferral rate decreased slightly to 6.4%
of original balance for this review, as compared to 6.5% at last
year's review.  The slight decrease was due to the sale of two
non-performing insurers.

Reflecting the relatively stable credit performance of the
underlying portfolios, senior coverage tests in all of the eight
CDOs are currently passing.  However, in five transactions,
mezzanine coverage tests or an optimal principal distribution
amount (OPDA) feature have continued to redirect a portion of
interest proceeds to pay down the most senior notes.

All transactions had paydowns to the most senior classes due to
the combination of the collateral redemptions and excess spread.
Further detail on the magnitude of the amortization since last
review is provided in the report.

As shown in the report, most portfolios are relatively
concentrated.  To account for a potential underperformance of the
oversized positions, Fitch applied a sensitivity scenario as
described in the criteria report 'Global Surveillance Criteria for
TruPS CDOs,' dated July 11, 2012.

Generally, the result of the sensitivity scenario guided
assignment of Rating Outlooks, while performance in the base case
was used to assign ratings.  In addition, for notes that were, in
the base case scenario, passing at rating levels higher than their
current levels, their performance in the sensitivity scenario
prevented a potential upgrade.  Given the long-term nature of the
portfolio and high degree of the concentration, potential future
underperformance from the oversized positions could lead to rating
volatility which would be inconsistent with high investment-grade
ratings.


* S&P Lowers Ratings on 241 Classes From 79 US RMBS Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 241
classes from 79 U.S. residential mortgage-backed securities (RMBS)
transactions and removed 182 of them from CreditWatch with
negative implications and 50 of them from CreditWatch with
developing implications. "We also raised our ratings on 11 classes
from six transactions, removed three of them from CreditWatch with
positive implications, and seven of them from CreditWatch with
developing implications. We also affirmed our ratings on 391
classes from 92 transactions and removed 29 of them from
CreditWatch negative, 59 of them from CreditWatch developing, and
13 of them from CreditWatch positive. We also withdrew our ratings
on three classes because they were paid in full and one class as
part of our interest-only criteria," S&P said.

The complete list of rating actions is available for free at:

     http://bankrupt.com/misc/S&P_RMBS_RA_10_11_12.pdf

"On Aug. 15, 2012, we placed our ratings on 343 classes from 93 of
the transactions within this review on CreditWatch negative,
positive, or developing, along with ratings from a group of other
RMBS securities due to the implementation of our recently revised
criteria for surveilling pre-2009 U.S. RMBS ratings. We completed
our review of the transactions herein using the revised
assumptions and these rating actions resolve some of the
CreditWatch placements. The directional movements of the
CreditWatch resolutions within this review are," S&P said:

                              3 or fewer       More than 3
From Watch   Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos         13          0        0        3        0
Watch Neg         29          0       52        0      130
Watch Dev         59          3       45        4        5

"In line with the updated criteria, we revised our remaining loss
projections for all of the transactions in this review from our
previous projections. The remaining projected loss increases
ranged from a low of 0.40% for Park Place Securities Inc. 2005-
WCW2 to a high of 110% for CWABS Asset Backed Certificates Trust
2005-7, and an average of 42% for the 95 transactions within this
review," S&P said.

The increase in projected losses resulted from one or more of
these factors:

    An increase in our default and loss multiples at higher
    investment-grade rating levels;

    A substantial portion of nondelinquent loans (generally
    between 20% and 50%) now categorized as reperforming (many of
    these loans have been modified) and having a default frequency
    of 45% or 50%;

    Increased roll-rates for 30- and 60-day delinquent loans;

    Application of a high prepayment/front end stress liquidation
    scenario; and

    A continued elevated level of observed severities.

"Despite the increase in remaining projected losses, we raised our
ratings on 11 classes from six transactions. In general, the
upgrades reflect two general trends we've seen in these types of
transactions," S&P said:

    The transactions have failed their cumulative loss trigger,
    resulting in the permanent sequential payment of principal to
    its classes, thereby locking out any principal payments to
    lower rated subordinate classes, which prevents credit support
    erosion; and

    Certain classes have a first priority in interest and
    principal payments driven by the occurrence of the first
    bullet.

"All of the upgrades affected classes from transactions issued in
2005 through 2007 and were originally rated in an investment-grade
category. All of the raised ratings have sufficient credit support
to absorb expected remaining losses," S&P said.

"For certain transactions, we took into consideration specific
performance characteristics that, in our view, may add a layer of
volatility to our loss assumptions when they are stressed at the
rating as suggested by our cash flow models. In these
circumstances, we either limited the extent of our upgrades
or affirmed our ratings on the classes of the transactions in
order to buffer against this uncertainty and promote ratings
stability," S&P said. In general, the bonds that were affected
reflect:

    Historical interest shortfalls;
    Low priority in principal payments;
    Significant growth in the delinquency pipeline;
    High proportion of re-performing loans in the pool;
    Significant growth in observed loss severities; and
    Weak hard-dollar credit support.

"We affirmed our ratings on 60 classes from 41 transactions in the
'AAA (sf)' through 'A (sf)' rating categories," S&P said. These
bonds generally reflect:

    Classes that are currently in first, second, or third payment
    priority

    Have sufficient credit support to absorb expected remaining
    losses; and

    Benefit from permanently failing cumulative loss triggers.

"In addition, we affirmed the ratings on 41 classes from 30
transactions in the 'BBB (sf)' through 'B (sf)' rating categories.
The projected credit support on these particular bonds remained
relatively in line with prior projections," S&P said.

"Lastly, we affirmed our ratings on 290 additional classes in the
'CCC (sf)' or 'CC (sf)' rating categories. We believe that the
projected credit support for these classes will remain
insufficient to cover the revised projected losses to these
classes," S&P said.

"We lowered our ratings on 241 classes from 79 transactions. Of
the lowered ratings, we downgraded 86 classes out of investment-
grade, including 11 that we downgraded to 'CCC (sf)'. Of the
classes downgraded out of investment-grade, 41 classes from 29
transactions were in 'AAA (sf)' or 'AA (sf)' rating categories
prior to today's actions. For a certain number of these downgrades
from 'AAA (sf)' or 'AA (sf)' to speculative-grade, the actions
reflect the application of our interest shortfall criteria.
Another 81 ratings remain at investment-grade after the downgrade.
The remaining lowered ratings were of classes that already had
speculative-grade ratings prior to the downgrade," S&P said.

"We also withdrew our ratings on three classes because they were
paid in full and one class as part of our interest-only criteria,"
S&P said.

"In accordance with our counterparty criteria, we considered any
applicable hedges related to these securities when performing
these rating actions and resolving the CreditWatch placements,"
S&P said.

Subordination, overcollateralization (when available), and excess
interest generally provide credit support for these subprime
transactions.

            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


* S&P Lowers Ratings on 514 Classes From 99 US RMBS Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 514
classes from 99 U.S. residential mortgage-backed securities (RMBS)
transactions and removed 414 of them from CreditWatch with
negative implications and 35 from CreditWatch with developing
implications. "We also raised our ratings on 66 classes and
removed one of them from CreditWatch negative, 21 from CreditWatch
developing, and 25 from CreditWatch positive. We also affirmed our
ratings on 607 classes from 118 transactions and removed 11 of
them from CreditWatch negative, 39 from CreditWatch developing,
and one from CreditWatch positive. We subsequently withdrew four
of the lowered ratings and two of the affirmed ratings because
of our view of the potential for performance volatility associated
with pools of fewer than 20 loans. In addition, we withdrew our
ratings on 43 classes from 18 transactions and removed 38 of them
from CreditWatch negative, one from CreditWatch developing and one
from CreditWatch positive. We withdrew 38 of these ratings in
accordance with our current interest-only criteria and five of
them because they have been paid in full," S&P said.

The complete list of rating actions is available for free at:

       http://bankrupt.com/misc/S&P_RMBS_RA_10_9_12.pdf

The transactions in this review were issued between 2002 and 2007
and are backed by adjustable- and fixed-rate prime jumbo mortgage
loans secured primarily by first liens on one- to four-family
residential properties.

"On Aug. 15, 2012, we placed our ratings on 587 classes from 96 of
these transactions on CreditWatch negative, positive or
developing, along with ratings from a group of other RMBS
securities due to the implementation of our recently revised
criteria for surveilling pre-2009 U.S. RMBS ratings. CreditWatch
negative placements accounted for approximately 57% of the prime
jumbo CreditWatch actions, CreditWatch developing placements
accounted for approximately 36%, and CreditWatch positive
placements accounted for approximately 7%. We completed our review
on these transactions using the revised assumptions, and these
rating actions resolve some of the CreditWatch placements," S&P
said.

                              3 or fewer       More than 3
From         Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos          1          3        0       22        0
Watch Neg         11          1      208        0      206
Watch Dev         39         15       33        6        2
Not on CW          0          0        0        0        0

"The high percentage of CreditWatch negative placements reflected
our projection that remaining losses for a majority of the prime
jumbo transactions will increase. We may have placed our ratings
on CreditWatch negative for certain structures that had reduced
forecasted losses due to an increased multiple of loss coverage
for certain investment-grade rated tranches as set forth in our
revised criteria," S&P said.

The increased projected losses resulted from one or more of these
factors:

    An increase in our default and loss multiples at higher
    investment-grade rating levels;

    An increased portion of nondelinquent loans (generally between
    1% and 8%) are now categorized as reperforming (many of these
    loans have been modified) and have a default frequency of 25%
    or 30%; and

    "Our extended liquidation curves which eroded projected credit
    support prior to when it would be needed," S&P said.

Shelf                                               # Deals/
                                                    structures
Name                                                Reviewed
Banc of America Funding Trust (BAF)                 12/19
Banc of America Mortgage Trust (BAM)                6/8
Bear Sterns ARM Trust (BSAT)                        27/34
ChaseFlex Trust (CHFX)                              2/2
Chase Mortgage Finance Trust (CMFT)                 3/3
GSR Mortgage Loan Trust (GSR)                       8/9
Merrill Lynch Mortgage Investors Trust MLCC (MLCC)  1/1
Sequoia Mortgage Trust (SEQ)                        11/12
Wells Fargo Mortgage Backed Securities (WFMS)       30/32
WaMu Mortgage Pass-Through Certificates (WAMU)      32/36

The tables detail information on each reviewed shelf as of August
2012.

Losses and Delinquencies*

Shelf     Avg. Pool    Cum. Loss   Serious DQ    Total DQ
Name      Factor (%)   Avg. (%)    Avg. (%)      Avg. (%)
BAF       35.74        4.92        16.48         19.50
BAM       21.47        1.06        12.83         15.64
BSAT      21.45        2.23        12.78         15.49
CHFX      33.22        2.29        15.45         17.39
CMFT      23.02        2.56        12.95         14.32
GSR       34.26        2.92        14.22         17.80
MLCC       7.78        0.24         5.32          6.84
SEQ       26.99        2.32        10.57         14.21
WFMS      30.13        2.51         7.44          9.35
WAMU      29.43        2.43         9.50         12.51

*Cumulative losses represent the percentage of the original pool
balance, and total and severe delinquencies represent the
percentage of the current pool balance.


Shelf     # IG         # Non-IG    # IG to       # Down/Up
Name      Affirmed     Affirmed    Non-IG        >3 notches
BAF       0            161         3             15/17
BAM       3            53          7             29/2
BSAT      26           58          8             51/1
CHFX      0            30          0             0/1
CMFT      0            4           1             8/0
GSR       0            57          0             1/2
MLCC      0            2           1             4/0
SEQ       0            24          4             12/3
WFMS      2            81          23            35/7
WAMU      3            103         8             53/12

IG-Investment grade.

"In addition, some of the reviewed transactions or respective
structures within a transaction are backed by a small remaining
population of mortgage loans. Standard & Poor's believes that the
liquidation of one of more of the loans in transactions with a
small number of remaining loans may have an adverse effect on
credit. This potential 'tail risk' to the rated classes resulted
from one or more of these factors," S&P said:

    Shifting-interest payment structures increase the possibility
    of volatile credit performance. The cash flow mechanics within
    these transactions allow unscheduled principal to be repaid to
    subordinate classes while more senior classes remain
    outstanding if certain performance triggers are met. This
    decreases the actual dollar amount of credit enhancement
    available to cover losses;

    The lack of optional terminations ("clean-up" calls) in which
    a designated participant can purchase the remaining loans
    within a trust when the pool factor declines to a defined
    percentage, effectively retiring the securities;

    The lack of credit enhancement floors that could add
    additional protection to the classes within a structure.

    Securities currently rated 'AAA (sf)' in transactions that
    have shifting-interest pay mechanisms and do not benefit from
    a credit enhancement floor or an equivalent functional
    mechanism will be rated no higher than 'AA+ (sf)'.

"In cases where a structure contained fewer than 100 loans or was
approaching 100 loans remaining, we addressed tail risk by
conducting additional loan-level analysis that stresses the loan
concentration risk within the specific pool. We may calculate loss
severities at the loan level using assumptions, such as market-
value declines published in the 2009 RMBS Criteria, instead of
using pool-level assumptions. Because we developed our loss
severity assumptions using an aggregate sample set of data, we
applied a 1.2x adjustment factor to the loss severity assumption
for each loan when calculating loan level loss severities to
account for potential variation between actual and calculated loss
severities when a loan is liquidated. The loss severity used in
our analysis is equal to the higher of the calculated loss
severity and 20%. We use a 20% minimum loss severity to mitigate
potential information risk differences between the actual property
profile and condition and the reported estimated value using a
housing price index. Finally, we apply a 50% minimum loss severity
to the largest remaining loan balance if the calculated amount is
lower. The final rating assigned to each class will be the lower
of the rating derived by applying our revised surveillance
criteria and the rating derived by applying our tail risk
criteria," S&P said.

"The ratings on six classes from Banc of America Mortgage 2003-5
Trust (structure 3) have been reviewed and subsequently withdrawn
because the pool contained fewer than 20 loans. If any of the
remaining loans in this pool were to default, the resulting loss
could have a greater effect on the pool's performance than if the
pool consisted of a larger number of loans. Because this
performance volatility may have an adverse effect on the stability
of our outstanding ratings, we subsequently withdrew four of the
lowered ratings and two of the affirmed ratings due to the small
number of loans remaining," S&P said.

"Some of the transactions in this review have failed their current
delinquency triggers, which can affect the allocation of principal
to their classes. However, the payment priority of the deals that
failed these triggers may allow for additional allocation of
principal to the subordinate classes if they begin passing their
delinquency triggers again. In these instances, according to our
criteria, we lowered the ratings to 'AA+ (sf)' even though some of
these classes pass our 'AAA (sf)' stress scenario," S&P said.

"Of the downgraded classes, we lowered our ratings on 55 classes
to speculative-grade from investment-grade. Of the classes we
downgraded to speculative-grade from investment-grade, we lowered
37 to ratings between 'BB+ (sf)' and 'B- (sf)' and lowered 18 to
'CCC (sf)' or 'CC (sf)'. Additionally, we lowered 307 ratings that
remain at investment-grade. The remaining 152 downgraded ratings
were of classes that already had speculative-grade ratings prior
to being lowered," S&P said.

"We affirmed our ratings on 556 classes in the 'CCC (sf)' or 'CC
(sf)' categories. We believe that the projected credit support for
these classes will remain insufficient to cover the revised base-
case projected losses to these classes," S&P said.

"Besides the six classes withdrawn due to the related pool
containing fewer than 20 loans, we withdrew our ratings on 43
classes from 18 transactions: we withdrew 38 in accordance with
our IO criteria because the referenced classes no longer sustained
ratings above 'A+ (sf)', and we withdrew five ratings because the
classes have been paid in full," S&P said.

"In accordance with our counterparty criteria, we considered any
applicable hedges related to these securities when performing
these rating actions and resolving the CreditWatch placements,"
S&P said.

Subordination generally provides credit support for these prime
jumbo transactions.

              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


* S&P Lowers Ratings on 19 Classes From 2 Canadian CMBS Deals
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 19
classes from two Canadian commercial mortgage-backed securities
(CMBS) transactions and removed S&P's ratings on 17 of these
classes from CreditWatch with negative implications.
"Concurrently, we raised our ratings on two classes from Merrill
Lynch Financial Assets Inc.'s series 2007-Canada 22. We also
affirmed our ratings on 13 classes from two CMBS transactions and
removed one of these ratings from CreditWatch with negative
implications. The CreditWatch resolutions are related to
CreditWatch placements that occurred on Sept. 5, 2012," S&P said.

"The rating actions on the principal and interest certificates
follow our analysis of the transactions using our recently updated
criteria for rating U.S. and Canadian CMBS transactions, which was
the primary driver of the rating actions," S&P said.

"Our rating actions on the interest-only (IO) certificates reflect
our current criteria for rating IO securities," S&P said.

"The downgrades on the principal and interest certificates reflect
our expected available credit enhancement for the affected
tranches, which we believe is less than our most recent estimate
of necessary credit enhancement for the most recent rating levels.
The downgrades also reflect our views regarding the current and
future performance of the collateral supporting the transactions,"
S&P said.

"The upgrades on the principal and interest certificates reflect
Standard & Poor's expected available credit enhancement for the
affected tranches, which we believe is greater than our most
recent estimate of necessary credit enhancement for the most
recent rating levels. The upgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions," S&P said.

"The rating actions follow a detailed review of the performance of
the collateral supporting the relevant securities and transaction
structures. This review was similar to the review we conducted
before placing 744 U.S. and Canadian CMBS ratings on CreditWatch
following the release of our updated ratings criteria for these
transactions, but was more detailed with respect to collateral and
transaction performance. For more information on the analytic
process we used for those CreditWatch placements, refer to 'The
Application Of Standard & Poor's Revised U.S. And Canadian CMBS
Criteria For The Sept. 5, 2012 CreditWatch Actions,' published
Sept. 5, 2012," 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 17-g7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS AND CREDITWATCH ACTIONS

Merrill Lynch Financial Assets Inc.
Commercial mortgage pass-through certificates series 2007-Canada
22

Class  To         From          Credit enhancement (%)
A-2    AAA (sf)   AAA (sf)                 18.81
A-3    AAA (sf)   AAA (sf)                 18.81
B      AA+ (sf)   AA(sf)                   15.54
C      A+ (sf)    A (sf)                   11.46
D      BBB- (sf)  BBB (sf)                  6.76
E      BB+ (sf)   BBB-(sf)/Watch Neg        5.33
F      BB- (sf)   BB+ (sf)/Watch Neg        4.26
G      B+ (sf)    BB (sf)/Watch Neg         3.36
H      B (sf)     BB- (sf)/Watch Neg        2.87
J      B- (sf)    B+ (sf)/Watch Neg         2.47
K      B- (sf)    B (sf)/Watch Neg          1.89
L      CCC (sf)   B- (sf)                   1.48
XC     AAA (sf)   AAA (sf)                   N/A
XP-1   AAA (sf)   AAA (sf)                   N/A
XP-2   AAA (sf)   AAA (sf)                   N/A


Real Estate Asset Liquidity Trust
Commercial mortgage pass-through certificates series 2007-2

Class  To         From          Credit enhancement (%)
A-1    AAA (sf)   AAA (sf)                 25.34
A-2    AAA (sf)   AAA (sf)                 25.34
A-J    AA (sf)    AAA (sf)/Watch Neg       14.41
B      A+ (sf)    AA (sf)/Watch Neg        11.72
C      BBB+ (sf)  A (sf)/Watch Neg          8.39
D-1    BB+ (sf)   BBB (sf)/Watch Neg        5.39
D-2    BB+ (sf)   BBB (sf)/Watch Neg        5.39
E-1    BB (sf)    BBB- (sf) /Watch Neg      4.28
E-2    BB (sf)    BBB- (sf)/Watch Neg       4.28
F      BB- (sf)   BB+ (sf)/Watch Neg        3.29
G      B+ (sf)    BB (sf)/Watch Neg         2.69
H      B+ (sf)    BB- (sf)/Watch Neg        2.38
J      B (sf)     B+ (sf)/Watch Neg         2.06
K      B (sf)     B (sf)/Watch Neg          1.90
L      B- (sf)    B- (sf)                   1.52
XC-1   AAA (sf)   AAA (sf)                   N/A
XC-2   AAA (sf)   AAA (sf)                   N/A
XP-1   AAA (sf)   AAA (sf)                   N/A
XP-2   AAA (sf)   AAA (sf)                   N/A

N/A-Not applicable.


* S&P Withdraws Ratings on 61 Classes From 30 CMBS, CDO Deals
-------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 61
classes from 30 commercial mortgage-backed securities (CMBS)
transactions and one commercial real estate collateralized
debt obligation (CR CDO) transactions.

"We withdrew our ratings on 53 principal and interest paying
classes from 26 CMBS transactions following the full repayment of
each class' principal balance, as noted in each transaction's
respective September 2012 trustee remittance report. We withdrew
our ratings on one interest-only (IO) class from one CMBS
transactions following the reduction of the classes' notional
balances, as noted in each transaction's respective trustee
remittance report," S&P said.

"We also withdrew our ratings on three IO classes from one CMBS
transaction following the repayment of all principal and interest
paying classes rated 'AA- (sf)' or higher, according to our
criteria for rating IO securities," S&P said.

"In addition, we withdrew our ratings on four principal and
interest paying classes from four CMBS transactions following the
repayment in full of each class' principal balance," S&P said.

               STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

SEC Rule 17g-7 requires an NRSRO, for any report accompanying a
credit rating relating to an asset-backed security as defined in
the Rule, to include a description of the representations,
warranties and enforcement mechanisms available to investors and a
description of how they differ from the representations,
warranties and enforcement mechanisms in issuances of similar
securities. The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.

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

          http://standardandpoorsdisclosure-17g7.com

RATINGS WITHDRAWN FOLLOWING REPAYMENT OF PRINCIPAL BALANCE OR
REDUCTION OF
NOTIONAL BALANCE

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2002-2
                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)
D                        NR                  AAA (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2003-1
                                 Rating
Class                    To                  From
ES-A                     NR                  AAA (sf)
ES-B                     NR                  AA+ (sf)
ES-C                     NR                  AA (sf)
ES-D                     NR                  AA- (sf)
ES-E                     NR                  A+ (sf)
ES-F                     NR                  A (sf)
ES-G                     NR                  A- (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2005-4
                                 Rating
Class                    To                  From
XP                       NR                  AAA (sf)

Banc of America Commercial Mortgage Trust 2008-1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Banc of America Large Loan Inc.
Commercial mortgage pass-through certificates series 2005-MIB1
                                 Rating
Class                    To                  From
B                        NR                  AA+ (sf)
C                        NR                  AA- (sf)
D                        NR                  A (sf)
E                        NR                  BBB+ (sf)
F                        NR                  BB+ (sf)
G                        NR                  B (sf)
H                        NR                  CCC- (sf)

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 1999-CLF1
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)


CD 2006-CD3 Mortgage Trust
Commercial mortgage pass-through certificates series 2006-CD3
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)


Citigroup Comm Mtg Trust Ser 2006-FL2
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
G                        NR                  AA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CP4
                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)

GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2002-3
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)
B                        NR                  AAA (sf)
C                        NR                  AAA (sf)
D                        NR                  AAA (sf)

GE Commercial Mortgage Corporation, Series 2006-C1 Trust
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Greenwich Capital Commercial Funding Corp.
Commercial mortgage pass-through certificates series 2002-C1
                                 Rating
Class                    To                  From
A-4                      NR                  AAA (sf)

J.P. Morgan Chase Commercial Mortgage Securities Trust 2006-LDP6
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-3FL                    NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2002-C4
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)
D                        NR                  AA+ (sf)

LB-UBS Commercial Mortgage Trust 2006-C4
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)


Lehman Brothers Floating Rate Commercial Mortgage Trust 2007-LLF
C5 Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  BBB (sf)

Madison Square 2004-1 Ltd.
CMBS backed notes series 2004-1
                                 Rating
Class                    To                  From
M                        NR                  BBB+ (sf)

Merrill Lynch Mortgage Trust
Commercial mortgage pass-through certificates series 2004-BPC1
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

Merrill Lynch Mortgage Trust 2008-C1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Merrill Lynch Mortgage Trust Series 2002-FED
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
B-1                      NR                  AA+ (sf)
B-2                      NR                  AA+ (sf)
B-3                      NR                  AA+ (sf)
B-4                      NR                  AA+ (sf)
B-5                      NR                  AA+ (sf)

ML-CFC Commercial Mortgage Trust 2006-1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)
A-3B                     NR                  AAA (sf)
A-3FL                    NR                  A (sf)

Morgan Stanley Capital I Trust 2003-IQ6
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2006-HQ9
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Nomura Asset Securities Corp.
Commercial mortgage pass-through certificates series 1998-D6
                                 Rating
Class                    To                  From
A-1C                     NR                  AAA (sf)

Salomon Brothers Commercial Mortgage Trust 2001-C1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
G                        NR                  B (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2002-C2
                                 Rating
Class                    To                  From
A-4                      NR                  AAA (sf)
B                        NR                  AAA (sf)
C                        NR                  AAA (sf)
D                        NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2003-C9
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2005-C17
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)


RATINGS WITHDRAWN DUE TO REPAYMENT OF ALL PRINCIPAL AND INTEREST
PAYING
CLASSES RATED 'AA- (sf)' OR HIGHER

Banc of America Large Loan Inc.
Commercial mortgage pass-through certificates series 2005-MIB1
                                 Rating
Class                    To                  From
X-1B                     NR                  AAA (sf)
X-2                      NR                  AAA (sf)
X-5                      NR                  AAA (sf)


RATINGS WITHDRAWN FOLLOWING REPAYMENT OF PRINCIPAL BALANCE AND
REMOVED FROM
CREDITWATCH NEGATIVE

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2003-1
                                 Rating
Class                    To                  From
ES-H                     NR                  BBB- (sf)/ Watch Neg


RATINGS WITHDRAWN FOLLOWING REPAYMENT OF PRINCIPAL BALANCE AND
REMOVED FROM
CREDITWATCH POSITIVE

Morgan Stanley Dean Witter Capital I Trust 2002-IQ2
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
D                        NR                  AA (sf)/Watch Pos

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2002-C1
                                 Rating
Class                    To                  From
L                        NR                  BB+ (sf)/Watch Pos

Washington Mutual Asset Securities Corp.
Commercial mortgage pass-through certificates series 2003-C1
                                 Rating
Class                    To                  From
F                        NR                  A- (sf)/Watc


* S&P Withdraws Ratings on 13 Classes From 2 CMBS Transactions
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 13
classes from two commercial mortgage-backed securities (CMBS)
transactions, and removed these 13 from CreditWatch with positive
implications. "Concurrently, we lowered our ratings on 11 classes
from two CMBS transactions and removed seven of them from
CreditWatch with negative implications. We also affirmed our
ratings on nine classes from one CMBS transaction and removed one
of these ratings from CreditWatch with negative implications. The
CreditWatch resolutions are related to CreditWatch placements that
occurred on Sept. 5, 2012," S&P said.

"The upgrades on the principal and interest certificates reflect
Standard & Poor's expected available credit enhancement for the
affected tranches, which we believe is greater than our most
recent estimate of necessary credit enhancement for the most
recent rating levels. The upgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions," S&P said.

"The downgrades of 10 of the 11 principal and interest
certificates reflect our expected available credit enhancement for
the affected tranches, which we believe is less than our most
recent estimate of necessary credit enhancement for the most
recent rating levels. The downgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions," S&P said.

"The downgrade of the 'AW34' raked class in the Morgan Stanley
Capital 2007-Top 27 reflects our analysis of the junior nonpooled
portion of the 330 West 34th Street loan and follows our recently
updated criteria for rating U.S. and Canadian CMBS transactions,
which applies a credit enhancement minimum equal to 1% of the
transaction or loan amount to address the potential for unexpected
trust expenses that may be incurred during the life of the loan or
transaction. These potential unexpected trust expenses may include
servicer fees, servicer advances, and potential trust legal fees.
We downgraded the 'AW34' raked class to 'BB+ (sf) because neither
the loan or the transaction documents include mechanisms to cover
unexpected potential trust expenses and the respective loan
consists exclusively of investment-grade rated classes. The rakes
certificates derive 100% of their cash flows from the junior non
pooled portion of the loan," S&P said.

"The rating actions taken on the IO certificates reflect our
current criteria for rating IO securities," S&P said.

"The rating actions follow a detailed review of the performance of
the collateral supporting the relevant securities and transaction
structures. This review was similar to the review we conducted
before placing 744 U.S. and Canadian CMBS ratings on CreditWatch
following the release of our updated ratings criteria for these
transactions but was more detailed with respect to collateral and
transaction performance," 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 AND CREDITWATCH ACTIONS

Morgan Stanley Capital I Trust 2007-Top 27
Commercial mortgage pass-through certificates

Class  To         From               Credit enhancement (%)
A-M    AA  (sf)   A- (sf)/Watch Pos                   17.87
A-MFL  AA  (sf)   A- (sf)/Watch Pos                   17.87
A-J    BBB+(sf)   BB (sf)/Watch Pos                    9.56
B      BB+ (sf)   BB-(sf)/Watch Pos                    7.19
C      BB  (sf)   B+ (sf)/Watch Pos                    5.85
D      B+  (sf)   B  (sf)/Watch Pos                    4.52
AW34   BB+ (sf)   AAA(sf)/Watch Neg                    0.00

LB Commercial Mortgage Trust 2007-C3
Commercial mortgage pass-through certificates

Class  To         From          Credit enhancement (%)
A-1A   AA (sf)    A (sf)/Watch Pos       34.31
A-4    AA (sf)    A (sf)/Watch Pos       34.31
A-4B   AA  (sf)   A (sf)/Watch Pos       34.31
A-4FL  AA  (sf)   A (sf)/Watch Pos       34.31
A-M    BBB-(sf)   BB+(sf)/Watch Pos      21.79
A-MB   BBB-(sf)   BB+(sf)/Watch Pos      21.79
A-MFL  BBB-(sf)   BB+(sf)/Watch Pos      21.79

Citigroup Commercial Mortgage Trust 2007-C6
Commercial mortgage pass-through certificates

Class     To         From        Credit enhancement (%)
A-1A      A+ (sf)    A+ (sf)                      31.12
A-2       AAA (sf)   AAA (sf)                     31.12
A-3       AAA (sf)   AAA (sf)                     31.12
A-3B      AAA (sf)   AAA (sf)                     31.12
A-4       A+ (sf)    A+ (sf)                      31.12
A-4FL     A+ (sf)    A+ (sf)                      31.12
A-SB      AAA (sf)   AAA (sf)                     31.12
A-M       BB- (sf)   BBB+(sf)/Watch Neg           20.47
A-MFL     BB- (sf)   BBB+(sf)/Watch Neg           20.47
A-J       B-  (sf)   BB- (sf)/Watch Neg           11.54
A-JFL     B-  (sf)   BB- (sf)/Watch Neg           11.54
B         B-  (sf)   B+ (sf)/Watch Neg            11.01
C         CCC (sf)   B (sf)/Watch Neg              9.41
D         CCC (sf)   B- (sf)                       8.61
E         CCC (sf)   B- (sf)                       7.95
F         CCC (sf)   B- (sf)                       7.15
G         CCC-(sf)   CCC+ (sf)                     6.08
H         CCC-(sf)   CCC- (sf)                     4.89
X         AAA (sf)   AAA (sf)                       N/A


* S&P Withdraws Ratings on 13 Classes From 4 CDOs, 3 CBO Deals
--------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 13
classes of notes from four cash flow collateralized loan
obligation (CLO) transactions and three collateralized bond
obligation (CBO) transactions.

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

Standard & Poor's notes that GIA Investment Grade CDO 2001 Ltd.
redeemed its classes in full after providing notice to us that the
issuer directed an optional redemption.

            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 WITHDRAWN

Berkeley Street CDO (Cayman) Ltd.
                            Rating
Class               To                  From
A-2                 NR                  AAA (sf)


Callidus Debt Partners CDO Fund I, Ltd.
                            Rating
Class               To                  From
B-2                 NR                  BB- (sf)


Dryden VII-Leveraged Loan CDO 2004
                            Rating
Class               To                  From
A-2L                NR                  AAA (sf)


GIA Investment Grade CDO 2001 Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)
A-2                 NR                  BBB+ (sf)
B                   NR                  CCC+ (sf)


Golub Capital Loan Trust 2005-1
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)
A-2                 NR                  AAA (sf)


Hewett's Island CLO II, Ltd.
                             Rating
Class               To                  From
B-1A                NR                  AAA (sf)
B-1B                NR                  AAA (sf)


LCM I Limited Partnership
                             Rating
Class               To                  From
C                   NR                  AAA (sf)
D-1                 NR                  B (sf)
D-2                 NR                  B (sf)

NR-Not rated.


* S&P Raises Ratings on 10 Classes From 3 CMBS Transactions
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 10
classes from three commercial mortgage-backed securities (CMBS)
transactions, and removed them from CreditWatch with positive
implications. "Concurrently, we lowered our ratings on 12 classes
from three CMBS transactions and removed six of them from
CreditWatch with negative implications. The CreditWatch
resolutions are related to CreditWatch placements that we
initiated on Sept. 5, 2012," S&P said.

"The upgrades reflect Standard & Poor's expected available credit
enhancement for the affected tranches, which we believe is greater
than our most recent estimate of necessary credit enhancement for
the most recent rating levels. The upgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions," S&P said.

"The downgrades reflect our expected available credit enhancement
for the affected tranches, which we believe is less than our most
recent estimate of necessary credit enhancement for the most
recent rating levels. The downgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions," S&P said.

"The rating actions follow a detailed review of the performance of
the collateral supporting the relevant securities and transaction
structures. This review was similar to the review we conducted
before placing 744 U.S. and Canadian CMBS ratings on CreditWatch
following the release of our updated ratings criteria for these
transactions, but was more detailed with respect to collateral and
transaction performance. For more information on the analytic
process we used for those CreditWatch placements, refer to 'The
Application Of Standard & Poor's Revised U.S. And Canadian CMBS
Criteria For The Sept. 5, 2012, CreditWatch Actions,' published
Sept. 5, 2012," 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 17-g7 Disclosure Reports
included in this credit rating report are available at:

           http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS AND CREDITWATCH ACTIONS

Banc of America Commercial Mortgage Trust 2007-3
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-4    A  (sf)    BBB(sf)/Watch Pos                   34.17
A-5    A  (sf)    BBB(sf)/Watch Pos                   34.17
A-1A   A  (sf)    BBB(sf)/Watch Pos                   34.17
A-J    B- (sf)    B+(sf)/Watch Neg                    14.36
B      B- (sf)    B(sf)/Watch Neg                     13.19
C      B-  (sf)   B(sf)/Watch Neg                     11.57
D      B-  (sf)   B(sf)/Watch Neg                     10.69
E     CCC(sf)     B-(sf)                               9.81
F     CCC-(sf)    B-(sf)                               8.64

Credit Suisse Commercial Mortgage Trust 2007-3
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-AB   AAA(sf)    BBB(sf)/Watch Pos                   30.52
A-4    A-(sf)     BBB(sf)/Watch Pos                   30.52
A-1-A1 A-(sf)     BBB(sf)/Watch Pos                   30.52
A-1-A2 A-(sf)     BBB(sf)/Watch Pos                   30.52
A-M    B-(sf)     BB-(sf)/Watch Neg                   17.46

JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC19
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-4    A+(sf)     A-(sf)/Watch Pos                    29.28
A-SB   AAA(sf)    A-(sf)/Watch Pos                    29.28
A-1A   A(sf)      A-(sf)/Watch Pos                    29.28
A-M    BB-(sf)    BB(sf)                              18.20
A-J    CCC-(sf)   B(sf)/Watch Neg                      9.34
B      CCC-(sf)   B-(sf)                               8.51
C      CCC-(sf)   CCC+(sf)                             7.26
D      CCC-(sf)   CCC(sf)                              6.15



                            *********

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
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Each Tuesday edition of the TCR contains a list of companies with
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The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
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                           *********

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, Carmel
Paderog, Meriam Fernandez, 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.

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