TCR_Public/121118.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

            Sunday, November 18, 2012, Vol. 16, No. 321

                            Headlines

ADDISON CDO: Fitch Withdraws 'Dsf' Rating on Three Note Classes
AMERICREDIT AUTOMOBILE: Fitch To Rate Class E Notes 'BBsf'
ANTHRACITE 2005-HY2: Fitch Affirms Junk Rating on 5 Note Classes
APIDOS CLO X: S&P Rates $22.75-Mil. Class E Deferrable Notes 'BB'
ARBOR REALTY 2004-1: Moody's Affirms 'Caa3' Rating on Cl. D Notes

BANC OF AMERICA 2006-3: Fitch Cuts Rating on 3 Certificate Classes
BAYVIEW FINANCIAL: Moody's Lowers Ratings on Two Bonds to 'C'
BB-UBS 2012-TFT: S&P Gives Prelim. 'BB' Rating on Class TE Notes
BEAR STEARNS 1997-02: Moody's Cuts Rating on 2-B-3 Tranche to 'B3'
BEAR STEARNS 2006-PWR14: Fitch Lowers Ratings on 5 Cert. Classes

BIRCH REAL I: Fitch Affirms Junk Rating on Four Note Classes
BLC CAPITAL 2002-A: S&P Puts 'B+' Rating on Class B Notes on Watch
C-BASS 2007-MX1: Moody's Cuts Two Note Class Ratings to 'B3'
C-BASS VIII: Fitch Affirms Junk Rating on Three Note Classes
CARRINGTON MORTGAGE: Moody's Lifts Rating on M-1 Tranche to 'B3'

CEDARWOODS CRE II: Moody's Cuts Ratings on 2 Note Classes to Caa3
CHL MORTGAGE 2004-7: Moody's Ups Rating on Cl. 4-X Tranche to 'B3'
CIFC FUNDING 2012-II: S&P Gives 'B' Rating on Class B-3L Notes
CIT MARINE: Moody's Lowers Rating on Certificates to 'B3'
CITIGROUP 2006-C4: Moody's Cuts Ratings on 2 Note Classes to 'C'

COMM 2012-CCRE4: Fitch Rates $18-Mil. Class F Notes 'Bsf'
COMM 2012-CCRE4: Moody's Assigns 'B2' Rating to Class F Certs.
COMM 2012-CCRE4: S&P Rates $18-Mil. Class F Certificates 'B+'
COPPER RIVER: S&P Raises Rating on Class E Notes to 'B'; Off Watch
CREDIT SUISSE 2006-C1: Fitch Junks Ratings on Nine Cert. Classes

CREDIT SUISSE 2006-C5: Moody's Cuts Ratings on 3 Certs. to 'C'
CSFB 2002-18: Moody's Cuts Rating on One Tranche to 'Caa3'
CSMC 2006-9: Moody's Lowers Ratings on 2 RMBS Classes to 'B3'
CWMBS 2002-1: Moody's Junks Rating on Class B-2 Certificates
DUANE STREET III: Moody's Hikes Rating on Class E Notes to 'Ba2'

E*TRADE RV: Moody's Puts 'B3' Rating on Review for Downgrade
FRANKLIN CLO VI: S&P Raises Class E Note Rating to 'B+'; Off Watch
FRASER SULLIVAN: Moody's Raises Rating on Class D Notes From Ba1
G-STAR 2003: Fitch Affirms Junk Ratings on Five Note Classes
GALAXY XIV: S&P Rates $27.5-Mil. Class E Deferrable Notes 'BB'

GALLATIN CLO IV 2012-1: S&P Rates Class F Def Notes 'B'
GMAC 1999-C3: Moody's Raises Rating on Class J Certs. to 'Ba2'
GOLDMAN SACHS 2012-GCJ9: Fitch Issues Presale Report on Some Certs
GRAMERCY 2006-1: Moody's Affirms 'Caa3' Ratings on 7 Note Classes
GRAMERCY 2007-1: Moody's Cuts Rating on Class A-1 Notes to 'B3'

GREENWICH CAPITAL: Fitch Downgrades Rating on Eight Cert. Classes
GSC INVESTMENT: Moody's Raises Rating on Class D Notes From Ba1
HALCYON STRUCTURED: Moody's Cuts Rating on Class D Notes to 'Ba2'
JP MORGAN 2004-CIBC10: Moody's Cuts Rating on F Certs. to 'Caa2'
ING INVESTMENT III: Moody's Raises Rating on Cl. C Notes From Ba1

ING INVESTMENT V: S&P  Affirms 'BB(sf)' Rating on Class D Notes
LB-UBS 2000-C3: Moody's Raises Rating on Class J Certs. to 'B3'
LB-UBS 2004-C1: Moody's Cuts Rating on Cl. J Securities to 'Caa1'
LB-UBS 2007-C6: Fitch Lowers Rating on 8 Certificate Classes
MAPS CLO I: S&P Raises Rating on Class E Notes From 'BB+'

MESA 2002-3: Moody's Cuts Rating on Class B-1 RMBS to 'Ba3'
ML-CFC 2007-6: Fitch Affirms Junk Ratings on Five Note Classes
MORGAN STANLEY 2000-PRIN: Moody's Affirms Ba3 Rating on X Certs.
MORGAN STANLEY 2007-TOP25: Moody's Cuts Ratings on 2 Certs. to 'C'
MOTEL 6 TRUST: Fitch Rates $20 Million Class E Notes 'BB+sf'

MOTEL 6 TRUST: S&P Rates $20-Mil. Class E Certificates 'BB+'
MORGAN STANLEY 2007-8: S&P Lowers rating on Class A2 Notes to 'B-'
MORGAN STANLEY 2007-IQ16: Fitch Cuts Ratings on 11 Cert. Classes
MSCI 2004-RR2: Fitch Affirms 'CCC' Rating on 4 Note Classes
N-STAR REAL III: Fitch Affirms Junk Rating on Five Note Classes

N-STAR REAL IX: Fitch Affirms Junk Ratings on 10 Note Classes
NOMURA CRE: Fitch Affirms Junk Rating on 16 Note Classes
OCP CLO 2012-2: S&P Rates $20MM Class E Deferrable Notes 'BB+'
PHOENIX CLO I: S&P Raises Rating on Class D Notes to 'B-'
RAIT CRE I: Moody's Affirms 'Caa3' Rating on Five Note Classes

RALI SERIES 2003-QS19: Moody's Cuts Ratings on 2 Tranches to 'B1'
RESI FINANCE: Moody's Cuts Rating on Class B10 Tranche to 'Ba3'
RESIDENTIAL RE 2011: S&P Cuts Rating on Class 5 Notes to 'B+'
SEQUOIA MORTGAGE 2012-6: Fitch to Rate Cl. B-4 Certificate 'BBsf'
SYNCORA GUARANTEE: Moody's Downgrades Ratings on 26 Securities

THORNBURG MORTGAGE: Moody's Cuts Rating on B-1 Tranche to 'Caa3'
VENTURE III: Moody's Hikes Rating on $12.5MM Cl. C Notes to 'Ba1'
WACHOVIA BANK 2006-C29: Moody's Cuts Rating on Cl. F Certs. to 'C'
WACHOVIA BANK 2006-C25: Moody's Cuts Ratings on 2 Certs. to 'C'
WFRBS 2012-C9: Moody's Assigns 'B2(sf)' Rating on Class F Certs

* Moody's Takes Rating Actions on $313-Mil. Prime RMBS Deals
* Moody's Reviews Stand-Alone Housing Bonds for Downgrade
* S&P Withdraws Ratings on 27 Note Classes From 14 CDO Deals
* S&P Withdraws Ratings on 619 Tranches From 116 CDO Transactions
* S&P Takes Various Rating Actions on 55 Classes From 6 CMBS Deals

* S&P Takes Various Rating Actions on 25 Classes From 3 CMBS Deals
* S&P Withdraws Ratings on 5 Note Classes From 2 CDO Deals
* S&P Lowers Ratings on 8 Note Classes to 'D' From 2 CDO Deals
* S&P Lowers Ratings on 26 Classes From 4 US CMBS Transactions
* S&P Cuts Ratings on 587 Classes From 177 US RMBS Transactions


                            *********

ADDISON CDO: Fitch Withdraws 'Dsf' Rating on Three Note Classes
---------------------------------------------------------------
Fitch Ratings has downgraded and withdrawn the ratings of three
classes of notes issued by Addison CDO, Ltd./Corp. as follows:

  -- $532,013 class Va notes to 'Dsf' from 'Csf';
  -- $2,613,140 class Vb notes to 'Dsf' from 'Csf';
  -- $4,200,000 class C combination notes to 'Dsf' from 'Csf'.

The note balances above are as reported in the note valuation
report produced by the trustee in relation to the transaction's
stated maturity distribution date, which occurred on Nov. 8, 2012.

On the transaction's stated maturity date none of the notes
received any distributions.  Instead, senior fees and expenses
were paid and Fitch calculates that approximately $226 thousand of
proceeds were reserved for future distributions.  Additionally,
the portfolio still contains one performing loan with a par
balance of about $421 thousand in addition to an equity position
and a defaulted bond.  In previous reviews Fitch did not expect
the defaulted bond to generate any future recoveries, while the
equity position may have minimal value.

The class Va and Vb notes have defaulted since they did not
receive their full interest and principal by the stated maturity
date.  The class C combination notes were rated to the ultimate
receipt of their initial $20 million principal balance and an
internal rate of return (IRR) on the original investment of 8.26%.
While Fitch calculates that these notes received over $28.6
million in total proceeds throughout the life of the transaction,
Fitch calculates the notes as having achieved an ultimate IRR of
approximately 5.3%, which falls short of the rating requirement.
Since the class C combination notes have not satisfied the IRR
requirement to which they were rated as of the transaction's
stated maturity date, Fitch considers the notes to have defaulted.
Fitch has withdrawn the ratings on each of the notes due to the
defaults of these tranches.

Addison CDO was a cash flow collateralized debt obligation (CDO)
that closed on Oct. 19, 2000 and was managed by Pacific Investment
Management Company LLC (PIMCO).  The transaction reached its
stated maturity on Nov. 8, 2012. The transaction had been
primarily invested in corporate loans and bonds.


AMERICREDIT AUTOMOBILE: Fitch To Rate Class E Notes 'BBsf'
----------------------------------------------------------
Fitch Ratings expects to rate AmeriCredit Automobile Receivables
Trust, series 2012-5.  Fitch's stress and rating sensitivity
analysis are discussed in the presale report titled 'AmeriCredit
Automobile Receivables Trust 2012-5', dated Nov.13, 2012, which is
available on Fitch's Web site.

Fitch expects to assign the following ratings:

  -- $203,400,000 class A-1 notes 'F1+sf';
  -- $315,300,000 class A-2 notes 'AAAsf'; Outlook Stable;
  -- $191,590,000 class A-3 notes 'AAAsf'; Outlook Stable;
  -- $76,517,000 class B notes 'AAsf'; Outlook Stable;
  -- $94,987,000 class C notes 'Asf'; Outlook Stable;
  -- $93,403,000 class D notes 'BBBsf'; Outlook Stable;
  -- $24,803,000 class E notes 'BBsf'; Outlook Stable.

Consistent Credit Enhancement Structure: The cash flow
distribution is a sequential-pay structure, consistent with prior
transactions. Initial hard credit enhancement (CE) is consistent
with 2012-4 and 2012-3, but lower than 2012-2.  The reserve totals
2.00% (non-declining), and initial overcollateralization (OC) is
5.25% (both of the initial pool balance), growing to a target of
14.25% (of the current pool balance, excluding the reserve).

Stronger Portfolio/Securitization Performance: Losses on GM
Financial's portfolio and 2009-2012 AMCAR securitizations have
declined to some of the lowest levels ever seen, supported by the
gradual economic recovery and strong used vehicle values
supporting higher recovery rates.

Stable Corporate Health: Fitch rates GM 'BB+' and GM Financial
'BB' with a Stable Rating Outlook for both.  GM Financial has
recorded positive corporate financial results since 2010, while
the overall health of GM has also improved.

Consistent Origination/Underwriting/Servicing: AmeriCredit
Financial Services Inc. demonstrates adequate abilities as
originator, underwriter, and servicer, as evidenced by historical
portfolio delinquency and loss experience and securitization
performance.  Fitch deems AFSI capable of adequately servicing
this series.

Legal Structure Integrity: The legal structure of the transaction
should provide that a bankruptcy of GM Financial would not impair
the timeliness of payments on the securities.


ANTHRACITE 2005-HY2: Fitch Affirms Junk Rating on 5 Note Classes
----------------------------------------------------------------
Fitch Ratings has downgraded four and affirmed five classes of
Anthracite 2005-HY2 Ltd./Corp as a result of continued negative
credit migration and increased principal losses on the underlying
collateral.

Since Fitch's last rating action in November 2011, approximately
19.8% of the collateral has been downgraded and 6.4% has been
upgraded.  Currently, 85.9% of the portfolio has a Fitch derived
rating below investment grade and 60.1% has a rating in the 'CCC'
category and below, compared to 85% and 62.7%, respectively, at
the last rating action.  Over this period, the class A notes have
received $5 million in pay downs and the collateral has
experienced approximately $31 million in principal losses.

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 notes' breakeven
rates are generally consistent with the ratings assigned below.

For the class B through G notes, Fitch analyzed each 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 B notes have been downgraded to 'CCsf', indicating that
default is probable.  Similarly, the class C notes have been
downgraded and the class D through G notes affirmed at 'Csf',
indicating that default is inevitable.  The class F and G notes
are currently receiving interest paid in kind (PIK) whereby the
principal amount of the notes is written up by the amount of
interest due.

Anthracite 2005-HY2 is backed by 54 tranches from 21 obligors.
The transaction closed in July 2005 and is considered a commercial
mortgage backed securities (CMBS) B-piece resecuritization (also
referred to as a first loss commercial real estate collateralized
debt obligation [CRE CDO]) as it primarily includes junior bonds
of CMBS transactions.  The portfolio is composed of 70.5% CMBS,
16.9% commercial real estate loans (CREL), and 12.6% real estate
investment trust (REIT) assets.
Fitch has downgraded the following classes:

  -- $96,106,804 class A to 'CCCsf' from 'Bsf';
  -- $52,593,000 class B to 'CCsf' from 'CCCsf';
  -- $25,360,000 class C-FL to 'Csf' from 'CCsf';
  -- $7,000,000 class C-FX to 'Csf' from 'CCsf'.

Fitch has affirmed the following classes:

  -- $25,275,000 class D-FL at 'Csf';
  -- $13,500,000 class D-FX at 'Csf';
  -- $9,376,000 class E at 'Csf';
  -- $58,481,483 class F at 'Csf';
  -- $60,277,862 class G at 'Csf'.


APIDOS CLO X: S&P Rates $22.75-Mil. Class E Deferrable Notes 'BB'
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Apidos
CLO X/Apidos CLO X LLC's $415.5 million floating- and fixed-rate
notes.

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

The ratings reflect S&P's view of:

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

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

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

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

-- The collateral manager's experienced management team.

-- S&P's projections regarding the timely interest and ultimate
    principal payments on the rated notes, which it assessed using
    its cash flow analysis and assumptions commensurate with the
    assigned ratings under various interest-rate scenarios,
    including LIBOR ranging from 0.30%-13.84%.

-- 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 collateral management fees;
    collateral manager incentive fees; and subordinated note
    payments into 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/1045.pdf

RATINGS ASSIGNED
Apidos CLO X/Apidos CLO X LLC

Class               Rating          Amount
                                  (mil. $)
A                   AAA (sf)        291.50
B-1                 AA (sf)          20.00
B-2                 AA (sf)          25.50
C (deferrable)      A (sf)           36.00
D (deferrable)      BBB (sf)         22.75
E (deferrable)      BB (sf)          19.75
Subordinated notes  NR               46.50

NR - Not rated.


ARBOR REALTY 2004-1: Moody's Affirms 'Caa3' Rating on Cl. D Notes
-----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of all classes
of Notes issued by Arbor Realty Mortgage Series 2004-1. The
affirmations are due to the key transaction parameters performing
within levels commensurate with the existing ratings levels. The
rating action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO
CLO) transactions.

Moody's rating action is as follows:

Cl. A, Affirmed at A1 (sf); previously on Dec 1, 2010 Downgraded
to A1 (sf)

Cl. B, Affirmed at Ba2 (sf); previously on Dec 1, 2010 Downgraded
to Ba2 (sf)

Cl. C, Affirmed at Caa2 (sf); previously on Dec 1, 2010 Downgraded
to Caa2 (sf)

Cl. D, Affirmed at Caa3 (sf); previously on Dec 1, 2010 Downgraded
to Caa3 (sf)

RATINGS RATIONALE

Arbor Realty Mortgage Securities Series 2004-1 is a currently
static (reinvestment period ended in April 2009) cash transaction
backed by a portfolio of a-notes and whole loans (41.9% of the
pool balance), b-notes (31.3%), mezzanine loans (26.6%), and
commercial mortgage backed securities (CMBS) (0.2%). As of the
October 15, 2012 Trustee report, the aggregate Note balance of the
transaction, including preferred shares, has decreased to $326.3
million from $469.0 million at issuance, with the paydown
currently directed to the Class A Notes. The paydown was directed
to Class C and Class D during the reinvestment period as a result
of a turbo feature that directed excess interest proceeds as
principal to those classes. Since the end of the reinvestment
period, the paydown has been directed in a senior sequential
priority.

There are seven assets with a par balance of $36.2 million (11.4%
of the current pool balance) that are considered defaulted
securities as of the October 15, 2012 Trustee report. While there
have been limited realized losses on the underlying collateral to
date, Moody's does expect moderate to significant losses to occur
on the defaulted securities once they are realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 8,177
compared to 7,402 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Aaa-Aa3 (0.5% compared to 0.0% at last
review), Baa1-Baa3 (0.0% compared to 4.4% at last review), B1-B3
(1.1% compared to 0.0% at last review), and Caa1-C (98.4% compared
to 95.6% at last review).

Moody's modeled a WAL of 2.7 years compared to 2.8 years at last
review.

Moody's modeled a fixed WARR of 21.7% compared to 21.6% at last
review.

Moody's modeled a MAC of 99.9%, the same as that at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on 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
21.7% to 11.7% or up to 31.7% would result in a modeled rating
movement on the rated tranches of 0 to 9 notches downward and 1 to
4 notches upward, respectively.

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

Primary sources of assumption uncertainty are the extent of 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.


BANC OF AMERICA 2006-3: Fitch Cuts Rating on 3 Certificate Classes
------------------------------------------------------------------
Fitch Ratings has downgraded three classes of Banc of America
Commercial Mortgage Inc., series 2006-3 commercial mortgage pass-
through certificates.

The downgrades are due to an increase in Fitch expected losses,
primarily from the specially serviced loans.  Fitch modeled losses
of 11.6% of the remaining pool; expected losses of the original
pool are at 16.1%, including losses already incurred to date.
Fitch has designated 22 loans (23.2%) as Fitch Loans of Concern,
including 10 specially serviced loans (10.3 %).

As of the October 2012 distribution date, the pool's aggregate
principal balance has reduced by 18.1% to $1.61 billion from $1.96
billion at issuance.  Interest shortfalls are affecting classes B
through P with cumulative unpaid interest totaling $19.8 million.

The largest contributor to Fitch modeled losses (5%) is a 377,000
square foot (sf) class A single-tenant office building located in
Parsippany, NJ.  Cendant, the single tenant at the property, has
signed a lease at another property and will be vacating the entire
building upon its October 2013 lease expiration date.  In November
2011, the Borrower requested a transition of the asset and
transfer of the deed to the Lender.  The Deed-in-Lieu was executed
in July 2012 and the property has since become a real estate owned
(REO) asset.

The second largest contributor to Fitch modeled losses (6.3%) is
secured by 573,370 sf of a 796,162-sf regional mall located in
Sioux City, IA.  The mall is shadow anchored by Sears and JC
Penney as neither of which are part of the collateral.  Second
quarter 2012 (2Q'12) occupancy dropped to 85% from 93% at YE2012
due to tenants vacating upon lease expirations.  The servicer
reported 2Q'12 debt service coverage ratio (DSCR) was 1.1x,
compared to 1.31x at issuance.

The third largest contributor to Fitch modeled losses (4.1%) is
secured by a 345-room hotel located in Phoenix, AZ, approximately
1.5 miles from the Phoenix International Airport.  The property
faces strong market competition and has been underperforming.
Trailing 12-month (TTM) 1Q'12 DSCR was 0.85x, compared to 0.84x at
YE2011 and 0.80x at YE2010.  DSCR at issuance was 1.44x.

The Rating Outlook on the class A-M remains Negative reflecting
several highly leveraged loans; nine of the top 15 loans have
Fitch loan-to-value () ratios over 90%.  In addition, several of
these loans have upcoming lease rollovers, which remains a
concern.

Fitch has downgraded the following classes:

  -- $196.5 million class A-M to 'Asf' from 'AAsf', Outlook
     Negative;
  -- $152.3 million class A-J to 'CCsf' from 'CCCsf'', RE 50%;
  -- $41.8 million class B to'Csf' from 'CCsf', RE 0%.

Fitch has affirmed the following classes:

  -- $41 million class A-3 at 'AAAsf', Outlook Stable;
  -- $1.01 billion class A-4 at 'AAAsf', Outlook Stable;
  -- $96.6 million class A-1A at 'AAAsf', Outlook Stable;
  -- $19.7 million class C at 'Csf', RE 0%;
  -- $31.9 million class D at 'Csf', RE 0%;
  -- $17.2 million class E at 'Csf', RE 0%;
  -- $0.8million class F at 'Dsf'; RE 0%.

Classes G, H, J, K, L and M have been reduced to zero due to
realized losses and remain at 'Dsf', RE 0%.  Classes A-1 and A-2
have paid in full.  Fitch does not rate classes N, O or P.

Fitch has withdrawn the rating of the interest only class XW at
prior review.


BAYVIEW FINANCIAL: Moody's Lowers Ratings on Two Bonds to 'C'
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of four bonds
issued by Bayview Financial Revolving Asset Trust 2004-B.

Complete rating actions are as follows:

Issuer: Bayview Financial Revolving Asset Trust 2004-B

Cl. A-1, Downgraded to B3 (sf); previously on May 16, 2012 B1 (sf)
Placed Under Review for Possible Downgrade

Cl. A-2, Downgraded to Caa2 (sf); previously on May 16, 2012 B1
(sf) Placed Under Review for Possible Downgrade

Cl. M-1, Downgraded to C (sf); previously on May 16, 2012 Caa2
(sf) Placed Under Review for Possible Downgrade

Cl. M-2, Downgraded to C (sf); previously on May 16, 2012 Ca (sf)
Placed Under Review for Possible Downgrade

Ratings Rationale

The actions primarily reflect the correction of an error in
previous rating reviews wherein losses were incorrectly allocated
to Classes A-1 and A-2 on a pro-rata basis instead of allocating
losses to Class A-2 before Class A-1. An incorrect weighted
average portfolio rating of the underlying bonds was also used to
determine the ratings on the resecuritization bonds. In addition,
the rating actions reflect the recent performance of the pools of
mortgages backing the underlying bonds and the updated loss
expectations on the resecuritization bonds.

The principal methodology used in this rating was "Moody's
Approach to Rating US Resecuritized Residential Mortgage-Backed
Securities" published in February 2011.

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 9.0% in September 2011 to 7.8% in September 2012.
Moody's expects unemployment rate to stay between 7.5% to 8.5% in
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.

As part of the sensitivity analysis, Moody's stressed the updated
losses on the underlying bonds by an additional 10% and found that
the implied ratings of the resecuritization bonds do not change.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF306380


BB-UBS 2012-TFT: S&P Gives Prelim. 'BB' Rating on Class TE Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to BB-UBS Trust 2012-TFT's $567.8 million commercial
mortgage pass-through certificates series 2012-TFT.

The note issuance is a commercial mortgage-backed securities
transaction backed by three commercial mortgage loans totaling
$567.8 million secured by three regional shopping malls: Tucson
Mall, Fashion Place, and Town East Mall.

The preliminary ratings are based on information as of Nov. 9,
2012. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

"The preliminary ratings reflect our view of the collateral's
historical and projected performance, the sponsor and manager's
experience, the trustee-provided liquidity, the loans' terms, and
the transaction's structure," 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 Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at:

      http://standardandpoorsdisclosure-17g7.com/1099.pdf

PRELIMINARY RATINGS ASSIGNED
BB-UBS Trust 2012-TFT


Class       Rating               Amount
                               (mil. $)
A           AAA (sf)        363,413,000
X-A         AAA (sf)     363,413,000(i)
X-B         AA (sf)       62,112,000(i)
B           AA (sf)          62,112,000
C           A (sf)           59,654,000
D           BBB+ (sf)        36,387,000
E           BBB- (sf)        31,346,000
TE(ii)      BB               14,840,000
R           NR                      N/A

(i) Notional balance.
(ii) Loan-specific class.
NR - Not rated.
N/A - Not applicable.


BEAR STEARNS 1997-02: Moody's Cuts Rating on 2-B-3 Tranche to 'B3'
------------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of four
tranches from Bear Stearns Structured Sec Inc 1997-02, backed by
Scratch and Dent loans.

Ratings Rationale

The actions are a result of the recent performance review of
Scratch and Dent pools 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 "US RMBS Surveillance Methodology for Scratch
and Dent" published in May 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.

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.

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

The primary sources of assumption uncertainty are our central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 9.0% in September 2011 to 7.8% in September 2012.
Moody's expects unemployment rate to stay between 7.5% to 8.5% in
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: Bear Stearns Structured Sec Inc. 1997-02

1-B-1, Downgraded to A2 (sf); previously on Nov 6, 1997 Assigned
Aa1 (sf)

1-B-2, Downgraded to B3 (sf); previously on Sep 10, 2010
Downgraded to Ba3 (sf)

2-B-2, Downgraded to A1 (sf); previously on Jul 7, 2004 Upgraded
to Aa1 (sf)

2-B-3, Downgraded to B3 (sf); previously on Sep 10, 2010
Downgraded to B1 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF306996

A list of updated estimated pool losses and sensitivity analysis
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_SF247004


BEAR STEARNS 2006-PWR14: Fitch Lowers Ratings on 5 Cert. Classes
----------------------------------------------------------------
Fitch Ratings has downgraded five classes of Bear Stearns
Commercial Mortgage Securities Trust, series 2006-PWR14 commercial
mortgage pass-through certificates.

The downgrades are primarily the result of higher certainty of
losses from the specially serviced loans.  Fitch modeled losses of
8.4% of the remaining pool and expected losses based on the
original pool balance are 10.3%, of which 3.02% are losses
realized to date.  Fitch designated 72 loans (33.7%) as Fitch
Loans of Concern, which include 12 specially serviced loans
(6.6%).

As of the October 2012 distribution date, the pools' aggregate
principal balance has been reduced by 15.1% (including 3.02% of
realized losses) to $1.995 billion from $2.096 billion at
issuance.  Interest shortfalls are affecting classes O through G.
There are no loans in the pool that are currently defeased.

The largest contributor to Fitch's modeled losses is the specially
serviced loan, Philips at Sunrise Shopping Center (3.1% of the
pool).  The loan is collateralized by a 414,082 square foot (sf)
retail center located in Massapequa, NY.  The current occupancy
has increased to 97% due to some recent leasing activity in 2012.
The loan has returned to the special servicer for a second time
due to a dispute between the lender and sponsor in regard to loan
covenants.

The second largest contributor to Fitch's modeled losses is the
specially serviced Drury Inn Portfolio (1.6% of the pool) with
three properties located in the San Antonio, TX and Albuquerque,
NM.  The hotels have Drury Inn and Best Western Flags.  As of
year-end 2011, the portfolio reported occupancy was 51.2%, which
is down from 81.1% at issuance.  The last reported DSCR by the
servicer was 0.51x as of March 2012.

The third largest contributor to Fitch's modeled losses is the
Ramada Plaza - La Guardia Airport (1%), a 214 room full service
hotel located 2.5 miles from the airport.  The loan was
transferred to the special servicer in January 2010 due to payment
default.  The loan was modified and returned to the master
servicer as corrected in April 2012.  Performance remains below
issuance with the last reported DSCR by the servicer at .69x as of
December 2011.

Fitch downgrades the following classes as indicated:

  -- $46.3 million class B to 'CCCsf' from 'Bsf'; RE 80%;
  -- $37 million class D to 'CCsf' from 'CCCsf; RE 0%;
  -- $21.5 million class E to 'Csf' from 'CCsf'; RE 0%;
  -- $24.6 million class F to 'Csf' from 'CCsf'; RE 0%;
  -- $24.6 million class G to 'Csf' from 'CCsf'; RE 0%.

Fitch affirms the following classes and revises Recovery Estimates
as indicated:

  -- $50.2 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $68.9 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $125 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $950.9 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $258.5 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $246.8 million class A-M at 'AAAsf'; Outlook Stable;
  -- $222.1 million class A-J at 'BBsf'; Outlook Negative from
     Stable;
  -- $24.7 million class C at 'CCCsf'; RE 0% from RE 80%.

Fitch does not rate class P. Class A-1 has paid in full.  Class O,
N, M, L, K, J, and H remains at 'D' with a Recovery Estimate of 0%
due to losses incurred.

Fitch has previously withdrawn the ratings on the interest-only
classes X-1, X-2 and X-W.


BIRCH REAL I: Fitch Affirms Junk Rating on Four Note Classes
------------------------------------------------------------
Fitch Ratings has affirmed four classes of notes issued by Birch
Real Estate CDO I, Ltd. (Birch I) as follows:

  -- $11,247,724 class A-2L at 'CCCsf';
  -- $2,163,024 class A-2 at 'CCCsf';
  -- $10,000,000 class A-3L at 'CCsf';
  -- $11,040,000 class B-1 at 'Csf'.

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

Although cash flow model indicates that the notes can pass at
higher rating levels, the results show a high level of variability
between the scenarios, thus the affirmation reflects the
relatively stable performance of the transaction since the last
review.

Since the last review in November 2011, the credit quality of the
underlying portfolio has deteriorated with 21% of the portfolio
downgraded a weighted average of 8.2 notches and approximately 16%
of the portfolio upgraded a weighted average of 4.0 notches.
Currently, 71.3% of the portfolio has a Fitch derived rating below
investment grade with 64.3% rated in the 'CCC' category or below,
compared to 58.2% and 52.9%, respectively, at the last review.

The affirmation of the class A-2L and A-2 (collectively, class A-
2) notes is due to the deleveraging of the transaction offsetting
the portfolio deterioration since Fitch's last review.  The class
A-2 notes have amortized $8.9 million, or 37.8% of its previous
outstanding balance through principal proceeds and excess spread
as a result of a failing class A overcollateralization test.
Although cash flow modeling results indicate that the notes can
pass at higher rating levels, the passing ratings display a high
level of variability between scenarios.  Furthermore, the
portfolio will become more concentrated as the portfolio continues
to amortize, with 33 assets and 21 issuers currently outstanding.
The potential for further negative credit migration remains a
concern as 19% of the portfolio is on Rating Watch Negative.

Breakeven levels for the class A-3L notes also indicate passing
ratings at higher rating stresses than their current ratings,
however, this class will be more sensitive to adverse selection
and potential negative migration in the portfolio.  These notes
received timely interest on the latest distribution date, and with
the recent expiration of the transaction's interest rate swap in
October 2012, are expected to continue receiving timely interest.

The class B-1L notes continue to defer interest due to the failing
class A coverage tests.  Currently, the class has an interest
shortfall amount of $4.2 million, and the notes are not expected
to receive accrued interest and its full principal at or prior to
maturity.  As a result, the ratings of the class B-1L notes are
affirmed at 'Csf'.

Birch I is a static, structured finance collateralized debt
obligation that closed on Dec. 20, 2002.  The initial portfolio
was selected by Bear, Stearns & Co., Inc. As of the latest trustee
report from November 2012, the portfolio is comprised of
residential mortgage-backed securities (77.3%), commercial
mortgage-backed securities (18.5%) and commercial asset-backed
securities (4.2%) from 1997 and 2002 vintages.


BLC CAPITAL 2002-A: S&P Puts 'B+' Rating on Class B Notes on Watch
------------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on the class
A and B notes from BLC Capital Corp.'s 2002-A on CreditWatch with
negative implications.

BLC Capital Corp. 2002-A is an asset-backed securities transaction
collateralized primarily by a pool of small business development
loans.

"The credit performance of the transaction has deteriorated since
our last rating actions in June 2011, as evidenced by an increase
in the cumulative net losses the portfolio has realized," S&P
said.

"According to the Sept. 30, 2012, servicer report, the portfolio
only has eight loans remaining. We note that about 5.6% of the
pool consists of loans to small business in areas affected by
Hurricane Sandy," S&P said.

"We expect to resolve the CreditWatch placements within 90 days
after we complete a comprehensive analysis and committee review,"
S&P said.

RATINGS PLACED ON CREDITWATCH NEGATIVE

BLC Capital Corp.
2002-A
                               Rating
Class               To                      From
A                   BB+ (sf)/Watch Neg      BB+ (sf)
B                   B+ (sf)/Watch Neg       B+ (sf)


C-BASS 2007-MX1: Moody's Cuts Two Note Class Ratings to 'B3'
------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of two
tranches from C-BASS Mortgage Loan Asset-Backed Certificates,
Series 2007-MX1, backed by Scratch and Dent loans.

Ratings Rationale

The actions are a result of the recent performance review of
Scratch and Dent pools 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 "US RMBS Surveillance Methodology for Scratch
and Dent" published in May 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.

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.

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

The primary sources of assumption uncertainty are our central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 9.0% in September 2011 to 7.8% in September 2012.
Moody's expects unemployment rate to stay between 7.5% to 8.5% in
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: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2007-MX1

  Cl. A-3, Downgraded to B3 (sf); previously on Apr 19, 2012 B1
  (sf) Placed Under Review for Possible Downgrade

  Cl. A-4, Downgraded to B3 (sf); previously on Apr 19, 2012 B1
  (sf) Placed Under Review for Possible Downgrade

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF306997

A list of updated estimated pool losses and sensitivity analysis
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_SF247004


C-BASS VIII: Fitch Affirms Junk Rating on Three Note Classes
------------------------------------------------------------
Fitch Ratings has upgraded and revised Rating Outlooks on two
classes and affirmed three classes of notes issued by C-BASS CBO
VIII, Ltd./Corp. (C-BASS VIII) as follows:

  -- $19,797,513 class A-2 notes upgraded to 'Asf' from 'BBBsf,
     Outlook to Stable from Positive;
  -- $18,350,000 class B notes upgraded to 'BBsf' from 'Bsf',
     Outlook to Stable from Negative;
  -- $20,700,000 class C notes affirmed at 'Csf';
  -- $5,874,338 class D-1 notes affirmed at 'Csf';
  -- $2,423,164 class D-2 notes affirmed at 'Csf'.

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

Since Fitch's last rating action in November 2011, the credit
quality of the collateral has deteriorated with approximately
31.4% downgraded a weighted average 2.7 notches and 0.2% upgraded
3 notches.  Currently, 61.9% of the portfolio has a Fitch-derived
rating below investment grade and 42.1% is rated in the 'CCC'
category or lower, compared to 54.7% and 43.6%, respectively, at
last rating action.

The class A-1 notes paid in full on the May 2, 2012 distribution
date and the class A-2 notes began to amortize, receiving $6.8
million, or 25.6% of their original balance, over the past three
payment dates.  The class A-2 and class B notes are upgraded due
to continued amortization increasing credit enhancement for both
classes.  Most cash flow model scenarios indicate the classes can
pass higher rating stresses; however, the classes are upgraded
only one category because the portfolio is becoming more
concentrated and continues to experience negative migration,
making both classes susceptible to adverse selection as the
portfolio continues to pay down.

The Outlook is revised to Stable for the class A-2 and class B
notes because there is cushion in the modeling results available
to mitigate further deterioration in the portfolio.

Breakeven levels for the class C and class D notes are below SF
PCM's 'CCC' default level, the lowest level of defaults projected
by SF PCM.  The class C notes are receiving partial interest
payments each period and continue to accumulate deferred interest.
The class D notes are expected to receive little if any future
distributions due to insufficient interest collections and failing
class C coverage tests. Both classes of notes are affirmed at
'Csf'.

C-BASS VIII is a cash structured finance (SF) collateralized debt
obligation (CDO) that closed on Nov. 10, 2003 and is monitored by
NIC Management LLC.  As of the Oct. 26, 2012 trustee report, the
portfolio is composed of residential mortgage-backed securities
(59.3%), consumer and commercial asset-backed securities (27.2%),
and SF CDOs (13.5%).


CARRINGTON MORTGAGE: Moody's Lifts Rating on M-1 Tranche to 'B3'
----------------------------------------------------------------
Moody's Investors Service has upgraded the rating of one tranche
from Carrington Mortgage Loan Trust, Series 2004-NC1, backed by
Subprime loans.

Ratings 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 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. We capture
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 above mentioned 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).

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 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 9.0% in September 2011 to 7.8% in September 2012.
Moody's expects unemployment rate to stay between 7.5% to 8.5% in
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: Carrington Mortgage Loan Trust, Series 2004-NC1

Cl. M-1, Upgraded to B3 (sf); previously on Mar 13, 2011
Downgraded to Caa2 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF306576

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


CEDARWOODS CRE II: Moody's Cuts Ratings on 2 Note Classes to Caa3
-----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of four
classes and affirmed the ratings of four classes of Notes issued
by Cedarwoods CRE CDO II, Ltd. The downgrades are due to credit
deterioration in the underlying collateral, deterioration of
certain par value tests, and an ongoing dispute between the
controlling classholders and the Collateral Manager and Class A-2
noteholders concerning a potential event of default and subsequent
liquidation of the Trust. The affirmations are due to key
transaction parameters performing within levels commensurate with
the existing ratings levels. The rating action is the result of
Moody's on-going surveillance of commercial real estate
collateralized debt obligation (CRE CDO CLO) transactions.

Moody's rating action is as follows:

Cl. A-1, Downgraded to B2 (sf); previously on Jan 18, 2012
Downgraded to B1 (sf)

Cl. A-2, Downgraded to Caa2 (sf); previously on Jan 18, 2012
Downgraded to Caa1 (sf)

Cl. A-3, Downgraded to Caa3 (sf); previously on Jan 18, 2012
Downgraded to Caa2 (sf)

Cl. B, Downgraded to Caa3 (sf); previously on Jan 18, 2012
Confirmed at Caa2 (sf)

Cl. C, Affirmed at Caa3 (sf); previously on Jan 18, 2012 Confirmed
at Caa3 (sf)

Cl. D, Affirmed at Caa3 (sf); previously on Jan 18, 2012 Confirmed
at Caa3 (sf)

Cl. E, Affirmed at Caa3 (sf); previously on Jan 18, 2012 Confirmed
at Caa3 (sf)

Cl. F, Affirmed at Caa3 (sf); previously on Jan 18, 2012 Confirmed
at Caa3 (sf)

Ratings Rationale

Cedarwoods CRE CDO II, Ltd. is a static (the reinvestment ended in
February, 2012) cashtransaction backed by a portfolio of
commercial mortgage backed securities (CMBS) (77.1% of the pool
balance), CRE CDOs (19.4%), real estate investment trust (REIT)
debt (2.9%) and rake bonds (0.6%). As of the September 25, 2012
Trustee report, the aggregate Note balance of the transaction,
including preferred shares, has decreased to $582.6 million from
$600 million at issuance, with the paydown directed to the Class
A-1 Notes, as a result of amortization of the collateral and
redirection of interest proceeds as principal proceeds due to the
failing of certain junior par value tests.

There are twenty-eight assets with a par balance of $150.2 million
(21.6% of the current pool balance compared to 7.7% at last
review) that are considered defaulted securities as of the
September 25, 2011 Trustee report. In addition, there are two
assets with a par balance $14.9 million (2.1% of the current pool
balance, compared to 6.8% at last review) that are considered
impaired securities. Moody's expects significant losses to occur
from the defaulted securities and impaired securities once they
are realized.

On September 20, 2011, the Trustee notified the relevant parties
that it had received a First Default Notice from the holder of
100% of the outstanding Controlling Class holder declaring that an
Event of Default (EOD) occured and directing the Trustee to
accelerate and liquidate the transaction. On September 26, 2011,
the Trustee notified the relevant parties that it had received a
response to the First Default Notice from the Collateral Manager.
On October 6, 2011 the Trustee notified the relevant parties that
it had received a Second Default Notice from the 100% of the
controlling class declaring that a second EOD had occurred. On
October 12, 2011, the Trustee notified the relevant parties that
it had received a response to the Second Default Notice from the
Collateral Manager. On December 2, 2011 the trustee notified the
relevant parties that an EOD had occurred and that the deal would
be liquidated. On December 5, 2011 the Trustee notified the
relevant parties that it had commenced the sale of the collateral.
On December 13, 2011 the trustee notified the relevant parties
that it had received a written objection to the EOD from the
Collateral Manager and Class A-2 Noteholder. US Bank filed suit
against the issuer, the collateral manager, the A-1 noteholders
and the A-2 noteholders with the United States District Court,
Southern District of New York regarding the EOD and the related
issues. The outcome of the case is still pending. Moody's will
continue to closely monitor the transaction.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit assessments for non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 5,189 compared to 4,076 at last review.

The distribution of current ratings and credit assessments is as
follows: Aaa-Aa3 (2.4% compared to 2.6% at last review), A1-A3
(6.8% compared to 6.8% at last review), Baa1-Baa3 (12.7% compared
to 19.8% at last review), Ba1-Ba3 (11.4% compared to 11.9% at last
review), B1-B3 (12.0% compared to 14.5% at last review), and Caa1-
C (54.8% compared to 44.3% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 4.1 years compared
to 4.7 years as at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
11.9% compared to 14.2% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 10.7% compared to 11.9% 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. 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 11.9% to 1.9% or up to 21.9% would result in rating
movement on the rated 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.


CHL MORTGAGE 2004-7: Moody's Ups Rating on Cl. 4-X Tranche to 'B3'
------------------------------------------------------------------
Moody's Investors Service has upgraded the rating of Class 4-X
from CHL Mortgage Pass-Through Trust 2004-7, backed by Alt-A
loans.

RATINGS RATIONALE

Class 4-X is an Interest-Only tranche that is linked to the Class
4-A-1 notional balance. According to Moody's published Interest-
Only Securities methodology "Moody's Approach to Rating Structured
Finance Interest-Only Securities," Class 4-X should have the same
rating as underlying tranche Class 4-A-1. On February 22 2012,
Class 4-X was erroneously downgraded to Caa3 despite the B3 rating
on Class 4-A-1. That error has now been corrected, and Class 4-X
also carries a B3 rating.

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.

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 7.9% in October 2012. 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 2004-7

Cl. 4-X, Upgraded to B3 (sf); previously on Feb 22, 2012 Upgraded
to Caa3 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF304657

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


CIFC FUNDING 2012-II: S&P Gives 'B' Rating on Class B-3L Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to CIFC
Funding 2012-II Ltd./CIFC Funding 2012-II LLC 's $676.5 million
fixed- and 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 portfolio manager's experienced management team.

    "Our projections regarding the timely interest and ultimate
    principal payments on the rated notes, which we assessed using
    our cash flow analysis and assumptions commensurate with the
    assigned ratings under various interest rate scenarios,
    including LIBOR ranging from 0.30%-11.36%," S&P said.

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

            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/1095.pdf

RATINGS ASSIGNED
CIFC Funding 2012-II Ltd./CIFC Funding 2012-II LLC

Class                   Rating                  Amount
                                              (mil. $)
A-1L                    AAA (sf)                 464.0
A-2F                    AA (sf)                   27.5
A-2L                    AA (sf)                   40.0
A-3L (deferrable)       A (sf)                    59.5
B-1L (deferrable)       BBB (sf)                  34.0
B-2L (deferrable)       BB- (sf)                  37.0
B-3L (deferrable)       B (sf)                   14.50
Subordinated notes      NR                       71.42

NR - Not rated.


CIT MARINE: Moody's Lowers Rating on Certificates to 'B3'
---------------------------------------------------------
Moody's Investors Service has downgraded one tranche and placed on
review for downgrade another tranche from two transactions backed
by recreational vehicle (RV) and marine installment sales
contracts serviced by Vericrest Financial, Inc.

Vericrest Financial, Inc., formerly known as CIT Group/Sales
Financing, Inc., was acquired by Lone Star Funds in 2009.

Complete rating actions as follow:

Issuer: CIT Marine Trust 1999-A

Certificates, Downgraded to B3 (sf); previously on Nov 3, 2011
Downgraded to B1 (sf)

Issuer: SSB RV Trust 2001-1

Cl. C, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 1, 2009 Downgraded to Baa1 (sf)

Ratings Rationale

For the CIT Marine Trust 1999-A transaction, the action is the
result of the deterioration in the security's level of credit
enhancement relative to its remaining loss expectation. Defaults
over the last six months caused erosion of the reserve account
which is now 12% of the current pool balance, lower than the
pool's expected remaining loss.

For the SSB RV Trust 2001-1 transaction, the review is the result
of updated pool cumulative net loss expectations which are higher
than prior assumptions. Losses on the underlying pool have
depleted the reserve account and the transaction is currently
under-collateralized by approximately $15 million, which is equal
to almost 66% of the Class D, which provides protection to the
Class C.

Unlike other vehicle-backed ABS, the impact of the weakened
economy on a RV and marine transaction has been more severe and
long lasting due to the non-essential nature of the underlying
collateral, and the longer financing terms, which on average range
between 170 and 185 months at closing. As a result, the
transaction has experienced more than one economic downturn during
its life.

Below are key performance metrics and credit assumptions for each
affected transaction. Credit assumptions include Moody's expected
lifetime CNL expectation which is expressed as a percentage of the
original pool balance; and Moody's lifetime remaining CNL
expectation which is expressed as a percentage of the current pool
balance. Performance metrics include pool factor; total credit
enhancement (expressed as a percentage of the outstanding
collateral pool balance) which typically consists of
subordination, overcollateralization, and a reserve fund; and per
annum excess spread.

Issuer: CIT Marine Trust 1999-A

Lifetime CNL expectation -- 6.80%, prior expectation (November
2011) was 6.80%

Lifetime Remaining CNL expectation -- 17.97%

Pool factor -- 0.93%

Total credit enhancement (excluding excess spread): Class
Certificates -- 12.26%

Excess spread per annum -- Approximately 1.1%

Issuer: SSB RV Trust 2001-1

Lifetime CNL expected range -- 9.50% - 9.75%, prior expectation
(November 2011) was 9.50%

Pool factor -- 3.18%

Total credit enhancement (excluding excess spread): Class C --
37.64%

Excess spread per annum -- Approximately 0.8%

Ratings on the affected securities may be downgraded if the
lifetime CNLs are higher by 5%.

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

Primary sources of assumption uncertainty are the current
macroeconomic environment, in which unemployment continues to
continues to remain at elevated levels, and weakness in the RV and
marine market. Overall, Moody's expects overall a sluggish
recovery in most of the world's largest economies, returning to
trend growth rate with elevated fiscal deficits and persistent
unemployment levels.

The principal methodology used in these ratings was " Moody's
Approach to Rating U.S. Auto Loan Backed Securities" published in
May 2011.


CITIGROUP 2006-C4: Moody's Cuts Ratings on 2 Note Classes to 'C'
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of eight classes
and affirmed the ratings of nine classes of Citigroup Commercial
Mortgage Trust Commercial Mortgage Pass-Through Certificates,
Series 2006-C4 as follows:

Cl. A-2, Affirmed at Aaa (sf); previously on Jun 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-SB, Affirmed at Aaa (sf); previously on Jun 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jun 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Jun 30, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aa1 (sf); previously on Dec 17, 2010
Downgraded to Aa1 (sf)

Cl. A-J, Downgraded to Baa3 (sf); previously on Dec 17, 2010
Downgraded to Baa1 (sf)

Cl. B, Downgraded to Ba2 (sf); previously on Dec 17, 2010
Downgraded to Baa3 (sf)

Cl. C, Downgraded to B1 (sf); previously on Dec 17, 2010
Downgraded to Ba2 (sf)

Cl. D, Downgraded to Caa1 (sf); previously on Dec 17, 2010
Downgraded to B2 (sf)

Cl. E, Downgraded to Caa2 (sf); previously on Dec 17, 2010
Downgraded to B3 (sf)

Cl. F, Downgraded to Ca (sf); previously on Dec 17, 2010
Downgraded to Caa2 (sf)

Cl. G, Downgraded to C (sf); previously on Dec 17, 2010 Downgraded
to Caa3 (sf)

Cl. H, Downgraded to C (sf); previously on Dec 17, 2010 Downgraded
to Ca (sf)

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

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

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

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

RATINGS RATIONALE

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans.

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

Moody's rating action reflects a base expected loss of 7.6% of the
current balance. At last review, Moody's base expected loss was
7.1%. Moody's current base expected loss plus cumulative realized
losses is 9.2% of the original balance as compared to 8.3% at last
review. Moody's provides a current list of base losses for conduit
and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating Structured Finance Interest-
Only Securities" published in February 2012.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's review also incorporated the CMBS IO calculator ver1.1,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit assessments; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type as defined in the
published methodology. The calculator then returns a calculated IO
rating based on both a target and mid-point. For example, a target
rating basis for a Baa3 (sf) rating is a 610 rating factor. The
midpoint rating basis for a Baa3 (sf) rating is 775 (i.e. the
simple average of a Baa3 (sf) rating factor of 610 and a Ba1 (sf)
rating factor of 940). If the calculated IO rating factor is 700,
the CMBS IO calculator ver1.1 would provide both a Baa3 (sf) and
Ba1 (sf) IO indication for consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 45, the same as at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated November 10, 2011.

DEAL PERFORMANCE

As of the October 17, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 10% to $2.04
billion from $2.26 billion at securitization. The Certificates are
collateralized by 156 mortgage loans ranging in size from less
than 1% to 9% of the pool, with the top ten loans representing 35%
of the pool. The pool does not contain any defeased loans or loans
with investment grade credit assessments.

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

Seven loans have been liquidated from the pool since
securitization, resulting in an aggregate $24.0 million loss (67%
loss severity on average). Due to principal reductions related to
modifications and additional trust expenses the current cumulative
bond loss is $51.7 million. At last review the pool had
experienced an aggregate $37.6 million cumulative bond loss.
Currently 11 loans, representing 9% of the pool, are in special
servicing. The master servicer has recognized appraisal reductions
totaling $68.2 million for the specially serviced loans. Moody's
has estimated a $80.3 loss (42% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for 19 poorly
performing loans and three B notes representing 8% of the pool.
Moody's has estimated a $41.2 million loss (26% expected loss
based on a 53% probability default) from these troubled loans.

Moody's was provided with full year 2011 and partial year 2012
operating results for 93% and 31%, respectively, of the performing
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV is 96% compared to 100% at Moody's prior
review. Moody's net cash flow reflects a weighted average haircut
of 10% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.2%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.37X and 1.08X,
respectively, compared 1.33X and 1.03X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three performing loans represent 20% of the pool balance.
The largest loan is the ShopKo Portfolio Loan ($184.0 million --
9.1% of the pool). The loan is secured by 112 cross-collateralized
and cross-defaulted ShopKo retail stores, located in 12 states,
with a total of 10,974,960 square feet (SF). This loan represents
a pari-passu interest in a $502.0 million first mortgage loan.
Performance has been stable. Moody's LTV and stressed DSCR are 75%
and 1.32X, respectively, compared to 80% and 1.24X at last review.

The second largest loan is Olen Pointe Brea Office Park Loan
($124.6 million -- 6.2% of the pool), which is secured by a
637,000 SF office building located in Brea, California. The
property was 94% leased as of June 2012, compared to 93% at last
review. Performance has been stable. Moody's LTV and stressed DSCR
are 109% and 0.87X, respectively, compared to 108% and 0.88X at
last review.

The third largest loan is the Reston Executive Center Loan ($93.0
million -- 4.6% of the pool), which is secured by a 486,000 SF
office complex located in Reston, Virginia. The property was 76%
leased as of September 2012 compared to 71% at last review. The
loan matures in four months. The borrower has already requested
the pay off quote. The loan sponsor is Vornado Realty L.P. Moody's
assumes the full payoff at maturity.


COMM 2012-CCRE4: Fitch Rates $18-Mil. Class F Notes 'Bsf'
---------------------------------------------------------
Fitch Ratings has assigned the following ratings and outlooks to
Deutsche Bank Securities, Inc.'s COMM 2012-CCRE4 commercial
mortgage pass-through certificates:

  -- $59,118,000 class A-1 'AAAsf'; Outlook Stable;
  -- $148,657,000 class A-2 'AAAsf'; Outlook Stable;
  -- $70,571,000 class A-SB 'AAAsf'; Outlook Stable;
  -- $499,354,000 class A-3 'AAAsf'; Outlook Stable;
  -- $888,800,000b class X-A 'AAAsf'; Outlook Stable;
  -- $104,156,000ab class X-B 'A-sf'; Outlook Stable;
  -- $111,100,000 class A-M 'AAAsf'; Outlook Stable;
  -- $65,271,000a class B 'AA-sf'; Outlook Stable;
  -- $38,885,000a class C 'A-sf'; Outlook Stable;
  -- $45,829,000a class D 'BBB-sf'; Outlook Stable;
  -- $19,442,000a class E 'BBsf'; Outlook Stable;
  -- $18,054,000a class F 'Bsf'; Outlook Stable.

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

Fitch does not rate the $34,719,345 class G.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 48 loans secured by 152 commercial
properties having an aggregate principal balance of approximately
$1.11 billion as of the cutoff date.  The loans were contributed
to the trust by German American Capital Corporation, Cantor
Commercial Real Estate, and KeyBank National Association.


COMM 2012-CCRE4: Moody's Assigns 'B2' Rating to Class F Certs.
--------------------------------------------------------------
Moody's Investors Service has assigned ratings to twelve classes
of CMBS securities issued by COMM 2012-CCRE4, Commercial Mortgage
Pass-Through Certificates, Series 2012-CCRE4.

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-SB, Definitive Rating Assigned Aaa (sf)

Cl. X-A, Definitive Rating Assigned Aaa (sf)

Cl. A-M, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa3 (sf)

Cl. X-B, Definitive Rating Assigned A2 (sf)

Cl. C, Definitive Rating Assigned A3 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba2 (sf)

Cl. F, Definitive Rating Assigned B2 (sf)

Ratings Rationale

The Certificates are collateralized by 48 fixed rate loans secured
by 152 properties. The ratings are based on the collateral and the
structure of the transaction.

Moody's CMBS ratings methodology combines both commercial real
estate and structured finance analysis. Based on commercial real
estate analysis, Moody's determines the credit quality of each
mortgage loan and calculates an expected loss on a loan specific
basis. Under structured finance, the credit enhancement for each
certificate typically depends on the expected frequency, severity,
and timing of future losses. Moody's also considers a range of
qualitative issues as well as the transaction's structural and
legal aspects.

The credit risk of loans is determined primarily by two factors:
1) Moody's assessment of the probability of default, which is
largely driven by each loan's DSCR; and 2) Moody's assessment of
the severity of loss upon a default, which is largely driven by
each loan's LTV ratio.

The Moody's Actual DSCR of 1.85X is greater than the 2007
conduit/fusion transaction average of 1.31X. The Moody's Stressed
DSCR of 1.13X is greater than the 2007 conduit/fusion transaction
average of 0.92X.

Moody's Trust LTV ratio of 94.4% is lower than the 2007
conduit/fusion transaction average of 110.6%. Moody's Total LTV
ratio (inclusive of subordinated debt and debt-like preferred
equity) of 98.0% is also considered when analyzing various stress
scenarios for the rated debt.

Moody's also considers both loan level diversity and property
level diversity when selecting a ratings approach. With respect to
loan level diversity, the pool's loan level (includes cross
collateralized and cross defaulted loans) Herfindahl Index is
20.7. The transaction's loan level diversity is in line with
Herfindahl scores found in most multi-borrower transactions issued
since 2009. With respect to property level diversity, the pool's
property level Herfindahl Index is 24.0. The transaction's
property diversity profile is in line with the indices calculated
in most multi-borrower transactions issued since 2009.

This deal has a super-senior Aaa class with 30% credit
enhancement. Although the additional enhancement offered to the
senior most certificate holders provides additional protection
against pool loss, the super-senior structure is credit negative
for the certificate that supports the super-senior class. If the
support certificate were to take a loss, the loss would have the
potential to be quite large on a percentage basis. Thin tranches
need more subordination to reduce the probability of default in
recognition that their loss-given default is higher. This
adjustment helps keep expected loss in balance and consistent
across deals. The transaction was structured with additional
subordination at class A-M to mitigate the potential increased
severity to class A-M.

Moody's also grades properties on a scale of 1 to 5 (best to
worst) and considers those grades when assessing the likelihood of
debt payment. The factors considered include property age, quality
of construction, location, market, and tenancy. The pool's
weighted average property quality grade is 2.3, which is higher
than the indices calculated in most multi-borrower transactions
since 2009.

The methodologies used in this rating were "Moody's Approach to
Rating U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating Structured Finance Interest-
Only Securities" published in February 2012.

Moody's analysis employs the excel-based CMBS Conduit Model v2.61
which derives credit enhancement levels based on an aggregation of
adjusted loan level proceeds derived from Moody's loan level DSCR
and LTV ratios. Major adjustments to determining proceeds include
loan structure, property type, sponsorship, and diversity. Moody's
analysis also uses the CMBS IO calculator ver_1.1, which
references the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology.

The V Score for this transaction is assessed as Low/Medium, the
same as the V score assigned to the U.S. Conduit and CMBS sector.
This reflects typical volatility with respect to the critical
assumptions used in the rating process as well as an average
disclosure of securitization collateral and ongoing performance.

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

Moody's Parameter Sensitivities: If Moody's value of the
collateral used in determining the initial rating were decreased
by 5%, 14%, and 23%, the model-indicated rating for the currently
rated Aaa Super Senior class would be Aaa, Aaa, and Aa1,
respectively; for the most junior Aaa rated class A-M would be
Aa1, Aa2, and A1, respectively. Parameter Sensitivities are not
intended to measure how the rating of the security might migrate
over time; rather they are designed to provide a quantitative
calculation of how the initial rating might change if key input
parameters used in the initial rating process differed. The
analysis assumes that the deal has not aged. Parameter
Sensitivities only reflect the ratings impact of each scenario
from a quantitative/model-indicated standpoint. Qualitative
factors are also taken into consideration in the ratings process,
so the actual ratings that would be assigned in each case could
vary from the information presented in the Parameter Sensitivity
analysis.

These ratings: (a) are based solely on information in the public
domain and/or information communicated to Moody's by the issuer at
the date it was prepared and such information has not been
independently verified by Moody's; (b) must be construed solely as
a statement of opinion and not a statement of fact or an offer,
invitation, inducement or recommendation to purchase, sell or hold
any securities or otherwise act in relation to the issuer or any
other entity or in connection with any other matter. Moody's does
not guarantee or make any representation or warranty as to the
correctness of any information, rating or communication relating
to the issuer. Moody's shall not be liable in contract, tort,
statutory duty or otherwise to the issuer or any other third party
for any loss, injury or cost caused to the issuer or any other
third party, in whole or in part, including by any negligence (but
excluding fraud, dishonesty and/or willful misconduct or any other
type of liability that by law cannot be excluded) on the part of,
or any contingency beyond the control of Moody's, or any of its
employees or agents, including any losses arising from or in
connection with the procurement, compilation, analysis,
interpretation, communication, dissemination, or delivery of any
information or rating relating to the issuer.


COMM 2012-CCRE4: S&P Rates $18-Mil. Class F Certificates 'B+'
-------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to COMM
2012-CCRE4 Mortgage Trust's $1.111 billion commercial mortgage
pass-through certificates series 2012-CCRE4.

The note issuance is a commercial mortgage-backed securities
transaction backed by 48 commercial mortgage loans with an
aggregate principal balance of $1.111 billion, secured by the fee
and leasehold interests in 152 properties across 34 states.

"The final ratings reflect the credit support provided by the
transaction structure, our view of the underlying collateral's
economics, the trustee-provided liquidity, the collateral pool's
relative diversity, and our overall qualitative assessment of the
transaction," 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 Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at:

      http://standardandpoorsdisclosure-17g7.com/1060.pdf

RATINGS ASSIGNED

COMM 2012-CCRE4 Mortgage Trust

Class       Rating                Amount
                                (mil. $)
A-1         AAA (sf)          59,118,000
A-2         AAA (sf)         148,657,000
A-SB        AAA (sf)          70,571,000
A-3         AAA (sf)         499,354,000
X-A         AAA (sf)     888,800,000(ii)
A-M         AAA (sf)         111,100,000
X-B(i)      A- (sf)      104,156,000(ii)
B(i)        AA- (sf)          65,271,000
C(i)        A- (sf)           38,885,000
D(i)        BBB- (sf)         45,829,000
E(i)        BB (sf)           19,442,000
F(i)        B+ (sf)           18,054,000
G(i)        NR                34,719,345

(i) Non-offered certificates.
(ii) Notional balance.
NR - Not rated.


COPPER RIVER: S&P Raises Rating on Class E Notes to 'B'; Off Watch
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, and E notes from Copper River CLO Ltd., a U.S.
collateralized loan obligation (CLO) managed by Guggenheim
Investment Management LLC. "In addition, we affirmed our ratings
on the class A-1A, A-1B, A-2A, A-2B, and D notes. At the same
time, we removed all of the ratings from CreditWatch positive,"
S&P said.

"The upgrades reflect the improvement in the credit quality of the
transaction's underlying assets since our last rating action in
December 2011. The affirmations reflect our belief that the credit
support available is commensurate with the current ratings," S&P
said.

"According to the Oct. 11, 2012 trustee report, the transaction
held $76.74 million in 'CCC' rated collateral, down from $95.59
million noted in the Nov. 18, 2011, trustee report, which we used
for our December 2011 rating actions. Furthermore, the amount of
defaulted obligations has decreased to $4.27 million from $5.46
million over the same period," S&P said.

"When calculating the overcollateralization (O/C) ratios, the
transaction's indenture haircuts a portion of the 'CCC' rated
collateral that exceeds 7.5% threshold. On Oct 11, 2012, the 'CCC'
rated obligation level was 10.19%, compared with 12.71% noted in
the Nov. 18, 2011, trustee report," S&P said.

"During the transaction's reinvestment period, which ends Jan. 14,
2014, the transaction has an APEX revolver facility, which has a
$35 million limit. The facility provides for the reimbursement of
principal losses in connection with credit defaults and credit-
impaired sales. According to the Sept. 21, 2012, trustee report,
the transaction had not drawn upon the APEX revolver facility,"
S&P said.

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

         STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Copper River CLO Ltd.
Class          Rating
          To            From
A-1A      A+ (sf)       A+ (sf)/Watch Pos
A-1B      A+ (sf)       A+ (sf)/Watch Pos
A-2A      AA (sf)       AA (sf)/Watch Pos
A-2B      A+ (sf)       A+ (sf)/Watch Pos
B         BBB (sf)      BBB- (sf)/Watch Pos
C         BB+ (sf)      BB (sf)/Watch Pos
D         B+ (sf)       B+ (sf)/Watch Pos
E         B (sf)        CCC+ (sf)/Watch Pos


CREDIT SUISSE 2006-C1: Fitch Junks Ratings on Nine Cert. Classes
----------------------------------------------------------------
Fitch Ratings has downgraded 15 classes and affirmed six classes
of Credit Suisse Commercial Mortgage Trust commercial mortgage
pass-through certificates series 2006-C1 (CSMC 2006-C1) due to an
increase in Fitch expected losses across the pool, primarily due
to increased losses on specially serviced loans.

Fitch modeled losses of 7.6% of the remaining pool; expected
losses on the original pool balance total 7.3%, including losses
already incurred.  The pool has experienced $37.8 million (1.3% of
the original pool balance) in realized losses to date.  Fitch has
designated 99 loans (32.3%) as Fitch Loans of Concern, which
includes 22 specially serviced assets (8.6%).

As of the October 2012 distribution date, the pool's aggregate
principal balance has been reduced by 21% to $2.38 billion from
$3.0 billion at issuance.  Per the servicer reporting, two loans
(0.5% of the pool) have defeased since issuance.  Interest
shortfalls are currently affecting classes K through S.

The largest contributor to expected losses is the specially-
serviced Lane Portfolio loan (1.7% of the pool), which is secured
by a portfolio of three hotels (589 rooms) located in Annapolis,
MD, Durham, NC, and Kentwood, MI.  The loan transferred to special
servicing in April 2010 due to insufficient cash flow.  Potential
resolution strategies are under discussion with the borrower.
The next largest contributor to expected losses is the 8201
Greensboro Drive loan (3.1%), which is secured by a 361,000-sf
office building located in McLean, VA, approximately 13 miles west
of Washington, D.C.  As of August 2012, occupancy had increased to
91.5% from 80% at last review; however, 10% of the tenancy rolls
over the next year.  The property remains over-leveraged.

The third largest contributor to expected losses is an REO
property, Village at Double Diamond (0.7%), a 58,000 sf retail
property located in Reno, NV.  Foreclosure was completed in August
2012.  Occupancy was recently reported at 62%.  New property
management has been installed with the plan to stabilize the rent
roll over the next two quarters with approximately 20% of the
leases expiring by year end.

Fitch downgrades the following classes and assigns or revises
Rating Outlooks and Recovery Estimates (REs) as indicated:

  -- $236.5 million class A-J to 'Asf' from 'AAsf', Outlook
     Stable;
  -- $18.8 million class B to 'Asf' from 'AAsf', Outlook to
     Negative from Stable;
  -- $37.5 million class C to 'BBBsf' from 'Asf', Outlook to
     Negative from Stable;
  -- $33.8 million class D to 'BBB-sf' from 'BBBsf', Outlook to
     Negative from Stable;
  -- $22.5 million class E to 'BBsf' from 'BBBsf', Outlook to
     Negative from Stable;
  -- $33.8 million class F to 'Bsf' from 'BBsf', Outlook to
     Negative from Stable;
  -- $30 million class G to 'CCCsf' from 'BBsf', RE 60%;
  -- $33.8 million class H to 'CCCsf' from 'Bsf', RE 0%;
  -- $30 million class J to 'CCsf' from 'B-sf', RE 0%;
  -- $37.5 million class K to 'Csf' from 'CCCsf', RE 0%;
  -- $15 million class L to 'Csf' from 'CCCsf', RE 0%;
  -- $11.3 million class M to 'Csf' from 'CCCsf', RE 0%;
  -- $11.3 million class N to 'Csf' from 'CCsf', RE 0%;
  -- $3.8 million class O to 'Csf' from 'CCsf', RE 0%;
  -- $3.5 million class Q to 'Dsf' from 'Csf', RE 0%.

Fitch affirms the following classes:

  -- $220.7 million class A-3 at 'AAAsf', Outlook Stable;
  -- $94.3 million class A-AB at 'AAAsf', Outlook Stable;
  -- $698 million class A-4 at 'AAAsf', Outlook Stable;
  -- $497.5 million class A-1-A at 'AAAsf', Outlook Stable;
  -- $300.4 million class A-M at 'AAAsf', Outlook Stable;
  -- $3.8 million class P at 'Csf', RE 0%.

Class A-2 is paid in full.  Fitch does not rate the class S or
class CCA certificates.  Fitch previously withdrew the ratings on
the interest-only class A-X and A-Y certificates.


CREDIT SUISSE 2006-C5: Moody's Cuts Ratings on 3 Certs. to 'C'
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of eight classes
and affirmed seven classes of Credit Suisse Commercial Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series 2006-
C5 as follows:

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

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

Cl. A-1-A, Affirmed at Aaa (sf); previously on Mar 9, 2011
Confirmed at Aaa (sf)

Cl. A-M, Downgraded to Baa2 (sf); previously on Nov 10, 2011
Downgraded to A1 (sf)

Cl. A-J, Downgraded to B2 (sf); previously on Nov 10, 2011
Downgraded to Ba1 (sf)

Cl. B, Downgraded to B3 (sf); previously on Nov 10, 2011
Downgraded to Ba2 (sf)

Cl. C, Downgraded to Caa2 (sf); previously on Nov 10, 2011
Downgraded to B1 (sf)

Cl. D, Downgraded to Ca (sf); previously on Nov 10, 2011
Downgraded to Caa1 (sf)

Cl. E, Downgraded to C (sf); previously on Nov 10, 2011 Confirmed
at Caa2 (sf)

Cl. F, Downgraded to C (sf); previously on Nov 10, 2011 Confirmed
at Caa3 (sf)

Cl. G, Downgraded to C (sf); previously on Nov 10, 2011 Confirmed
at Ca (sf)

Cl. H, Affirmed at C (sf); previously on Jan 13, 2011 Downgraded
to C (sf)

Cl. J, Affirmed at C (sf); previously on Dec 16, 2009 Downgraded
to C (sf)

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

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

Ratings Rationale

The downgrades are due to higher anticipated and realized losses
from specially serviced and troubled loans. The affirmations of
the principal classes are due to sufficient credit enhancement
levels for the current ratings. Based on Moody's current base
expected loss, the credit enhancement levels for the affirmed
classes are sufficient to maintain their ratings. The ratings of
the IO Classes, Classes A-X and A-SP are consistent with the
expected credit performance of their referenced classes and thus
are affirmed.

Moody's rating action reflects a base expected loss of 10.8% of
the current balance compared to 9.4% at last review. Moody's
provides a current list of base expected losses for conduit and
fusion CMBS transactions on moodys.com at
http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 Conduit Transactions" published in September 2000, and
"Moody's Approach to Rating Structured Finance Interest-Only
Securities" published in February 2012.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying credit assessment of the loan which corresponds to a
range of credit enhancement levels. Actual fusion credit
enhancement levels are selected based on loan level diversity,
pool leverage and other concentrations and correlations within the
pool. Negative pooling, or adding credit enhancement at the
underlying rating level, is incorporated for loans with similar
credit assessments in the same transaction.

Moody's review also incorporated the CMBS IO calculator ver1.1
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point. For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.1
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 43, compared to 48 at last review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated November 10, 2011.

DEAL PERFORMANCE

As of the October 17, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 17% to $2.93
billion from $3.53 billion at securitization. The Certificates are
collateralized by 256 mortgage loans ranging in size from less
than 1% to 7% of the pool. There are no loans with credit
assessments. One loan representing less than 1% is has defeased
and secured by U.S Government securities.

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

Forty loans have been liquidated from the pool since
securitization, resulting in an aggregate $127.6 million loss (56%
loss severity on average). Currently 24 loans, representing 18% of
the pool, are in special servicing. The largest specially-serviced
loan is the Babcock & Brown FX4 Loan ($191.3 million -- 6.5% of
the pool), which is secured by 18 multifamily properties located
in Texas, South Carolina and Georgia. The collateral consists of
older vintage Class B properties and totals 4,892 units. The
largest geographic concentrations are in Houston and Dallas, Texas
and Columbia, South Carolina. The loan was transferred to special
servicing in February 2009 due to the borrower's request for a
loan modification. The loan has been in payment default since
February 2012. The lender is working on an appointment of a
receiver and preparing for deed-in-lieu of foreclosure. The loan
matures in January 2016.

The second largest loan in special servicing is the West Covina
Portfolio Loan ($75.7 million -- 2.6% of the pool) which is
secured by a 229,300 square foot (SF) anchored retail center and
215,200 SF suburban office building. Financial performance has
declined since securitization and the loan was transferred to
special servicing in June 2009. Foreclosure was filed on September
3, 2009. The remaining specially serviced loans are secured by a
mix of property types. Moody's has estimated an aggregate $210.0
million loss (41% expected loss on average) for all of the
specially serviced loans.

Based on the most recent remittance statement, Classes D through P
have experienced cumulative interest shortfalls totaling $20.9
million. Moody's anticipates that interest shortfalls may increase
due to workout fees associated with the payoff of modified loans.
Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, appraisal subordinate
entitlement reductions (ASERs), extraordinary trust expenses and
non-advancing by the master servicer based on a determination of
non-recoverability.

Moody's has assumed a high default probability for 36 poorly
performing loans representing 7% of the pool and has estimated an
aggregate $31.5 million loss (16% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2011 and partial year 2012
operating results for 96% and 67% of the performing pool
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 109% compared to 105% at last full
review. Moody's net cash flow reflects a weighted average haircut
of 11.2% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.3%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.24X and 0.95X, respectively, compared to
1.31X and 0.97X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing conduit loans represent 17% of the pool
balance. The largest conduit loan is the Queens Multifamily
Portfolio Loan ($192.0 million -- 6.6% of the pool), which is
secured by 31 multifamily properties with 2,124 units located in
the Borough of Queens, New York. The borrower purchased the
property in 2006 for $277.5 million and planned to increase value
through a comprehensive capital improvement program and conversion
of rent regulated units to market rate units. Progress in
achieving those goals and objectives has been slower than
anticipated due to multifamily market conditions in New York City,
changes to rules impacting regulated multifamily units and higher
than anticipated operating expenses. The loan has been on the
servicer's watchlist for several years due to low DSCR. The
portfolio's financial performance has begun to show signs of
improvement due to sustained high occupancy at 93% as of December
2011. The loan is interest-only throughout the term and matures in
December 2013. Moody's LTV and stressed DSCR are 121% and 0.72X,
respectively, compared to 120% and 0.72X, at last review.

The second largest loan is the 720 Fifth Avenue Loan ($165.0
million -- 5.6% of the pool), which is secured by a 121,108 SF
mixed-use property located in the Fifth Avenue retail submarket of
Manhattan. The property was 93% leased as of December 2011, the
same as at last review. The largest tenant is Abercrombie & Fitch
(54% of net rentable area (NRA), with various lease expiration
dates from 2013 through 2022). The loan is interest-only
throughout the term and matures November 2016. Moody's LTV and
stressed DSCR are 118% and 0.76X, respectively, compared to 117%
and 0.76X at last review.

The third largest conduit loan is the HGSI Headquarters Loan
($145.2 million -- 5.0% of the pool), which is secured by a
635,000 SF office property located in Rockville, Maryland. The
property is 100% leased to Human Genome Sciences, Inc. through May
2026 and serves as its corporate headquarters. Property
performance is consistent with Moody's original projections.
Moody's LTV and stressed DSCR are 107% and 0.94X, respectively,
compared to 108% and 0.93X at last review.


CSFB 2002-18: Moody's Cuts Rating on One Tranche to 'Caa3'
----------------------------------------------------------
Moody's Investors Service has downgraded the rating of four
tranches from CSFB Mortgage-Backed Pass-Through Certificates,
Series 2002-18.

Ratings Rationale

The downgrades are a result of deteriorating performance of the
underlying pool resulting in higher than expected losses for the
bonds that 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 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 7.9% in October 2012. 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
2002-18

Cl. II-B-1, Downgraded to Caa3 (sf); previously on Mar 18, 2011
Downgraded to Caa2 (sf)

Cl. II-A-1, Downgraded to Baa1 (sf); previously on Mar 18, 2011
Downgraded to Aa3 (sf)

Cl. II-P, Downgraded to Baa1 (sf); previously on Mar 18, 2011
Downgraded to Aa3 (sf)

Cl. II-PP, Downgraded to Baa1 (sf); previously on Mar 18, 2011
Downgraded to Aa3 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF304655

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


CSMC 2006-9: Moody's Lowers Ratings on 2 RMBS Classes to 'B3'
-------------------------------------------------------------
Moody's Investors Service has downgraded Class 6-A-1 and Class 6-
A-2 from CSMC Mortgage-Backed Trust Series 2006-9. The collateral
backing this deal primarily consists of first-lien, fixed Alt-A
residential mortgages.

Complete rating actions are as follows:

Issuer: CSMC Mortgage-Backed Trust Series 2006-9

Cl. 6-A-1, Downgraded to B3 (sf); previously on May 30, 2012 Ba2
(sf) Placed Under Review for Possible Downgrade

Cl. 6-A-2, Downgraded to B3 (sf); previously on May 30, 2012 Ba2
(sf) Placed Under Review for Possible Downgrade

Ratings Rationale

The downgrades result from application of corrected pool projected
losses associated with subgroup 6. Classes 6-A-1 and 6-A-2 are
backed by collateral from subgroup 6. In the rating action taken
on July 11, 2011 on Classes 6-A-1 and 6-A-2, the proportion of
combined pool projected losses allocated to subgroup 6 was
understated relative to its delinquent loans pipeline. The error
has now been corrected, and the rating action reflects that
change.

The methodologies used in this rating 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

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 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 April 2011 to 7.9% in October 2012. 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_SF305512

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


CWMBS 2002-1: Moody's Junks Rating on Class B-2 Certificates
------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches from CWMBS Re-Performing Loan REMIC Trust Certificates,
Series 2002-1. The collateral backing this deal consists of first-
lien fixed mortgage loans insured by Federal Housing
Administration (FHA), an agency of the U.S. Department of Urban
Development (HUD) or guaranteed by the Veterans Administration
(VA).

Complete rating actions are as follows:

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

Cl. M, Downgraded to Baa3 (sf); previously on Aug 25, 2011
Downgraded to Baa1 (sf)

Cl. B-1, Downgraded to Ba3 (sf); previously on Aug 25, 2011
Downgraded to Ba2 (sf)

Cl. B-2, Downgraded to Caa1 (sf); previously on Aug 25, 2011
Downgraded to B3 (sf)

Ratings Rationale

The actions are a result of the recent performance of FHA-VA
portfolio and reflect Moody's updated loss expectations on these
pools and structural nuances of the transactions. The downgrades
are a result of higher than expected losses and the erosion credit
enhancement supporting some of these bonds. These are shifting
interest structures and the subordinate bonds are paying down
principal exposing the bonds to tail- end losses.

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

Moody's final rating actions are based on current levels of credit
enhancement, collateral performance, and updated pool-level loss
expectations. Moody's took into account credit enhancement
provided by seniority, and other structural features within the
senior note waterfalls.

The methodologies used in this rating were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, and "FHA-VA 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.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast. The unemployment rate fell
from 9.1% in June 2011 to 7.9% in October 2012. Moody's expects
house prices to drop another 1% from their 4Q2011 levels before
gradually rising towards the end of 2013.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF305629

A list of updated estimated pool losses and sensitivity analysis
may be found at:

http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF256626


DUANE STREET III: Moody's Hikes Rating on Class E Notes to 'Ba2'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Duane Street CLO III, Ltd.:

U.S.$7,500,000 Class A-2b Senior Floating Rate Notes Due 2021,
Upgraded to Aaa (sf); previously on August 16, 2011 Upgraded to
Aa1 (sf);

U.S.$33,000,000 Class B Senior Floating Rate Notes Due 2021,
Upgraded to Aa1 (sf); previously on August 16, 2011 Upgraded to
Aa3 (sf);

U.S.$28,500,000 Class C Deferrable Mezzanine Floating Rate Notes
Due 2021, Upgraded to A1 (sf); previously on August 16, 2011
Upgraded to Baa1 (sf);

U.S.$27,500,000 Class D Deferrable Mezzanine Floating Rate Notes
Due 2021, Upgraded to Baa3 (sf); previously on August 16, 2011
Upgraded to Ba1 (sf);

U.S.$14,000,000 Class E Deferrable Junior Floating Rate Notes Due
2021, Upgraded to Ba2 (sf); previously on August 16, 2011 Upgraded
to Ba3 (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 January 2013. 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 and higher spread levels
compared to the levels assumed at the last rating action in August
2011. Moody's modeled a WARF of 2644 compared to 2813 and a WAS of
3.58% compared to 2.72% at the time of 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 $535.3 million,
defaulted par of $14.2 million, a weighted average default
probability of 17.05%, (implying a WARF of 2644), a weighted
average recovery rate upon default of 50.13%, and a diversity
score of 66. 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.

Duane Street CLO III, 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% (2115)

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

Moody's Adjusted WARF + 20% (3173)

Class A-1: 0
Class A-2a: 0
Class A-2b: 0
Class B: -1
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:

1) Deleveraging: The main source of uncertainty in this
transaction is when 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.


E*TRADE RV: Moody's Puts 'B3' Rating on Review for Downgrade
------------------------------------------------------------
Moody's Investors Service has placed three tranches from E*Trade
RV and Marine Trust 2004-1 on review for downgrade. The
transaction is serviced by GEMB Lending, Inc. GEMB Lending, Inc.
is part of the GE Capital operating division of General Electric.

Complete rating actions as follow:

Issuer: E*Trade RV and Marine Trust 2004-1

Cl. B, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jul 24, 2009 Downgraded to Baa2 (sf)

Cl. C, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Jul 24, 2009 Downgraded to Ba2 (sf)

Cl. D, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Jul 24, 2009 Downgraded to B3 (sf)

Ratings Rationale

The review is a result of weaker performance than previously
expected which has eroded the level of credit enhancement for the
affected securities. Losses on the underlying pool have depleted
the reserve account and the transaction is currently under-
collateralized by approximately $1.2 million, which is equal to
approximately 27% of the junior most Class E, which provides
protection to the senior and mezzanine securities.

Unlike other vehicle-backed ABS, the impact of the weakened
economy on a RV and marine transaction has been more severe and
long lasting due to the non-essential nature of the underlying
collateral, and the longer financing terms, which on average range
between 170 and 185 months at closing. As a result, the
transaction has experienced more than one economic downturn during
its life.

Below are key performance metrics and credit assumptions for the
affected transaction. Credit assumptions include Moody's expected
lifetime CNL expectation which is expressed as a percentage of the
original pool balance; Performance metrics include pool factor;
total credit enhancement (expressed as a percentage of the
outstanding collateral pool balance) which typically consists of
subordination, overcollateralization, and a reserve fund; and per
annum excess spread.

Issuer: E*Trade RV and Marine Trust 2004-1

Lifetime CNL expected range -- 11.0% - 12.0%; prior expectation
(November 2011) -- 10.0%

Pool Factor -- 20.38%

Total credit enhancement (excluding excess spread) - Class A-4
91.44%, Class A-5 36.54%, Class-B 26.12%, Class-C 16.5%, Class-D
5.29%

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

Primary sources of assumption uncertainty are the current
macroeconomic environment, in which unemployment continues to
remain at elevated levels, and weakness in the RV and marine
market. Overall, Moody's expects overall a sluggish recovery in
most of the world's largest economies, returning to trend growth
rate with elevated fiscal deficits and persistent unemployment
levels.

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


FRANKLIN CLO VI: S&P Raises Class E Note Rating to 'B+'; Off Watch
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, D, and E notes from Franklin CLO VI Ltd., a U.S.
collateralized loan obligation (CLO) managed by Franklin Advisors
Inc. In addition, we affirmed our rating on the class A notes.

"The upgrades reflect improvement in the credit quality of the
underlying assets since our last upgrade action in January 2011.
The affirmed rating reflects our belief that the credit support
available is commensurate with the current rating level," S&P
said.

Franklin CLO VI Ltd. is still in its reinvestment period and will
continue to invest principal proceeds in new collateral until July
30, 2013.

The improvements in the transaction are reflected in the reduction
in 'CCC' rated collateral and the defaulted assets held. According
to the Sept. 25, 2012, trustee report, the transaction held $14.03
million in 'CCC' rated collateral, down from $28.01 million noted
in the Dec. 27, 2010, trustee report, which we used for our
January actions," S&P said.

"Currently, the transaction has $3.58 million in defaulted assets
in the underlying collateral pool. This compares with more than
$8.99 million at the time of the last rating action," S&P said.

"Over the same time period, the transaction's coverage ratios have
improved. The overcollateralization ratios have improved, on
average, about 1.57% and the interest coverage ratios have
improved, on average, by more than 167%. The weighted average
spread increased to 4.2% from 3.6%," S&P said.

"The rating on the class E notes is capped at 'B+ (sf)' by the top
obligor test, part of the supplemental tests we introduced in
September 2009," 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 Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at:

      http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Franklin CLO VI Ltd.
                       Rating
Class              To           From
A                  AA+ (sf)     AA+ (sf)
B                  AA (sf)      A+ (sf)/Watch Pos
C                  A (sf)       BBB+ (sf)/Watch Pos
D                  BBB (sf)     BB+ (sf)/Watch Pos
E                  B+ (sf)      CCC+ (sf)/Watch Pos


FRASER SULLIVAN: Moody's Raises Rating on Class D Notes From Ba1
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Fraser Sullivan CLO II Ltd.:

U.S. $33,000,000 Class B Senior Secured Floating Rate Notes due
2020, Upgraded to Aaa (sf); previously on August 23, 2011 Upgraded
to Aa1 (sf);

U.S. $32,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to A1 (sf); previously on August 23, 2011
Upgraded to A2 (sf);

U.S. $33,000,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to Baa3 (sf); previously on August 23,
2011 Upgraded to Ba1 (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 higher spread levels and higher
diversity score compared to the levels assumed at the last rating
action in August 2011. Moody's modeled a WAS of 3.8% compared to
3.0% and a diversity score of 61 compared to 54 at the time of the
last rating action. Moody's also notes that the transaction's
reported 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 $471.6 million,
defaulted par of $14.3 million, a weighted average default
probability of 18.49% (implying a WARF of 2724), a weighted
average recovery rate upon default of 48.6%, and a diversity score
of 61. 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.

Fraser Sullivan CLO II 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% (2179)

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

Moody's Adjusted WARF + 20% (3269)

Class A-1a: 0
Class A-1b: 0
Class A-2: 0
Class B: -1
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:

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.


G-STAR 2003: Fitch Affirms Junk Ratings on Five Note Classes
------------------------------------------------------------
Fitch Ratings has upgraded one and affirmed five classes of G-Star
2003-3 Ltd./Corp as a result of paydowns to the senior notes
offsetting the deterioration of the underlying collateral.

Since Fitch's last rating action in December 2011, approximately
15.4% of the underlying collateral has been downgraded and 1.9%
has been upgraded.  Currently, 67.3% of the portfolio has a Fitch
derived rating below investment grade and 53.3% has a rating in
the 'CCC' category and below, compared to 46.8% and 37.5%,
respectively, at the last rating action.  Over this period, the
class A-1 notes have received $47.5 million for a total of $309
million in pay downs 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-1 notes'
breakeven rates are generally consistent with the ratings assigned
below.

For the class A-2 through B notes, Fitch analyzed each 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 A-2 notes have been affirmed at 'CCsf', indicating that
default is probable.  Similarly, the class A-3 and B notes have
been affirmed at 'Csf', indicating that default is inevitable.
The class B notes are currently receiving interest paid in kind
(PIK) whereby the principal amount of the notes is written up by
the amount of interest due.

The upgrade and Stable Outlook on the class A-1 notes reflects the
credit quality of the underlying collateral and the view that the
transaction will continue to delever.

G-Star 2003-3 is a cash flow commercial real estate collateralized
debt obligation (CRE CDO) which closed on March 13, 2003.  The
collateral is composed of 57% residential mortgage backed
securities (RMBS), 35.9% commercial mortgage backed securities
(CMBS), 3.5% real estate investment trusts (REIT), 2.1% structured
finance CDOs, and 1.5% asset backed securities (ABS).

Fitch has taken the following actions as indicated:

  -- $31,001,801 class A-1 notes upgraded to 'BBsf' from 'Bsf';
     Outlook Stable;
  -- $48,000,000 class A-2 notes affirmed at 'CCsf';
  -- $18,000,000 class A-3 notes affirmed at 'Csf';
  -- $6,050,881 class B-1 notes affirmed at 'Csf';
  -- $18,733,701 class B-2 notes affirmed at 'Csf';
  -- $24,000,000 preferred shares affirmed at 'Csf'.


GALAXY XIV: S&P Rates $27.5-Mil. Class E Deferrable Notes 'BB'
--------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Galaxy
XIV CLO Ltd./Galaxy XIV CLO Inc.'s $462.0 million fixed- and
floating-rate notes.

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

The ratings reflect S&P's view of:

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

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

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

-- The diversified collateral portfolio, which primarily
    comprises 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 it assessed using
    its cash flow analysis and assumptions commensurate with the
    assigned ratings under various interest-rate scenarios,
    including LIBOR ranging from 0.3523% to 13.8391%.

-- 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, incentive management fees, and subordinated note
    payments into 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/1061.pdf

RATINGS ASSIGNED

Galaxy XIV CLO Ltd./Galaxy XIV CLO Inc.

Class                   Rating            Amount
                                        (mil. $)
A                       AAA (sf)          318.75
B                       AA (sf)            53.25
C-1 (deferrable)        A (sf)             19.50
C-2 (deferrable)        A (sf)             21.00
D (deferrable)          BBB (sf)           27.50
E (deferrable)          BB (sf)            22.00
Subordinated notes      NR                 58.00

NR - Not rated.


GALLATIN CLO IV 2012-1: S&P Rates Class F Def Notes 'B'
-------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
Gallatin CLO IV 2012-1 Ltd./Gallatin CLO IV 2012-1 LLC's $283.50
million floating-rate notes.

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

The ratings reflect S&P's view of:

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

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

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

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

-- The collateral manager's experienced management team.

-- S&P's projections regarding the timely interest and ultimate
    principal payments on the rated notes, which it assessed using
    its cash flow analysis and assumptions commensurate with the
    assigned ratings under various interest-rate scenarios,
    including LIBOR ranging from 0.3439%-12.6500%.

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

              STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

      http://standardandpoorsdisclosure-17g7.com/1082.pdf

RATINGS ASSIGNED

Gallatin CLO IV 2012-1 Ltd./Gallatin CLO IV 2012-1 LLC

Class                    Rating          Amount
                                       (mil. $)
A                        AAA (sf)        189.00
B                        AA (sf)          39.00
C (deferrable)           A (sf)           24.00
D (deferrable)           BBB (sf)         12.00
E (deferrable)           BB (sf)          14.00
F (deferrable)           B (sf)            5.50
Subordinated notes       NR               31.70

NR - Not rated.


GMAC 1999-C3: Moody's Raises Rating on Class J Certs. to 'Ba2'
--------------------------------------------------------------
Moody's Investors Service upgraded the ratings of two classes and
affirmed two classes of GMAC Commercial Mortgage Securities, Inc.
Mortgage Pass-Through Certificates, Series 1999-C3 as follows:

Cl. H, Upgraded to Ba1 (sf); previously on Dec 9, 2011 Downgraded
to B3 (sf)

Cl. J, Upgraded to Ba2 (sf); previously on Apr 27, 2011 Downgraded
to Caa1 (sf)

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

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

Ratings Rationale

The upgrades are due to defeasance, increased credit subordination
due to loan payoffs, and amortization. The pool has paid down by
37% since Moody's last full review.

The affirmations are due to key parameters, including Moody's LTV
ratio, Moody's stressed debt service coverage ratio (DSCR) and the
Herfindahl Index (Herf), remaining within acceptable ranges. Based
on Moody's current base expected loss, the credit enhancement
levels for the affirmed classes are sufficient to maintain their
current ratings. The rating of the IO Class, Class X is consistent
with the performance of its referenced classes and is thus
affirmed.

Moody's rating action reflects a cumulative base expected loss of
6.7% of the current pooled balance, as compared to 20.5% at last
review. Moody's provides a current list of base and stress
scenario losses for conduit and fusion CMBS transactions on
moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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 U.S. CMBS Conduit Transactions" published in September
2000, "Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000, and "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's review also incorporated the CMBS IO calculator ver1.1
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit assessments; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point . For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.1
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 6 compared to 9 at Moody's prior review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.5 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 9, 2011.

DEAL PERFORMANCE

As of the October 15, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $28 million
from $1.2 billion at securitization. The Certificates are
collateralized by six mortgage loans ranging in size from 2% to
28% of the pool.

Currently no loans are on the master servicer's watchlist. The
watchlist includes loans which meet certain portfolio review
guidelines established as part of the CRE Finance Council's
(CREFC) monthly reporting package. As part of its ongoing
monitoring of a transaction, Moody's reviews the watchlist to
assess which loans have material issues that could impact
performance.

Twenty-four loans have been liquidated from the pool since
securitization, resulting in an aggregate $33 million loss (15%
loss severity on average). Currently one loan, representing 19% of
the pool, is in special servicing.

The specially serviced loan is the Shiloh Square Shopping Center
Loan ($5.5 million -- 19.4% of the pool), which is secured by a
85,000 square foot (SF) retail center in Garland, Texas. The loan
transferred to special servicing in May 2009 and foreclosure was
completed in May 2012. As of September 2012, the property was 91%
leased and 18% occupied due to the grocery anchor being dark.

The pool only contains three loans that are not defeased and not
in special servicing. The largest loan is the Burleson Towne
Centre Loan ($5.7 million -- 20.1% of the pool). The loan is
secured by a 126,000 SF shopping center located in Burleson,
Texas. JC Penney leases 74% of the space through October 2019. The
property was 98% leased as of June 2012 compared to 94% as last
review. Moody's LTV and stressed DSCR are 70% and 1.54X,
respectively, compared to 60% and 1.82X at last review.

The second largest conduit loan is the Rivercrest Apartments Loan
($2.2 million -- 7.9% of the pool), which is secured by a 120 unit
multifamily property located in Albany, Georgia. The property was
93% leased as of June 2012, compared to 98% at last review.
Moody's LTV and stressed DSCR are 64% and 1.62X, respectively,
compared to 88% and 1.16X at last review.

The third largest conduit loan is the CVS Pharmacy Baltimore Loan
($0.5 million -- 1.7% of the pool), which is secured by a 13,000
SF CVS Pharmacy located in Downtown Baltimore, Maryland. The
property was 100% leased by CVS/Caremark Corp. (Baa2 --- Outlook -
Positive) as of June 2012, same as at last review. Moody's LTV and
stressed DSCR are 37% and 2.86X, respectively, compared to 38% and
2.78X at last review.

Moody's was provided with full year 2010 and partial year 2011
operating statements for all three of those loans. Excluding
specially serviced and defeased loans, Moody's weighted average
LTV is 66% as compared to 75% at last review. Moody's net cash
flow reflects a weighted average haircut of 12.3% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.6%.

Excluding specially serviced and defeased loans, Moody's actual
and stressed DSCRs are 1.27X and 1.64X, respectively, compared to
1.28X and 1.47X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.


GOLDMAN SACHS 2012-GCJ9: Fitch Issues Presale Report on Some Certs
------------------------------------------------------------------
Fitch Ratings has issued a presale report on Goldman Sachs
Commercial Mortgage Capital, L.P. GS Mortgage Securities Trust,
Series 2012-GCJ9 Commercial Mortgage Pass-Through Certificates.

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

  -- $72,318,000 Class A-1 'AAAsf'; Outlook Stable;
  -- $202,504,000 Class A-2 'AAAsf'; Outlook Stable;
  -- $607,410,000 Class A-3 'AAAsf'; Outlook Stable;
  -- $90,017,000 Class A-AB 'AAAsf'; Outlook Stable;
  -- $1,083,364,000(*) Class X-A 'AAAsf'; Outlook Stable;
  -- $111,115,000 Class A-S 'AAAsf'; Outlook Stable;
  -- $90,280,000 Class B 'AA-sf'; Outlook Stable;
  -- $57,293,000 Class C 'A-sf'; Outlook Stable;
  -- $57,293,000 Class D 'BBB-sf'; Outlook Stable;
  -- $27,779,000 Class E 'BBsf'; Outlook Stable;
  -- $22,570,000 Class F 'Bsf'; Outlook Stable.

(*)Notional amount and interest only.

The expected ratings are based on information provided by the
issuer as of Nov. 6, 2012.  Fitch does not expect to rate the
$305,564,224 interest-only class X-B or the $50,349,224 Class G.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 74 loans secured by 135 commercial
properties having an aggregate principal balance of approximately
$1.39 billion as of the cutoff date.  The loans were contributed
to the trust by Citigroup Global Market Realty Corp., Goldman
Sachs Commercial Mortgage Capital, L.P., Jefferies LoanCore LLC,
GS Commercial Real Estate, LP, and Archetype Mortgage Capital.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 75.9% of the properties
by balance, and performed cash flow analysis and asset summary
reviews on 82.8% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.19 times (x), a Fitch stressed loan-to-value (LTV) of
103.2%, and a Fitch debt yield of 9.0%.  Fitch's aggregate net
cash flow represents a variance of 11.1% to issuer cash flows.

The Master Servicer and Special Servicer will be Wells Fargo Bank,
N.A. and Rialto Capital Advisors, LLC, rated 'CMS2' and 'CSS2-',
respectively, by Fitch.


GRAMERCY 2006-1: Moody's Affirms 'Caa3' Ratings on 7 Note Classes
-----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of all classes
of Notes issued by Gramercy Real Estate CDO 2006-1, Ltd. The
affirmations are due to key transaction parameters performing
within levels commensurate with the existing ratings levels. The
rating action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation and
collateralized loan obligation (CRE CDO CLO) transactions.

Moody's rating action is as follows:

Cl. A-1, Affirmed at Aaa (sf); previously on Apr 7, 2009 Confirmed
at Aaa (sf)

Cl. A-2, Affirmed at Baa3 (sf); previously on Nov 17, 2010
Downgraded to Baa3 (sf)

Cl. B, Affirmed at Caa1 (sf); previously on Nov 17, 2010
Downgraded to Caa1 (sf)

Cl. C, Affirmed at Caa2 (sf); previously on Apr 7, 2009 Downgraded
to Caa2 (sf)

Cl. D, Affirmed at Caa3 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

Cl. E, Affirmed at Caa3 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

Cl. F, Affirmed at Caa3 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

Cl. G, Affirmed at Caa3 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

Cl. H, Affirmed at Caa3 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

Cl. J, Affirmed at Caa3 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

Cl. K, Affirmed at Caa3 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

Ratings Rationale

Gramercy Real Estate CDO 2006-1, Ltd. is a static (the
reinvestment period ended in July 2011) cash transaction backed by
a portfolio of whole loans (62.1% of the pool balance), commercial
mortgage backed securities (CMBS) (16.2%), B-Notes (8.0%),
mezzanine loans (4.2%),commercial real estate preferred equity
(3.9%), real estate investment trust (REIT) term loan (3.1%), and
CRE CDO debt (2.5%). As of the September 28, 2012 trustee report,
the aggregate Note balance of the transaction, including
Preference Shares, has decreased to $852.9 million from $1.0
billion at issuance, as a result of the combination of the junior
notes cancellation to Class C, Class D, Class E, and Class F Notes
and of the paydown directed to the Class A-1 Notes from regular
amortization of collateral, and resolution and sales of defaulted
collateral. In general, holding all key parameters static, the
junior note cancellations results in slightly higher expected
losses and longer weighted average lives on the senior Notes,
while producing slightly lower expected losses on the mezzanine
and junior Notes. However, this does not cause, in and of itself,
a downgrade or upgrade of any outstanding classes of Notes. The
transaction is failing all its par value tests while passing all
of its interest coverage tests. Currently, the transaction is
under-collateralized by $9.4 million (including cash principal
available for regular distribution).

There are eight assets with par balance of $152.5 million (19.2%
of the current pool balance) that are considered defaulted
securities as of the September 28, 2012 trustee report, compared
to nine defaulted securities totaling $146.0 million par amount
(14.5%) at last review. Moody's does expect moderate to high
losses to occur from these defaulted securities once they are
realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated 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 5,992 compared to 5,972 at last review. The
current distribution of Moody's rated collateral and assessments
for non-Moody's rated collateral is as follows: Aaa-Aa3 (1.9%
compared to 2.3%), A1-A3 (1.5% compared to 1.0%),Baa1-Baa3 (3.6%
compared to 6.9% at last review), Ba1-Ba3 (2.5% compared to 5.1%
at last review), B1-B3 (13.8% compared to 16.1% at last review),
and Caa1-Ca/C (76.7% compared to 68.6% at last review).

Moody's modeled to a WAL of 3.0 years, compared to 3.1 years at
last review. The current WAL is based on the assumption about
extensions.

Moody's modeled a fixed 35.3% WARR, compared to 35.1% at last
review.

Moody's modeled a MAC of 19.3%, compared to 13.1% 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. 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 35.3% to 25.3% or up to 45.3% would result in modeled
rating movement on the rated Notes of 0 to 4 notches downward and
0 to 6 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.


GRAMERCY 2007-1: Moody's Cuts Rating on Class A-1 Notes to 'B3'
---------------------------------------------------------------
Moody's Investors Service has downgraded the rating of one and
affirmed the ratings of four classes of Notes issued by Gramercy
Real Estate CDO 2007-1, Ltd. The downgrades are due to
deterioration in underlying collateral performance as evidenced by
transition in Moody's weighted average rating factor (WARF),
weighted average recovery rate (WARR), negative migration of
principal coverage tests, and a greater percentage of defaulted
securities since last review. The affirmations are due to key
transaction parameters performing within levels commensurate with
the existing ratings levels. The rating action is the result of
Moody's on-going surveillance of commercial real estate
collateralized debt obligation (CRE CDO and Re-REMIC)
transactions.

Moody's rating action is as follows:

Cl. A-1, Downgraded to B3 (sf); previously on Nov 23, 2011
Downgraded to Ba3 (sf)

Cl. A-2, Affirmed at B3 (sf); previously on Nov 23, 2011
Downgraded to B3 (sf)

Cl. A-3, Affirmed at Caa3 (sf); previously on Nov 23, 2011
Downgraded to Caa3 (sf)

Cl. B-FL, Affirmed at Caa3 (sf); previously on Dec 1, 2010
Downgraded to Caa3 (sf)

Cl. B-FX, Affirmed at Caa3 (sf); previously on Dec 1, 2010
Downgraded to Caa3 (sf)

Ratings Rationale

Gramercy Real Estate CDO 2007-1, Ltd. is a static (the
reinvestment period ended in August 2012) cash transaction backed
by a portfolio of commercial mortgage backed securities (CMBS)
(78.0%), whole loans (14.1% of the pool balance), mezzanine loans
(7.5%), and B-Notes (0.4%). As of the September 28, 2012 trustee
report, the aggregate Note balance of the transaction, including
Preference Shares, has decreased to $1.08 billion from $1.1
billion at issuance, as a result of the paydown directed to the
Class A-1 Notes from regular amortization of collateral,
resolution and sales of collateral, and interest proceeds paid as
principal proceeds as a result of failing the par value tests.
Also, an insurance company guarantees the scheduled payment of
interest and principal on the Class A-2 Notes. The transaction is
failing all its par value tests. Currently, the transaction is
under-collateralized by $24.4 million (including cash principal
available for regular distribution).

There are six assets with par balance of $94.9 million (9.0% of
the current pool balance) that are considered defaulted securities
as of the September 28, 2012 trustee report, compared to two
defaulted securities totaling $56.5 million par amount (5.3%) at
last review. Moody's does expect moderate to high losses to occur
from these defaulted securities once they are realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
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 3,772 compared to 3,046 at last review. The
current distribution of Moody's rated collateral and assessments
for non-Moody's rated collateral is as follows: Aaa-Aa3 (1.9%
compared to 0.5%), A1-A3 (1.8% compared to 0.3%),Baa1-Baa3 (10.9%
compared to 26.2% at last review), Ba1-Ba3 (9.8% compared to 14.4%
at last review), B1-B3 (30.7% compared to 29.3% at last review),
and Caa1-Ca/C (44.9% compared to 29.3% at last review).

Moody's modeled to a WAL of 4.3 years, compared to 5.6 years at
last review. The current WAL is based on the assumption about
extensions.

Moody's modeled a fixed 20.3% WARR, compared to 25.1% at last
review.

Moody's modeled a MAC of 9.7%, compared to 12.2% 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. 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 20.3% to 10.3% or up to 30.3% would result in modeled
rating movement on the rated Notes of 0 to 1 notches downward and
0 to 1 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.


GREENWICH CAPITAL: Fitch Downgrades Rating on Eight Cert. Classes
-----------------------------------------------------------------
Fitch Ratings downgrades eight classes of Greenwich Capital
Commercial Funding Corp. (GCCFC), series 2007-GG9, commercial
mortgage pass-through certificates, due to increased loss
expectations on the specially serviced loans, higher than expected
realized losses from dispositions and further deterioration of
collateral performance.

The downgrades reflect an increase in Fitch modeled losses across
the pool, which includes modeled losses on loans in special
servicing, and on performing loans with declines in performance
indicative of a higher probability of default.  Fitch modeled
losses of 14.9% (15.1% cumulative transaction losses, which
includes losses realized to date) based on modeled losses on the
specially serviced loans and loans assumed to default during the
term or not refinance at maturity.

The Outlook for classes A-M and A-MFX remains Negative, as further
collateral underperformance may lead to a downgrade.  Should cash
flows deteriorate further on the performing loans, or if realized
losses exceed current expectations on the specially serviced
loans, downgrades of these classes are possible.  In addition,
interest shortfalls have increased significantly since Fitch's
last rating action.

As of the October 2012 distribution date, the pool's aggregate
principal balance has decreased 11.6% to $5.81 billion from $6.58
billion at issuance.  As of October 2012, there are cumulative
interest shortfalls in the amount of $36.5 million; currently
affecting classes B through S.  Fitch has designated 79 loans
(46.8%) as Fitch Loans of Concern, which includes 32 specially
serviced loans (25.4%).

The largest contributor to loss is the Schron Industrial Portfolio
(5.2%) The loan is secured by a portfolio of 36 industrial
properties located in Nassau and Suffolk Counties on Long Island,
NY.  The loan transferred to the special servicer in December 2010
for imminent default.  The loan was modified in 2012 and remains
specially serviced.  The loan was split into an A/B structure,
with an A-note balance of $220 million and a subordinate B-note
balance of $85 million and a scheduled maturity date of December
2016.

The second largest contributor to loss is the specially serviced
Peachtree Center (3.6%) in Atlanta, GA.  The collateral consists
of six office buildings totaling 2.4 million square feet (sf),
three parking garages and a 134,024 sf retail center.  The loan
transferred to special servicing in February 2010 due to imminent
default.  A loan modification has closed with the loan split into
a springing A/B structure consisting of a $140 million A-note and
a $67.6 million B-note.  The bi-furcated loan is scheduled to
mature in June 2015.

The third largest contributor to loss (2.4%) is secured by the
Hyatt Regency Bethesda.  The collateral is a 390 room full-service
hotel.  The loan transferred to special servicing in December 2009
due to imminent default.  The hotel was adversely affected by the
economic downturn; however, trailing 12-month (TTM) occupancy has
improved to 78.6% as of June 2012. The October 2012 remittance
indicated the property is in foreclosure.

Fitch has downgraded and maintained Outlooks on the following
classes as indicated:

  -- $557.6 million class A-M to 'BBBsf' from 'AAAsf'; Outlook
     Negative;
  -- $100 million class A-MFX to 'BBBsf' from 'AAAsf'; Outlook
     Negative.

In addition, Fitch has downgraded the following classes and
assigned Recovery Estimates (RE) as follows:

  -- $575.4 million class A-J to 'CCCsf' from 'Bsf'; RE 60%;
  -- $32.9 million class B to 'CCsf' from 'CCCsf', RE 0%;
  -- $98.6 million class C to 'CCsf' from 'CCCsf', RE 0%;
  -- $41.1 million class D to 'CCsf' from 'CCCsf', RE 0%;
  -- $41.1 million class E to 'CCsf' from 'CCCsf', RE 0%;
  -- $82.2 million class H to 'Csf' from 'CCsf', RE 0%.

Fitch has affirmed the following classes as indicated:

  -- $811 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $86 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $84.5 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $2.67 billion class A-4 at 'AAAsf'; Outlook Stable;
  -- $317.7 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $57.5 million class F at 'CCsf', RE 0%;
  -- $57.5 million class G at 'CCsf', RE 0%;
  -- $65.8 million class J at 'Csf', RE 0%;
  -- $65.8 million class K at 'Csf', RE 0%;
  -- $32.9 million class L at 'Csf', RE 0%;
  -- $16.4 million class M at 'Csf', RE 0%.
  -- $17.5 million class N at 'Dsf', RE 0%.

Classes O, P and Q are fully depleted and remain at 'Dsf', RE 0%,
due to realized losses.

Class A-1 has been paid in full.  The non-rated class S is fully
depleted.  Fitch previously withdrew the ratings of class A-MFL
and the interest-only class X.


GSC INVESTMENT: Moody's Raises Rating on Class D Notes From Ba1
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by GSC Investment Corp. CLO 2007, Ltd.:

U.S. $296,000,000 Class A Floating Rate Senior Notes Due 2020,
Upgraded to Aaa (sf); previously on October 7, 2011 Upgraded to
Aa1 (sf);

U.S $22,000,000 Class B Floating Rate Senior Notes Due 2020,
Upgraded to Aa2 (sf); previously on October 7, 2011 Upgraded to A2
(sf);

U.S. $14,000,000 Class C Deferrable Floating Rate Notes Due 2020,
Upgraded to A2 (sf); previously on October 7, 2011 Upgraded to
Baa2 (sf);

U.S. $16,000,000 Class D Deferrable Floating Rate Notes Due 2020,
Upgraded to Baa3 (sf); previously on October 7, 2011 Upgraded to
Ba1 (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 January 2013. 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 and higher spread levels
compared to the levels assumed at the last rating action in
October 2011. Moody's modeled a WARF of 2488 compared to 3116 and
a WAS of 3.73% compared to 3.15% at the time of 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 $385 million,
defaulted par of $15.3 million, a weighted average default
probability of 18.59% (implying a WARF of 2488), a weighted
average recovery rate upon default of 50.5%, 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.

GSC Investment Corp. CLO Ltd 2007, issued in January 2008, 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% (1990)

Class A: 0
Class B: +2
Class C: +2
Class D: +2
Class E: +1

Moody's Adjusted WARF + 20% (2986)

Class A: 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:

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.

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

4) Post-Reinvestment Period Trading: Subject to certain
requirements, the deal is allowed to reinvest certain proceeds
after the end of the reinvestment period, and as such the manager
has the ability to deteriorate some collateral quality metrics to
the covenant levels. In particular, given that the post-
reinvestment period reinvesting criteria do not require the
reinvestment asset to have a Moody's rating equal to or better
than the rating of the security sold or prepaid, Moody's
considered the deal's sensitivity to a portfolio having a higher
WARF.


HALCYON STRUCTURED: Moody's Cuts Rating on Class D Notes to 'Ba2'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Halcyon Structured Asset Management Long
Secured/Short Unsecured 2007-3 Ltd.:

U.S.$31,500,000 Class A-2 Senior Secured Floating Rate Notes Due
December 29, 2019, Upgraded to Aa1 (sf); previously on Aug 8, 2011
Upgraded to A1 (sf)

U.S.$21,000,000 Class B Senior Secured Deferrable Floating Rate
Notes Due December 29, 2019, Upgraded to A3 (sf); previously on
Aug 8, 2011 Upgraded to Baa2 (sf)

U.S.$9,100,000 Class C Secured Deferrable Floating Rate Notes Due
December 29, 2019, Upgraded to Baa3 (sf); previously on Aug 8,
2011 Upgraded to Ba1 (sf)

U.S.$21,700,000 Class D Secured Deferrable Floating Rate Notes Due
December 29, 2019, Upgraded to Ba2 (sf); previously on Aug 8, 2011
Upgraded to B1 (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 and higher spread levels
compared to the levels assumed at the last rating action in August
2011. Moody's modeled a WARF of 2544 compared to 2762 at the time
of the last rating action and a WAS of 3.85% compared to 2.80% 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 $431.8 million,
defaulted par of $8.5 million, a weighted average default
probability of 17.05% (implying a WARF of 2544), a weighted
average recovery rate upon default of 48.39%, and a diversity
score of 50. 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.

Halcyon Structured Asset Management Long Secured/Short Unsecured
2007-3 Ltd., issued in November 2007, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

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

Moody's modeled the transaction using 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% (2036)

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

Moody's Adjusted WARF + 20% (3053)

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

1) Deleveraging: The main source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will commence on March 29th, 2013 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) Application of Principal Proceeds: Another source of
uncertainty is the extent to which the current cash in the
principal proceeds account, totaling $113 million, will be
reinvested prior to the end of the reinvestment period on December
29th, 2012, or subsequently used to pay down the notes on the
March 29th 2013 payment date. Moody's tested the sensitivity of
the notes' ratings to multiple scenarios, assuming different
levels of reinvestment and redemption.

3) 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.


JP MORGAN 2004-CIBC10: Moody's Cuts Rating on F Certs. to 'Caa2'
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes,
and affirmed the ratings of 12 classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp., Commercial Mortgage Pass-
Through Certificates, Series 2004-CIBC10 as follows:

Cl. A-5, Affirmed at Aaa (sf); previously on Dec 7, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-6, Affirmed at Aaa (sf); previously on Dec 7, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Dec 7, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-J, Affirmed at Aa1 (sf); previously on Dec 10, 2010
Downgraded to Aa1 (sf)

Cl. B, Downgraded to A3 (sf); previously on Dec 10, 2010
Downgraded to A2 (sf)

Cl. C, Downgraded to Baa3 (sf); previously on Dec 10, 2010
Downgraded to Baa1 (sf)

Cl. D, Downgraded to Ba1 (sf); previously on Dec 10, 2010
Downgraded to Baa2 (sf)

Cl. E, Downgraded to B1 (sf); previously on Nov 10, 2011
Downgraded to Ba1 (sf)

Cl. F, Downgraded to Caa2 (sf); previously on Nov 10, 2011
Downgraded to B2 (sf)

Cl. G, Affirmed at Caa3 (sf); previously on Dec 10, 2010
Downgraded to Caa3 (sf)

Cl. H, Affirmed at Ca (sf); previously on Dec 10, 2010 Downgraded
to Ca (sf)

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

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

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

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

Cl. N, Affirmed at C (sf); previously on Nov 19, 2009 Downgraded
to C (sf)

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

Ratings Rationale

The downgrades are due to higher than expected losses for the pool
resulting from realized and anticipated losses from troubled loans
and loans in special servicing, along with concerns about
increased interest shortfalls.

The affirmations are due to key parameters, including Moody's loan
to value (LTV) ratio, Moody's stressed debt service coverage ratio
(DSCR) and the Herfindahl Index (Herf), remaining within
acceptable ranges. Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings. The rating of the IO
Class, Class X-1, is consistent with the expected credit
performance of its referenced classes and thus is affirmed.

Moody's rating action reflects a cumulative base expected loss of
9% of the current balance, the same as at last review. Moody's
current base expected loss plus cumulative realized losses is 7.5%
of the original balance as compared to 6.7% at last review.
Moody's provides a current list of base losses for conduit and
fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating Structured Finance Interest-
Only Securities" published in February 2012.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's review also incorporated the CMBS IO calculator ver 1.1,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point . For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 54, compared to 62 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated November 10, 2011.

DEAL PERFORMANCE

As of the October 12, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 40% to $1.18
billion from $1.96 billion at securitization. The Certificates are
collateralized by 157 mortgage loans ranging in size from less
than 1% to 7% of the pool, with the top ten non-defeased loans
representing 27% of the pool. Seventeen loans, representing 11% of
the pool, have defeased and are secured by U.S. Government
securities.

Thirty-one loans, representing 16% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of its
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Eighteen loans have been liquidated from the pool, resulting in a
realized loss of $40.7 million (18% loss severity). Currently five
loans, representing 11% of the pool, are in special servicing. The
largest specially serviced loan is the Continental Plaza Loan
($88.0 million -- 7.4% of the pool). The loan is secured by three
office buildings and a single story retail center totaling 639,000
square feet (SF) which are located in Hackensack, New Jersey. The
loan was transferred to special servicing in April 2009 due to
imminent default and the property was foreclosed in February 2010.
The property was 62% leased as of July 2012, essentially the same
as last review.

The remaining four specially serviced properties are secured by a
mix of property types. The master servicer has recognized an
aggregate $77.7 million appraisal reduction for all five of the
specially serviced loans. Moody's estimates an aggregate $82
million loss for the specially serviced loans (61% expected loss
on average).

Moody's has assumed a high default probability for ten poorly
performing loans representing 5% of the pool and has estimated an
aggregate $11.2 million loss (17% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2011 operating results for 98%
of the pool. Excluding special serviced and troubled loans,
Moody's weighted average LTV is 85%, essentially the same as at
Moody's prior review. Moody's net cash flow reflects a weighted
average haircut of 11% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.37X and 1.27X, respectively, compared to
1.38X and 1.26X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing conduit loans represent 8.6% of the pool
balance. The largest loan is the Walden Pond at East Moriches Loan
($34.6 million -- 2.9% of the pool), which is secured by a 324-
unit multifamily property located in East Moriches, New York. The
property was 97% leased as of May 2012, compared to 98% at last
review. Performance has improved since last review due to an
increase in base rents at the property. Moody's LTV and stressed
DSCR are 101% and 0.91X, respectively, compared to 109% and 0.85X
at last review.

The second largest loan is the Sherman Tower Center Loan ($34.1
million -- 2.9% of the pool), which is secured by a 285,000 SF
shadow-anchored retail shopping center located in Sherman, Texas.
The center is part of a larger 678,000 SF retail center. The
collateral is shadow-anchored by Target, Home Depot and Wal-Mart.
The property was 100% leased as of March 2012, the same as at last
review. Performance has improved due to an increase in effective
gross income and decrease in operating expenses. Moody's LTV and
stressed DSCR are 89% and 1.10X, respectively, compared to 93% and
1.05X at last review.

The third largest loan is the Fountain Square Loan ($33.2 million
-- 2.8% of the pool), which is secured by three office buildings
representing 242,000 SF located in Boca Raton, Florida. As of June
2012, the subject was 66% leased, compared to 74% at last review
and 80% in 2010. The decline in property performance is mainly due
to the loss of three tenants (12.4% of the NRA) in 2011. In
addition, 25% of the NRA is set to expire in 2013 and an
additional 18% in 2014. Due to the decline in property performance
and the upcoming tenant rollover, Moody's is concerned about the
loan's ability to refinance at the maturity date in November 2014
and views this loan as a troubled loan. Moody's LTV and stressed
DSCR is 137% and 0.71X, respectively, compared to 145% and 0.67X
at last review.


ING INVESTMENT III: Moody's Raises Rating on Cl. C Notes From Ba1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by ING Investment Management CLO III, Ltd.:

U.S.$25,000,000 Class A-2b Floating Rate Notes Due December 13,
2020, Upgraded to Aaa (sf); previously on August 5, 2011 Upgraded
to Aa1 (sf);

U.S.$23,000,000 Class A-3 Floating Rate Notes Due December 13,
2020, Upgraded to Aa2 (sf); previously on August 5, 2011 Upgraded
to Aa3 (sf);

U.S.$29,500,000 Class B Deferrable Floating Rate Notes Due
December 13, 2020, Upgraded to A3 (sf); previously on August 5,
2011 Upgraded to Baa1 (sf);

U.S.$15,500,000 Class C Floating Rate Notes Due December 13, 2020,
Upgraded to Baa3 (sf); previously on August 5, 2011 Upgraded to
Ba1 (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 January 2013. 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 and higher spread levels
compared to the levels assumed at the last rating action in August
2011. Moody's modeled a WARF of 2542 compared to 2652 and a
weighted average spread of 4% compared to 2.79% at the time of the
last rating action. Moody's also notes that the transaction's
reported collateral quality and overcollateralization ratios are
relatively 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 $470 million,
defaulted par of $16 million, a weighted average default
probability of 18.75% (implying a WARF of 2542), a weighted
average recovery rate upon default of 50.31%, and a diversity
score of 77. 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.

ING Investment Management CLO III, 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% (2033)

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

Moody's Adjusted WARF + 20% (3050)

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

1) Deleveraging: The main source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will begin 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.


ING INVESTMENT V: S&P  Affirms 'BB(sf)' Rating on Class D Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B and C notes from ING Investment Management CLO V Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by ING
Alternative Asset Management LLC. "At the same time, we affirmed
our ratings on the class A-1a, A-1b, A-2, and D notes," S&P said.

"The upgrades reflect an improvement in the performance of the
transaction's underlying asset since December 2010, when we
upgraded all of the notes. As of the October 2012 trustee report,
the transaction's underlying portfolio included $1.96 million of
defaulted assets. This was down from the $5.23 million we
referenced for our December 2010 rating actions," S&P said.

The upgrades also reflect an improvement in the
overcollateralization (O/C) available to support the notes. The
trustee reported these O/C ratios in the October 2012 monthly
report:

    The class A O/C ratio was 121.2%, compared with a reported
    ratio of 120.0% in October 2010;
    The class B O/C ratio was 113.9%, compared with a reported
    ratio of 112.7% in October 2010;
    The class C O/C ratio was 108.6%, compared with a reported
    ratio of 107.5% in October 2010; and
    The class D O/C ratio was 106.2%, compared with a reported
    ratio of 105.1% in October 2010.

"We affirmed our ratings on the class A-1a, A-1b, A-2, and D notes
to reflect the credit support available at the current rating
levels," S&P said.

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

          http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

ING Investment Management CLO V Ltd.
                   Rating
Class         To           From
A-1a          AAA (sf)     AAA (sf)
A-1b          AA+ (sf)     AA+ (sf)
A-2           AA- (sf)     AA- (sf)
B             A (sf)       A- (sf)
C             BBB (sf)     BBB- (sf)
D             BB (sf)      BB (sf)

TRANSACTION INFORMATION
Issuer:             ING Investment Management CLO V Ltd.
Coissuer:           ING Investment Management CLO V Inc.
Collateral manager: ING Alternative Asset Management LLC
Trustee:            U.S. Bank N.A.
Transaction type:   Cash flow CDO


LB-UBS 2000-C3: Moody's Raises Rating on Class J Certs. to 'B3'
---------------------------------------------------------------
Moody's Investors Service upgraded the ratings of two classes and
affirmed three classes of LB-UBS Commercial Mortgage Trust 2000-
C3, Commercial Mortgage Pass-Through Certificates, Series 2000-C3
as follows:

Cl. H, Upgraded to Ba1 (sf); previously on Jan 6, 2012 Upgraded to
B1 (sf)

Cl. J, Upgraded to B3 (sf); previously on May 12, 2010 Downgraded
to Caa3 (sf)

Cl. K, Affirmed at C (sf); previously on May 12, 2010 Downgraded
to C (sf)

Cl. L, Affirmed at C (sf); previously on May 12, 2010 Downgraded
to C (sf)

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

Ratings Rationale

The upgrades are due to defeasance, increased credit subordination
due to loan payoffs, and amortization. The pool has paid down by
66% since Moody's last full review.

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

Moody's rating action reflects a cumulative base expected loss of
$9.1 million or 28% of the current balance. At last review,
Moody's cumulative base expected loss was $19.6 million or 20% of
the current balance. Moody's provides a current list of base
losses for conduit and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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 U.S. CMBS Conduit Transactions" published in September
2000, "Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000, and "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's review also incorporated the CMBS IO calculator ver1.1
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit assessments; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point . For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.1
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 4 compared to 8 at Moody's prior review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.5 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated January 6, 2012.

DEAL PERFORMANCE

As of the October 17, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $32.8
million from $1.3 billion at securitization. The Certificates are
collateralized by 9 mortgage loans ranging in size from roughly 4%
to 25% of the pool. The pool consists of three defeased loans
representing 33% of the pool, a credit tenant lease component
representing 14% of the pool, and three specially serviced loans
representing 53% of the pool.

Currently no loans are on the master servicer's watchlist. The
watchlist includes loans which meet certain portfolio review
guidelines established as part of the CRE Finance Council's
(CREFC) monthly reporting package. As part of its ongoing
monitoring of a transaction, Moody's reviews the watchlist to
assess which loans have material issues that could impact
performance.

Thirty-one loans have been liquidated from the pool, resulting in
a realized loss of $37.6 million (28% loss severity).

The largest specially-serviced loan is Peacock Center ($7.3
million -- 22.2% of the pool), which is secured by a 73,000
square-foot neighborhood retail center in Mount Airy, Maryland.
The largest tenant, Super Fresh (A&P), with 76% of the net
rentable area (NRA), rejected its lease in June 2011, reducing
occupancy to 14%. The property is currently real estate owned
("REO").

The second-largest specially-serviced loan is Ballenger Creek
Plaza ($7.2 million -- 21.8% share of the pool), which is secured
by a 76,000 square-foot neighborhood retail center in Frederick,
Maryland. As with Peacock Center, the largest tenant, Super Fresh
(A&P), with 54% of NRA, rejected its lease in June 2011, reducing
occupancy to 29% as of September 2012.

The third-largest specially-serviced loan is Mid America Business
Park II ($2.8 million -- 8.7% share of the pool), which is secured
by a 120,000 square-foot industrial property in Oklahoma City,
Oklahoma. Foreclosure has been filed. Moody's assumed an aggregate
$9.1 million estimated loss (52% expected loss overall) for the
specially serviced loans.

The CTL component consists of three loans secured by bondable
leases. The corporate credits are CVS Caremark Corp. (Moody's
senior unsecured rating Baa2, Outlook - Positive) and Walgreen Co.
(Moody's senior unsecured rating Baa1, Outlook - Negative).

Moody's was provided with full year 2011 or partial year 2012
operating results for 100% of the pool.


LB-UBS 2004-C1: Moody's Cuts Rating on Cl. J Securities to 'Caa1'
-----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of three classes
and affirmed 13 classes of LB-UBS Commercial Mortgage Trust Series
2004-C1 as follows:

Cl. A-3, Affirmed at Aaa (sf); previously on Feb 20, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Feb 20, 2004
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Nov 21, 2006 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Nov 21, 2006 Upgraded
to Aaa (sf)

Cl. D, Affirmed at Aa1 (sf); previously on Nov 21, 2006 Upgraded
to Aa1 (sf)

Cl. E, Affirmed at Aa3 (sf); previously on Nov 21, 2006 Upgraded
to Aa3 (sf)

Cl. F, Affirmed at A1 (sf); previously on Nov 21, 2006 Upgraded to
A1 (sf)

Cl. G, Downgraded to Ba1 (sf); previously on Feb 20, 2004
Definitive Rating Assigned A3 (sf)

Cl. H, Downgraded to B3 (sf); previously on Dec 1, 2011 Downgraded
to B1 (sf)

Cl. J, Downgraded to Caa1 (sf); previously on Dec 1, 2011
Downgraded to B3 (sf)

Cl. K, Affirmed at Caa3 (sf); previously on Aug 4, 2011 Downgraded
to Caa3 (sf)

Cl. L, Affirmed at Ca (sf); previously on Nov 18, 2010 Downgraded
to Ca (sf)

Cl. M, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (sf)

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

Cl. X-ST, Affirmed at A3 (sf); previously on Feb 22, 2012
Downgraded to A3 (sf)

Ratings Rationale

The downgrades are due to interest shortfall concerns. Interest
shortfalls are contained to Class J, which is the same as at
Moody's December 2011 review. However, the amount of shortfalls at
Class J have increased to $106 thousand from $38 thousand at
Moody's previous review. The Passaic Street Industrial Park Loan
($38M -- 3.9% of the pool) was recently modified into a $22M A-
Note and a $16M B-Note. Interest on the B-Note is not payable,
while the interest rate on the A-Note was initially reduced to
4.5% from 6.65%. The modification is causing approximately $128
thousand of recurring monthly shortfalls.

The affirmations for the 11 principal and interest bonds are due
to key parameters, including Moody's loan to value (LTV) ratio,
Moody's stressed DSCR and the Herfindahl Index (Herf), remaining
within acceptable ranges. Based on Moody's current base expected
loss, the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings.

The rating of the IO Classes, Class X-CL and X-ST, are consistent
with the expected credit performance of their referenced classes
and thus are affirmed.

Moody's rating action reflects a cumulative base expected loss of
4.8% of the current pooled balance compared to 4.7% at Moody's
prior review. Moody's provides a current list of base expected
losses for conduit and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 Fusion U.S. CMBS Transactions" published in April 2005,
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000, and "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's review also utilized the IO calculator ver1.1, which uses
the following inputs to calculate the proposed IO rating based on
the published methodology: original and current bond ratings and
credit assessments; original and current bond balances grossed up
for losses for all bonds the IO(s) reference(s) within the
transaction; and IO type as defined in the published methodology.
The calculator then returns a calculated IO rating based on both a
target and mid-point. For example, a target rating basis for a
Baa3 (sf) rating is a 610 rating factor. The midpoint rating basis
for a Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3
(sf) rating factor of 610 and a Ba1 (sf) rating factor of 940). If
the calculated IO rating factor is 700, the CMBS IO calculator
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

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

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel based Large Loan Model v 8.5 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated December 1, 2011.

DEAL PERFORMANCE

As of the October 17, 2012 distribution date, the transaction's
aggregate pooled certificate balance has decreased by 31% to $976
million from $1.4 billion at securitization. The Certificates are
collateralized by 81 mortgage loans ranging in size from less than
1% to 20% of the pool, with the top ten loans representing 63% of
the pool. Ten loans, representing 7% of the pool, have been
defeased and are collateralized with U.S. Government Securities.
Three loans, representing 49% of the pool, have investment grade
credit assessments.

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

Seven loans have been liquidated at a loss from the pool,
resulting in an aggregate realized loss of $13 million (37%
average loss severity). Five loans, representing 4% of the pool,
are currently in special servicing. The largest specially serviced
loan was formerly known as the Colonial Bank Plaza Loan ($15
million -- 1.6%). It is secured by 110,000 square feet (SF) of
office in Las Vegas, Nevada. Colonial Banks was shut down by the
F.D.I.C. in 2009 and is no longer a tenant at the property. The
loan transferred to special servicing in August 2010 and became
real estate owned (REO) in July 2011. The servicer intends to
stabilize the asset and market it for sale in 2013.

The remaining three specially serviced loans are secured by a mix
of office, retail and multifamily property types. The servicer has
recognized an aggregate $21 million appraisal reduction for three
of the four specially serviced loans, while Moody's review
incorporates an aggregate $23 million loss (69% average loss
severity) for all of the specially serviced loans.

Moody's has assumed a high default probability for five poorly
performing loans representing 3% of the pool and has estimated a
$14 million aggregate loss (51% expected loss based on a 72%
probability default) from these troubled loans.

Moody's was provided with full year 2011 and partial year 2012
operating results for 95% and 70% of the pool's non-defeased
loans. Moody's weighted average conduit LTV is 83% compared to 82%
at Moody's prior review. The conduit portion of the pool excludes
specially serviced, troubled and defeased loans as well as the
three loans with credit assessments. Moody's net cash flow
reflects a weighted average haircut of 6% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 9.5%.

Moody's actual and stressed conduit DSCRs are 1.48X and 1.31X,
respectively, compared to 1.43X and 1.31X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The largest loan with a credit assessment is the GIC Office
Portfolio Loan ($190 million -- 19.5%), which is a pari-passu
interest in a $666 million first mortgage loan. The loan is
secured by a portfolio of 12 office properties located in seven
states and totaling 6.4 million SF. The largest geographic
concentrations are Illinois (39%), Pennsylvania (17%) and
California (12%). The portfolio was 87% leased as of March 2012,
which is the same as at last review. The portfolio is also
encumbered by a $119 million B Note. The loan had a 60-month
interest only period, but is now amortizing. The loan matures in
January 2014. Moody's current credit assessment and stressed DSCR
are Baa3 and 1.45X, respectively, compared to Baa3 and 1.44X at
Moody's last review.

The second largest loan with a credit assessment is the UBS Center
-- Stamford Loan ($182 million -- 18.6%), which is secured by the
leasehold interest in a 682,000 SF Class A office property located
in Stamford, Connecticut. The property is 100% leased to UBS AG
and serves as the U.S. headquarters of UBS Investment Bank. The
lease is triple net and expires in December 2017. The loan is
structured with a 23.75 year amortization schedule and matures in
October 2016. Moody's current credit assessment is A3, the same as
at Moody's last review.

The third largest loan with a credit assessment is the MGM Tower
Loan ($110 million -- 11.3%), which is secured by a 777,000 SF
Class A office building located in the Century City office
submarket of Los Angeles, California. The property is also
encumbered by a $76 million B Note. As of July 2012, the property
was 78% leased compared to 84% as of December 2011. MGM previously
occupied approximately 342,000 SF at the tower, however, MGM
declared bankruptcy and vacated all of its space. Although the
sponsor has been able to lease approximately half of the former
MGM space, property performance has declined. The loan has
amortized 16% since securitization, which partially mitigates the
decline in property performance. Moody's current credit assessment
and stressed DSCR are Aa1 and 2.50X, respectively, compared to Aa1
and 2.72X at Moody's last review.

The top three performing conduit loans represent 7% of the pool
balance. The largest conduit loan is the Kurtell Medical Office
Portfolio Loan ($26 million -- 2.7%), which is secured by 212,000
SF contained in five medical office buildings and one out-patient
surgical center located in Nashville, Tennessee (5) and Orlando,
Florida. The portfolio contains one underperforming property, but
the overall portfolio is 94% leased as of June 2012. Moody's LTV
and stressed DSCR are 85% and 1.27X, respectively, compared to 80%
and 1.35X at Moody's last review.

The second largest loan is the Passaic Street Industrial Park A-
Note ($22 million -- 2.2%), which is secured by 2.2 million SF of
Class C industrial warehouse space located in Woodridge, New
Jersey. The loan transferred to special servicing in March 2010
due to imminent monetary default. As previously discussed, the
$38M whole loan was modified with a note bifurcation and an
interest rate reduction in May 2012. The collateral is 62% leased
as of June 2012. Moody's LTV and stressed DSCR for the A-Note are
129% and 0.78X, respectively.

The third largest loan is The Fountains Loan ($19 million --
2.0%), which is secured by a 130,000 SF grocery-anchored retail
center located in Overland Park, Kansas. As of December 2011, the
property was 94% leased, which is the same as at last review.
Moody's LTV and stressed DSCR are 93% and 1.1X, respectively,
compared to 101% and 0.96X at Moody's last review.


LB-UBS 2007-C6: Fitch Lowers Rating on 8 Certificate Classes
------------------------------------------------------------
Fitch Ratings has downgraded eight classes and affirmed 16 classes
of LB-UBS Commercial Mortgage Trust (LBUBS) commercial mortgage
pass-through certificates series 2007-C6.

The downgrades reflect an increase in Fitch expected losses across
the pool, primarily due to updated valuations and workout
strategies on the existing specially serviced loans as well as the
transfer of additional loans to special servicing since Fitch's
December 2011 review.  Fitch modeled losses of 10.5% of the
remaining pool; expected losses on the original pool balance total
12.8%, including losses already incurred.  The pool has
experienced $116.2 million (3.9% of the original pool balance) in
realized losses to date.  Fitch has designated 75 loans (42.4%) as
Fitch Loans of Concern, which includes 56 specially serviced
assets (19.9%).

As of the October 2012 distribution date, the pool's aggregate
principal balance has been reduced by 15.2% to $2.53 billion from
$2.98 billion at issuance.  No loans have defeased since issuance.
Interest shortfalls are currently affecting classes J through T.

The sixth largest loan was impacted recently by Hurricane Sandy,
100 Wall Street (4.6% of the pool) located in the South Ferry
financial district of downtown Manhattan.  Servicer comments and a
walkby inspection by Fitch revealed that the building is currently
off line due to flood damage at the property.  The servicer
reported that the borrower has begun the process for completing
the necessary building repairs including discussions with the
insurance company for the subject property.

The largest contributor to expected losses is the McCandless
Towers loan (4.6% of the pool).  The property, which is also
referred to as the Santa Clara Towers, is collateralized by two
11-story, Silicone Valley office buildings totaling 426,326 square
feet (sf) located in Santa Clara, CA.  The property has
experienced cash flow issues due to occupancy declines, as well as
softening market conditions.  The year-to-date (YTD) June 2011
debt service coverage ratio (DSCR) reported in-line with issuance
at 1.00 times (x), compared to year end (YE) December 2011 at
0.87x. The June 2012 rent roll reported occupancy at 88%, compared
to issuance at 96%.  Significant near term rollover is expected at
the property due to the March 2013 lease expiration of McAfee
Associates Inc., (46% of total net rentable area [NRA]) which
occupies 100% of Tower II (214,080 sf).  As of October 2012, the
loan is current and there are more than $4.6 million in upfront
and ongoing leasing cost reserves.

The next largest contributor to expected losses is the Peco
Portfolio (12.8%), which consists of 39 crossed-collateralized
loans totaling $323.2 million secured by 39 retail properties
located across 13 states, totaling 4.25 million sf.  Primarily
grocery-anchored, the portfolio's major tenants include Tops
Markets, Bi-Lo Grocery, Big Lots, and Publix.  The loans had
recently transferred to special servicing in August 2012 in
response to the borrower's notice of imminent default from cash
flow constraints due to the monthly amortization payments
scheduled to begin with the August 2012 payment date.  The YTD
March 2012 DSCR reported at 1.34x. The annualized YTD March 2012
DSCR based on amortized payments would calculate to approximately
1.08x. The portfolio occupancy reported at 89% as of March 2012.
As of the October 2012 distribution date, the loans are 30-days
delinquent with debt service payments paid through the August 2012
payment date.

The third largest contributor to expected losses is the Greensboro
Park loan (4.3%), which is secured by two office buildings
totaling 485,047 sf located in the Tyson's corner area of McLean,
VA.  The property has experienced cash flow issues due to
occupancy declines since issuance.  The June 2012 rent roll
reported occupancy at 73%, below issuance at 87%. The YTD June
2012 NOI DSCR reported at 0.77x, compared to 1.18x at issuance.
As of the October 2012 distribution date, the loan is current and
there is approximately $9.4 million in reserves, which includes a
$7.5 million letter of credit scheduled to expire in April 2013.

Fitch downgrades the following classes and assigns or revises
Rating Outlooks and Recovery Estimates (REs) as indicated:

  -- $156.4 million class A-J to 'BBB-sf' from 'BBBsf', Outlook to
     Negative from Stable;
  -- $33.5 million class B to 'BBsf' from 'BBB-sf', Outlook
     Negative;
  -- $37.2 million class C to 'Bsf' from 'BBsf', Outlook Negative;
  -- $33.5 million class D to 'CCCsf' from 'Bsf', RE 70%;
  -- $29.8 million class E to 'CCCsf' from 'B-sf', RE 0%;
  -- $29.8 million class F to 'CCsf' from 'CCCsf', RE 0%;
  -- $33.5 million class G to 'CCsf' from 'CCCsf', RE 0%;
  -- $37.2 million class H to 'Csf' from 'CCsf', RE 0%.

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

  -- $227.9 million class A-M at 'AAAsf', Outlook to Negative from
     Stable;
  -- $70 million class A-MFL at 'AAAsf', Outlook to Negative from
     Stable;
  -- $41 million class J at 'Csf', RE 0%;
  -- $29.8 million class K at 'Csf', RE 0%;
  -- $17.8 million class L at 'Dsf', RE 0%;
  -- Class M at 'Dsf', RE 0%;
  -- Class N at 'Dsf', RE 0%;
  -- Class P at 'Dsf', RE 0%;
  -- Class Q at 'Dsf', RE 0%;
  -- Class S at 'Dsf', RE 0%.

Fitch affirms the following classes as indicated:

  -- $218.9 million class A-2 at 'AAAsf', Outlook Stable;
  -- $19.2 million class A-2FL at 'AAAsf', Outlook Stable;
  -- $169 million class A-3 at 'AAAsf', Outlook Stable;
  -- $62.9 million class A-AB at 'AAAsf', Outlook Stable;
  -- $910.4 million class A-4 at 'AAAsf', Outlook Stable;
  -- $369.3 million class A-1A at 'AAAsf', Outlook Stable.

The class A-1 certificates have paid in full.  The balances for
classes M, N, P, Q, S and the unrated class T have been reduced to
zero due to realized losses.  Fitch previously withdrew the rating
on the interest-only class X certificates.


MAPS CLO I: S&P Raises Rating on Class E Notes From 'BB+'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C, D-1, D-2, and E notes from Maps CLO Fund I LLC, a U.S.
collateralized loan obligation (CLO) transaction, managed by
GSO/Blackstone Debt Funds Management. "In addition, we affirmed
our ratings on the class A-1, A-2, A-3, and B notes," S&P said.

"The upgrades reflect $94.08 million in paydowns to the class A
notes, and improvement in the credit quality of the underlying
assets since our last rating action in December 2011. The
affirmations reflect our belief that the credit support available
is commensurate with the current rating levels," S&P said.

"According to the Sept. 21, 2012 note valuation report, class A
notes paid down by $20.45 million. In addition, the transaction
held $35.44 million in 'CCC' rated collateral, down from $57.25
million noted in the Nov. 11, 2011, trustee report, which we used
for our December 2011 rating actions. Furthermore, the amount of
defaulted obligations decreased to $1.41 million from $2.63
million," S&P said.

"When calculating the overcollateralization (O/C) ratios, the
transaction's indenture haircuts a portion of the 'CCC' rated
collateral that exceeds the threshold of 20%. On Sept 21, 2012,
the 'CCC' rated obligation level was 18.75%, compared with 21.56%
noted in the Nov. 11, 2011, trustee report," S&P said.

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

         STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Maps CLO Fund I LLC
         Rating
Class To        From
A-1   AAA (sf)  AAA (sf)
A-2   AAA (sf)  AAA (sf)
A-3   AAA (sf)  AAA (sf)
B     AAA (sf)  AAA (sf)
C     AAA (sf)  AA+ (sf)/Watch Pos
D-1   AA+ (sf)  A+ (sf)/Watch Pos
D-2   AA+ (sf)  A+ (sf)/Watch Pos
E     A (sf)    BB+ (sf)/Watch Pos


MESA 2002-3: Moody's Cuts Rating on Class B-1 RMBS to 'Ba3'
-----------------------------------------------------------
Moody's Investors Service has downgraded the rating of class B-1
issued by MESA 2002-3 Global Issuance Company to Ba3 (sf) from
Baa2 (sf).

Complete rating action is as follows:

Issuer: MESA 2002-3 Global Issuance Company

Cl. B-1, Downgraded to Ba3 (sf); previously on May 23, 2012 Baa2
(sf) Placed Under Review for Possible Downgrade

Ratings Rationale

The action is a result of recent performance of the pool of
mortgages backing the resecuritization bond and reflects Moody's
updated loss expectations on the pool. The bond is backed by a
pool of subprime fixed-rate and adjustable-rate home equity and
home improvement loans.

The methodology used in this rating was "Moody's Approach to
Rating US Resecuritized Residential Mortgage-Backed Securities"
published in February 2011.

Other methodologies used are "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.

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 7.9% in October 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.

As part of the sensitivity analysis, Moody's stressed the updated
loss on the underlying bond by an additional 10% and found that
the implied rating of the resecuritization bond does not change.

A list of these actions including CUSIP identifiers may be found
at: http://moodys.com/viewresearchdoc.aspx?docid=PBS_SF286208


ML-CFC 2007-6: Fitch Affirms Junk Ratings on Five Note Classes
--------------------------------------------------------------
Fitch Ratings has downgraded five classes and affirmed 16 classes
of ML-CFC Commercial Mortgage Trust commercial mortgage pass-
through certificates series 2007-6.

Fitch modeled losses of 20.5% of the remaining pool; expected
losses on the original pool balance total 19.4%, including losses
already incurred.  The pool has experienced $21.5 million (1% of
the original pool balance) in realized losses to date.  The pool
contains 20 specially serviced assets (38.5%), and Fitch has
designated 48 loans as Fitch Loans of Concern.

As of the October 2012 distribution date, the pool's aggregate
principal balance has been reduced by 10.3% to $1.93 billion from
$2.15 billion at issuance.  No loans have defeased since issuance.
Interest shortfalls are currently affecting classes AJ through Q.
The largest contributor to losses was MKSP Retail Portfolio - A2,
which is secured by eight neighborhood, regional, and power
centers located in four distinct markets in Florida.  Five
properties are located in the Orlando metropolitan statistical
area (MSA), one in the Palm Beach MSA, one in the Ft.  Lauderdale
MSA, and one in Port Charlotte in southwest Florida.  Significant
tenants include Publix, Bed Bath & Beyond, Bealls, and Ross Dress
for Less.

Property performance has steadily declined due to weak local
retail markets, which has resulted in lower rents and a drop in
occupancy from 88% at issuance to 78% at June 30, 2012.  The loan
was modified in March 2012 while in special servicing.  Terms of
the modification included the bifurcation of the loan into a
senior ($130.3 million) and junior ($93.1 million) component.
Although losses are not expected imminently, any recovery to the
subject B-note is contingent upon full recovery to the A-note
proceeds at the loan's maturity in March 2019.  Unless collateral
performance improves, recovery to the B-note component is
unlikely.

The second largest contributor to losses was Peter Cooper
Village/Stuyvesant Town (PCV/ST), which is in special servicing.
PCV/ST comprises 56 multi-story buildings, situated on 80 acres,
and includes a total of 11,227 apartments.  The special servicer
has gained control of the property by acquiring the mezzanine debt
of the borrower.  The special servicer is working to stabilize the
asset and has engaged Rose Associates as property manager.
Property performance continues to be below what is needed to
service the debt.  The most recent servicer reported occupancy is
99%.  A litigation affecting over 4,000 units is ongoing
simultaneous with settlement talks to decide future legal rents
and historical overcharge liability.  Per the Special Servicer,
litigation resolution is a prerequisite to optimal capital
recovery, and likely not possible until 2014.

The third largest contributor to losses was MKSP Retail Portfolio
B2, which is secured by one grocery-anchored and one unanchored
retail center in two distinct markets in Florida.  The grocery-
anchored center is located in Ft.  Lauderdale, and the unanchored
center is located in Palm Beach County. Significant tenants
include Winn Dixie and CVS.  Total occupancy on the portfolio has
gradually declined from 92% at issuance to 78% at June 30, 2012,
driven by occupancy at the Palm Beach County property.  The loan
was modified in March 2012 while in special servicing.  Terms of
the modification included the bifurcation of the loan into a
senior ($29.7 million) and junior ($29.7 million) component.
Although losses are not expected imminently, any recovery to the
subject B-note is contingent upon full recovery to the A-note
proceeds at the loan's maturity in March 2019.  Unless collateral
performance improves, recovery to the B-note component is
unlikely.

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

  -- $214.6 million class AM to 'BBsf' from 'BBB-sf', Outlook
     Negative;
  -- $16.1 million class C to 'CCsf' from 'CCCsf', RE 0%;
  -- $34.9 million class D to 'CCsf' from 'CCCsf', RE 0%;
  -- $24.1 million class F to 'Csf' from 'CCsf', RE 0%;
  -- $24.1 million class G to 'Csf' from 'CCsf', RE 0%.

Fitch affirms the following classes but assigns or revises REs as
indicated:

  -- $107.4 million class AJ at 'CCCsf', RE 100%;
  -- $75 million class AJ-FL at 'CCCsf', RE 25%;
  -- $42.9 million class B at 'CCCsf', RE 0%;
  -- $18.8 million class E at 'CCsf', RE 0%;
  -- $26.8 million class H at 'Csf', RE 0%.

Fitch affirms the following classes as indicated:

  -- $83 million class A-2 at 'AAAsf', Outlook Stable;
  -- $73 million class A-2FL at 'AAAsf', Outlook Stable;
  -- $60.7 million class A-3 at 'AAAsf', Outlook Stable;
  -- $729 million class A-4 at 'AAAsf', Outlook Stable;
  -- $345.4 million class A-1A at 'AAAsf', Outlook Stable;
  -- $5.4 million class J at 'Csf', RE 0%;
  -- $5.4 million class K at 'Csf', RE 0%;
  -- $5.4 million class L at 'Csf', RE 0%;
  -- $5.4 million class M at 'Csf', RE 0%;
  -- $5.4 million class N at 'Csf', RE 0%;
  -- $5.4 million class P at 'Csf', RE 0%.

Fitch previously withdrew the rating on the interest-only class X
certificates.  Class A-1 has paid in full, and class Q is not
rated by Fitch.


MORGAN STANLEY 2000-PRIN: Moody's Affirms Ba3 Rating on X Certs.
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of six classes of
Morgan Stanley Dean Witter Capital I Inc., Commercial Mortgage
Pass-Through Certificates, Series 2000-PRIN as follows:

Cl. A-4, Affirmed at Aaa (sf); previously on Nov 7, 2000
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Jul 19, 2006 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Aug 29, 2007 Upgraded
to Aaa (sf)

Cl. D, Affirmed at Aaa (sf); previously on Nov 10, 2011 Upgraded
to Aaa (sf)

Cl. E, Affirmed at Aa1 (sf); previously on Nov 10, 2011 Upgraded
to Aa1 (sf)

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

Ratings Rationale

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

Moody's rating action reflects a cumulative base expected loss of
2.7% of the current balance. At last full review, Moody's
cumulative base expected loss was 3.0%. Moody's provides a current
list of base expected losses for conduit and fusion CMBS
transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

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

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 16 compared to 19 at Moody's prior full review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.5 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated November 10, 2011.

DEAL PERFORMANCE

As of the October 23, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 87% to $79.41
million from $597.99 million at securitization. The Certificates
are collateralized by 31 mortgage loans ranging in size from less
than 1% to 12% of the pool, with the top ten loans representing
66% of the pool.

Ten loans, representing 27% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of its
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Two loans have been liquidated from the pool since securitization,
resulting in an aggregate $590,000 loss (1% loss severity on
average). There are currently no loans in special servicing.

Moody's has assumed a high default probability for one poorly
performing loan representing 6% of the pool and has estimated a
$1.17 million loss (25% expected loss based on a 50% probability
default) from this troubled loan.

Moody's was provided with full year 2011 operating results for 96%
of the performing pool. Excluding the troubled loan, Moody's
weighted average LTV is 41% compared to 42% at last full review.
Moody's net cash flow reflects a weighted average haircut of 11%
to the most recently available net operating income. Moody's value
reflects a weighted average capitalization rate of 9.7%.

Excluding the troubled loan, Moody's actual and stressed DSCRs are
1.49X and 3.65X, respectively, compared to 1.44X and 3.42X at last
review. Moody's actual DSCR is based on Moody's net cash flow
(NCF) and the loan's actual debt service. Moody's stressed DSCR is
based on Moody's NCF and a 9.25% stressed rate applied to the loan
balance.

The top three performing loans represent 31% of the pool. The
largest loan is the Liberty Square Shopping Center Loan ($13.5
million --17.0% of the pool), which is secured by a 346,385 square
foot (SF) retail center located in Burlington (Burlington County),
New Jersey. The center is anchored by Wal-Mart, ACME Supermarket
and Marshall's. As of December 2011, the property was 89% leased,
same as at last review. Marshall's (10.5% of net rentable area)
has a lease expiration in January 2013. However, property
performance has been stable and the loan is benefitting from
amortization. Moody's LTV and stressed DSCR are 49% and 2.06X,
respectively, compared to 51% and 1.96X at last review.

The second largest loan is the Stop & Shop Loan ($6.06 million --
7.6% of the pool), which is secured by a 190,000 SF anchored
retail center located in 15 miles southwest of Boston,
Massachusetts. The collateral is located along US Route 1, a main
commercial corridor. Home Depot, which occupies 61% of the gross
leasable area (GLA), owns its own improvements has a 97-year
ground lease through September 2097. Home Depot has prepaid the
ground rent for its parcel and does not pay reimbursements. Stop &
Shop, which leases 34% of the GLA, has a 21-year lease through
June 2018. No other tenant occupies more than 2% of the GLA. As of
December 2011, the property was 98% leased, same as at last
review. Moody's LTV and stressed DSCR are 81% and 1.29X,
respectively, compared to 82% and 1.28X, at last review.

The third largest loan is the 5560 Katella Avenue Loan ($5.42
million -- 6.8% of the pool), which is secured by a 215,000 SF
single-tenant industrial property located in Cypress, California.
The property is 100% leased to Global Experience Specialist
through December 2015. Property performance has declined slightly
due to a decline in base rents. However, the loan is benefitting
from amortization. Moody's LTV and stressed DSCR are 58% and
1.78X, respectively, compared to 58% and 1.77X at last review.


MORGAN STANLEY 2007-TOP25: Moody's Cuts Ratings on 2 Certs. to 'C'
------------------------------------------------------------------
Moody's Investors Service downgraded the ratings of six classes
and affirmed six classes of Morgan Stanley Commercial Mortgage
Pass-Through Certificates, Series 2007-TOP25 as follows:

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

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

Cl. A-3, Affirmed at Aaa (sf); previously on Feb 2, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Feb 2, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at A1 (sf); previously on Nov 10, 2011
Downgraded to A1 (sf)

Cl. A-J, Downgraded to B1 (sf); previously on Nov 10, 2011
Downgraded to Ba3 (sf)

Cl. B, Downgraded to Caa2 (sf); previously on Nov 10, 2011
Downgraded to Caa1 (sf)

Cl. C, Downgraded to Caa3 (sf); previously on Nov 10, 2011
Downgraded to Caa2 (sf)

Cl. D, Downgraded to Ca (sf); previously on Nov 10, 2011 Confirmed
at Caa3 (sf)

Cl. E, Downgraded to C (sf); previously on Nov 10, 2011 Confirmed
at Ca (sf)

Cl. F, Downgraded to C (sf); previously on Nov 10, 2011 Confirmed
at Ca (sf)

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

Ratings Rationale

The downgrades are due to higher expected losses from specially
serviced and troubled loans. The affirmations of the principal
classes are due to sufficient credit enhancement levels for the
current ratings. Based on Moody's current base expected loss, the
credit enhancement levels for the affirmed classes are sufficient
to maintain their ratings. The rating of the IO Class, Class X is
consistent with the expected credit performance of its referenced
classes and thus is affirmed.

Moody's rating action reflects a base expected loss of 6.4% of the
current balance compared to 9.3% at last review. Moody's provides
a current list of base expected losses for conduit and fusion CMBS
transactions on moodys.com at
http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 Fusion Transactions" published in April 2005, and "Moody's
Approach to Rating Structured Finance Interest-Only Securities"
published in February 2012.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying credit assessment of the loan which corresponds to a
range of credit enhancement levels. Actual fusion credit
enhancement levels are selected based on loan level diversity,
pool leverage and other concentrations and correlations within the
pool. Negative pooling, or adding credit enhancement at the
underlying rating level, is incorporated for loans with similar
credit assessments in the same transaction.

Moody's review also incorporated the CMBS IO calculator ver1.1
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point. For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.1
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 49, compared to 50 at last review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated November 10, 2011.

DEAL PERFORMANCE

As of the October 12, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 11% to $1.39
billion from $1.56 billion at securitization. The Certificates are
collateralized by 193 mortgage loans ranging in size from less
than 1% to 7% of the pool. There are two loans, representing 3.1%
of the pool with credit assessments. There are no defeased loans
at this time.

Fifty loans, representing 15% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of its
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Seven loans have been liquidated from the pool since
securitization, resulting in an aggregate $68.8 million loss (83%
loss severity on average). Currently six loans, representing 2% of
the pool, are in special servicing. The specially serviced loans
are secured by a mix of property types. Moody's has estimated an
aggregate $14.0 million loss (57% expected loss on average) for
all of the specially serviced loans.

Moody's has assumed a high default probability for 18 poorly
performing loans representing 6% of the pool and has estimated an
aggregate $17.5 million loss (20% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2011 and partial year 2012
operating results for 98% and 80% of the performing pool
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 100% compared to 102% at last full
review. Moody's net cash flow reflects a weighted average haircut
of 10.3% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.6%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.60X and 1.17X, respectively, compared to
1.47X and 1.08X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit assessment is the London NYC Hotel
Land Interest Loan ($27.0 million -- 1.9% of the pool), which is
secured by the ground lease under the 564-room London NYC Hotel
situated on West 54th Street in New York City. The loan is
interest-only for the entire 10 year term and matures in November
2016. Moody's current credit assessment and stressed DSCR are Aaa
and 2.71X, respectively, the same as at last review.

The second loan with a credit assessment is the 24 Fifth Avenue
Coop Loan ($15.5 million -- 1.1% of the pool), which is secured by
a 419-unit Class A residential coop building located on lower
Fifth Avenue in New York City. The loan is interest only for the
entire 10-year term. Despite the stable occupancy, the overall
performance has declined due to a 43% increase in property taxes
since 2008. Moody's current credit assessment and stressed DSCR
are Aaa and 2.67X, respectively, compared to Aaa and 2.70X at last
review.

The top three performing conduit loans represent 17% of the pool
balance. The largest loan is the Mount Pleasant Towne Centre Loan
($95.2 million -- 6.9% of the pool), which is secured by a 443,000
square foot (SF) regional outdoor mall located in Mount Pleasant
South Carolina, which is just outside of Charleston. The mall is
anchored by Belk, and the largest tenants include Bed Bath and
Beyond, Old Navy, Barnes and Noble, and Consolidated theaters. The
loan is interest only throughout the term and matures in 2016. As
of March 2012, the property was 93% leased compared to 91% at last
review. Moody's LTV and stressed DSCR are 128% and 0.72X,
respectively, compared to 135% and 0.68X at last review.

The second largest conduit loan is the Four Seasons Hotel Loan
($72.0 million -- 5.2% of the pool), which is secured by a 285-
room luxury hotel located in Los Angeles, California. The loan is
interest only throughout the term and matures in 2016. The
performance has declined significantly since 2008 due to low
occupancy and general decline in the hotel market but over the
past year has begun to show improvement. Moody's LTV and stressed
DSCR are 110% and 1.01X, respectively, compared to 168% and 0.67X
at last review.

The third largest conduit loan is the Shoppes at Park Place Loan
($71.0 million -- 5.1% of the pool), which is secured by a 325,000
SF foot regional outdoor mall located in Pinellas Park Florida,
about 15 miles west of Tampa Florida. The largest tenants are
Regal Cinemas and American Signature Furniture. The mall is shadow
anchored by Target and Home Depot. The property was 99% leased as
of June 2012 compared to 100% at last review. The loan is interest
only throughout the term and matures in 2017. The property's
performance has remained stable over the life of the loan. Moody's
LTV and stressed DSCR are 133% and 0.73X, respectively, compared
to 130% and 0.75X at last review.


MOTEL 6 TRUST: Fitch Rates $20 Million Class E Notes 'BB+sf'
------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Motel 6 Trust 2012-MTL6 Commercial Mortgage Pass-
Through Certificates Series 2012-MTL6:

  -- $105,000,000 class A-1 'AAAsf'; Outlook Stable;
  -- $404,500,000 class A-2 'AAAsf'; Outlook Stable;
  -- $404,500,000* class XA-1 'AAAsf'; Outlook Stable;
  -- $509,500,000* class XA-2 'AAAsf'; Outlook Stable;
  -- $540,500,000* class XB-1 'BB+sf'; Outlook Stable;
  -- $540,500,000* class XB-2 'BB+sf'; Outlook Stable;
  -- $189,900,000 class B 'AA-sf'; Outlook Stable;
  -- $145,100,000 class C 'A-sf'; Outlook Stable;
  -- $185,500,000 class D 'BBB-sf'; Outlook Stable;
  -- $20,000,000 class E 'BB+sf'; Outlook Stable.

* Notional amount and interest only.


MOTEL 6 TRUST: S&P Rates $20-Mil. Class E Certificates 'BB+'
------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Motel 6
Trust 2012-MTL6's $1.05 billion commercial mortgage pass-through
certificates series 2012-MTL6.

"The note issuance is a commercial mortgage-backed securities
transaction backed by a $1.05 billion commercial mortgage loan
secured by (1) 508 limited-service and extended-stay hotels; (2)
intellectual property (IP), including a borrower's interests in
the IP license agreements; (3) the payment guarantor's equity
interests in the IP borrower and the franchisors; and (4) a
pledge of all cash flows from nine properties with ground leases
that have not been assigned to the borrowers or do not permit a
mortgage," S&P said.

"The ratings reflect our view of the transaction's structure, the
collateral's historical and projected performance, the sponsor's
and manager's experience, the trustee-provided liquidity, the
loan's terms, and the relative diversity of the collateral pool.
Our ratings also reflect the borrower's preliminary assessment
that the properties located in the 14 states where the Hurricane
made landfall (on Oct. 29, 2012) were not materially affected,"
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 Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at:

     http://standardandpoorsdisclosure-17g7.com/1058.pdf

RATINGS ASSIGNED

Motel 6 Trust 2012-MTL6

Class       Rating                Amount
                                (mil. $)
A-1         AAA (sf)         105,000,000
A-2         AAA (sf)         404,500,000
XA-1        AAA (sf)      404,500,000(i)
XA-2        AAA (sf)      509,500,000(i)
XB-1        BB+ (sf)      540,500,000(i)
XB-2        BB+ (sf)      540,500,000(i)
B           AA- (sf)         189,900,000
C           A- (sf)          145,100,000
D           BBB- (sf)        185,500,000
E           BB+ (sf)          20,000,000
R           NR                       N/A

(i) Notional balance.
NR - Not rated.
N/A - Not applicable.


MORGAN STANLEY 2007-8: S&P Lowers rating on Class A2 Notes to 'B-'
------------------------------------------------------------------
Standard & Poor's Ratings Services corrected its ratings on the
senior and A2 notes from Morgan Stanley ACES SPC's series 2007-8
by lowering them to 'BB+ (sf)' from 'A- (sf)' and 'B- (sf)' from
'BBB- (sf)'. The transaction is an investment-grade corporate-
backed synthetic collateralized debt obligation (CDO) transaction.

S&P raised the ratings on the senior and A2 notes to 'A- (sf)' and
'BBB- (sf)', respectively, on Nov. 5, 2012, due to an error.

            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

RATINGS CORRECTED

Morgan Stanley ACES SPC
Series 2007-8
                         Rating
Class               To                  From
Senior              BB+ (sf)            A- (sf)
A2                  B- (sf)             BBB- (sf)


MORGAN STANLEY 2007-IQ16: Fitch Cuts Ratings on 11 Cert. Classes
----------------------------------------------------------------
Fitch Ratings has downgraded 11 classes and affirmed 11 classes of
Morgan Stanley Capital I (MSCI) Trust commercial mortgage pass-
through certificates, series 2007-IQ16, due to increased loss
expectations from loans in special servicing and further
deterioration of collateral performance.

Fitch modeled losses of 10.5% of the remaining pool; expected
losses on the original pool balance total 9.6%.  Fitch has
designated 60 loans (21.9%) as Fitch Loans of Concern, which
includes 23 specially serviced assets (14.5%).

As of the October 2012 distribution date, the pool's aggregate
principal balance has been reduced by 12.1% to $2.28 billion from
$2.6 billion at issuance.  Per the servicer reporting, one loan
(0.2% of the pool) has defeased since issuance.  Interest
shortfalls are currently affecting classes J through S.

The largest contributor to expected losses is the specially-
serviced Hilton Daytona Beach loan (4.2% of the pool), which is
secured by a 744-key, full-service hotel located in Daytona Beach,
Florida.  The loan transferred to special servicing in October
2011 due to imminent default. As of September 2012, the hotel
achieved year-to-date occupancy, ADR, and RevPAR of 71.9%,
$138.94, and $99.94, respectively, surpassing its competitive set
averages of 64.8%, $119.33, and $77.31.  Results over the same
period in 2011 for year-to-date occupancy, ADR, and RevPAR were
71.2%, $135.43, and $96.40, respectively.  The borrower and
special servicer are in discussion on a strategy for resolution,
with modification terms being evaluated.

The next largest contributor to expected losses is the specially-
serviced Ashtabula Mall loan (1.7%), which is secured by a 754,882
sf regional mall located in Ashtabula, OH.  Performance of the
mall continues to deteriorate with the departure of Sears in June
2012.  The mall has only two remaining anchors from the original
five at issuance.  The remaining anchors are JC Penney and K-Mart.
The mall was 49.7% occupied as of August 2012.  The loan is in
foreclosure proceedings, and a receiver was appointed in October
2011. Fitch anticipates significant losses based on recent
valuations.

The third largest contributor to expected losses is the Milford
Crossing loan (3.3%), which is secured by a 379,685 sf retail
property located in Milford, CT.  As of June 2012, occupancy of
the center improved to 96% from 89% at YE 2011 due to the signing
of a new lease in the vacant Circuit City space.  As of June 2012,
DSCR of the property was 0.82x but is anticipated to improve with
the commencement of the new lease.  The loan is current as of
October 2012.

The second largest loan (5.5% of collateral balance) in the pool,
60 Wall Street, was affected by Hurricane Sandy and was without
power for a period of time.  As of Nov. 2, 2012, the servicer has
advised that no adverse material damages to the building have
occurred. Based on a cursory inspection by a Fitch analyst on Nov.
14, 2012, it appeared to be open, but several buildings in the
vicinity were damaged; a large boiler was on the street in front
of the subject property.

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

  -- $131 million class A-J to 'Bsf' from 'BBBsf', Outlook
     Negative;

  -- $30 million class A-JFL to 'Bsf' from 'BBBsf', Outlook
     Negative;

  -- $33.7 million class A-JA to 'Bsf' from 'BBBsf', Outlook
     Negative;

  -- $19.5 million class B to 'CCCsf' from 'BBsf', RE 60%;

  -- $26 million class C to 'CCCsf' from 'BBsf', RE 0%;

  -- $16.2 million class D to 'CCCsf' from 'Bsf', RE 0%;

  -- $38.9 million class E to 'CCsf' from 'CCCsf', RE 0%;

  -- $13 million class F to 'Csf' from 'CCCsf', RE 0%;

  -- $35.7 million class G to 'Csf' from 'CCCsf', RE 0%;

  -- $26 million class H to 'Csf' from 'CCsf', RE 0%;

  -- $6.7 million class L to 'Dsf' from 'Csf', RE 0%.

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

  -- $210.2 million class A-1A at 'AAAsf', Outlook Stable;

  -- $17.3 million class A-2 at 'AAAsf', Outlook Stable;

  -- $83 million class A-3 at 'AAAsf', Outlook Stable;

  -- $1.3 billion class A-4 at 'AAAsf', Outlook Stable;

  -- $194.7 million class A-M at 'AAAsf', Outlook to Negative from
     Stable;

  -- $20 million class A-MFL at 'AAAsf', Outlook to Negative from
     Stable;

  -- $44.9 million class A-MA at 'AAAsf', Outlook to Negative from
     Stable;

  -- $26 million class J at 'Csf', RE 0%;

  -- $32.4 million class K at 'Csf', RE 0%;

  -- $0 class M at 'Dsf', RE 0%;

  -- $0 class N at 'Dsf', RE 0%.

Class A-1 has paid in full.  Fitch does not rate the class O, P, Q
and S certificates.  Fitch previously withdrew the ratings on the
interest-only class X-1 and X-2 certificates.


MSCI 2004-RR2: Fitch Affirms 'CCC' Rating on 4 Note Classes
-----------------------------------------------------------
Fitch Ratings has affirmed 12 classes issued by MSCI 2004-RR2 as a
result of stable performance on the underlying portfolio since the
last rating action.

Since Fitch's last rating action in December 2011, approximately
22.9% of the underlying collateral has been upgraded.  Currently,
55.2% of the portfolio has a Fitch derived rating below investment
grade and 15.2% has a rating in the 'CCC' category and below,
compared to 60.7% and 13% at the last rating action.  Over this
time, the class A-2 notes have received $19.7 million for a total
of $87.7 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 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.  Additionally, Fitch performed a
deterministic scenario where recovery estimate on the distressed
collateral was modeled in accordance with the principal waterfall.
An asset by asset analysis was then performed for the remaining
assets to determine the collateral coverage for the remaining
liabilities.  Based on this analysis, the credit enhancement for
the class A-2 through J notes is consistent with the current
rating of the notes.

For the class K 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 K through M notes have been affirmed at 'CCCsf',
indicating that default is possible.

The Stable Outlook on the class A-2 notes reflects Fitch's
expectation that the notes will continue to delever.  The Negative
Outlook on the class B through H notes reflects the risk of
adverse selection as the portfolio continues to amortize.

MSCI 2004-RR2 is a static Re-Remic backed by commercial mortgage
backed securities (CMBS) B-pieces that closed June 29, 2004.  The
transaction is collateralized by 13 CMBS assets from 11 obligors
from the 1997-2000 vintages.

Fitch has affirmed the following classes:

  -- $21,324,734 class A-2 notes at 'AAAsf'; Outlook to Stable
     from Negative;
  -- $30,164,000 class B notes at 'BBBsf'; Outlook Negative;
  -- $15,082,000 class C notes at 'BBsf'; Outlook Negative;
  -- $5,299,000 class D notes at 'BBsf'; Outlook Negative;
  -- $12,229,000 class E notes at 'Bsf'; Outlook Negative;
  -- $3,261,000 class F notes at 'Bsf'; Outlook Negative;
  -- $6,930,000 class G notes at 'Bsf'; Outlook Negative;
  -- $3,668,000 class H notes at 'Bsf'; Outlook Negative;
  -- $2,446,000 class J notes at 'CCCsf';
  -- $2,446,000 class K notes at 'CCCsf';
  -- $2,446,000 class L notes at 'CCCsf';
  -- $1,630,000 class M notes at 'CCCsf'.


N-STAR REAL III: Fitch Affirms Junk Rating on Five Note Classes
---------------------------------------------------------------
Fitch Ratings has downgraded four and affirmed five classes of N-
Star Real Estate CDO III Ltd. (N-Star III) as a result of
significant negative credit migration on the underlying
collateral.

Since Fitch's last rating action in November 2011, approximately
32.4% of the collateral has been downgraded and 2.9% has been
upgraded.  Currently, 93.2% of the portfolio has a Fitch-derived
rating below investment grade and 73.6% has a rating in the 'CCC'
category and below, compared to 72.5% and 43.7%, respectively, at
the last rating action.  Similarly, the percentage of the
portfolio considered defaulted per the trustee has increased since
the last rating action to 33.1% from 11%.  Over this period, the
class A-1 notes have received $131.5 million in pay-downs, of
which approximately $118.1 million of the proceeds are from the
sale of credit risk securities.

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 notes' breakeven
rates are generally consistent with the ratings assigned below.

For the class B through D 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 B and C-1 notes have been downgraded and the class C-2
and D notes affirmed at 'CCsf', indicating that default is
probable.  The class C through D notes are currently receiving
interest paid in kind (PIK) whereby the principal amount of the
notes is written up by the amount of interest due.

N-Star III is a collateralized debt obligation (CDO) that closed
on March 10, 2005.  The transaction is backed by 58 securities
from 54 obligors.  The current portfolio consists of 87.1%
commercial mortgage backed securities (CMBS) from the 1999 through
2009 vintages, 7.6% are commercial real estate loans (CRELs), and
5.3% are structured finance CDOs (SF CDOs).

Fitch has taken the following actions as indicated:

  -- $113,179,372 class A-1 notes downgraded to 'CCCsf' from
     'Bsf';
  -- $14,872,148 class A-2A notes affirmed at 'CCCsf';
  -- $4,957,383 class A-2B notes affirmed at 'CCCsf';
  -- $14,872,148 class B notes downgraded to 'CCsf' from 'CCCsf';
  -- $4,994,735 class C-1A notes downgraded to 'CCsf' from
     'CCCsf';
  -- $6,123,596 class C-1B notes downgraded to 'CCsf' from
     'CCCsf';
  -- $9,313,215 class C-2A notes affirmed at 'CCsf';
  -- $2,044,563 class C-2B notes affirmed at 'CCsf';
  -- $9,582,839 class D notes affirmed at 'CCsf'.


N-STAR REAL IX: Fitch Affirms Junk Ratings on 10 Note Classes
-------------------------------------------------------------
Fitch Ratings has downgraded two and affirmed 10 classes issued by
N-Star Real Estate CDO IX Ltd. (N-Star IX) as a result of
continued negative credit migration since the last rating action.

Since the last rating action in December 2011, approximately 42%
of the collateral has been downgraded.  Currently, 91.3% of the
portfolio has a Fitch derived rating below investment grade and
62.9% has a rating in the 'CCC' category and below, compared to
85.8% and 52.5%, respectively, at the last rating action.  Over
this period, the class A notes have received $5 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-1 and A-2 notes'
breakeven rates are generally consistent with the ratings assigned
below.

For the class A-3 through K 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 A-3
notes have been downgraded and the B through J notes have been
affirmed at 'CCsf', indicating that default is probable.
Similarly, the class K notes have been affirmed at 'Csf',
indicating that default is inevitable.

N-Star IX is a revolving collateralized debt obligation (CDO)
which closed Feb. 28, 2007.  The portfolio is composed of 78%
commercial mortgage-backed securities (CMBS), 14.6% of commercial
real estate loans (CREL), 6.1% of structured finance CDOs (SF
CDOs), 0.8% of residential mortgage-backed securities, and 0.5%
real estate investment trust securities (REITs).

Fitch has taken the following actions as indicated:

  -- $506,960,107 class A-1 downgraded to 'CCCsf' from 'Bsf';
  -- $96,000,000 class A-2 affirmed at 'CCCsf'
  -- $48,000,000 class A-3 downgraded to 'CCsf' from 'CCCsf';
  -- $32,000,000 class B affirmed at 'CCsf';
  -- $12,800,000 class C affirmed at 'CCsf';
  -- $15,200,000 class D affirmed at 'CCsf';
  -- $4,800,000 class E affirmed at 'CCsf';
  -- $3,600,000 class F affirmed at 'CCsf';
  -- $5,580,000 class G affirmed at 'CCsf';
  -- $5,000,000 class H affirmed at 'CCsf';
  -- $7,040,000 class J affirmed at 'CCsf';
  -- $6,000,000 class K affirmed at 'Csf'.


NOMURA CRE: Fitch Affirms Junk Rating on 16 Note Classes
--------------------------------------------------------
Fitch Ratings has affirmed all classes of Nomura CRE CDO 2007-2,
Ltd. /LLC (Nomura 2007-2) reflecting Fitch's base case loss
expectation of 34.2%.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market value and cash flow declines.

Since the latest rating action and as of the September 2012
trustee report, the transaction has paid down by $8 million (0.7%
of the original deal balance) and has realized losses of
approximately $79 million as a result of two loans paying off in
full and four loans disposed of with losses.  The disposed loans
had a weighted average loss rate of 56%.  The asset manager added
18 new assets with built par of approximately $1.9 million.  The
percentage of defaulted assets and Fitch Loans of Concern have
decreased to 36.3% and 11.1%, respectively, compared to 47.4% and
21.1% at the latest rating action.  The Fitch derived weighted
average rating of the rated securities has improved to 'B-/CCC+'
from 'CC'. One additional loan (11.7% of current pool) was removed
at a 99% recovery subsequent to the September 2012 trustee report.

Nomura 2007-2 is a commercial CRE CDO managed by C-III Investment
Management LLC. The transaction has a five-year reinvestment
period that ends in February 2013.  As of the September 2012
trustee report and per Fitch categorizations, the CDO was
substantially invested as follows: whole loans/A-note (71.3%), B-
notes (13.6%), commercial mortgage-backed securities (CMBS: 8.2%),
CRE CDO (4.4%), CRE mezzanine loans (2.2%), and principal cash
(0.3%).

As of the September 2012 trustee report, all overcollateralization
ratios have breached their covenants.  Classes D and below are not
receiving any interest payments.  Interest is being capitalized on
these classes; total capitalized interest to date is $13.5
million.

Fitch was notified by the asset manager of its proposal to replace
the banking institution for the CDO's eligible accounts to
Citibank, N.A. from Bank of America. Citibank N.A. is currently
rated 'A/F1' by Fitch and according to Fitch's criteria,
'Counterparty Criteria for Structured Finance Transactions,' dated
May 30, 2012, satisfies Fitch's eligibility criteria for the
Nomura 2007-2 transaction.  The agency would not expect to
downgrade or withdraw the note ratings of the transaction as a
result of the replacement.

Under Fitch's methodology, approximately 70% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled average cash flow
decline is 7.7% from, generally, either year end 2011 or trailing
12-month second quarter 2012. Fitch estimates recoveries to be
51.1%.

The largest component of Fitch's base case loss expectation is a
B-note (6.6%) secured by a portfolio of 20 office properties
located in Washington, D.C. and Seattle, WA.  The senior loan and
B-note were both transferred to special servicing in April 2010
for imminent default.  The borrower and the special servicer have
negotiated a modification whereby the asset manager expects no
interest payments to the B-note during the extension period.
Fitch modeled a full loss on this B-note position.

The next largest component of Fitch's base case loss expectation
is a whole loan (8.5%) secured by a 347,972 square foot (sf)
office property located in San Diego, CA.  The asset is real-
estate owned (REO) as of December 2011.  The property is under
contract for sale with a closing date expected prior to the end of
the year. Fitch modeled a term default with a substantial loss in
its base case scenario.

The third largest component of Fitch's base case loss expectation
is a whole loan (3%) secured by a 287,070 sf retail property
located in Cleveland, OH.  The loan defaulted during the first
half of 2010 when the borrower ceased making debt service
payments.  As of March 2012, the property was 43% occupied.  The
property lost its anchor grocery tenant in December 2006.  Since
the property has a 30-year TIF obligation and no leasing traction,
the asset manager expects no recovery. Fitch modeled a full loss.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio tests to project future default levels
for the underlying portfolio.

Recoveries are based on stressed cash flows and Fitch's long-term
capitalization rates.  The default levels were then compared to
the breakeven levels generated by Fitch's cash flow model of the
CDO under the various default timing and interest rate stress
scenarios, as described in the report 'Global Criteria for Cash
Flow Analysis in CDOs'.  The breakeven rates for classes A-1 and
A-R are generally consistent with the ratings listed below.

The ratings for classes A-2 through O are based on a deterministic
analysis that considers Fitch's base case loss expectation for the
pool and the current percentage of defaulted assets and Fitch
Loans of Concern factoring in anticipated recoveries relative to
each classes credit enhancement.

Fitch has affirmed the following classes:

  -- $452.7 million class A-1 at 'CCCsf'; RE 100%;
  -- $72.1 million class A-R at 'CCCsf'; RE 100%;
  -- $60.7 million class A-2 at 'CCCsf'; RE 15%;
  -- $70.5 million class B at 'CCCsf'; RE 0%;
  -- $26.6 million class C at 'CCCsf'; RE 0%;
  -- $27.8 million class D at 'CCsf'; RE 0%;
  -- $21 million class E at 'CCsf'; RE 0%;
  -- $22.3 million class F at 'CCsf'; RE 0%;
  -- $25.8 million class G at 'Csf'; RE 0%;
  -- $21 million class H at 'Csf'; RE 0%;
  -- $26.4 million class J at 'Csf'; RE 0%;
  -- $25.2 million class K at 'Csf'; RE 0%;
  -- $9.9 million Class L at 'Csf'; RE 0%;
  -- $6.5 million Class M at 'Csf'; RE 0%;
  -- $9.5 million Class N at 'Csf'; RE 0%;
  -- $15.7 million Class O at 'Csf'; RE 0%.


OCP CLO 2012-2: S&P Rates $20MM Class E Deferrable Notes 'BB+'
--------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to OCP CLO
2012-2 Ltd./OCP CLO 2012-2 Corp.'s $471.875 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 it 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/1113.pdf

RATINGS ASSIGNED

OCP CLO 2012-2 Ltd./OCP CLO 2012-2 Corp.

Class                               Rating            Amount
                                                    (mil. $)
X1                                  AAA (sf)           3.750
X2                                  AAA (sf)           3.750
A1                                  AAA (sf)         162.500
A2                                  AAA (sf)         158.750
B                                   AA (sf)           65.625
C (deferrable)                      A (sf)            35.000
D (deferrable)                      BBB (sf)          22.500
E (deferrable)                      BB (sf)           20.000
Combination notes (deferrable)(i)   A (sf)           213.400
Subordinated notes                  NR                49.500

(i) Combination notes consist of an aggregate amount of up to
    $213,399,805, with the components consisting of up to
    $162,500,000 of the class A1 notes, $33,195,525 of the class B
    notes, and $17,704,280 of the class C notes. On the closing
    date, the issuer will have a total of $174,500,000 of
    combination notes outstanding, consisting of $132,878,519 of
    class A1 notes, $27,144,444 of class B notes and $14,477,037
    of class C notes. The individual components of the combination
    notes are included in the outstanding amount of the related
    components and will earn interest in the same manner as the
    related components. The component amounts outstanding can
    vary, subject to conditions as described in the indenture.

NR - Not rated.


PHOENIX CLO I: S&P Raises Rating on Class D Notes to 'B-'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, and D notes from Phoenix CLO I Ltd. and the class B, C-1, C-
2, D-1, D-2 notes from Phoenix CLO II Ltd. The two deals are U.S.
collateralized loan obligation (CLO) transactions managed by ING
Alternative Asset Management LLC. "At the same time, we affirmed
our 'AA+ (sf)' ratings on each of the class A notes issued from
the two transactions (see list). Both transactions, formerly known
as Avenue CLO IV Ltd. and Avenue CLO V Ltd. had a collateral
management change, and subsequent name change, back in January
2010," S&P said.

"The upgrades reflect an improvement in the overcollateralization
(O/C) available to support the notes in both transactions, since
we last upgraded some of the notes in late 2010," S&P said. The
trustee reported the following O/C ratios in the September 2012
monthly report for the Phoenix CLO I Ltd. transaction:

    The class A O/C ratio was 127.2%, compared with a reported
    ratio of 125.2% in September 2010;
    The class B O/C ratio was 111.8%, compared with a reported
    ratio of 110.1% in September 2010;
    The class C O/C ratio was 107.5%, compared with a reported
    ratio of 105.8% in September 2010; and
    The class D O/C ratio was 103.3%, compared with a reported
    ratio of 101.7% in September 2010.

The trustee reported these O/C ratios in the September 2012
monthly report for the Phoenix CLO II Ltd. transaction:

    The class A O/C ratio was 127.5%, compared with a reported
    ratio of 120.0% in October 2010;
    The class B O/C ratio was 112.2%, compared with a reported
    ratio of 112.7% in October 2010;
    The class C O/C ratio was 108.0%, compared with a reported
    ratio of 107.5% in October 2010; and
    The class D O/C ratio was 103.7%, compared with a reported
    ratio of 105.2% in October 2010.

"The upgrades of Phoenix CLO I Ltd. also reflect a slight
improvement in the performance of the transaction's underlying
asset portfolio, since the time of our last actions. The amount of
'CCC' rated assets and defaulted assets have both decreased over
that period. As of the September 2012 monthly report, the amount
of defaulted assets was $13.06 million, down from $16.37 million
in September 2010. Through the same period, the amount of 'CCC'
rated assets decreased to $25.37 million from $30.76 million," S&P
said.

"The class D-1 and D-2 note ratings from the Phoenix CLO II Ltd.
transaction were constrained by the application of the largest
obligor default test, a supplemental stress test we introduced as
part of our 2009 corporate criteria update," S&P said.

"We downgraded the class D note from the Phoenix CLO I Ltd.
transaction to 'CC (sf)' in November 2009.  At that time, the
credit enhancement available to the notes had seen a significant
deterioration since issuance. In the September 2009 monthly
report, the class D O/C ratio was 95.40%. As highlighted, this
ratio has improved drastically since then. Additionally, the class
D notes have benefitted from a more diversified obligor
concentration within the portfolio, the main component employed by
the aforementioned largest obligor default test," S&P said.

"We affirmed our ratings on both of the class A notes from Phoenix
CLO I Ltd. and Phoenix CLO II Ltd. to reflect the credit support
available at the current rating levels," S&P said.

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

         STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Phoenix CLO I Ltd.
                   Rating
Class         To           From
A             AA+ (sf)     AA+ (sf)
B             A- (sf)      BBB+ (sf)
C             BBB- (sf)    B+ (sf)
D             B- (sf)      CC (sf)

Phoenix CLO II Ltd.
                   Rating
Class         To           From
A             AA+ (sf)     AA+ (sf)
B             A (sf)       BBB+ (sf)
C-1           BBB (sf)     BB+ (sf)
C-2           BBB (sf)     BB+ (sf)
D-1           B+ (sf)      CCC- (sf)
D-2           B+ (sf)      CCC- (sf)


RAIT CRE I: Moody's Affirms 'Caa3' Rating on Five Note Classes
--------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of all the
classes of Notes issued by RAIT CRE CDO I, Ltd. due to key
transaction parameters performing within levels commensurate with
the existing ratings levels. The rating action is the result of
Moody's on-going surveillance of commercial real estate
collateralized debt obligation and collateralized loan obligation
(CRE CDO CLO) transactions.

Moody's rating action is as follows:

Cl. A-1A, Affirmed at Aa2 (sf); previously on Dec 15, 2011
Downgraded to Aa2 (sf)

Cl. A-1B, Affirmed at Aa2 (sf); previously on Dec 15, 2011
Downgraded to Aa2 (sf)

Cl. A-2, Affirmed at Baa3 (sf); previously on Dec 15, 2011
Downgraded to Baa3 (sf)

Cl. B, Affirmed at B1 (sf); previously on Dec 15, 2011 Downgraded
to B1 (sf)

Cl. C, Affirmed at Caa1 (sf); previously on Dec 15, 2011
Downgraded to Caa1 (sf)

Cl. D, Affirmed at Caa2 (sf); previously on Dec 15, 2011
Downgraded to Caa2 (sf)

Cl. E, Affirmed at Caa3 (sf); previously on Dec 15, 2011
Downgraded to Caa3 (sf)

Cl. F, Affirmed at Caa3 (sf); previously on Dec 15, 2011
Downgraded to Caa3 (sf)

Cl. G, Affirmed at Caa3 (sf); previously on Dec 15, 2011
Downgraded to Caa3 (sf)

Cl. H, Affirmed at Caa3 (sf); previously on Dec 15, 2011
Downgraded to Caa3 (sf)

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

Ratings Rationale

RAIT CRE CDO I, Ltd. is a static cash CRE CDO transaction backed
by a portfolio of whole loans (69.0% of the deal balance),
mezzanine loans and preferred equity participations (28.5%), b-
notes (1.5%) and REIT debt (1.0%). As of the October 7, 2012
trustee report, the aggregate Note balance of the transaction,
including preferred shares, has decreased to $965.3 million from
$1.018 billion at issuance, with the paydown directed to the Class
A1A and A1B Notes, as a result of regular amortization of the
underlying collateral. Additionally, there have been partial
cancellations to the Class D, F, G and H Notes. In general,
holding all key parameters static, the junior note cancellations
results in slightly higher expected losses and longer weighted
average lives on the senior Notes, while producing slightly lower
expected losses on the mezzanine and junior Notes. However, this
does not cause, in and of itself, a downgrade or upgrade of any
outstanding classes of Notes.

There are nine assets with a par balance of $23.5 million (2.4% of
the current pool balance) that are considered defaulted interests
as of the October 7, 2012 trustee report. Seven of these assets
(61.0% of the defaulted balance) are mezzanine loans and two
assets are b-notes (39.0%). Moody's expects moderate to high
losses from these defaulted interests to occur once they are
realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral.

Moody's modeled a bottom-dollar WARF of 7,530, compared to 7,125
at last review. The current distribution of Moody's rated
collateral and assessments for non-Moody's rated collateral is as
follows: Baa1-Baa3 (1.9% compared to 2.1% at last review), Ba1-Ba3
(1.0% compared to 0.1% at last review), B1-B3 (1.9% compared to
3.9% at last review), and Caa1-C (95.2% compared to 93.9% at last
review).

Moody's modeled a WAL of 4.9 years, compared to 7.0 years at last
review. The current WAL is based on the assumption about
extensions.

Moody's modeled a fixed WARR, excluding defaulted interests, of
40.4% compared to 39.6% at last review.

Moody's modeled a MAC of 100.0%, the same as at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on 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
40.4% to 30.4% or up to 50.4% would result in modeled rating
movements on the rated Notes of 0 to 7 notches downward and 0 to
10 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.


RALI SERIES 2003-QS19: Moody's Cuts Ratings on 2 Tranches to 'B1'
-----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of four
tranches from RALI Series 2003-QS19 Trust, backed by Alt-A loans.

Ratings Rationale

The downgrades are a result of deteriorating performance of the
underlying pools resulting in higher than expected losses for the
bonds than previously anticipated. In addition, the downgrade of
Class NB-5 reflects correction of a prior error. Class NB-5 is an
Interest-Only tranche that is linked to the Class NB-4 notional
balance. On May 31, 2012, Class NB-4 was downgraded to Baa3 (sf),
and Class NB-5 was inadvertently not included in the rating
action. Class NB-5 has now been downgraded to Baa3 (sf) and now
carries the same rating as Class NB-4.

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.

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 7.9% in October 2012. 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: RALI Series 2003-QS19 Trust

CB, Downgraded to Ba1 (sf); previously on May 31, 2012 Downgraded
to Baa3 (sf)

NB-2, Downgraded to B1 (sf); previously on May 31, 2012 Downgraded
to Ba2 (sf)

NB-5, Downgraded to Baa3 (sf); previously on Mar 30, 2011
Downgraded to A3 (sf)

NB-7, Downgraded to B1 (sf); previously on May 31, 2012 Downgraded
to Ba2 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF306379

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


RESI FINANCE: Moody's Cuts Rating on Class B10 Tranche to 'Ba3'
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of nine
tranches from one RMBS synthetic transaction, referencing Prime
Loans, issued by RESI 2003-A transaction.

Complete rating actions are as follows:

Issuer: RESI Finance Limited Partnership 2003-A/RESI Finance DE
Corporation 2003-A, Series 2003-A

Cl. B2, Downgraded to Aa2 (sf); previously on Aug 1, 2006 Upgraded
to Aaa (sf)

Cl. B3, Downgraded to A1 (sf); previously on Apr 21, 2011
Downgraded to Aa1 (sf)

Cl. B4, Downgraded to A2 (sf); previously on Apr 21, 2011
Downgraded to Aa2 (sf)

Cl. B5, Downgraded to Baa1 (sf); previously on Apr 21, 2011
Downgraded to A1 (sf)

Cl. B6, Downgraded to Baa2 (sf); previously on Apr 21, 2011
Downgraded to A2 (sf)

Cl. B7, Downgraded to Baa3 (sf); previously on Apr 21, 2011
Downgraded to A3 (sf)

Cl. B8, Downgraded to Ba1 (sf); previously on Apr 21, 2011
Downgraded to Baa1 (sf)

Cl. B9, Downgraded to Ba2 (sf); previously on Apr 21, 2011
Downgraded to Baa2 (sf)

Cl. B10, Downgraded to Ba3 (sf); previously on Apr 21, 2011
Downgraded to Ba1 (sf)

Ratings Rationale

The synthetic transaction provides Bank of America, N.A. (the
"Protection Buyer") credit protection on a pool of mortgages (the
"reference portfolio") through a credit default swap with the
issuer (the "Protection Seller") of the notes. Investors in the
notes have an interest in the holdings of the issuer, which
include highly rated investment instruments, a forward delivery
agreement and fee collections on the agreement with the Protection
Buyer. Investors are exposed to losses from the reference
portfolio but benefit only indirectly from cash flows from these
assets. The reference portfolio of this transaction includes prime
conforming and nonconforming fixed-rate and adjustable-rate
mortgages purchased from various originators.

The rating actions are a result of the recent performance of the
underlying reference portfolio of this transaction and reflect
Moody's updated loss expectations on the pool. The downgrades are
a result of deteriorating performance 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 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

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
originated before 2005, Moody's first applies a baseline
delinquency rate of 3.0%. 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 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.

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 7.9% in October 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_SF306383

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


RESIDENTIAL RE 2011: S&P Cuts Rating on Class 5 Notes to 'B+'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on
Residential Reinsurance 2011 Ltd Series 2011-1 (Res Re 2011) Class
5 notes to 'B+(sf)' from 'BB-(sf)'. The notes remain on
CreditWatch with negative implications. The 'BB(sf)' rating on
Residential Reinsurance 2012 Ltd. Series 2012-1 (Res Re 2012)
Class 5 notes remains on CreditWatch with negative implications.

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. The current risk
period began on June 1, 2012, and ends on May 31, 2013.

"We placed the ratings on CreditWatch on Nov. 6, 2012, due to a
loss estimate notice related to Catastrophe Series 90 (Hurricane
Sandy) submitted by USAA to Res Re 2011 and 2012. The estimates of
ultimate net losses range from a low of $129 million to a high of
$363 million, with a point estimate of $291 million," S&P said.

"To date, there have been two covered events: Catastrophe Series
77 (a Colorado and Wyoming wind and hail tornado that occurred on
June 6) and Catastrophe Series 83 (a central and northeast U.S.
wind and hail tornado that occurred on June 28) that have
generated estimated covered losses of $187 million. These events
plus the losses from Sandy decrease the amount of future losses
necessary to trigger an event payment and in our view, increase
the risk associated with these bonds," S&P said.

We have received from AIR Worldwide Corp. (the reset and
calculation agent) updated probabilities of attachment for the
remaining risk period, using each of the lost estimates listed
above. The current rating actions are based on the point estimate
loss amount," S&P said.

"Each issuance was left on CreditWatch with negative implications
because there is the potential for the ultimate net losses from
Sandy to increase. If losses from Sandy were to come in at the
high estimate, the Res Re 2011 notes could be lowered up to two
notches and the Res Re 2012 notes could be lowered by one notch.
We expect to resolve the status of each CreditWatch within 90
days," S&P said.

"To the extent losses accrue through the risk period but do not
reach the attachment point, then the attachment point is reset on
June 1, 2013, the risk period starts anew, and all losses from the
previous risk period will not count for the current risk period,"
S&P said.

RATINGS LIST

Ratings Lowered; On CreditWatch    To                  From
Residential Reinsurance 2011 Ltd.
Series 2011-1 Class 5             B+(sf)/Watch Neg    BB-(sf)
                                                       /Watch Neg

Ratings Remain On CreditWatch
Residential Reinsurance 2012 Ltd
Series 2012-1 Class 5             BB(sf)/Watch Neg


SEQUOIA MORTGAGE 2012-6: Fitch to Rate Cl. B-4 Certificate 'BBsf'
-----------------------------------------------------------------
Fitch Ratings expects to rate Sequoia Mortgage Trust 2012-6.
Fitch's stress and rating sensitivity analysis are discussed in
the presale report titled 'Sequoia Mortgage Trust 2012-6', dated
Nov. 13, 2012, which is available on Fitch's web site,
www.fitchratings.com.

Fitch expects to assign the following ratings:

  -- $100,000,000 class A-1 certificate 'AAAsf'; Outlook Stable;
  -- $100,000,000 class A-2 certificate 'AAAsf'; Outlook Stable;
  -- $80,209,000 class A-3 certificate 'AAAsf'; Outlook Stable;
  -- $280,209,000 class A-IO1 notional certificate 'AAAsf';
     Outlook Stable;
  -- $100,000,000 class A-IO2 notional certificate 'AAAsf';
     Outlook Stable;
  -- $80,209,000 class A-IO3 notional certificate 'AAAsf'; Outlook
     Stable;
  -- $7,989,000 class B-1 certificate 'AAsf'; Outlook Stable;
  -- $4,220,000 class B-2 certificate 'Asf'; Outlook Stable;
  -- $3,467,000 class B-3 certificate 'BBBsf'; Outlook Stable;
  -- $2,412,000 non-offered class B-4 certificate 'BBsf'; Outlook
     Stable;

The non-offered class B-5 certificate will not be rated.


SYNCORA GUARANTEE: Moody's Downgrades Ratings on 26 Securities
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 26 classes
and confirmed the ratings of 16 classes of US structured finance
securities wrapped by Syncora Guarantee Inc. The impacted
securities are backed by first or second lien-US residential
mortgages.

A list of the affected credit ratings is available at:

                         http://is.gd/N1QbV6

Ratings Rationale

This action is solely driven by Moody's announcement on Nov. 8,
2012 that it has withdrawn the insurance financial strength rating
of Syncora Guarantee Inc. and its affiliates.

Moody's ratings on structured finance securities that are
guaranteed or "wrapped" by a financial guarantor are generally
maintained at a level equal to the higher of the following: a) the
rating of the guarantor (if rated at the investment grade level);
or b) the published or unpublished underlying rating. Moody's
approach to rating wrapped transactions is outlined in Moody's
special comment entitled "Assignment of Wrapped Ratings When
Financial Guarantor Falls Below Investment Grade" (May, 2008); and
Moody's November 10, 2008 announcement entitled "Moody's Modifies
Approach to Rating Structured Finance Securities Wrapped by
Financial Guarantors". With the withdrawal of Syncora's rating,
the ratings on these structured finance securities are without
regard to the financial guaranty. The principal methodology used
in determining the underlying rating is the same methodology for
rating securities that do not have a financial guaranty and are
listed in the link noted below.

This action is driven solely by the withdrawal of Syncora's rating
and is not a result of change in key assumptions, expected losses,
cash flows and stress scenarios on the underlying assets.


THORNBURG MORTGAGE: Moody's Cuts Rating on B-1 Tranche to 'Caa3'
----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of five
tranches from one RMBS transaction, backed by Prime Loans, issued
by Thornburg Mortgage.

Complete rating actions are as follows:

Issuer: Thornburg Mortgage Securities Trust 2004-4

Cl. B-1, Downgraded to Caa3 (sf); previously on Apr 11, 2012
Downgraded to Caa1 (sf)

Cl. IV-A, Downgraded to Baa3 (sf); previously on Apr 20, 2011
Downgraded to A3 (sf)

Cl. IV-AX, Downgraded to Baa3 (sf); previously on Apr 20, 2011
Downgraded to A3 (sf)

Cl. V-A, Downgraded to Ba2 (sf); previously on Apr 11, 2012
Downgraded to Ba1 (sf)

Cl. V-AX, Downgraded to Ba2 (sf); previously on Apr 11, 2012
Downgraded to Ba1 (sf)

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 downgrades are a result of deteriorating performance
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 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

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
originated before 2005, Moody's first applies a baseline
delinquency rate of 3.0%. 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 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.

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% 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_SF306384

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


VENTURE III: Moody's Hikes Rating on $12.5MM Cl. C Notes to 'Ba1'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Venture III CDO Limited:

U.S. $30,000,000 Class A-2 Floating Rate Notes due 2016, Upgraded
to Aaa (sf); previously on September 14, 2011 Upgrade to Aa1 (sf);

U.S. $16,000,000 Class B Deferrable Floating Rate Notes due 2016,
Upgraded to Aa1 (sf); previously on September 14, 2011 Upgrade to
A3 (sf); and

U.S. $12,500,000 Class C Floating Rate Notes due 2016, Upgraded to
Ba1 (sf); previously on September 14, 2011 Upgrade to Ba2 (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 September 2011. Moody's notes that the Class
A-1 Notes have been paid down by approximately 68% or $83 million
since the last rating action. Based on the latest trustee report
dated October 10, 2012, the Class A, Class B and Class C
overcollateralization ratios (prior to the payment made on the
October payment date) are reported at 147.1%, 124.4% and 111.1%,
respectively, versus August levels of 127.9%. 115.8% and 107.8%,
respectively.

Notwithstanding benefits of the deleveraging, Moody's notes that
the credit quality of the underlying portfolio has deteriorated
since the last rating action. Based on the October 2012 trustee
report, the weighted average rating factor is currently 2763
compared to 2548 in August 2011.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes. Based on the October 2012 trustee
report, securities that mature after the maturity date of the
notes currently make up approximately 16% of the underlying
portfolio. These investments potentially expose the notes to
market risk in the event of liquidation at the time of the notes'
maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $107 million,
defaulted par of $16.7 million, a weighted average default
probability of 11.80% (implying a WARF of 2726), a weighted
average recovery rate upon default of 47.0%, and a diversity score
of 41. 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.

Venture III CDO Limited, issued in December 2003, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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% (2184)

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

Moody's Adjusted WARF + 20% (3276)

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

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 bond/loan market
and/or collateral sales by the manager, which may have significant
impact on the notes' ratings.

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

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


WACHOVIA BANK 2006-C29: Moody's Cuts Rating on Cl. F Certs. to 'C'
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 15 classes and
downgraded seven CMBS Classes of Wachovia Bank Commercial Mortgage
Pass-Through Certificates, Series 2006-C29 as follows:

Cl. A-2, Affirmed at Aaa (sf); previously on Dec 21, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Dec 21, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-PB, Affirmed at Aaa (sf); previously on Dec 21, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Dec 21, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Dec 21, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Downgraded to A3 (sf); previously on Dec 10, 2010
Downgraded to Aa2 (sf)

Cl. A-J, Downgraded to B1 (sf); previously on Dec 10, 2010
Downgraded to Baa3 (sf)

Cl. B, Downgraded to Caa1 (sf); previously on Dec 10, 2010
Downgraded to Ba3 (sf)

Cl. C, Downgraded to Caa2 (sf); previously on Dec 10, 2010
Downgraded to B3 (sf)

Cl. D, Downgraded to Caa3 (sf); previously on Dec 10, 2010
Downgraded to Caa1 (sf)

Cl. E, Downgraded to Ca (sf); previously on Dec 10, 2010
Downgraded to Caa2 (sf)

Cl. F, Downgraded to C (sf); previously on Dec 10, 2010 Downgraded
to Ca (sf)

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

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

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

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

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

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

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

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

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

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

Ratings Rationale

The downgrades are due to higher realized losses, anticipated
losses from loans in special servicing and forecast increases in
interest shortfalls. The IO Class, Class IO, is affirmed since it
is consistent with the expected credit performance of its
referenced classes. The affirmations of the principal classes are
due to key parameters, including Moody's loan to value (LTV)
ratio, Moody's stressed debt service coverage ratio (DSCR) and the
Herfindahl Index (Herf), remaining within acceptable ranges. Based
on Moody's current base expected loss, the credit enhancement
levels for the affirmed classes are sufficient to maintain their
current ratings.

Moody's rating action reflects a cumulative base expected loss of
10.6% of the current balance compared to 9.5% at last review.
Moody's provides a current list of base expected losses for
conduit and fusion CMBS transactions on moodys.com at
http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Rating Structured Finance Interest-Only
Securities" published in February 2012.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying credit assessment of the loan which corresponds to a
range of credit enhancement levels. Actual fusion credit
enhancement levels are selected based on loan level diversity,
pool leverage and other concentrations and correlations within the
pool. Negative pooling, or adding credit enhancement at the
underlying rating level, is incorporated for loans with similar
credit assessments in the same transaction.

Moody's review also incorporated the CMBS IO calculator ver1.1
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point. For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.1
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 29, down from 31 at last review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated November 10, 2011.

DEAL PERFORMANCE

As of the October 17, 2012 distribution date, the transaction's
aggregate certificate balance has decreased 13% to $2.94 billion
from $3.37 billion at securitization. The Certificates are
collateralized by 131 mortgage loans ranging in size from less
than 1% to 11% of the pool. One loan, representing less than 1% of
the pool, has defeased and is backed by U.S. government
securities. There is one loan with an investment grade credit
assessment, representing 6% of the pool.

There are presently 39 loans, representing 18% of the pool, on the
master servicer's watchlist. The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the CRE Finance Council (CREFC) monthly reporting package. As part
of its ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Nine loans have been liquidated from the pool since
securitization, resulting in an aggregate $43.3 million loss (40%
loss severity on average). Currently 17 loans, representing 13% of
the pool, are in special servicing. The largest specially serviced
loan is the Renaissance Tower Office Building Loan ($127.6 million
-- 4.3% of the pool), which is secured by a 1.7 million square
foot (SF) office building located in Dallas, Texas. The loan was
transferred to special servicing in May 2011 due to imminent
default and is 90+ days delinquent.

Moody's has assumed a high default probability for 26 poorly
performing loans representing 16% of the pool and has estimated an
$77.5 million aggregate loss (16% expected loss based on a 50%
probability of default) from these troubled loans.

Based on the most recent remittance statement, Classes E through Q
have experienced cumulative interest shortfalls totaling $22.1
million compared to $12.4 million at last review. The servicer has
also recognized appraisal reductions totaling $185.3 million on 13
specially serviced loans. Moody's anticipates that the pool will
continue to experience interest shortfalls due to the high
exposure to specially serviced loans. Special servicing fees,
including workout and liquidation fees, appraisal subordinate
entitlement reductions (ASERs) and extraordinary trust expenses
cause interest shortfalls.

Moody's was provided with full year 2011 and partial year 2012
operating results for 100% and 83% of the performing pool,
respectively. Excluding troubled loans, Moody's weighted average
conduit LTV is 105% compared to 108% at last review. Moody's net
cash flow reflects a weighted average haircut of 10.7% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.1%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed conduit DSCRs are 1.50X and 0.98X, respectively,
compared to 1.47X and 0.95X, respectively, at last full review.
Moody's actual DSCR is based on Moody's net cash flow (NCF) and
the loan's actual debt service. Moody's stressed DSCR is based on
Moody's NCF and a 9.25% stressed rate applied to the loan balance.

The loan with a credit assessment is the International Wholesale
Pool Loan ($161.0 million -- 5.5% of the pool), which is secured
by 13 cross-collateralized and cross-defaulted retail properties
located in Connecticut, Florida, Massachusetts, Mississippi, New
Jersey, New York and North Carolina. The properties were 94% lease
as of June 2012 versus 94% leased at last review. Performance has
been stable. Moody's current credit assessment and stressed DSCR
are Baa2 and 1.34X compared to Baa2 and 1.28X at last review.

The top three performing conduit loans represent 24% of the pool
balance. The largest loan is the Duke Realty Industrial Pool Loan
($319 million -- 10.9% of the pool), which is secured by 27 cross-
collateralized and cross-defaulted industrial properties located
in five submarkets in Indiana and Georgia. The portfolio was 97%
leased as of December 2011 compared to 90% at last review. Despite
occupancy increases, property performance has declined slightly
since last review due to lower revenue achievement.. Moody's LTV
and stressed DSCR are 121% and 0.8X, respectively, compared to
116% and 0.84X at securitization.

The second largest loan is the Syndicate Pool 2 Loan ($234 million
-- 8.0% of the pool), which is secured by 16 cross-collateralized
and cross-defaulted retail properties located in 12 different
states. The portfolio was 95% leased as of June 2012 compared to
91% at last review. The portfolio performance has improved in
concert with occupancy increases since last review. Moody's LTV
and stressed DSCR are 74% and 1.32X, respectively, compared to 76%
and 1.28X at last review.

The third largest loan is the Westfield Fox Valley Loan ($150
million -- 5.1% of the pool), which is secured by a 1.4 million SF
regional mall located in Aurora, Illinois. The mall is anchored by
Sears, Macy's and JC Penney, which are not part of the collateral.
The property was 88% leased as of June 2012 compared to 85% at
last review. Financial performance has increased since last
review. Moody's LTV and stressed DSCR are 99% and 0.99X,
respectively, unchanged since last review.


WACHOVIA BANK 2006-C25: Moody's Cuts Ratings on 2 Certs. to 'C'
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of 12 classes and
affirmed 13 classes of Wachovia Bank Commercial Mortgage Trust,
Commercial Mortgage Pass-Through Certificates, Series 2006-C25 as
follows:

Cl. A-2, Affirmed at Aaa (sf); previously on Jul 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jul 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-PB1, Affirmed at Aaa (sf); previously on Jul 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-PB2, Affirmed at Aaa (sf); previously on Jul 26, 2006
Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Jul 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-5, Affirmed at Aaa (sf); previously on Jul 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Jul 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Downgraded to Aa2 (sf); previously on Dec 10, 2010
Confirmed at Aaa (sf)

Cl. A-J, Downgraded to Baa3 (sf); previously on Dec 10, 2010
Downgraded to A3 (sf)

Cl. B, Downgraded to Ba1 (sf); previously on Dec 10, 2010
Downgraded to Baa1 (sf)

Cl. C, Downgraded to Ba2 (sf); previously on Dec 10, 2010
Downgraded to Baa2 (sf)

Cl. D, Downgraded to Ba3 (sf); previously on Dec 10, 2010
Downgraded to Baa3 (sf)

Cl. E, Downgraded to B1 (sf); previously on Dec 10, 2010
Downgraded to Ba1 (sf)

Cl. F, Downgraded to B3 (sf); previously on Dec 10, 2010
Downgraded to Ba3 (sf)

Cl. G, Downgraded to Caa2 (sf); previously on Dec 10, 2010
Downgraded to B3 (sf)

Cl. H, Downgraded to Caa3 (sf); previously on Dec 10, 2010
Downgraded to Caa1 (sf)

Cl. J, Downgraded to Ca (sf); previously on Dec 10, 2010
Downgraded to Caa2 (sf)

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

Cl. L, Downgraded to C (sf); previously on Dec 10, 2010 Downgraded
to Ca (sf)

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

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

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

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

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

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

Ratings Rationale

The downgrades are due to realized and anticipated losses from
loans in special servicing and trouble loans. The affirmations of
the principal classes are due to sufficient credit enhancement
levels for the current ratings. Based on Moody's current base
expected loss, the credit enhancement levels for the affirmed
classes are sufficient to maintain their ratings. The rating of
the IO Class, Class XC is consistent with the expected credit
performance of its referenced classes and thus is affirmed.

Moody's rating action reflects a base expected loss of 9.0% of the
current balance compared to 6.3% at last review. Moody's provides
a current list of base expected losses for conduit and fusion CMBS
transactions on moodys.com at
http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 Fusion Transactions" published in April 2005, and "Moody's
Approach to Rating Structured Finance Interest-Only Securities"
published in February 2012.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Mooody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying credit assessment of the loan which corresponds to a
range of credit enhancement levels. Actual fusion credit
enhancement levels are selected based on loan level diversity,
pool leverage and other concentrations and correlations within the
pool. Negative pooling, or adding credit enhancement at the
underlying rating level, is incorporated for loans with similar
credit assessments in the same transaction.

Moody's review also incorporated the CMBS IO calculator ver1.1
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point. For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.1
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 30, compared to 29 at last review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated November 10, 2011.

Deal Performance

As of the October 17, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 13% to $2.50
billion from $2.87 billion at securitization. The Certificates are
collateralized by 128 mortgage loans ranging in size from less
than 1% to 12% of the pool. One loan, representing 1.6% of the
pool, has a credit assessment. Two loans representing less than 1%
of the pool have defeased and are secured by US Government
securities.

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

Nine loans have been liquidated from the pool since
securitization, resulting in an aggregate $30.9 million loss (46%
loss severity on average). Currently 12 loans, representing 9% of
the pool, are in special servicing. The largest specially serviced
loan is the Central Park Pool Loan ($82.1 million - 3.3% of the
pool). The loan is secured by a portfolio consisting of 11
properties totaling 810,600 square feet (SF). The properties are a
mix of office, retail and research and development space, all
located in Cincinnati, Ohio. The loan transferred to special
servicing in July 2011 as the result of imminent monetary default.
A deed in lieu transaction closed in June 2012 and the property is
currently 82% occupied. The remaining specially serviced loans are
secured by a mix of property types. Moody's estimates an aggregate
$126.3 million loss for all of the specially serviced loans (54%
expected loss on average). The master servicer has recognized
appraisal reductions totaling $123.4 million for the specially
serviced loans.

Moody's has assumed a high default probability for 11 poorly
performing loans representing 5% of the pool and has estimated an
aggregate $25.7 million loss (19% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2011 and partial year 2012
operating results for 99% and 86% of the performing pool
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 100% compared to 101% at last full
review. Moody's net cash flow reflects a weighted average haircut
of 14.8% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.1%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.34X and 1.03X, respectively, compared to
1.32X and 1.01X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The loan with a credit assessment is the Paramount Building Loan
($39.5 million -- 1.6% of the pool), which is secured by a 639,000
SF office building located in New York City. The property was 76%
leased as of September 2012, compared to 77% at last review.
Previously, the largest tenant, Off Track Betting (OTB) vacated
last year due to the closure of OTB by the State of New York.
Currently the largest tenant is Hard Rock Caf‚ (7.0% of the net
rentable area (NRA); lease expiration October 2021). The loan is
interest-only during its entire ten-year period maturing in April
2016. Moody's current credit assessment and stressed DSCR are Aaa
and 3.78X, respectively, compared to Aaa and 3.21X at last review.

The top three performing conduit loans represent 26% of the pool.
The largest loan is the Prime Outlets Pool Loan ($294.3 million --
11.8% of the pool), which is a 50% participation interest in a
$588.6 million loan secured by ten retail centers located in eight
states, including Texas, Pennsylvania, Florida, and Ohio. The
total gross leasable area is 3.5 million SF. Property performance
has improved due to the effect of a substitution of collateral
that was finalized in June 2011. The loan had a 24-month interest-
only period and is now amortizing on a 360-month schedule maturing
in January 2016. Moody's LTV and stressed DSCR are 80% and 1.21X,
respectively, compared to 92% and 1.05X at last full review.

The second largest loan is the Marriott-Chicago Loan ($187.7
million -- 7.5% of the pool), which is secured by a 1,192-room
full service hotel located in Chicago, Illinois. The loan has a
non-pooled junior component of $24.5 million. Property performance
has slightly improved since last review. The loan had a 42-month
interest-only period and is now amortizing on a 360-month schedule
maturing in April 2016. Moody's LTV and stressed DSCR are 94% and
1.20X, respectively, compared to 106% and 1.07X at last full
review.

The third largest loan is the 530 Fifth Avenue Loan ($169.6
million -- 6.8% of the pool), which is secured by a 500,000 SF
office property located in New York City. The property is also
encumbered by a $24.6 million non-trust junior component and $25
million of mezzanine financing. The largest tenant is JP Morgan
(14.5% of the NRA; lease expiration May 2013). As of September
2012, the property was 89% leased compared to 95% at last full
review. The loan had a 48-month interest-only period and is now
amortizing on a 360-month schedule maturing in May 2016. Moody's
LTV and stressed DSCR are 109% and 0.84X, respectively, the same
as at last review.


WFRBS 2012-C9: Moody's Assigns 'B2(sf)' Rating on Class F Certs
---------------------------------------------------------------
Moody's Investors Service has assigned ratings to twelve classes
of CMBS securities, issued by WFRBS Commercial Mortgage Trust,
Commercial Mortgage Pass-Through Certificates, Series 2012-C9.

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-SB, Definitive Rating Assigned Aaa (sf)

Cl. A-S, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa3 (sf)

Cl. C, Definitive Rating Assigned A3 (sf)

Cl. X-A, Definitive Rating Assigned Aaa (sf)

Cl. X-B, Definitive Rating Assigned A1 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

Cl. E, Definitive Rating Assigned Ba2 (sf)

Cl. F, Definitive Rating Assigned B2 (sf)

Ratings Rationale

The Certificates are collateralized by 73 fixed rate loans secured
by 100 properties. The ratings are based on the collateral and the
structure of the transaction.

Moody's CMBS ratings methodology combines both commercial real
estate and structured finance analysis. Based on commercial real
estate analysis, Moody's determines the credit quality of each
mortgage loan and calculates an expected loss on a loan specific
basis. Under structured finance, the credit enhancement for each
certificate typically depends on the expected frequency, severity,
and timing of future losses. Moody's also considers a range of
qualitative issues as well as the transaction's structural and
legal aspects.

The credit risk of loans is determined primarily by two factors:
1) Moody's assessment of the probability of default, which is
largely driven by each loan's DSCR; and 2) Moody's assessment of
the severity of loss upon a default, which is largely driven by
each loan's LTV ratio.

The Moody's Actual DSCR of 1.50X is greater than the 2007
conduit/fusion transaction average of 1.31X. The Moody's Stressed
DSCR of 1.06X is greater than the 2007 conduit/fusion transaction
average of 0.92X.

Moody's Trust LTV ratio of 103.2% is lower than the 2007
conduit/fusion transaction average of 110.6%. Moody's Total LTV
ratio (inclusive of subordinated debt and debt-like preferred
equity) of 104.5% is also considered when analyzing various stress
scenarios for the rated debt.

Moody's also considers both loan level diversity and property
level diversity when selecting a ratings approach. With respect to
loan level diversity, the pool's loan level (includes cross
collateralized and cross defaulted loans) Herfindahl Index is
31.5. The transaction's loan level diversity is at the higher end
of the band of Herfindahl scores found in most multi-borrower
transactions issued since 2009. With respect to property level
diversity, the pool's property level Herfindahl Index is 33.0. The
transaction's property diversity profile is higher than the
indices calculated in most multi-borrower transactions issued
since 2009.

This deal has a super-senior Aaa class with 30% credit
enhancement. Although the additional enhancement offered to the
senior most certificate holders provides additional protection
against pool loss, the super-senior structure is credit negative
for the certificate that supports the super-senior class. If the
support certificate were to take a loss, the loss would have the
potential to be quite large on a percentage basis. Thin tranches
need more subordination to reduce the probability of default in
recognition that their loss-given default is higher. This
adjustment helps keep expected loss in balance and consistent
across deals. The transaction was structured with additional
subordination at class A-S to mitigate the potential increased
severity to class A-S.

Moody's also grades properties on a scale of 1 to 5 (best to
worst) and considers those grades when assessing the likelihood of
debt payment. The factors considered include property age, quality
of construction, location, market, and tenancy. The pool's
weighted average property quality grade is 2.4, which is higher
than the indices calculated in most multi-borrower transactions
since 2009.

The methodologies used in this rating were "Moody's Approach to
Rating U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating Structured Finance Interest-
Only Securities" published in February 2012.

Moody's analysis employs the excel-based CMBS Conduit Model v2.61
which derives credit enhancement levels based on an aggregation of
adjusted loan level proceeds derived from Moody's loan level DSCR
and LTV ratios. Major adjustments to determining proceeds include
loan structure, property type, sponsorship, and diversity. Moody's
analysis also uses the CMBS IO calculator ver_1.1, which
references the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology.

The V Score for this transaction is assessed as Low/Medium, the
same as the V score assigned to the U.S. Conduit and CMBS sector.
This reflects typical volatility with respect to the critical
assumptions used in the rating process as well as an average
disclosure of securitization collateral and ongoing performance.

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

Moody's Parameter Sensitivities: If Moody's value of the
collateral used in determining the initial rating were decreased
by 5%, 16%, and 29%, the model-indicated rating for the currently
rated Aaa Super Senior class would be Aaa, Aaa, and Aa1,
respectively; for the most junior Aaa rated class A-S would be
Aa1, Aa1, and A2, respectively. Parameter Sensitivities are not
intended to measure how the rating of the security might migrate
over time; rather they are designed to provide a quantitative
calculation of how the initial rating might change if key input
parameters used in the initial rating process differed. The
analysis assumes that the deal has not aged. Parameter
Sensitivities only reflect the ratings impact of each scenario
from a quantitative/model-indicated standpoint. Qualitative
factors are also taken into consideration in the ratings process,
so the actual ratings that would be assigned in each case could
vary from the information presented in the Parameter Sensitivity
analysis.

These ratings: (a) are based solely on information in the public
domain and/or information communicated to Moody's by the issuer at
the date it was prepared and such information has not been
independently verified by Moody's; (b) must be construed solely as
a statement of opinion and not a statement of fact or an offer,
invitation, inducement or recommendation to purchase, sell or hold
any securities or otherwise act in relation to the issuer or any
other entity or in connection with any other matter. Moody's does
not guarantee or make any representation or warranty as to the
correctness of any information, rating or communication relating
to the issuer. Moody's shall not be liable in contract, tort,
statutory duty or otherwise to the issuer or any other third party
for any loss, injury or cost caused to the issuer or any other
third party, in whole or in part, including by any negligence (but
excluding fraud, dishonesty and/or willful misconduct or any other
type of liability that by law cannot be excluded) on the part of,
or any contingency beyond the control of Moody's, or any of its
employees or agents, including any losses arising from or in
connection with the procurement, compilation, analysis,
interpretation, communication, dissemination, or delivery of any
information or rating relating to the issuer.


* Moody's Takes Rating Actions on $313-Mil. Prime RMBS Deals
------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 46
tranches from eight RMBS transactions, backed by Prime jumbo
loans, issued by miscellaneous issuers.

Complete rating actions are as follows:

Issuer: Charlie Mac Trust 2004-2

Cl. A-1, Downgraded to Ba1 (sf); previously on Mar 2, 2012
Downgraded to A2 (sf)

Cl. A-2, Downgraded to Ba1 (sf); previously on Mar 2, 2012
Downgraded to A3 (sf)

Cl. A-3, Downgraded to Ba2 (sf); previously on Mar 2, 2012
Downgraded to A3 (sf)

Cl. B-1, Downgraded to Caa2 (sf); previously on Mar 2, 2012
Downgraded to Ba3 (sf)

Cl. B-2, Downgraded to Ca (sf); previously on Mar 2, 2012
Downgraded to Caa3 (sf)

Issuer: Chase Mortgage Finance Trust, Series 2004-S2

Cl. IA-3, Downgraded to A1 (sf); previously on Apr 22, 2011
Downgraded to Aa1 (sf)

Cl. A-P, Downgraded to Baa1 (sf); previously on Apr 5, 2012
Downgraded to A2 (sf)

Cl. B-1, Downgraded to Caa3 (sf); previously on Apr 5, 2012
Downgraded to B3 (sf)

Cl. IIA-3, Downgraded to Baa2 (sf); previously on Apr 5, 2012
Downgraded to A3 (sf)

Cl. IIA-4, Downgraded to Baa2 (sf); previously on Apr 5, 2012
Downgraded to A2 (sf)

Cl. IIA-6, Downgraded to Baa2 (sf); previously on Apr 5, 2012
Downgraded to A2 (sf)

Issuer: CHL Mortgage Pass-Through Trust, Series 2002-J5

Cl. 2-A-1, Downgraded to A2 (sf); previously on Apr 13, 2012
Downgraded to Aa3 (sf)

Cl. 1-A-16, Downgraded to Baa3 (sf); previously on Apr 13, 2012
Downgraded to A3 (sf)

Cl. PO, Downgraded to Baa3 (sf); previously on Apr 13, 2012
Downgraded to A3 (sf)

Issuer: Citicorp Mortgage Securities, Inc. 2004-1

Cl. IA-3, Downgraded to Baa3 (sf); previously on May 17, 2011
Downgraded to Baa1 (sf)

Underlying Rating: Downgraded to Baa3 (sf); previously on May 17,
2011 Downgraded to Baa1 (sf)

Financial Guarantor: MBIA Insurance Corporation (B3 placed on
review for possible downgrade on Dec 19, 2011)

Cl. IA-3A, Downgraded to Baa3 (sf); previously on May 17, 2011
Downgraded to Baa1 (sf)

Cl. IA-4A, Downgraded to B1 (sf); previously on Apr 6, 2012
Confirmed at Baa3 (sf)

Cl. IA-PO, Downgraded to Ba1 (sf); previously on May 17, 2011
Downgraded to Baa2 (sf)

Cl. IA-4, Downgraded to Baa2 (sf); previously on Apr 6, 2012
Confirmed at A3 (sf)

Cl. IIA-2, Downgraded to Baa3 (sf); previously on Apr 6, 2012
Downgraded to A3 (sf)

Cl. IIA-PO, Downgraded to Baa3 (sf); previously on May 17, 2011
Downgraded to Baa1 (sf)

Issuer: GMACM Mortgage Loan Trust 2004-J4

Cl. A-6, Downgraded to Baa2 (sf); previously on Apr 25, 2012
Downgraded to A3 (sf)

Cl. A-7, Downgraded to Baa2 (sf); previously on Apr 25, 2012
Downgraded to A3 (sf)

Cl. PO, Downgraded to Baa2 (sf); previously on Apr 25, 2012
Downgraded to A3 (sf)

Issuer: MASTR Asset Securitization Trust 2003-4

Cl. 6-A-2, Downgraded to Aa3 (sf); previously on May 16, 2003
Assigned Aaa (sf)

Cl. 6-A-3, Downgraded to A2 (sf); previously on Apr 28, 2011
Downgraded to Aa1 (sf)

Cl. 6-A-5, Downgraded to Aa1 (sf); previously on May 16, 2003
Assigned Aaa (sf)

Cl. 6-A-6, Downgraded to Aa1 (sf); previously on May 16, 2003
Assigned Aaa (sf)

Cl. 6-A-7, Downgraded to Aa1 (sf); previously on May 16, 2003
Assigned Aaa (sf)

Cl. 6-A-9, Downgraded to A1 (sf); previously on Apr 28, 2011
Downgraded to Aa1 (sf)

Cl. 6-A-10, Downgraded to A1 (sf); previously on Apr 28, 2011
Downgraded to Aa1 (sf)

Cl. 6-A-11, Downgraded to A1 (sf); previously on Apr 28, 2011
Downgraded to Aa1 (sf)

Cl. 6-A-16, Downgraded to Aa3 (sf); previously on Apr 28, 2011
Downgraded to Aa1 (sf)

Cl. 6-A-17, Downgraded to A2 (sf); previously on Apr 28, 2011
Downgraded to Aa1 (sf)

Cl. 6-B-3, Downgraded to Ca (sf); previously on Apr 28, 2011
Downgraded to Caa1 (sf)

Issuer: Merrill Lynch Mortgage Investors Trust MLCC 2004-G

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

Cl. A-2, Downgraded to Baa2 (sf); previously on Apr 18, 2011
Downgraded to A3 (sf)

Cl. X-A, Downgraded to Baa2 (sf); previously on Apr 18, 2011
Downgraded to A3 (sf)

Cl. B-1, Downgraded to B3 (sf); previously on Apr 18, 2011
Downgraded to B1 (sf)

Cl. B-2, Downgraded to Ca (sf); previously on Apr 18, 2011
Downgraded to Caa2 (sf)

Cl. B-3, Downgraded to C (sf); previously on Apr 18, 2011
Downgraded to Ca (sf)

Cl. X-B, Downgraded to Caa3 (sf); previously on Feb 22, 2012
Downgraded to Caa2 (sf)

Issuer: MRFC Mortgage Pass-Through Certificates, Series 2002-TBC1

Cl. A, Downgraded to Baa1 (sf); previously on May 2, 2012
Downgraded to A1 (sf)

Cl. B-1, Downgraded to Baa3 (sf); previously on May 2, 2012
Downgraded to A3 (sf)

Cl. B-2, Downgraded to Ba3 (sf); previously on May 2, 2012
Downgraded to Baa2 (sf)

Cl. B-3, Downgraded to B3 (sf); previously on May 2, 2012
Downgraded to Ba2 (sf)

RATINGS RATIONALE

The actions are a result of the recent performance of the pools
and reflect Moody's updated loss expectations on these pools. The
downgrades are a result of deteriorating performance of the pools
and structural features 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. 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 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

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.

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 7.9% in October 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_SF305627

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


* Moody's Reviews Stand-Alone Housing Bonds for Downgrade
---------------------------------------------------------
Moody's Investors Service has placed the following ratings of
stand-alone multifamily housing bonds with mortgage enhancements
under review for possible downgrade.

1) Harrisonburg Redevelopment & Housing Auth, VA Taxable Multi-
Family Housing Revenue Bonds (Huntington Village Apartments
Project) 2001B; rated Aaa, under review for downgrade;
approximately $1,720,000 of debt outstanding.

2) Yonkers Industrial Development Agency, NY Multi-Family Housing
Revenue Bonds (Herriot Street Housing, L.P. Project) 2004; rated
Ba1, under review for downgrade; approximately $13,190,000 of debt
outstanding.

3) Ohio Housing Finance Agency, Multi-Family Housing Revenue Bonds
(Sharon Green Townhomes) 2005G; rated Ba1, under review for
downgrade; approximately $5,535,000 of debt outstanding.

The principal methodology used for the above referenced ratings
was Fixed Rate Multifamily Housing Bonds Secured by Fannie Mae's
Stand-By Credit Enhancement Instrument, published November 2006.

4) St. Paul Housing & Redevelopment Auth., MN Multi-Family (GNMA
Collateralized - Riverview Highland Project) 2002; rated Ba1,
under review for downgrade; approximately $3,710,000 of debt
outstanding.

The principal methodology used for the above referenced rating was
GNMA Collateralized Multifamily Housing Bonds, published July
2010.

Ratings Rationale

Cash flow projections assuming 0% reinvestment rates demonstrate
that the asset-to-debt ratio is currently, or forecasted to fall,
below 100%. Over the next several weeks, Moody's will assess the
credit implications of the cash flow projections and align the
ratings appropriately. This review could result in multi-notch
downgrades to the ratings of the bonds.

Detailed Credit Discussion

The bonds are secured by a mortgage that is guaranteed by either
Ginnie Mae or Fannie Mae's Stand-by Credit Enhancement Instrument.
Monthly mortgage receipts are not reinvested in a guaranteed
investment contract (GIC) that assures a fixed rate of return,
subjecting the transaction to interest rate risk on retained
revenues. As a result, revenue from the monthly mortgage receipts,
interest earned on those receipts from money market funds or other
short-term investments and monthly mortgage payments need to be
sufficient to support debt service on the bonds. Additionally, at
all times the ratio of the value of the assets held by the
trustee, consisting of the amortized value of the credit-enhanced
mortgage and funds pledged to bondholders, to the bonds
outstanding and accrued interest to any redemption date should
exceed 100%.

Outlook

What Could Change The Rating: UP

- An increase in the asset-to-debt ratio above 100%

- Greater return on reinvestment following increases in the
   interest rate environment

What Could Change The Rating: DOWN

- Prolonged low interest rate environment

- A decline in the asset-to-debt ratio


* S&P Withdraws Ratings on 27 Note Classes From 14 CDO Deals
------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 27
classes of notes from 10 collateralized loan obligation
transactions, two collateralized debt obligation (CDO)
transactions backed by commercial mortgage-backed securities, one
collateralized bond obligation transaction, and one CDO
transaction backed by residential mortgage-backed securities.

"The withdrawals follow the complete paydown of the notes on their
most recent payment dates. Standard & Poor's notes that Atrium CDO
and DFR Middle Market CLO Ltd. redeemed their classes in full
after providing notice to us that the issuers directed optional
redemptions," 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 Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at:

      http://standardandpoorsdisclosure-17g7.com

RATINGS WITHDRAWN

505 CLO I Ltd.
                    Rating             Rating
Class               To                  From
B                   NR                  AAA (sf)

ACAS Business Loan Trust 2005-1
                    Rating             Rating
Class               To                  From
C                   NR                  B+ (sf)

Atrium CDO
                    Rating             Rating
Class               To                  From
A                   NR                  AAA (sf)
B-1                 NR                  AA (sf)
B-2                 NR                  AA (sf)
C-1                 NR                  BBB+ (sf)
C-2                 NR                  BBB+ (sf)
D-1                 NR                  BB+ (sf)
D-2                 NR                  BB+ (sf)

Black Diamond International Funding Ltd 2005-A
                            Rating
Class               To                  From
2005-A MTN          NR                  AAA (sf)
Sr VFN              NR                  AAA (sf)

C-Bass CBO VI Ltd.
                            Rating
Class               To                  From
B                   NR                  BBB (sf)

DFR Middle Market CLO Ltd.
                             Rating
Class               To                  From
B                   NR                  AAA (sf)
C                   NR                  A+ (sf)
D                   NR                  BBB+ (sf)

G-Star 2002-1 Ltd.
                            Rating
Class               To                  From
A-2                 NR                  AA+ (sf)

G-Star 2002-2 Ltd.
                            Rating
Class               To                  From
A-2                 NR                  AAA (sf)

Nicholas-Applegate CBO II Ltd.
                            Rating
Class               To                  From
B                   NR                  CCC- (sf)

NYLIM Flatiron CLO 2004-1 Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)

Primus CLO I Ltd.
                             Rating
Class               To                  From
A-1-B               NR                  AA+ (sf)
A-2                 NR                  AA+ (sf)
B                   NR                  A+ (sf)
C                   NR                  BBB+ (sf)
D                   NR                  BB+ (sf)

Sargas CLO II Ltd.
                             Rating
Class               To                  From
D                   NR                  BBB (sf)

Symphony CLO IX L.P.
                             Rating
Class               To                  From
X                   NR                  AAA (sf)

Vinacasa CLO Ltd.
                             Rating
Class               To                  From
A-2                 NR                  AAA (sf)

NR - Not rated.


* S&P Withdraws Ratings on 619 Tranches From 116 CDO Transactions
-----------------------------------------------------------------
Standard & Poor's Rating Services withdrew its ratings on 619
tranches from 116 U.S. cash flow and hybrid collateralized debt
obligation (CDO) transactions. The affected notes are primarily
issued by transactions that are collateralized by or reference
structured finance (SF) assets, including U.S. residential
mortgage-backed securities (RMBS).

"The affected classes of the cash flow and hybrid CDO transactions
have carried a rating of 'CCC' or 'CC' or 'D'. A significant
portion of these notes have little realistic prospect of receiving
full payment. Further, we do not expect some of these notes to
receive any payments in the future," S&P said.

"The rating withdrawal follows the application of our policy for
withdrawal of ratings, following what we believe to be a lack of
market interest in the rating assigned to these notes," S&P said.

RATINGS WITHDRAWN

ABACUS 2005-3 Ltd.
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  D(sf)
B Series 2          NR                  D(sf)
C                   NR                  D(sf)
C Series2           NR                  D(sf)
D                   NR                  D(sf)
D Series 2          NR                  D(sf)
D Series 3          NR                  D(sf)
E                   NR                  D(sf)

ABACUS 2006-13 Ltd.
                            Rating
Class               To                  From
A                   NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  CC(sf)
D                   NR                  CC(sf)
E                   NR                  CC(sf)
F                   NR                  CC(sf)
G                   NR                  CC(sf)
H                   NR                  CC(sf)
K                   NR                  CC(sf)
L                   NR                  D(sf)
M                   NR                  D(sf)

ABACUS 2006-17 Ltd
                            Rating
Class               To                  From
A-1                 NR                  CC(sf)
A-2                 NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)
F                   NR                  D(sf)
G                   NR                  D(sf)
H                   NR                  D(sf)
J                   NR                  D(sf)
K                   NR                  D(sf)
L                   NR                  D(sf)
M                   NR                  D(sf)
N                   NR                  D(sf)
O                   NR                  D(sf)
P                   NR                  D(sf)
Q                   NR                  D(sf)

ABACUS 2006-NS1 Ltd.
                            Rating
Class               To                  From
A                   NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  CC(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)
F                   NR                  D(sf)
G                   NR                  D(sf)
H                   NR                  D(sf)
J                   NR                  D(sf)
K                   NR                  D(sf)

ABACUS 2007-18 Ltd
                            Rating
Class               To                  From
A-1                 NR                  CC(sf)
A-3                 NR                  CC(sf)
B Series 2          NR                  D(sf)

ABS Capital Funding II, Ltd.
                            Rating
Class               To                  From
A-1                 NR                  D(sf)
A-2                 NR                  CCC-(sf)
A-3                 NR                  D(sf)
B                   NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)

ABSpoke 2005-IA, Ltd.
                            Rating
Class               To                  From
ABSpoke             NR                  CC(sf)

ABSpoke 2005-VIA, Ltd.
                            Rating
Class               To                  From
VFRN                NR                  CCC-(sf)

Acacia CDO 5, Ltd.
                            Rating
Class               To                  From
A                   NR                  CCC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)

Adirondack 2005-1, Ltd.
                            Rating
Class               To                  From
A-1LT-a             NR                  CCC-(sf)
A-1LT-b             NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)

Adirondack 2005-2 Ltd.
                            Rating
Class               To                  From
A-1LT-a             NR                  CCC-(sf)

A-1LT-b             NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)

Altius III Fdg Ltd.
                            Rating
Class               To                  From
A-1a                NR                  D(sf)
A-1b-1B             NR                  D(sf)
A-1b-1F             NR                  CC(sf)
A-1b-2              NR                  D(sf)
A-1b-3              NR                  D(sf)
A-1b-V              NR                  D(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)
S                   NR                  CCC-(sf)

Anderson Mezzanine Funding 2007-1, Ltd.
                            Rating
Class               To                  From
A-1a                NR                  D(sf)
A-1b                NR                  D(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
S                   NR                  CCC-(sf)

Ayresome CDO I, Ltd.
                            Rating
Class               To                  From
A-1a                NR                  CCC(sf)

A-1b                NR                  CC(sf)
A-2                 NR                  D(sf)
A-3                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
Combo Secs          NR                  D(sf)
D                   NR                  D(sf)

Bernoulli High Grade CDO I, Ltd.
                            Rating
Class               To                  From
A-1A                NR                  D(sf)
A-1B                NR                  CCC-(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)

Bluegrass ABS CDO II Ltd.
                            Rating
Class               To                  From
A-1MT-a             NR                  CCC-(sf)
A-1MT-b             NR                  CCC-(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)
Type I Com          NR                  D(sf)

Calculus ABS Resecuritization Trust Series 2007-1
2007-1
                            Rating
Class               To                  From
VarDisTrUn          NR                  CCC-(sf)

Calculus ABS Resecuritization Trust Series 2007-2
2007-2
                            Rating
Class               To                  From
VarDisTrUn          NR                  CCC-(sf)


Capital Guardian ABS CDO I, Ltd.
                            Rating
Class               To                  From
B                   NR                  D(sf)
C                   NR                  D(sf)
Pfd Shares          NR                  D(sf)

Cascade Funding CDO I, Ltd
                            Rating
Class               To                  From
A-1                 NR                  CC(sf)
A-2                 NR                  D(sf)

C-Bass CBO XII, Ltd.
                            Rating
Class               To                  From
A                   NR                  CCC(sf)
B                   NR                  CC(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)

Class V Funding II Ltd
                            Rating
Class               To                  From
A-1                 NR                  D(sf)
A-2A                NR                  D(sf)
A-2B                NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)

Commodore CDO I Ltd.
                            Rating
Class               To                  From
B                   NR                  CCC-(sf)
C                   NR                  D(sf)

Commodore CDO II Ltd
                            Rating
Class               To                  From

A-1MM               NR                  CC/C(sf)
A-2 (a)             NR                  CC(sf)
A-2 (b)             NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Commodore CDO IV Ltd
                            Rating
Class               To                  From
A-1(a)-F            NR                  CCC-(sf)
A-1(a)-U            NR                  CCC-(sf)
A-1(b)              NR                  CC(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
Comp Nts            NR                  D(sf)
D                   NR                  D(sf)

Coolidge Funding, Ltd.
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)

CRAFT 2005-3 Ltd.
                            Rating
Class               To                  From
A                   NR                  A+srp
B                   NR                  Asrp
C                   NR                  BBB+srp
Junior AAA          NR                  A+srp

Credit Default Swap
                            Rating
Class               To                  From
Tranche             NR                  CCsrp

Crest G-Star 2001-1 LP
2001-1
                            Rating
Class               To                  From
B-1                 NR                  CCC-(sf)
B-2                 NR                  CCC-(sf)
C                   NR                  CC(sf)
D                   NR                  CC(sf)

Crystal Cove CDO, Ltd.
                            Rating
Class               To                  From
A1                  NR                  CC(sf)
A2                  NR                  D(sf)
B                   NR                  D(sf)
C1                  NR                  D(sf)
C2                  NR                  D(sf)

CWCapital COBALT III Synthetic CDO Ltd
                            Rating
Class               To                  From
A                   NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)
F                   NR                  D(sf)
G                   NR                  D(sf)

Duke Funding High Grade III, Ltd.
                            Rating
Class               To                  From
A-1A                NR                  D(sf)
A-1B1               NR                  D(sf)
A-1B2               NR                  CCC-(sf)
A-2                 NR                  D(sf)
B-1                 NR                  D(sf)
B-2                 NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)
D                   NR                  D(sf)
Sub Nts             NR                  D(sf)

Dunhill ABS CDO Ltd
                            Rating
Class               To                  From
A-1NV               NR                  CCC-(sf)
A-1VA               NR                  CCC-(sf)
A-1VB               NR                  CCC-(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Eaton Vance CDO II Ltd.
                            Rating
Class               To                  From
A                   NR                  D(sf)

Eirles Two Ltd.
242-245 & 247
                            Rating
Class               To                  From
Series 242          NR                  D(sf)
Series 243          NR                  CC(sf)
Series 244          NR                  CC(sf)
Series 245          NR                  D(sf)
Series 247          NR                  CC(sf)

Eolo Investments B.V.
2006-1
                            Rating
Class               To                  From
Tranche             NR                  CCsrp

ESP Funding I Ltd
B07591
                            Rating
Class               To                  From
A-1R                NR                  CC(sf)
A-1T1               NR                  CC(sf)
A-1T2               NR                  CC(sf)
A-2                 NR                  D(sf)
A-3                 NR                  D(sf)
A-4                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Fort Point CDO I Ltd.
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2a                NR                  D(sf)
A-2b                NR                  D(sf)
A-3a                NR                  D(sf)
A-3b                NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Galleria V Ltd
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  CCC-(sf)
B                   NR                  CC(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)
Pref Share          NR                  D(sf)

Global Credit Pref Corp.
                            Rating
Class               To                  From
Pfd Shares          NR                  P-5(Low)

GSC ABS CDO 2006-2m, Ltd.
                            Rating
Class               To                  From
A1A                 NR                  D(sf)
A1B                 NR                  D(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)
F                   NR                  D(sf)
G                   NR                  D(sf)

HARBOR SPC
2006-1
                            Rating
Class               To                  From
A                   NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)

High Grade Structured Credit 2004-1 Limited
                            Rating
Class               To                  From
C                   NR                  CC(sf)
D                   NR                  CC(sf)
E                   NR                  CC(sf)

Huntington CDO Ltd
                            Rating
Class               To                  From
A-1A                NR                  CCC-(sf)
A-1B                NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  CC(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)

Independence III CDO, Ltd.
                            Rating
Class               To                  From
A-1                 NR                  D(sf)
B                   NR                  CC(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)

Ischus CDO I Ltd
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)
Combo Secs          NR                  D(sf)

Jupiter High Grade CDO Ltd
                            Rating
Class               To                  From
A-1A                NR                  CCC-(sf)
A-1B                NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Kimberlite CDO I Ltd.
                            Rating
Class               To                  From
A                   NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
COMBO Nts           NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)
F                   NR                  D(sf)
G                   NR                  D(sf)
H                   NR                  D(sf)
Super Sen           NR                  CC(sf)

Kleros Preferred Funding Ltd
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)

Lakeside CDO I Ltd
                            Rating
Class               To                  From
A-1                 NR                  CC(sf)

Lakeside CDO II Ltd
                            Rating
Class               To                  From
A-1                 NR                  CCC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Lenox CDO Ltd
                            Rating
Class               To                  From
A-1J                NR                  D(sf)
A-1S                NR                  CCC-(sf)
A-2                 NR                  D(sf)
B-1                 NR                  D(sf)
B-2                 NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E-1                 NR                  D(sf)
E-2                 NR                  D(sf)

Lenox Street 2007-1. Ltd.
                            Rating
Class               To                  From
A                   NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)
F                   NR                  D(sf)
G                   NR                  D(sf)
H                   NR                  D(sf)
J                   NR                  D(sf)

Longport Funding Ltd
                            Rating
Class               To                  From
A-1A                NR                  CCC-(sf)
A-1B                NR                  D(sf)
A-2-P**             NR                  D(sf)
A-3                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D-1                 NR                  D(sf)
D-2                 NR                  D(sf)
Part. Note          NR                  D(sf)

Maclaurin SPC
                            Rating
Class               To                  From
A                   NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  CC(sf)
D                   NR                  CC(sf)
E                   NR                  CC(sf)
F                   NR                  CC(sf)
G                   NR                  CC(sf)
H                   NR                  CC(sf)
J                   NR                  CC(sf)

Magnolia Finance II PLC
2006-6A2E
                            Rating
Class               To                  From
Notes               NR                  CC(sf)
2006-6A2G
                            Rating
Class               To                  From
Notes               NR                  CC(sf)
2006-6B
                            Rating
Class               To                  From
Series B            NR                  CC(sf)
2006-6C
                            Rating
Class               To                  From
Series C            NR                  CC(sf)
2006-6D
                            Rating
Class               To                  From
Series D            NR                  CC(sf)
2006-6E
                            Rating
Class               To                  From
Series E            NR                  CC(sf)

Mercury CDO 2004-1 Ltd
                            Rating
Class               To                  From
A-1NV               NR                  CCC-(sf)
A-1VA               NR                  CCC-(sf)
A-1VB               NR                  CCC-(sf)
A-2A                NR                  CC(sf)
A-2B                NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Mercury CDO II Ltd
                            Rating
Class               To                  From
A-1                 NR                  CC(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)


Mid Ocean CBO 2000-1 Ltd.
                            Rating
Class               To                  From
A-1L                NR                  CC(sf)

Mid Ocean CBO 2001-1 Ltd
                            Rating
Class               To                  From
A-1                 NR                  CC(sf)
A-1L                NR                  CC(sf)
A-2L                NR                  D(sf)
B-1L                NR                  D(sf)

MKP CBO IV, Ltd.
                            Rating
Class               To                  From
A-1                 NR                  CCC(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Newcastle CDO VI Limited
                            Rating
Class               To                  From
I-B                 NR                  CC(sf)
II Def              NR                  CC(sf)
III-FL Def          NR                  D(sf)
III-FX Def          NR                  D(sf)
IMMLT               NR                  CCC(sf)
IV-FL Def           NR                  D(sf)
IV-FX Def           NR                  D(sf)
V-Def               NR                  D(sf)

North Street Referenced Linked Notes, 2004-6 Limited
                            Rating
Class               To                  From
A                   NR                  CC(sf)

Northlake CDO I, Limited

                            Rating
Class               To                  From
I-A                 NR                  D(sf)
II                  NR                  D(sf)
III                 NR                  D(sf)
I-MM                NR                  CCC-(sf)

Opus CDO I Ltd.
                            Rating
Class               To                  From
A                   NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
Combo Note          NR                  D(sf)
D                   NR                  D(sf)
Sub Notes           NR                  D(sf)

Orchard Park Ltd.
                            Rating
Class               To                  From
A-1 ser 1           NR                  CC(sf)
A-1 ser 2           NR                  CC(sf)

Orchid Structured Finance CDO II, Ltd.
                            Rating
Class               To                  From
A-1                 NR                  D(sf)
A-2                 NR                  D(sf)
A-3                 NR                  D(sf)
B                   NR                  D(sf)

Orchid Structured Finance CDO, Ltd.
                            Rating
Class               To                  From
A-2                 NR                  CCC-(sf)
B                   NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)

Palisades CDO Ltd.

                            Rating
Class               To                  From
A-1A                NR                  CCC-(sf)
A-1B                NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B-1                 NR                  D(sf)
B-2                 NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)
Type II             NR                  D(sf)

Porter Square CDO I, Ltd
                            Rating
Class               To                  From
B                   NR                  CCC-(sf)
C                   NR                  D(sf)

Putnam Structured Product Funding 2003-1 Ltd.
                            Rating
Class               To                  From
A-2                 NR                  CCC-(sf)
B                   NR                  CC(sf)
C                   NR                  CC(sf)

Reservoir Funding Ltd
                            Rating
Class               To                  From
A-1-NV              NR                  CCC(sf)
A-1-V               NR                  CCC(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)

Restructured Asset Certificates with Enhanced Returns Series 2007-
2-E Certificates
2007-2-E
                            Rating
Class               To                  From
2006-2-E            NR                  CCC-(sf)


Revelstoke CDO I Limited
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  D(sf)
A-3                 NR                  D(sf)
B                   NR                  D(sf)

Rockville CDO I Ltd
                            Rating
Class               To                  From
A-1                 NR                  D(sf)
A-2                 NR                  D(sf)
A-3                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)

Rutland Rated Investments
13
                            Rating
Class               To                  From
Series 13           NR                  CC(sf)
14
                            Rating
Class               To                  From
Series 14           NR                  CC(sf)
56
                            Rating
Class               To                  From
Series 56           NR                  CC(sf)
57
                            Rating
Class               To                  From
Series 57           NR                  CC(sf)

Saturn Ventures 2004 - Fund America Investors III, Limited
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)

A-2                 NR                  CC(sf)
A-3                 NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)

Solstice ABS CBO III Ltd
                            Rating
Class               To                  From
A-2                 NR                  CCC-(sf)
B                   NR                  CC(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)

Solstice ABS CBO Ltd.
                            Rating
Class               To                  From
A                   NR                  CCC-(sf)

Sorin Real Estate CDO III Ltd
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  CC(sf)
C-FL                NR                  D(sf)
C-FX                NR                  D(sf)
D                   NR                  D(sf)

SPGS SPC
MSC 2006-SRR1-A2
                            Rating
Class               To                  From
A2                  NR                  CC(sf)
A2-S                NR                  CC(sf)
MSC 2006-SRR1-B
                            Rating
Class               To                  From
B                   NR                  CC(sf)
B-S                 NR                  CC(sf)

MSC2007-SRR3
                            Rating
Class               To                  From
A                   NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  CC(sf)
D                   NR                  CC(sf)
E                   NR                  CC(sf)
F                   NR                  CC(sf)
G                   NR                  CC(sf)
H                   NR                  CC(sf)
J                   NR                  CC(sf)
K                   NR                  D(sf)
L                   NR                  D(sf)
M                   NR                  D(sf)
N                   NR                  D(sf)
O                   NR                  D(sf)
P                   NR                  D(sf)
Q                   NR                  D(sf)
R                   NR                  D(sf)

SPGS SPC, acting for the account of MSC 2006-SRR2 Segregated
Portfolio
MSC 2006-SRR2
                            Rating
Class               To                  From
A-1                 NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  CC(sf)
D                   NR                  CC(sf)
E                   NR                  CC(sf)
F                   NR                  CC(sf)
G                   NR                  CC(sf)
H                   NR                  CC(sf)
J                   NR                  CC(sf)
K                   NR                  D(sf)
L                   NR                  D(sf)
M                   NR                  D(sf)

N                   NR                  D(sf)
O                   NR                  D(sf)
P                   NR                  D(sf)
Q                   NR                  D(sf)

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

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

Straits Global ABS CDO I Ltd
                            Rating
Class               To                  From
A Combo             NR                  D(sf)
A-1                 NR                  CCC-(sf)
A-2                 NR                  D(sf)
B Combo             NR                  D(sf)
B-1                 NR                  D(sf)
B-2                 NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)

Streeterville ABS CDO Ltd
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B-1                 NR                  D(sf)
B-2                 NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)


Structured Finance Advisors ABS CDO III, Ltd.
                            Rating
Class               To                  From
A                   NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
Pfd Shares          NR                  D(sf)

Summit RMBS CDO I Ltd
                            Rating
Class               To                  From
A-1J                NR                  CC(sf)
A-1S                NR                  CCC-(sf)
A-2                 NR                  D(sf)
A-3F                NR                  D(sf)
A-3V                NR                  D(sf)
BF                  NR                  D(sf)
BV                  NR                  D(sf)
Comb I              NR                  D(sf)
Comb II             NR                  D(sf)
Pref Share          NR                  D(sf)

Taberna Preferred Fdg VII Ltd.
                            Rating
Class               To                  From
A-1LA               NR                  D(sf)
A-1LB               NR                  D(sf)
A-2LA               NR                  D(sf)
A-2LB               NR                  CC(sf)
A-3L                NR                  CC(sf)
B-1L                NR                  CC(sf)
B-2L                NR                  CC(sf)
C-1(combo)          NR                  CC(sf)

TABERNA Preferred Funding III Ltd
                            Rating
Class               To                  From
A-1A                NR                  D(sf)

A-1B                NR                  D(sf)
A-1C                NR                  D(sf)
A-2A                NR                  D(sf)
A-2B                NR                  D(sf)
B-1                 NR                  D(sf)
B-2                 NR                  D(sf)
C-1                 NR                  CC(sf)
C-2                 NR                  CC(sf)
D                   NR                  CC(sf)
E                   NR                  CC(sf)

TABERNA Preferred Funding IV Ltd
                            Rating
Class               To                  From
A-1                 NR                  D(sf)
A-2                 NR                  D(sf)
A-3                 NR                  D(sf)
B-1                 NR                  D(sf)
B-2                 NR                  D(sf)
C-1                 NR                  CC(sf)
C-2                 NR                  CC(sf)
C-3                 NR                  CC(sf)
D-1                 NR                  CC(sf)
D-2                 NR                  CC(sf)
E                   NR                  CC(sf)

Taberna Preferred Funding IX Ltd
                            Rating
Class               To                  From
A-1LA               NR                  CCC-(sf)
A-1LAD              NR                  CCC-(sf)
A-1LB               NR                  CC(sf)
A-2LA               NR                  CC(sf)
A-2LB               NR                  CC(sf)
A-3LA               NR                  CC(sf)
A-3LB               NR                  CC(sf)
B-1L                NR                  CC(sf)

B-2L                NR                  CC(sf)

Taberna Preferred Funding V, Ltd.
                            Rating
Class               To                  From
A-1LA               NR                  D(sf)
A-1LAD              NR                  D(sf)
A-1LB               NR                  D(sf)
A-2L                NR                  CC(sf)
A-3FV               NR                  CC(sf)
A-3FX               NR                  CC(sf)
A-3L                NR                  CC(sf)
B-1L                NR                  CC(sf)
B-2FX               NR                  CC(sf)
B-2L                NR                  CC(sf)

Taberna Preferred Funding VI Ltd
                            Rating
Class               To                  From
A-1A                NR                  D(sf)
A-1B                NR                  D(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
Comb Notes          NR                  CC(sf)
D-1                 NR                  CC(sf)
D-2                 NR                  CC(sf)
E-1                 NR                  CC(sf)
E-2                 NR                  CC(sf)
F-1                 NR                  CC(sf)
F-2                 NR                  CC(sf)

TIAA Structured Finance CDO I Ltd.
                            Rating
Class               To                  From
A-1                 NR                  CC(sf)
A-2                 NR                  CC(sf)


Trainer Wortham First Republic CBO II, Ltd.
                            Rating
Class               To                  From
A-1L                NR                  CC(sf)
A-2L                NR                  D(sf)
A-3L                NR                  D(sf)
B-1L                NR                  D(sf)
Pfd Shares          NR                  D(sf)

Trainer Wortham First Republic CBO III, Ltd.
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
Pre.Shares          NR                  D(sf)

Triaxx Prime CDO 2006-1 Ltd.
2006-1
                            Rating
Class               To                  From
A-1                 NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
X                   NR                  D(sf)

Triaxx Prime CDO 2006-2, Ltd.
                            Rating
Class               To                  From
A-1A                NR                  CCC-(sf)
A-1B2               NR                  CCC-(sf)
A-1BV               NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  CC(sf)

X                   NR                  CC(sf)

Triaxx Prime CDO 2007-1 Ltd
                            Rating
Class               To                  From
A-1D                NR                  CCC-(sf)
A-1T                NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  D(sf)
X                   NR                  CC(sf)

UBS AG (London Branch)
                            Rating
Class               To                  From
Var Notes           NR                  CCC-(sf)

Vermeer Funding II, Ltd.
                            Rating
Class               To                  From
A-1                 NR                  CCC(sf)
A-2A                NR                  CC(sf)
A-2B                NR                  CC(sf)
B                   NR                  D(sf)
C-1                 NR                  D(sf)
C-2                 NR                  D(sf)
Combo Secs          NR                  D(sf)

Vertical CRE CDO 2006-1, Ltd.
                            Rating
Class               To                  From
A                   NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)
E                   NR                  D(sf)
F                   NR                  D(sf)
G                   NR                  D(sf)
H                   NR                  D(sf)


West Coast Funding I Ltd
                            Rating
Class               To                  From
A-1a                NR                  CCC-(sf)
A-1b                NR                  D(sf)
A-1v                NR                  D(sf)
A-2                 NR                  D(sf)
A-3                 NR                  D(sf)
B                   NR                  D(sf)
C                   NR                  D(sf)
D                   NR                  D(sf)

Whately CDO I, Ltd.
                            Rating
Class               To                  From
A-1A                NR                  CCC-(sf)
A-1BF               NR                  D(sf)
A-1BV               NR                  D(sf)
A-2                 NR                  D(sf)
A-3                 NR                  D(sf)
B-F                 NR                  D(sf)
B-V                 NR                  D(sf)
Combo A             NR                  D(sf)

Whitehawk CDO Funding Ltd
                            Rating
Class               To                  From
A-1LT               NR                  CCC-(sf)
A-2                 NR                  CC(sf)
B                   NR                  CC(sf)
C                   NR                  CC(sf)
D                   NR                  CC(sf)


* S&P Takes Various Rating Actions on 55 Classes From 6 CMBS Deals
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on five
classes from three commercial mortgage-backed securities (CMBS)
transactions and removed four of them from CreditWatch with
positive implications. "Concurrently, we lowered our ratings on 28
classes from four CMBS transactions and removed six of them from
CreditWatch with negative implications. Finally, we affirmed our
ratings on 22 classes from four CMBS transactions and removed
three of these ratings from CreditWatch with positive
implications. The CreditWatch resolutions are related to
CreditWatch placements that occurred 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. We raised our ratings on
classes A-1-A and A-4 from CD 2007-CD4 Commercial Mortgage Trust
2007-CD4 and on class A-SB from J.P. Morgan Chase Commercial
Mortgage Securities Corp. 2007-LDP11 to 'AAA (sf)' to reflect the
results of our cash flow analysis. Our cash flow analysis
indicates that these classes should receive their respective full
repayment of principal due to time tranching," 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. Furthermore, we lowered
our ratings on various classes from three transactions to 'D (sf)'
due to interest shortfalls experienced by these classes and our
expectation that these classes will continue to experience
interest shortfalls and not repay in the near future. Details of
these rating actions are as follows: classes D, E, F, G, and H
from Greenwich Capital Commercial Funding Corp.'s 2007-GG9 have
experienced interest shortfalls for five or more months; classes
B, C, and D from GECMC 2007-C1 and classes D, E, and F from LB-UBS
Commercial Mortgage Trust 2007-C2 have been experiencing interest
shortfalls for nine or more months," S&P said.

"The affirmations primarily reflect our expected available credit
enhancement for the affected tranches, which we believe will
remain consistent with the most recent estimate of necessary
credit enhancement for the current rating levels. The affirmed
ratings also acknowledge our expectations regarding the current
and future performance of the collateral supporting the
transactions," S&P said.

"The rating actions taken on the interest-only (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 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

LB-UBS Commercial Mortgage Trust 2007-C2
Commercial mortgage pass-through certificates series 2007-C2
              Rating
Class     To        From         Credit enhancement (%)
A-2       AAA (sf)  AAA (sf)                 32.99
A-AB      AAA (sf)  AAA (sf)                 32.99
A-3       A- (sf)   A- (sf)/Watch Pos        32.99
A-1A      A- (sf)   A- (sf)/Watch Pos        32.99
A-M       B+(sf)    BB (sf)                  20.65
A-J       CCC- (sf) CCC+ (sf)                 9.69
B         CCC- (sf) CCC+ (sf)                 8.77
C         CCC- (sf) CCC (sf)                  6.92
D         D (sf)    CCC (sf)                  5.53
E         D (sf)    CCC (sf)                  5.06
F         D (sf)    CCC- (sf)                 4.14
G         D (sf)    CCC- (sf)                 2.90
X-CL      AAA (sf)  AAA (sf)                   N/A
X-CP      AAA (sf)  AAA (sf)                   N/A
X-W       AAA (sf)  AAA (sf)                   N/A

CD 2007-CD4
Commercial mortgage pass-through certificates series 2007-CD4
              Rating
Class     To        From         Credit enhancement (%)
A-4       AAA (sf)  A- (sf)/Watch Pos         35.36
A-1A      AAA (sf)  A- (sf)/Watch Pos         35.36

JPMorgan Chase Commercial Mortgage Securities Trust 2007-LDP11
Commercial mortgage pass-through certificates series 2007-LDP11
              Rating
Class     To         From        Credit enhancement (%)
A-2       AAA (sf)   AAA (sf)           32.84
A-2FL     AAA (sf)   AAA (sf)           32.84
A-3       AAA (sf)   AAA (sf)           32.84
A-4       BBB+ (sf)  BBB+ (sf)          32.84
A-SB      AAA (sf)   BBB+(sf)           32.84
A-1A      BBB+ (sf)  BBB+(sf)           32.84
A-M       B+(sf)    BB(sf)/Watch Neg    21.55
A-J       B- (sf)   B (sf)/Watch Neg    12.66
B         B- (sf)   B (sf)/Watch Neg    11.95
C         CCC (sf)  B- (sf)             10.26
D         CCC- (sf) CCC+ (sf)            9.13
E         CCC- (sf) CCC (sf)             8.56
F         CCC-(sf)  CCC- (sf)            7.58
X         AAA (sf)  AAA (sf)              N/A

GE Commercial Mortgage Corp. Series 2007-C1 Trust
Commercial mortgage pass-through certificates series 2007-C1
              Rating
Class     To        From          Credit enhancement (%)
A-2       AAA (sf)  AAA (sf)            33.48
A-3       AAA (sf)  AAA (sf)            33.48
A-AB      AAA (sf)  AAA (sf)            33.48
A-4       BBB+ (sf) BBB+ (sf)           33.48
A-1A      BBB+ (sf) BBB+ (sf)           33.48
A-M       B- (sf)   BB (sf)/Watch Neg   20.26
A-MFL     B- (sf)   BB (sf)/Watch Neg   20.26
A-J       CCC- (sf) B- (sf)             10.18
A-JFL     CCC- (sf) B- (sf)             10.18
B         D (sf)    CCC+ (sf)            8.86
C         D (sf)    CCC- (sf)            7.37
D         D (sf)    CCC- (sf)            6.05
XC        AAA (sf)  AAA (sf)              N/A
XP        AAA (sf)  AAA (sf)              N/A

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2007-C30
              Rating
Class     To        From          Credit enhancement (%)
A-5       A+ (sf)   BBB (sf)/Watch Pos  32.86
A-1A      A+ (sf)   BBB (sf)/Watch Pos  32.86

Greenwich Capital Commercial Funding Corp.
Commercial mortgage pass-through certificates series 2007-GG9
              Rating
Class     To        From          Credit enhancement (%)
A-1-A     A (sf)    A (sf)/Watch Pos    31.69
A-M       B+ (sf)   BBB- (sf)/Watch Neg 20.38
A-MFX     B+ (sf)   BBB- (sf)           20.38
D         D (sf)    CCC (sf)             7.51
E         D (sf)    CCC (sf)             6.81
F         D (sf)    CCC- (sf)            5.82
G         D (sf)    CCC- (sf)            4.83
H         D (sf)    CCC- (sf)            3.41

N/A - Not applicable.


* S&P Takes Various Rating Actions on 25 Classes From 3 CMBS Deals
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on six
classes from three commercial mortgage-backed securities (CMBS)
transactions and removed them from CreditWatch with positive
implications. "Concurrently, we lowered our ratings on 15 classes
from two CMBS transactions and removed six of them from
CreditWatch with negative implications. We also affirmed our
ratings on four classes from one CMBS transaction. 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. We raised our ratings on
classes A-1-A and A-3 from Credit Suisse Commercial Mortgage Trust
2007-C2 and classes A-3 and A-SB from Merrill Lynch Mortgage Trust
2007-c1 to 'AAA (sf)' to reflect the results of our cash flow
analysis," S&P said.

"Our cash flow analysis indicates that these classes should
receive their respective full repayment of principal due to time
tranching," 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. We lowered our ratings on classes A-1A and A-
4 from Merrill Lynch Mortgage Trust 2007-C1 to reflect our
analysis of the Empirian Multifamily Portfolio Pool 1 and Empirian
Multifamily Portfolio Pool 3 loans, which were modified on Dec.
14, 2011. The modification included the creation of $115.4 million
and $99.1 million Hope Notes respectively, which combined
represent 6.5% of the pool. We lowered the ratings on the class B,
C, D, E and F bonds from Merrill Lynch Mortgage Trust 2007-C1 to
'D (sf)' to reflect our expectation that these classes will
continue to experience interest shortfalls indefinitely," S&P
said.

"The affirmations reflect our expected available credit
enhancement for the affected tranches, which we believe will
remain consistent with the most recent estimate of necessary
credit enhancement for the current rating levels. The affirmed
ratings also acknowledge our expectations regarding the current
and future performance of the collateral supporting the respective
transactions. We affirmed our ratings on the classes A-2FL and A-
3FL from Merrill Lynch Mortgage Trust 2007-C1 based on our current
counterparty criteria. Merrill Lynch Capital Services Inc. (not
rated) is the swap counterparty for the subject classes. It is our
understanding, based on information we received from the swap
counterparty, that Merrill Lynch & Co. Inc. (A-/Negative/A-2) is
the guarantor for obligations of Merrill Lynch Capital Services
Inc. In addition, Merrill Lynch Derivative Products AG ('AAA')
guarantees the obligations of Merrill Lynch Capital Services Inc.
based on a guaranty agreement. However, because Merrill Lynch
Derivative Products AG can terminate the guaranty agreement after
the swap counterparty satisfies certain ratings requirements, we
did not give any credit to the guaranty agreement in our analysis.
Following the application of our counterparty criteria for
structured finance transactions, the 'A (sf)' ratings on the
subject classes are one notch above our rating on Merrill Lynch
& Co. Inc. and are based primarily on our understanding that the
derivative obligations contain counterparty replacement
frameworks," S&P said.

"We affirmed our ratings on the interest-only (IO) certificates to
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,"
S&P said.

"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

Credit Suisse Commercial Mortgage Trust Series 2007-C2
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-3     AAA (sf)   A- (sf)/Watch Pos              31.44
A-1-A   AAA (sf)   A- (sf)/Watch Pos               31.44


Merrill Lynch Mortgage Trust 2007-C1
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-2    AAA (sf)   AAA (sf)                            32.48
A-2FL  A (sf)     A (sf)                              32.48
A-3    AAA (sf)   A+ (sf)/ Watch Pos                  32.48
A-3FL  A (sf)     A (sf)                              32.48
A-SB   AAA (sf)   A+ (sf)/Watch Pos                   32.48
A-4    BBB+(sf)   A+ (sf)                             32.48
A-1A   BBB+(sf)   A+ (sf)                             32.48
AM     B-(sf)     BBB-(sf)/Watch Neg                  20.28
AJ     CCC- (sf)  B+ (sf)/Watch Neg                   10.21
AJ-FL  CCC- (sf)  B+ (sf)/ Watch Neg                  10.21
B      D (sf)     CCC+ (sf)                            7.62
C      D (sf)     CCC- (sf)                            6.40
D      D (sf)     CCC- (sf)                            5.02
E      D (sf)     CCC- (sf)                            3.65
F      D (sf)     CCC- (sf)                            2.12
X      AAA (sf)   AAA (sf)                              N/A

JPMorgan Chase Commercial Mortgage Securities 2007-CIBC18
Commercial mortgage pass-through certificates series
                Rating
Class     To            From         Credit enhancement (%)
A-4       AA(sf)        A+(sf)/Watch Pos         27.18
A-1A      AA(sf)        A+(sf)/Watch Pos         27.18
A-J       B-(sf)        B+(sf)/Watch Neg          7.66
B         CCC (sf)      B(sf)/Watch Neg           5.52
C         CCC(sf)       B(sf)/Watch Neg           4.67
D         CCC-(sf)      B-(sf)                    2.95
E         CCC-(sf)      CCC(sf)                   1.81


* S&P Withdraws Ratings on 5 Note Classes From 2 CDO Deals
----------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on five
classes of notes from two synthetic corporate investment-grade
collateralized debt obligation (CDO) transactions.

"We withdrew the ratings following our receipt of redemption
notices from the trustees," 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

North Street Referenced Linked Notes 2005-9 Ltd.
Series 2005-9
                              Rating
Class                   To           From
C                       NR           AAA (sf)
D                       NR           AAA (sf)
E                       NR           AAA (sf)
F                       NR           BB+ (sf)

STRATA 2006-36 Ltd.
Series 2006-36
                              Rating
Class                   To           From
Notes                   NR           CCC- (sf)

NR - Not rated.


* S&P Lowers Ratings on 8 Note Classes to 'D' From 2 CDO Deals
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D (sf)'
on eight classes of notes from two synthetic collateralized debt
obligation (CDO) transactions.

Aphex Capital NSCR 2007-7SR Ltd. is a synthetic CDO backed by
commercial mortgage-backed securities (CMBS). The lowered ratings
follow interest shortfalls according to the September 2012 note
payment report.

Newport Waves CDO series 7 is a synthetic corporate investment
grade CDO. The lowered rating on the class A3-ELS notes follow
credit events on the transaction's underlying reference entities,
which caused the notes to incur principal losses.

         STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Aphex Capital NSCR 2007-7SR Ltd
Series 2007-7SR
                             Rating
Class                   To           From
A-2                     D (sf)       CC (sf)
B                       D (sf)       CC (sf)
C                       D (sf)       CC (sf)
D-A                     D (sf)       CC (sf)
D-B                     D (sf)       CC (sf)
E                       D (sf)       CC (sf)
F                       D (sf)       CC (sf)

Newport Waves CDO
Series 7
                            Rating
Class                   To           From
A3-ELS                  D (sf)       CCC- (sf)


* S&P Lowers Ratings on 26 Classes From 4 US CMBS Transactions
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 26
classes from four U.S. commercial mortgage-backed securities
(CMBS) transactions and removed 18 of these ratings from
CreditWatch with negative implications. "The CreditWatch
resolutions are related to CreditWatch placements that we
initiated on Sept. 5, 2012," 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. Furthermore, we lowered
the ratings on classes F and G from Bear Stearns Commercial
Mortgage Securities Trust 2006-PWR12 to 'D (sf)' due to these
classes experiencing interest shortfalls for three months or more
and our expectation that they will continue to experience interest
shortfalls for the foreseeable future," 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 17-g7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Bear Stearns Commercial Mortgage Securities Trust 2006-PWR11
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-J    BB (sf)    BBB- (sf)/Watch Neg                 12.38
B      B+ (sf)    BB (sf)/Watch Neg                   10.10
C      B (sf)     BB- (sf)/Watch Neg                   8.67
D      B- (sf)    B (sf)/Watch Neg                     6.96
E      B- (sf)    B (sf)/Watch Neg                     5.81
F      CCC (sf)   B- (sf)                              4.53
G      CCC- (sf)  CCC (sf)                             3.39

Bear Stearns Commercial Mortgage Securities Trust 2006-PWR12
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-J    BB- (sf)   BB+ (sf)/Watch Neg                   9.78
B      B (sf)     BB- (sf)/Watch Neg                   7.26
C      B- (sf)    B+ (sf)/Watch Neg                    6.22
D      CCC (sf)   B (sf)/Watch Neg                     4.29
E      CCC- (sf)  B- (sf)                              3.10
F      D (sf)     CCC+ (sf)                            1.62
G      D (sf)     CCC- (sf)                            0.43

Bear Stearns Commercial Mortgage Securities Trust 2006-PWR13
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-J    BB- (sf)   BBB- (sf)/Watch Neg                 11.47
B      B (sf)     BB- (sf)/Watch Neg                   8.95
C      B- (sf)    B+ (sf)/Watch Neg                    7.83
D      B- (sf)    B (sf)/Watch Neg                     6.29
E      CCC (sf)   B- (sf)                              5.17
F      CCC- (sf)  CCC (sf)                             3.91

Bear Stearns Commercial Mortgage Securities Trust 2006-PWR14
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-J    BB (sf)    BBB (sf)/Watch Neg                   9.39
B      B (sf)     BB+ (sf)/Watch Neg                   7.18
C      B- (sf)    BB (sf)/Watch Neg                    6.01
D      B- (sf)    B+ (sf)/Watch Neg                    4.24
E      CCC (sf)   B (sf)/Watch Neg                     3.21
F      CCC- (sf)  CCC+ (sf)                            2.03


* S&P Cuts Ratings on 587 Classes From 177 US RMBS Transactions
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 587
classes from 177 U.S. residential mortgage-backed securities
(RMBS) transactions and removed 277 of them from CreditWatch with
negative implications, 34 of them from CreditWatch with developing
implications, and one of them from CreditWatch with positive
implications. "We also raised our ratings on 41 classes from 19
transactions and removed 19 of them from CreditWatch positive,
nine of them from CreditWatch developing, and one of them from
CreditWatch negative. We also affirmed our ratings on 702 classes
from 170 transactions and removed 29 of them from CreditWatch
negative, 18 from CreditWatch developing, and six from CreditWatch
positive. We also withdrew our ratings on 28 classes from 16
transactions. All of the withdrawn ratings were on CreditWatch
negative," S&P said.

The complete CreditWatch list is available for free at:

            http://bankrupt.com/misc/S&P_110912_RMBS.pdf

"The transactions in this review were issued between 2002 and 2007
and are backed by primarily by adjustable- and fixed-rate Alt-A,
high LTV, and Neg-am mortgage loans secured primarily by first
liens on one- to four-family residential properties," S&P said.

"On Aug. 15, 2012, we placed our ratings on 425 classes from 75
transactions within this review on CreditWatch negative, positive,
or developing, along with ratings from a group of other RMBS
securities after implementing our recently revised criteria for
surveilling pre-2009 U.S. RMBS ratings. CreditWatch negative
accounted for approximately 57% of the actions, CreditWatch
developing accounted for approximately 36%, and CreditWatch
positive accounted for approximately 7%. We completed our review
using the new methodology and assumptions and the rating actions
resolve some of the CreditWatch placements; an overview of the
directional change of the CreditWatch resolutions is," S&P said:

                              3 or fewer       More than 3
From         Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos          6         15        1        4        0
Watch Neg         29          1       78        0       199
Watch Dev         18          7       31        2        3

"The high number of CreditWatch negative placements reflected our
projection that remaining losses for most of the transactions in
this review will increase. We may have also 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.

Increases in projected losses resulted from one or more of the
factors:

    "An increase in our default and loss multiples at higher
    investment-grade rating levels," S&P said;

    A substantial portion of non-delinquent loans now categorized
    as reperforming (many of these loans have been modified) and
    having a default frequency of between 30% and 45%;

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

    "An overall continued elevated level of observed loss
    severities. We used deal- or shelf-specific loss severities
    for the majority of the transactions within this review: 67%
    of the Alt-A and 33% of the Neg-am structures had loss
    severities that were greater than the default loss severity
    for its respective cohort," S&P said; and

    Principal losses resulting from interest shortfalls in
    transactions where principal and interest are commingled.

Shelf                                               No.Deals/
                                                    Structures
Name                                                Reviewed
Adjustable Rate Mortgage Trust  (ARMT)              4/8
Alternative Loan Trust  (CWA0)                      110/118
Asset-Backed Certificates Trust  (CWHE)             1/1
Banc of America Alternative Loan Trust  (BAA0)      2/2
Banc of America Funding Trust (BAF0)                3/4
Banc of America Mortgage Trust (BMS0)               1/1
BCAP LLC Trust  (BCP0)                              2/4
Bear Stearns ALT-A Trust  (BSAA)                    10/22
Bear Stearns ALT-A II Trust (BSA2)                  1/1
Bear Stearns ARM Trust  (BSAT)                      2/2
Bear Stearns Asset Backed Securities I Tr (BSH0)    14/18
Bear Stearns Asset Backed Securities Trust  (BSHE)  4/4
ChaseFlex Trust  (CFX0)                             3/4
Chevy Chase Funding LLC (CCF0)                      2/2
CHL Mortgage Pass-Through Trust  (CWF0)             3/4
Citigroup Mortgage Loan Trust  (CML0/CTM0)          5/7
Credit Suisse First Boston Mtg Sec. Corp (CSF0)     1/2
CSAB Mortgage Backed Trust  (CSAB)                  4/5
CSFB Mortgage-Backed Trust  (CSF0)                  2/4
CSMC Mortgage-Backed Trust  (CSM0)                  5/8
CWABS Asset Backed Certificates Trust  (CWHE)       1/1
CWABS Trust  (CWF0)                                 2/2
Deutsche Alt A Securities Inc Mtg Loan Tr (DAA0)    9/10
Deutsche Alt-A Securities (DAA0)                    1/1
First Horizon Alternative Mtg Securities Tr (FHAT)  1/1
First Horizon Mortgage Pass-Through Trust  (FHMT)   1/1
GSAA Home Equity Trust/GSAA Trust  (GSAA)           7/7
Impac CMB Trust  (IMHE)                             7/9
Impac Secured Assets Corp. (ISC0)                   2/2
IndyMac INDX Mortgage Loan Trust  (INX0)            1/1
Lehman XS Trust (LXS0)                              2/4
MASTR Adjustable Rate Mortgages Trust  (MARM)       1/2
MASTR Alternative Loan Trust  (MALT)                3/5
Merrill Lynch Mortgage Investors Trust (MLM0)       1/1
Morgan Stanley Mortgage Loan Trust  (MSM0)          1/2
MortgageIT Trust  (MIT0)                            3/4
Nomura Asset Acceptance Corporation (NAA0)          1/2
Opteum Mortgage Acceptance Corporation (OMAC)       2/2
RAMP Trust (RFC0)                                   2/3
Sequoia Mortgage Trust  (SQMT)                      1/1
Specialty Underwriting and Res. Finance Tr (SURF)   1/1
Structured Adjustable Rate Mortgage Loan Tr (SAR0)  1/1
TBW Mortgage-Backed Trust  (TBW0)                   1/1
Terwin Mortgage Trust  (TWM0)                       1/1
Thornburg Mortgage Securities Trust  (THR0)         2/2
WaMu Mortgage Pass-Through Certificates Tr (WMS0)   6/6
Washington Mutual MSC Mtg Pass-Thr. Cert. Tr (WMSC) 1/1

The tables below detail information by vintage and on each
reviewed shelf as
of September 2012.

Structure Count

Vintage   Alt-A   Neg-Am   Prime   High-LTV
2002      2
2003      7
2004      38      2                3
2005      91      8        2
2006      81
2007      56      5

Total DQ (%)

Vintage   Alt-A   Neg-Am   Prime   High-LTV
2002      17.59
2003      9.86
2004      19.70   14.46            12.09
2005      25.16   26.70    20.14
2006      36.30
2007      35.15   51.10

Severe DQ (%)

Vintage   Alt-A   Neg-Am   Prime   High-LTV
2002      13.32
2003       7.61
2004      15.66   13.34            8.70
2005      21.04   21.57    17.59
2006      31.76
2007      30.71   46.35

Losses and Delinquencies*

Shelf     Avg. Pool    Cum. Loss   Serious DQ    Total DQ
Name      Factor (%)   Avg. (%)    Avg. (%)      Avg. (%)
ARMT      28.16        12.44       26.10         28.45
BAA0      50.36         8.99       31.67         36.64
BAF0      38.20        13.41       29.58         33.58
BCP0      46.10        14.49       30.61         34.74
BMS0      47.17         7.05       36.87         40.99
BSA2      46.18        18.13       40.36         43.46
BSAA      27.36        16.46       33.92         36.77
BSAT      41.79        11.21       23.89         27.52
BSH0      57.78        12.45       31.51         36.10
BSHE      27.33         7.26       22.97         26.53
CCF0       8.21         1.25       10.35         13.44
CFX0      43.31        13.69       31.35         33.51
CML0      40.39        15.42       27.21         31.96
CSAB      41.40        19.20       38.82         42.55
CSF0      26.59         5.88       18.41         20.34
CSM0      37.38        11.67       30.57         34.12
CTM0      14.09         2.31       12.55         15.48
CWA0      40.50         8.02       25.97         31.45
CWF0      40.14         8.84       25.66         30.05
CWHE      15.90        19.63       57.55         61.57
DAA0      34.30        14.70       29.18         32.11
FHAT      23.22         1.93        7.45         10.12
FHMT      23.04         1.13        8.04         11.45
GSAA      19.27         4.07       22.94         26.07
IMHE      17.50         4.18        9.34         12.55
INX0       5.15         1.43       19.69         19.99
ISC0      15.98         1.94       19.01         20.58
LXS0      40.87        14.80       35.84         38.99
MALT      23.68         0.96        7.75         12.01
MARM      40.66        15.52       21.41         25.33
MIT0      23.90         2.46        6.40          9.54
MLM0      33.93         7.11       20.46         26.19
MSM0      34.04         9.89       19.17         24.01
NAA0      41.25        27.58       39.80         43.12
OMAC      19.69         6.30       12.55         15.32
RFC0      11.85         5.12        8.70         12.09
SAR0       7.26         7.08       29.20         36.08
SQMT      16.05         0.62        6.00         10.36
SURF      28.33         0.20        6.11         12.14
TBW0      45.89        18.33       18.01         22.12
THR0      14.52         0.16        2.35          4.64
TWM0      28.78        31.92       20.76         27.44
WMS0      17.94         2.79       19.30         24.55
WMSC       6.82         0.17       18.61         20.86

"As demonstrated, newer vintages are experiencing higher
total and severe delinquencies than older ones. The Banc of
America Mortgage Trust, CSAB Mortgage Backed Trust, CWABS Asset
Backed Certificates Trust, and Nomura Asset Acceptance Corp.
transactions are among those in this review with the highest
average delinquencies. The CSAB Mortgage Backed Trust, CWABS Asset
Backed Certificates Trust, Nomura Asset Acceptance Corp., and
Terwin Mortgage Trust transactions show the highest cumulative
losses to date. Among the better performing transactions in this
review based on cumulative losses and delinquencies are the
Thornburg Mortgage Securities Trust, Specialty Underwriting and
Residential Finance Trust, Sequoia Mortgage Trust, and MASTR
Alternative Loan Trust transactions," S&P said.

"In line with the factors, we revised our remaining loss
projections for all of the transactions in this review from our
previous projections. As a result of a majority of these
transactions having increased loss projections, 43% of the rating
actions in this review were downgrades and most of the remaining
actions were affirmations," S&P said.

"Despite the increase in remaining projected losses for a majority
of the transactions, we upgraded 41 classes from 17 Alt-A
transactions, one Neg-am transaction, and one high LTV
transaction. The upgrades reflect sufficient credit enhancement to
support projected losses at the rating level. Some of these
classes are the most senior tranches outstanding in their
respective transactions. Our decisions on these classes primarily
reflected the structural mechanics of these transactions, namely
situations where cumulative loss triggers embedded in the deals
have failed, causing principal to be distributed sequentially,
which helps prevent credit support erosion and increases the
likelihood that these tranches will receive their full share of
principal payments prior to the realization of our projected
losses. Other classes have been upgraded due to an extended loss
curve that increases the amount of excess spread available for
credit support in our projections," S&P said.

"Lastly, the upgrades of some senior classes that receive
principal and interest from a particular loan group were as a
result of better projected group level performance," S&P said.

"Class IV-M-1 from Credit Suisse First Boston Mortgage Securities
Corp. 2003-AR18 was removed from CreditWatch negative and upgraded
to 'AAA (sf)' from 'AA+ (sf)'. The previous CreditWatch placement
was due to its small loan count and inherent tail risk. However,
this class had significant credit support to withstand our
projected losses at the 'AAA' rating level," S&P said.

"We affirmed our ratings on 702 classes from 170 transactions and
removed 29 of them from CreditWatch negative, 18 of them from
CreditWatch developing, and six of them from CreditWatch positive.
Of these, 620 classes are rated 'CCC (sf)' or 'CC (sf)'. We
believe that the projected credit support for these classes will
remain insufficient to cover the revised projected losses.
Conversely, the affirmations for classes with ratings above 'CCC'
reflect our opinion that the credit support for these classes will
remain sufficient to cover the revised projected losses," S&P
said.

"We lowered our ratings on 587 classes from 177 transactions. Of
the lowered ratings, we downgraded 84 classes out of investment-
grade, including 12 that we downgraded to 'CCC (sf)'. Another 187
ratings remain at investment-grade after being lowered. The
remaining downgraded classes already had speculative-grade ratings
prior to 's actions. We downgraded 168 classes to 'D (sf)' due to
observed principal write-downs," S&P said.

"Senior tranches accounted for the bulk of the lowered ratings
(532); the remaining downgrades affected mezzanine classes.
Contrary to the characteristics that distinguished the upgrades
and affirmations highlighted, these downgraded tranches generally
did not exhibit either a high priority in payment or a short
projected life," S&P said.

"The downgrades were primarily due to significantly greater
lifetime loss projections driven by increased loss severities and
loans classified as reperforming, which caused an increase in our
projected default rates on non-delinquent loans.  Also, ratings
that we lowered but that remain at investment-grade were primarily
driven by our increased stress multiples applied to ratings 'A
(sf)' and above," S&P said.

"The A-1 class from GSAA Home Equity Trust 2004-6 was removed from
CreditWatch positive and lowered to 'A+ (sf)' from 'AA- (sf)' due
to an adjustment to the transaction's rating stress multiples,"
S&P said.

"We reviewed seven Alt-A transactions issued by Impac CMB Trust
between 2002 and 2005. A majority of these transactions were
subject to higher remaining loss projections due to a high amount
of reperforming loans. These transactions have a pro-rata
principal pay structure that inherently deteriorates credit
support over the life of the transaction," S&P said.

"We reviewed 18 Alt-A transactions issued by Bear Stearns Asset
Backed Securities Trust, issued between 2002 and 2007. Some of
these transactions also pay pro-rata principal payments throughout
the life of the deal, which resulted in projected erosion of
subordination and lower ratings for some of the senior tranches,"
S&P said.

"We reviewed four Alt-A transactions issued by CSAB Mortgage-
Backed Trust issued in 2006 and 2007. All four transactions
reviewed no longer have mezzanine classes. The senior classes
cannot take write-downs, and as a result the transactions are
largely undercollateralized. All reviewed classes have a current
rating of either 'CC' or 'CCC', except for the bond-insured
classes," S&P said.

"We withdrew our ratings on 28 classes from 16 transactions in
accordance with our interest-only criteria because the referenced
classes no longer sustained ratings above 'A+ (sf)'," S&P said.

"Some of the reviewed transactions were backed by a small
remaining population of mortgage loans. We address tail risk in
transactions by conducting additional loan-level analysis that
stresses the loan concentration risk within the applicable
transactions," 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 as applicable generally provide credit support for these
Alt-A, Neg-am, and high LTV transactions. Some classes may also
benefit from bond insurance. In these cases, the long-term rating
on the class reflects the higher of the rating on the bond insurer
and the underlying credit rating on the security without the
benefit of such bond insurance," 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



                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers"
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR.  Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors" Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Howard C. Tolentino, Joseph Medel C. Martirez, 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.

This material is copyrighted and any commercial use, resale or
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $775 for 6 months delivered via
e-mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Christopher
Beard at 240/629-3300.


                  *** End of Transmission ***