TCR_Public/121125.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 25, 2012, Vol. 16, No. 328

                            Headlines

ADAMS OUTDOOR: Fitch Affirms 'BBsf' Rating on $57-Mil. Notes
AMERICREDIT AUTOMOBILE: Fitch Rates $24-Mil. Cl. E Notes 'BBsf'
BABSON CLO 2005-I: S&P Raises Ratings on 2 Note Classes From 'BB+'
BANC OF AMERICA 2006-BIX1: Moody's Cuts Rating on X-4 Certs. to B3
BANC OF AMERICA 2007-1: Moody's Cuts Ratings 3 Cert. Classes to Ca

BEAR STEARNS 2003-TOP10: Fitch Keeps CCC Ratings on 2 Loan Classes
BEAR STEARNS 2006-1: S&P Cuts Rating on Class B Certs. to 'D'
BEAR STEARNS 2006-TOP24: Fitch Cuts Ratings on 4 Cert. Classes
BLADE ENGINE 2006-1: S&P Cuts Rating on Class B Notes to 'BB+'
BLUEMOUNTAIN CLO: S&P Affirms 'BB+' Rating on Class D Notes

BLUEMOUNTAIN CLO 2012-2: S&P Gives 'BB' Rating on Class E Notes
C-BASS CBO VII: Moody's Hikes Rating on $20MM Cl. C Notes to 'Ba1'
C-BASS MORTGAGE: Moody's Lifts Rating on Class A-2 Certs. to 'B1'
CASTLE GARDEN: S&P Raises Ratings on 2 Note Classes to 'BB+'
CENTRAL PLAINS: Moody's Puts 'B2' Rating on Watch for Downgrade

CITIGROUP COMM'L 2006-C5: Fitch Cuts Rating on 2 Certs. to 'CCCsf'
CITIGROUP MORTGAGE 2004-2: Moody's Cuts 4 Tranch Ratings to 'B3'
COAST INVESTMENT 2002-1: S&P Affirms 'CC' Rating on 3 Debt Classes
COLUMBUSNOVA CLO: Moody's Raises Rating on Cl. E Notes to 'Ba1'
COLUMN CANADA 2006-WEM: S&P Cuts Rating on Class K Certs. to 'BB+'

COMM 2006-C7: Fitch Cuts Ratings on 2 Cert. Classes to 'Csf'
COMMONWEALTH REIT: Moody's Cuts Preferred Stock Rating to 'Ba1'
CREDIT SUISSE 2001-CP4: S&P Cuts Rating on Class F Certs. to 'D'
CREDIT SUISSE 2003-C4: Moody's Affirms 'C' Rating on Cl. L Certs.
CREDIT SUISSE 2004-C5: Moody's Keeps 'C' Ratings on 3 Certs.

CRESS 2008-1: S&P Lowers Ratings on 8 Note Classes to 'D'
CSFB MORTGAGE 2003-10: Moody's Cuts Rating on One Tranche to C
CSFB MORTGAGE 2004-CF1: Moody's Cuts Rating on Cl. B Certs to 'C'
GALAXY IV CLO: S&P Raises Rating on 2 Note Classes From 'BB-'
GALAXY VII CLO: S&P Affirms 'BB' Rating on Class E Notes

GE CAPITAL 2007-C1: Moody's Cuts Ratings on 2 Cert. Classes to Ba1
GS COMMERCIAL 2012-GCJ9: Moody's Rates Class F Certs. '(P)B2'
GS MORTGAGE 2004-GG2: Moody's Cuts Rating on Class H Certs. to 'C'
GSRPM MORTGAGE 2007-1: Moody's Cuts Class A Cert. Rating to 'Caa3'
HALCYON LOAN 2012-2: S&P Gives Prelim 'BB' Rating on Class E Notes

HARTFORD MEZZANINE: Moody's Raises Rating on Cl. G Notes to 'B1'
INTEGRAL FUNDING: Moody's Raises Rating on Cl. D Notes to 'Ba3'
JP MORGAN 2002-C3: Moody's Cuts Rating on Cl. F Certs. to 'Caa2'
JP MORGAN 2007-1: Fitch Cuts Ratings on 2 Debt Classes
JP MORGAN 2007-LDP10: Moody's Cuts Ratings on 2 Cert. Classes to C

L2L EDUCATION 2006-1: S&P Affirms 'B+' Rating on Class C Notes
LEGG MASON CDO I: S&P Cuts Rating on Class G to 'CCC-'; Off Watch
LEGG MASON CDO II: S&P Lowers Ratings on 2 Debt Classes to 'CCC-'
LEHMAN BROTHERS: Moody's Cuts Rating on Class X-2 CMBS to 'B3'
MBIA INSURANCE: Moody's Lowers Ratings of 179 Securities

MERRILL LYNCH 2007-C1: Fitch Cuts Rating on 6 Cert. Classes
MORGAN STANLEY 2005-IQ9: Fitch Cuts Rating on 2 Certs. to 'CCCsf'
NATIONAL COLLEGIATE: Moody's Reviews Ratings on 92 Tranches
NOMURA ASSET 2007-S2: Moody's Hikes Rating on A Tranche From 'C'
NORTHSTAR 2012-1: S&P Gives 'B' Rating on Class F Certificates

NYLIM FLATIRON 2004-1: S%P Affirms 'B+' Rating on Class D Notes
NZCG FUNDING: S&P Says 'CCC'-Rated Collateral Down to $8.03-Mil.
OAK HILL IV: S&P Raises Ratings on 3 Note Classes From 'BB+'
PSSA FLOATING: Moody's Cuts Rating on $90.2-Mil. Certs. to Caa2
RAAC SERIES 2007-SP2: Moody's Lifts Rating on A-1 Tranche to Caa1

RESTRUCTURED ASSET 2004-13-E: Moody's Hikes Cert. Rating to Ba2
ROCK 1 CRE: Moody's Affirms Caa3 Ratings on 7 Note Classes
SALOMON BROTHERS: Moody's Cuts Rating on Cl. X-1 Certs. to Caa3
SALT VERDE: Moody's Reviews 'B2' Bond Rating for Downgrade
SCHOONER TRUST 2006-5: Moody's Affirms 'B3' Rating on Cl. L Certs.

SEQUOIA MORTGAGE: Moody's Cuts Cl. B-3 Tranche Rating to 'Caa3'
SHACKLETON II: S&P Gives 'BB' Rating on Class E Deferrable Notes
SOUTHPORT CLO: S&P Ups Rating on Class D Notes to 'BB+'; Off Watch
STUDENT LOAN 2007-1: Moody's Reviews 'Caa2' Rating on 2 Certs.
SUFFIELD CLO: Fitch Affirms Junk Ratings on Three Note Classes

UBS-CITIGROUP: Moody's Affirms 'B2' Rating on Cl. G Certificates
WACHOVIA BANK 2007-C34: Moody's Cuts Ratings on 2 Notes to 'Csf'
WACHOVIA CRE: Moody's Lifts Ratings on 2 Note Classes to 'Caa2'
WELLS FARGO 2004: Moody's Lowers Ratings on Two Tranches to 'C'

* S&P Lowers Ratings on 5 JC Penney-Related Transactions to 'B-'
* S&P Lowers Ratings on 232 Classes From 103 US RMBS Transactions
* S&P Lowers Ratings on 1,036 Classes From 347 US RMBS Deals
* S&P Lowers Ratings on 461 Classes From 204 US RMBS Transactions
* S&P Takes Various Rating Actions on 23 Classes From 4 CMBS Deals

* S&P Takes Various Rating Actions on 25 Classes From 5 CMBS Deals
* S&P Takes Various Rating Actions on 19 Classes From 2 CMBS Deals
* S&P Takes Various Rating Actions on 32 Classes From 6 CMBS Deals
* S&P Raises Ratings on 15 Classes From 5 CMBS Transactions
* S&P Withdraws Ratings on 61 Classes From 46 CMBS Transactions

* S&P Withdraws Ratings on 982 Classes From 205 RMBS Transactions

                            *********

ADAMS OUTDOOR: Fitch Affirms 'BBsf' Rating on $57-Mil. Notes
------------------------------------------------------------
Fitch Ratings affirms Adams Outdoor Advertising LP secured
billboard revenue notes, series 2010-1, as follows:

  -- $246.6 million class A notes at 'Asf'; Outlook Stable;
  -- $44 million class B notes at 'BBBsf'; Outlook Stable;
  -- $57 million class C notes at 'BBsf'; Outlook Stable.

The transaction represents a securitization in the form of notes
backed by outdoor advertising structures, with over 10,000
billboard faces and other advertising displays.

The affirmations are due to the stable performance of the
collateral since issuance.  The notes are secured by: a pledge of
the equity in the issuer, Adams Outdoor Advertising (AOA), which
owns the permits, billboard structures, ground leases, and
advertising contracts; and a lien on all of the assets of the
issuer.  AOA focuses on maximizing profitability of the portfolio
through the most effective combination of occupancy and rate
levels.

As part of its review, Fitch analyzed the financial information
provided by the master servicer, Midland Loan Services.  As of
October 2012, the reported trailing twelve month (TTM) net cash
flow and year over year occupancy levels have increased from
Fitch's last rating action.  Due to the scheduled amortization of
the class A notes and the stable performance of the pool, Fitch's
calculated debt yield has increased to 14.1% from 13.1% at
issuance.


AMERICREDIT AUTOMOBILE: Fitch Rates $24-Mil. Cl. E Notes 'BBsf'
---------------------------------------------------------------
Fitch Ratings assigns the following ratings to AmeriCredit
Automobile Receivables Trust, series 2012-5:

  -- $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.

Fitch's ratings are based on the stable credit quality of the
receivables pool, strong portfolio and securitization performance
and sound origination and servicing practices of AmeriCredit
Financial Services, Inc.


BABSON CLO 2005-I: S&P Raises Ratings on 2 Note Classes From 'BB+'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C-1 and C-2 notes issued by Babson CLO Ltd. 2005-I, a
collateralized loan obligation (CLO) transaction managed by Babson
Capital Management LLC. "At the same time, we affirmed our ratings
on the class A-1A, A-1B-1, A-1B-2, A2, B-1, and B-2 notes and
withdrew our rating on the class P note," S&P said.

"The class C notes are pari passu and the current balance is
75.27% of the original balance. The lower balance is due to
paydowns in early 2009 that were triggered because of class C
coverage test failures; the transaction is structured such that
the class C notes can be paid down using available interest
proceeds if they fail the class C coverage test. Since then, these
tests have been passing and there have been no further paydowns to
the class C notes," S&P said.

"The defaults in the transaction declined since our last rating
action in December 2010. The trustee reports $9.8 million par of
defaulted collateral in the October 2012 trustee report, down from
$21.9 million par in the October 2010 trustee report that we used
for our December 2010 rating actions. Most of the defaults were
recovered a value higher than those assumed. In addition, the
credit quality of the underlying portfolio improved during this
time period resulting in lower scenario default rates (SDRs)," S&P
said.

All coverage tests are currently passing and all
overcollateralization ratios have increased during this period.

"We raised our ratings on class C due to an increase in credit
support at the prior rating levels," S&P said.

"We withdrew our rating on the class P note because it was fully
exchanged and no longer outstanding," S&P said.

The affirmations reflect the availability of credit support at the
classes' current rating levels.

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

               STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Babson CLO Ltd. 2005-I
                  Rating
Class         To          From
C-1 Def       BBB- (sf)    BB+ (sf)
C-2 Def       BBB- (sf)    BB+ (sf)
P             NR           AA+ (sf)

RATINGS AFFIRMED

Babson CLO Ltd. 2005-I
Class         Rating
A-1A          AA+ (sf)
A-1B-1        AA+ (sf)
A-1B-2        AA+ (sf)
A2            AA (sf)
B-1 Def       A- (sf)
B-2 Def       A- (sf)

TRANSACTION INFORMATION

Issuer:              Babson CLO Ltd. 2005-I
Coissuer:            Babson CLO Inc. 2005-I
Collateral manager:  Babson Capital Management LLC
Underwriter:         Citigroup Global Markets Inc.
Trustee:             Bank of New York Mellon (The)
Transaction type:    Cash flow CLO


BANC OF AMERICA 2006-BIX1: Moody's Cuts Rating on X-4 Certs. to B3
------------------------------------------------------------------
Moody's Investors Service downgraded the rating of one notional
class, affirmed one notional class and affirmed three non-pooled,
or rake, classes of Banc of America Large Loan, Inc. Commercial
Mortgage Pass-Through Certificates, Series 2006-BIX1 as follows:

Cl. J-CP, Affirmed at Baa3 (sf); previously on Dec 9, 2011
Upgraded to Baa3 (sf)

Cl. K-CP, Affirmed at Ba1 (sf); previously on Dec 9, 2011 Upgraded
to Ba1 (sf)

Cl. L-CP, Affirmed at Ba2 (sf); previously on Dec 9, 2011 Upgraded
to Ba2 (sf)

Cl. X-1B, Affirmed at B2 (sf); previously on Feb 22, 2012
Downgraded to B2 (sf)

Cl. X-4, Downgraded to B3 (sf); previously on Feb 22, 2012
Downgraded to B1 (sf)

Ratings Rationale

The downgrade of notional Class X-4 is due to Moody's lower
weighted average credit assessments of the two reference assets,
the CarrAmerica -- Pool 3 (National Portfolio) Loan and the
Ballantyne Village Loan. The affirmations of non-pooled classes J-
CP, K-CP and L-CP are due to the stable performance of the
CarrAmerica -- Pool 3 (National Portfolio) Loan. The affirmation
of notional Class X-1B is based on the credit quality of its
referenced 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 CMBS Large Loan/Single Borrower Transactions" published in
July 2000, and "Moody's Approach to Rating Structured Finance
Interest-Only Securities" published in February 2012.

Moody's review incorporated the use of the excel-based Large Loan
Model v 8.5. 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. The model
includes 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 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 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 9, 2011.

DEAL PERFORMANCE

As of the November 15, 2012 Payment Date the transaction's
certificate balance has decreased by approximately 90% to $121.5
million from $1.2 billion at securitization due to the full payoff
of 15 loans in the pool and release premiums and/or loan pay downs
associated with two loans (the Blackstone/CarrAmerica -- Pool 3
(National Portfolio) loan and the JER Denver Office Portfolio
Loan.

The pool to date has experienced $199 in cumulative bond losses
affecting Class L and $550,664 in interest shortfalls affecting
Classes J, K and L.

Moody's weighed average pooled loan to value (LTV) ratio is 86%
and Moody's pooled stressed debt service coverage ratio (DSCR) is
1.62X.

The certificates are currently collateralized by three floating
rate loans ranging in size from 7% to 65% of the pool balance. Two
of the loans are collateralized by office properties (72%) and one
is collateralized by a retail property (28%). Two loans are
currently in special servicing, the Ballantyne Village Loan (28%)
and the JER Denver Office Portfolio Loan (7%).

The largest loan, the CarrAmerica -- Pool 3 (National Portfolio)
Loan ($72.8 million - 65% of the pooled balance) is the 40%
portion of a pari-passu split loan structure that is securitized
in COMM 2006-FL12 (52.5%) and CGCMT 2006-FL2 (7.5%). There is also
$9.7 million of non-pooled trust debt (Classes J-CP, K-CP and L-
CP), a $50.6 million non-trust subordinate secured component, and
$51.6 million of mezzanine debt. The loan is currently secured by
17 office and research and development (R&D) properties. Fourteen
properties containing approximately 3.7 million square feet are
subject to first mortgage liens. The borrower's joint venture
interests in three properties are secured by pledges of refinance
and sale proceeds. The outstanding trust balance has decreased by
87% since securitization from the payment of property release
premiums and from a loan modification that extended the maturity
date to August 2013 and required a one-time principal pay down and
contractual amortization. At securitization the loan was secured
by 73 properties. The remaining portfolio has geographic
concentration in California's Silicon Valley with 11 properties
located in North San Jose, Sunnyvale, Santa Clara and Palo Alto.
The other three properties subject to first mortgage liens are
located in Los Angeles and Seattle. As of October 2012 the loan
collateral secured by first mortgage liens had an average
occupancy rate of 93%. Moody's credit assessment for the pooled
debt is Baa2, the same as last review.

The Ballantyne Village Loan ($31.5 million -- 28%) is secured by a
166,041 square foot lifestyle retail center located in Charlotte,
North Carolina. The loan was transferred to special servicing in
July 2009 and was subject to an appraisal reduction in February
2012 based on an appraised value of $23.13 million. Pursuant to a
Deed-in-Lieu of Foreclosure Agreement effective as of 11/01/2012,
title transferred to a Special Purpose Entity subsidiary of the
Trust and is now held as REO. A qualified property manager has
been engaged to manage and lease the asset. The Special Servicer
continues to take all necessary actions to maximize the recovery
to the Trust, including requesting proposals from national brokers
to list the property for sale. Moody's credit assessment is C, the
same as at last review.

The JER Denver Office Portfolio Loan ($7.6 million -- 7%) is
secured by office properties located in Greenwood Village
(Denver), Colorado. The loan has paid down by approximately 85%
since securitization from the payment of release premiums from the
sale of four of the original six properties. The loan was
transferred to special servicing in May 2011. The transfer was due
to written correspondence from the Borrower requesting an
extension and modification of the loan due to difficulty in
refinancing the loan. The loan had a final maturity date of
October 5, 2012. The loan is currently in a short-term forbearance
to allow time for the remaining two properties to be sold. The two
remaining properties, Quebec Court I and Quebec Court II contain a
total of 287,294 square feet and are both 100% leased to Time
Warner Telecom and Comcast Cable Communications, respectively,
with lease expirations dates in October 2015 and November 2021.
The $32 million whole loan includes a $24.4 million non-trust
subordinate secured component. Moody's credit assessment is A1,
compared to Caa1 at last review.


BANC OF AMERICA 2007-1: Moody's Cuts Ratings 3 Cert. Classes to Ca
------------------------------------------------------------------
Moody's Investors Service downgraded the ratings of nine classes
and affirmed 13 classes of Banc of America Commercial Mortgage
Inc., Commercial Mortgage Pass-Through Certificates, Series 2007-1
as follows:

Cl. A-3, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-MFX, Downgraded to Baa3 (sf); previously on Aug 23, 2012
Baa1 (sf) Placed Under Review for Possible Downgrade

Cl. A-MFL, Downgraded to Baa3 (sf); previously on Aug 23, 2012
Baa1 (sf) Placed Under Review for Possible Downgrade

Cl. A-J, Downgraded to Caa1 (sf); previously on Aug 23, 2012 B2
(sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to Caa2 (sf); previously on Aug 23, 2012 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. C, Downgraded to Caa3 (sf); previously on Aug 23, 2012 Caa2
(sf) Placed Under Review for Possible Downgrade

Cl. D, Downgraded to Ca (sf); previously on Aug 23, 2012 Caa3 (sf)
Placed Under Review for Possible Downgrade

Cl. E, Downgraded to Ca (sf); previously on Aug 23, 2012 Caa3 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Downgraded to Ca (sf); previously on Aug 23, 2012 Caa3 (sf)
Placed Under Review for Possible Downgrade

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

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

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

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

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

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

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

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

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

Cl. XW, Downgraded to B1 (sf); previously on Aug 23, 2012 Ba3 (sf)
Placed Under Review for Possible Downgrade

Ratings Rationale

On August 23, 2012 Moody's placed six classes on review for
possible downgrade in order to further evaluate the ongoing risk
of future interest shortfalls and the timing and severity of
losses from the two largest specially serviced loans in the pool
-- the Skyline Portfolio Loan and the Solana Loan. While there is
still a significant amount of uncertainty concerning the two loans
at this point in time is does not look like the expected
resolution strategy will lead to a large spike in recurring
interest shortfalls. This action concludes Moody's review.

The downgrades of the principal classes are due to higher expected
losses from specially serviced and troubled loans. The rating of
the IO Class, Class XW, was downgraded to align with the expected
credit performance of its referenced classes.

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

Moody's rating action reflects a base expected loss of 15.6% of
the current balance. At last full review, Moody's cumulative base
expected loss was 13.9%. 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, 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 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 24 compared to 27 at Moody's prior full review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through 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 July 12, 2012.

DEAL PERFORMANCE

As of the October 15, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 8% to $2.58 billion
from $3.15 billion at securitization. The Certificates are
collateralized by 142 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten loans representing
44% of the pool.

Thirty-nine loans, representing 32% 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.

Thirteen loans have been liquidated from the pool since
securitization, resulting in an aggregate $35.4 million loss (67%
loss severity on average). Currently 13 loans, representing 24% of
the pool, are in special servicing. The largest specially serviced
loan is the Skyline Portfolio Loan ($271 million -- 10.5% of the
pool), which represents a 40% pari passu interest in a $678
million first mortgage loan with the other pieces securitized in
GECMC 2007-C1 and JPMCC 2007-LDP10. The loan is secured by eight
cross-collateralized and cross-defaulted office properties
totaling 2.6 million square feet (SF) which are located outside of
Washington, DC in Falls Church, Virginia. At securitization, over
55% of the net rentable area (NRA) was leased by the General
Services Administration (GSA). The GSA has been vacating its space
as leases expire. The portfolio is 62% leased as of November 2012.
The portfolio was appraised at $296.6 million as of July 2012
compared to $872 million at securitization. The special servicer
is in discussions with the borrower regarding a possible loan
modification. The loan sponsor is Vornado Realty Trust (Senior
Unsecured Rating Baa2, Stable Outlook). The servicer has
recognized a $168 million appraisal reduction for this loan.

The second largest specially serviced loan is the Solana Loan
($220 million --8.5% of the pool), which represents a 61% pari
passu interest in a $360 million first mortgage loan. The loan is
secured by a 1.9 million SF mixed use complex consisting of
office, retail and a 198-room full service hotel located in
Westlake, Texas. The non-hotel component is 67% leased, down from
84% in December 2011 as a result of the lease expiration and
departure of a major tenant (Sabre, 20% of NRA). Loan modification
discussions commenced, but there is no firm modification proposal
being discussed at this time. The servicer is dual tracking
foreclosure and a modification. A receiver was appointed in
November 2011 and 133,000 SF of new leases and renewals have been
executed since then. The servicer has recognized a $109 million
appraisal reduction for this loan.

The master servicer has recognized an aggregate $429.1 million
appraisal reduction for the specially serviced loans. Moody's has
estimated an aggregate loss of $291.9 million (48% expected loss
on average) for all of the specially serviced loans.

Moody's has assumed a high default probability for 29 poorly
performing loans representing 12% of the pool and has estimated a
$63.6 million loss (23% expected loss based on a 50% probability
default) from these troubled loans.

Moody's was provided with full year 2011 operating results for
100% of the performing pool. Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 104% compared to
110% at last full review. Moody's net cash flow reflects a
weighted average haircut of 12% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 8.8%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.30X and 0.95X, respectively, compared to
1.23X and 0.90X 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 loans represent 20% of the pool. The largest loan is
the StratReal Industrial Portfolio I Loan ($190.0 million -- 7.4%
of the pool), which is secured by a portfolio of 12 industrial
properties, totaling 5.5 million SF, located in Ohio (8),
Tennessee (3) and California (1). Occupancy as of October 2012 was
73%, down from 77% at last review. Ford Motor Co. which occupies
14% of the GLA renewed its lease which expired in March 2012
through May 2018. The loan has been on the watchlist since May
2011 due to significant lease rollover. However, many tenants have
renewed their leases. Moody's LTV and stressed DSCR are 124% and
0.76X, respectively, same as at last review.

The second largest loan is the Hirschfield Portfolio Loan ($167.0
million -- 6.5% of the pool), which is secured by four multifamily
properties, totaling 1,841 units, located in three submarkets in
the Baltimore metropolitan area. Performance has been stable to
slightly improving since 2009. Occupancy as of year-end 2011 was
93%. The loan has paid off in full as of October 26, 2012.

The third largest loan consists of the cross collateralized and
cross-defaulted Inland -- Bradley Portfolio Pool A & B Loans
(total $156.6 million --6.1% of the pool), which was originally
secured by 26 office, industrial, and retail properties located
across 13 states. One property with an original allocated balance
of $25.6 million has been released. Largest tenants include
Pearson Education (1.1MM SF, 10/2016 expiration), Dopaco Inc.
(299,000 SF, 12/2015 expiration), and Lamos Metal (224,000 SF,
1/2022 expiration). Moody's LTV and stressed DSCR are 93% and
0.99X, respectively, same as at last review.


BEAR STEARNS 2003-TOP10: Fitch Keeps CCC Ratings on 2 Loan Classes
------------------------------------------------------------------
Fitch Ratings has affirmed all classes of Bear Stearns Commercial
Mortgage Securities Trust, Series 2003-TOP 10.

The affirmations are the result of stable performance as well as
increasing concentration of the pool as a result of loan payoff
and amortization.  Of the remaining pool, 80.7% mature in 2013 and
Fitch expects additional payoffs in the coming months.

Fitch modeled losses of 3.4% of the remaining pool; expected
losses of the original pool are 2.1% including losses already
incurred to date (0.3%).  Fitch has designated 10 loans (24.1%) as
Fitch Loans of Concern, which include four specially serviced
loans (2.8%).

As of the November 2012 distribution date, the pool's aggregate
principal balance has been reduced by 60.5% (including 0.3% of
realized losses) to $478.7 million from $1.212 billion at
issuance.  Cumulative interest shortfalls in the amount of
$273,055 are currently affecting class O.  There are 17 loans in
the pool that are defeased (15.3%).

The largest contributor to Fitch's modeled losses is a 68,163
square foot (sf) office building located in Phoenix, AZ (1.4% of
the pool).  As of July 2012, the property reported occupancy was
45%, which is down from 96% at issuance.  The loan transferred to
the special servicer in December 2011.  The sponsor and special
servicer are currently negotiating a modification that is
projected to close in December 2012.

The second largest contributor to Fitch's modeled losses is a
retail center (2.4% of the pool) located in Vacaville, CA.  The
center is shadow anchored by a Sam's Club and Wal-Mart.  The
center's occupancy has held steady at 78% since June 2010 when Old
Navy vacated upon its lease expiration.  The sponsor continues to
aggressively market the space and intends to lease it to a
national big-box retailer.

The third largest contributor to Fitch's modeled losses is a
105,833 sf retail center (1.3% of the pool) located in Altamonte
Springs, FL.  As of December 2011, the property reported occupancy
was 63%, which is down from 99% at issuance.  The loan transferred
to the special servicer in May 2010 for imminent payment default.
A receiver was recently appointed by the courts and the
foreclosure process is ongoing.

Fitch continues to monitor the largest loan in the pool, Federal
Center Plaza, which is scheduled to mature in early 2013.  The
General Services Administration lease (50% of the net rentable
area) expires in January 2013 and lease renewal negotiations are
progressing at a slower than anticipated rate.

Fitch has affirmed the following classes and revised recovery
estimates as indicated:

  -- $321.4 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $34.8 million class B at 'AAAsf'; Outlook Stable;
  -- $37.9 million class C at 'AAsf'; Outlook Stable;
  -- $12.1 million class D at 'Asf'; Outlook Stable;
  -- $15.2 million class E at 'BBB+sf'; Outlook Stable;
  -- $9.1 million class F at 'BBBsf'; Outlook Stable;
  -- $7.6 million class G at 'BBB-sf'; Outlook Stable;
  -- $10.6 million class H at 'BBsf'; Outlook Stable;
  -- $4.5 million class J at 'Bsf'; Outlook Stable;
  -- $6.1 million class K at 'Bsf'; Outlook Negative;
  -- $4.5 million class L at 'CCCsf'; RE 100%;
  -- $3.0 million class M at 'CCCsf'; RE 15%;
  -- $3.0 million class N at 'CCsf'; RE 0%.

Fitch does not rate class O.  The ratings on class X-1 and X-2
were previously withdrawn.  Class A-1 has paid in full.


BEAR STEARNS 2006-1: S&P Cuts Rating on Class B Certs. to 'D'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of commercial mortgage pass-through certificates from two
U.S. commercial mortgage-backed securities (CMBS) transactions due
to principal losses.

"We lowered our rating on class B to 'D (sf)' from Bear Stearns
Small Balance Commercial Mortgage Loan Trust 2006-1 and classes E,
F, and G from GMAC Commercial Mortgage Securities, Inc., series
2004-C2, because of principal losses that these transactions
incurred," S&P said.

"We've detail the four downgraded classes from the two U.S. CMBS
transactions," S&P said:

Bear Stearns Small Balance Commercial Mortgage Loan Trust 2006-1

"We lowered our rating on the class B certificate to 'D (sf)' to
reflect a $278,081 principal loss. The class had a current
outstanding principal balance of $2.3 million as of the Oct. 25,
2012, trustee remittance report," S&P said.

  GMAC Commercial Mortgage Securities, Inc. Series 2004-C2

"We lowered our ratings to 'D (sf)' on the classes E, F, and G
certificates because of principal losses resulting from the
liquidation of one asset that was with the special servicer,
Midland Loan Services, Inc. According to the Nov. 13, 2012,
remittance report, the trust experienced $55.7 million in
principal losses upon the recent disposition of the Parmatown
Shopping Center. The class E certificate experienced a loss of
91.1% of its $12.8 million opening balance and classes F and G
incurred 100% loss to their opening balance. Classes H and J also
experienced losses that reduced the classes' outstanding balance
to zero. Standard & Poor's had previously lowered the classes H
and J certificates to 'D (sf)'," S&P said.

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

          http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED

Bear Stearns Small Balance Commercial Mortgage Loan Trust 2006-
1Commercial
mortgage pass-through certificates
                                           Reported
         Rating              Credit   Interest shortfalls
Class  To        From     enhcmt(%)  Current  Accumulated
B        D(sf)      CCC+(sf)         0.00      0.00     0.00

GMAC Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2004-C2
                                          Reported
         Rating              Credit   interest shortfalls
Class  To        From     enhcmt(%)  Current  Accumulated
E        D(sf)    CCC+(sf)      0.00        0.00     0.00
F        D(sf)    CCC(sf)       0.00        0.00     0.00
G        D(sf)    CCC-(sf)      0.00        0.00     0.00


BEAR STEARNS 2006-TOP24: Fitch Cuts Ratings on 4 Cert. Classes
--------------------------------------------------------------
Fitch Ratings has downgraded four and affirmed 14 classes of Bear
Stearns Commercial Mortgage Securities Trust commercial mortgage
pass-through certificates, series 2006-TOP24 (BSCMT 2006-TOP24).

The downgrades reflect an increase in Fitch expected losses. Fitch
modeled losses of 8.02% of the original pool balance (including
losses incurred to date).  There are currently eight specially
serviced loans (8.9%).  The Negative Outlooks reflect the high
Fitch loan-to-values (LTVs) on several of the larger loans in the
pool.

As of the November 2012 distribution date, the pool's aggregate
principal balance has been reduced by 22.25% (including 13.59% of
realized losses) to $1.19 billion from $1.53 billion at issuance.
One loan (0.51%) is defeased.  Interest shortfalls are affecting
classes B through H.

The largest contributor to modeled losses consists of a 585-room
full-service hotel in Phoenix, AZ.  The asset, which transferred
to special servicing in October 2009 due to imminent default, was
foreclosed upon in August 2010.  The property was marketed for
sale, and a purchase and sales agreement was executed in November
2012.

The next largest contributor to losses consists of a 295-room
full-service hotel located in Schiller Park, IL, within proximity
to Chicago O'Hare Airport.  The loan, which was previously
performing under a modification, failed to stabilize, and
transferred back to the special servicer on Dec. 15, 2011.  Based
on the most recent property performance data, performance remains
below expectations from issuance.

The largest loan in the pool, US Bancorp Tower (15.4%), is
collateralized by a 1 million square foot class A office building
in Portland, OR.  The largest tenant, US Bancorp (rated 'AA-
/F1+/OS' by Fitch), occupies over 40% of the net rentable area
under two separate leases expiring in 2015.  Property performance
has been stable since issuance.  Whereas this loan represents 15%
of the transaction, any declines in future performance will have a
significant impact on overall deal expected losses.  Fitch will
continue to monitor US Bancorp's 2015 lease expiration, which may
affect the loan's ability to refinance at the August 2016 maturity
date.

Fitch takes various rating actions as indicated:

  -- $41.8 million class A-3 affirmed at 'AAAsf'; Outlook Stable;
  -- $68.2 million class A-AB affirmed at 'AAAsf'; Outlook Stable;
  -- $715.3 million class A-4 affirmed at 'AAAsf'; Outlook Stable;
  -- $153.5 million class A-M downgraded to 'Asf' from 'AAsf';
     Outlook to Negative from Stable;
  -- $101.7 million class A-J affirmed at 'BBB-sf'; Outlook
     Negative;
  -- $28.8 million class B downgraded to 'CCCsf' from 'Bsf'; RE
     100%;
  -- $13.4 million class C downgraded to 'CCsf' from 'CCCsf'; RE
     0%;
  -- $21.1 million class D downgraded to 'Csf' from 'CCsf'; RE 0%;
  -- $13.4 million class E affirmed at 'Csf'; RE 0%;
  -- $13.4 million class F affirmed at 'Csf'; RE 0%;
  -- $19.2 million class G affirmed at 'Csf'; RE 0%;
  -- $3.5 million class H affirmed at 'Dsf'; RE 0%;
  -- $0 class J affirmed at 'Dsf'; RE 0%;
  -- $0 class K affirmed at 'Dsf'; RE 0%;
  -- $0 class L affirmed at 'Dsf'; RE 0%;
  -- $0 class M affirmed at 'Dsf'; RE 0%;
  -- $0 million class N affirmed at 'Dsf'; RE 0%;
  -- $0 million class O affirmed at 'Dsf'; RE 0%.

Classes A-1 and A-2 have paid in full.  Classes X-1 and X-2 were
previously withdrawn and Class P is not rated.


BLADE ENGINE 2006-1: S&P Cuts Rating on Class B Notes to 'BB+'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A-1 and A-2 notes issued by Blade Engine Securitization Ltd.
to 'A- (sf)' from 'A (sf)' and its rating on the class B notes to
'BB+ (sf)' from 'BBB+ (sf)'. The notes are collateralized
primarily by the lease revenue and sales proceeds from a portfolio
of aircraft engines.

The ratings reflect S&P's opinion of:

-- The aircraft engine collateral's value and rental income
    potential;

-- The transaction's increasing loan-to-value (LTV) ratio based
    on the engine portfolio's updated appraisal in June 2012;

-- The declining lease rental collection;

-- The relatively older engine models;

-- The class A-1 and B notes' vulnerability to interest rate
    risk;

-- The number of engines not on lease;

-- The class B notes' slower pace of amortization;

-- The payment structure and cash flow mechanics, including
    senior and junior cash reserve accounts;

-- The transaction's legal structure; and

-- GE Commercial Aviation Services demonstrated servicing
    ability.

"As of Nov. 15, 2012, the collateral comprised 48 aircraft
engines; two aircraft engines have been sold out of the portfolio
since the deal's inception in 2006. Of the 48 engines, 41 were
leased to 22 lessees operating in 16 countries, and seven were
off-lease. The top five lessees, as measured by the engines' June
2012 appraised values, represented approximately 50% of the
collateral. The collateral's June 2012 appraised value was
approximately $320 million. The LTV ratio of the class A-1 and A-2
notes increased to 80% and the LTV ratio of the class B notes
increased to 89% based on the June 2012 appraised value," S&P
said.

"The engine models in the portfolio are relatively older than
other rated engine securitization transactions. Of the 48 engines,
17 engines have reached their respective inflection date (i.e.,
the date when the aircraft that the engine powers is out of
production). As production of a particular aircraft ends, the
demand in the related engine models will decrease, and therefore,
it will become harder for the servicer to market the lease of such
engines. We believe that the more engines either passing or
approaching their inflection dates will affect the transaction's
future cash generating ability. As of Nov. 15, 2012, seven engines
were not on lease, an increase from three in March 2011 (the time
of our last review). The weighted average lease rate (calculated
as the total lease rental divided by the total appraised value)
has decreased and is noticeably lower than that of the recently
rated engine securitization transactions," S&P said.

"Unlike other recently rated engine securitization transactions,
Blade Engine's class A-1 and B notes are both floating-rate notes
and therefore are vulnerable to interest rate risk. Currently, an
interest rate swap covering the interest rate risk is due to
mature in 2018," S&P said.

According to the Nov. 15, 2012, payment period monthly report, the
class A-1 and A-2 notes' received interest payment and minimum
principal; the class B notes only received interest payment. Since
August 2012, the class B notes have been only receiving interest
payment.

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED

Blade Engine Securitization Ltd.
$330 million floating- and fixed-rate notes series 2006-1
Class                  Rating
                To                From
A-1             A- (sf)           A (sf)
A-2             A- (sf)           A (sf)
B               BB+ (sf)          BBB+ (sf)


BLUEMOUNTAIN CLO: S&P Affirms 'BB+' Rating on Class D Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised and removed from
CreditWatch positive its ratings on three classes of notes from
BlueMountain CLO Ltd., a collateralized loan obligation (CLO)
transaction managed by BlueMountain Capital Management L.P. "We
also affirmed our ratings on the class A-1 and the class D notes.
We also removed our rating on the class D note from CreditWatch,"
S&P said.

"The upgrades reflect the paydowns to the class A-1 note and the
increase in the overcollateralization (OC) levels since our March
2012 rating actions. Since then, the transaction has paid down the
class A-1 note balance to 63% of its initial balance. The class
A/B Overcollateralization ratio has increased to 133.18% from
122.35% as of the February 2012 trustee report," S&P said.

"We affirmed and removed from CreditWatch our rating on the class
D notes. The transaction currently has approximately $18 million
in underlying collateral (5.31% of the collateral portfolio) that
matures after the legal final maturity of the transaction. This
may subject the rated notes to the market value risk of these
long-dated assets. We did also note that the weighted average life
of the portfolio has increased from 3.40 to 3.57 years from the
time of our March 2012 rating actions. The maturities of some
assets that were set to mature in 2014 as of the February 2012
trustee report had been extended as of the October 2012 report,"
S&P said.

"We will continue to review our ratings on the notes and assess
whether, in our view, the ratings remain consistent with the
credit enhancement available," S&P said.

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

        http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

BlueMountain CLO Ltd.

                   Rating
             To               From
A-1          AAA (sf)         AAA (sf)
A-2          AAA (sf)         AA+ (sf)/Watch Pos
B            AA+ (sf)         AA- (sf)/Watch Pos
C            A+ (sf)          A- (sf)/Watch Pos
D            BB+ (sf)         BB+ (sf)/Watch Pos



BLUEMOUNTAIN CLO 2012-2: S&P Gives 'BB' Rating on Class E Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
BlueMountain CLO 2012-2 Ltd./BlueMountain CLO 2012-2 LLC's $554.55
million floating-rate notes.

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

    The portfolio manager's experienced management team.

    Its 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/1054.pdf

RATINGS ASSIGNED

BlueMountain CLO 2012-2 Ltd./BlueMountain CLO 2012-2 LLC

Class                Rating                   Amount
                                            (mil. $)
A-1                  AAA (sf)                 372.20
A-2                  AAA (sf)                  10.00
B-1                  AA (sf)                   48.10
B-2                  AA (sf)                   20.00
C (deferrable)       A (sf)                    48.90
D (deferrable)       BBB (sf)                  30.10
E (deferrable)       BB (sf)                   25.25
Subordinated notes   NR                        62.70

NR - Not rated.


C-BASS CBO VII: Moody's Hikes Rating on $20MM Cl. C Notes to 'Ba1'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the rating of the following
notes issued by C-Bass CBO VII Ltd.:

U.S. $20,000,000 Class C Third Priority Secured Floating Rate
Deferrable Interest Notes Due 2038 (current outstanding balance of
$17,207,143), Upgraded to Ba1 (sf); previously on May 14, 2010
Downgraded to B2 (sf)

Ratings Rationale

According to Moody's, the rating action taken on the notes is
primarily a result of deleveraging of the senior notes and an
increase in the transaction's overcollateralization ratio since
the rating action in May 2010. Moody's notes that the Class A
Notes and Class B Notes were paid down in full and Class C Notes
have been paid down by approximately 14%, or $2.8 million since
the last rating action. Based on the latest trustee report dated
November 5, 2012, the Class C overcollateralization ratio is
reported at 227.1%, versus March 2010 level of 146.6%.

C-Bass CBO VII, Ltd., issued in July 2003, is a collateralized
debt obligation backed primarily by a portfolio of RMBS and ABS
originated from 2002 to 2003.

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

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.8 to model the loss distribution for SF CDOs. Within this
framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference.
Specifically, correlated defaults are simulated using a normal (or
"Gaussian") copula model that applies the asset correlation
framework. Recovery rates for defaulted credits are generated by
applying within the simulation the distributional assumptions,
including correlation between recovery values. Together, the
simulated defaults and recoveries across each of the Monte Carlo
scenarios define the loss distribution for the reference pool.

Once the loss distribution for the collateral has been calculated,
each collateral loss scenario derived through the CDOROM loss
distribution is associated with the interest and principal
received by the rated liability classes via the CDOEdge cash-flow
model . The cash flow model takes into account the following:
collateral cash flows, the transaction covenants, the priority of
payments (waterfall) for interest and principal proceeds received
from portfolio assets, reinvestment assumptions, the timing of
defaults, interest-rate scenarios and foreign exchange risk (if
present). The Expected Loss (EL) for each tranche is the weighted
average of losses to each tranche across all the scenarios, where
the weight is the likelihood of the scenario occurring. Moody's
defines the loss as the shortfall in the present value of cash
flows to the tranche relative to the present value of the promised
cash flows. The present values are calculated using the promised
tranche coupon rate as the discount rate. For floating rate
tranches, the discount rate is based on the promised spread over
Libor and the assumed Libor scenario.

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

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios, discussed below. Results are shown in terms
of the number of notches' difference versus the current model
output, where a positive difference corresponds to lower expected
loss, assuming that all other factors are held equal:

Moody's Caa rated assets notched up by 2 rating notches:

Class C: 0
Class D: 0

Moody's Caa rated assets notched down by 2 rating notches:

Class C: 0
Class D: 0


C-BASS MORTGAGE: Moody's Lifts Rating on Class A-2 Certs. to 'B1'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the rating of Class A-2
from C-Bass Mortgage Loan Asset-Backed Certificates, Series 2006-
RP2, backed by Scratch and Dent Loans.

Ratings Rationale

The action is a result of the recent performance review of Scratch
and Dent pools and reflect Moody's updated loss expectations on
this pool. The update is due to faster-than-expected pay-down on
Class A-2 owing mainly to liquidations.

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 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: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2006-RP2

Cl. A-2, Upgraded to B1 (sf); previously on Apr 24, 2009
Downgraded to B3 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF307879

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


CASTLE GARDEN: S&P Raises Ratings on 2 Note Classes to 'BB+'
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, A-3a, A-3b, A-4, B-1, B-2, C-1, C-2, D-1, and D-2 notes
from Castle Garden Funding, a U.S. collateralized loan obligation
(CLO) transaction managed by CSFB Alternative Capital Inc. "At the
same time, we removed our ratings on the class A-4, B-1, B-2, C-1,
C-2, D-1, and D-2 notes from CreditWatch with positive
implications, where we placed them on Aug. 17, 2012," S&P said.

"The upgrades mainly reflect paydowns to the class A-1, A-2, and
A-3a notes and a subsequent improvement in the credit enhancement
available to support the notes since June 2011, when we upgraded
most of the notes. Since that time, the transaction has paid down
the class A-1, A-2, and A-3a notes by approximately $124 million,
reducing their outstanding note balances to 80.8%, 80.8%, and
78.6%, respectively, of their original balances at issuance," S&P
said.

The upgrades also reflect an improvement in the
overcollateralization (O/C) available to support the notes,
primarily due to the aforementioned paydowns. The trustee reported
the following O/C ratios in the October 2012 monthly report:

    The class A O/C ratio was 130.24%, compared with a reported
    ratio of 122.85% in May 2011;
    The class B O/C ratio was 120.48%, compared with a reported
    ratio of 115.20% in May 2011;
    The class C O/C ratio was 113.91%, compared with a reported
    ratio of 109.94% in May 2011; and
    The class D O/C ratio was 111.14%, compared with a reported
    ratio of 107.69% in May 2011.

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 AND CREDITWATCH ACTIONS

Castle Garden Funding
                   Rating
Class         To           From
A-1           AAA (sf)     AA+ (sf)
A-2           AAA (sf)     AA+ (sf)
A-3a          AAA (sf)     AA+ (sf)
A-3b          AAA (sf)     AA+ (sf)
A-4           AA+ (sf)     A+ (sf)/Watch Pos
B-1           A+ (sf)      BBB+ (sf)/Watch Pos
B-2           A+ (sf)      BBB+ (sf)/Watch Pos
C-1           BBB (sf)     BB+ (sf)/Watch Pos
C-2           BBB (sf)     BB+ (sf)/Watch Pos
D-1           BB+ (sf)     B+ (sf)/Watch Pos
D-2           BB+ (sf)     B+ (sf)/Watch Pos

TRANSACTION INFORMATION
Issuer:             Castle Garden Funding
Coissuer:           Castle Garden Funding (Delaware) Corp.
Collateral manager: CSFB Alternative Capital Inc.
Underwriter:        Credit Suisse First Boston Corp.
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CDO


CENTRAL PLAINS: Moody's Puts 'B2' Rating on Watch for Downgrade
---------------------------------------------------------------
Moody's Investors Service has placed on watch for downgrade the B2
rating of Central Plains Energy Project Gas Project Revenue Bonds,
Series 2007A and 2007B (Project No. 1) following the downgrade of
MBIA, Inc. to Caa1 from B2. The bonds have exposure to MBIA, Inc.
through a repurchase agreement provided by MBIA Inc. (Caa1) that
is also insured by MBIA Insurance Corporation (Caa2) in which
funds needed for debt service payments are invested.

The principal methodology used in rating this issue was Gas
Prepayment Bonds published in December 2008.


CITIGROUP COMM'L 2006-C5: Fitch Cuts Rating on 2 Certs. to 'CCCsf'
------------------------------------------------------------------
Fitch Ratings downgrades five classes of Citigroup Commercial
Mortgage Trust, series 2006-C5, commercial mortgage pass-through
certificates, due to further deterioration of performance.  The
downgrades are driven by a decline in value of several loans in
special servicing as well as a decline in performance of several
large loans since Fitch's last rating action.

Fitch modeled losses of 8.5% of the current balance which includes
expected losses on the specially serviced loans and Fitch loans of
concern.  Cumulative losses, which include realized losses and
current modeled losses, were 10.6% of the original balance
compared to 8.6% at the last rating action.

As of the October 2012 distribution date, the transaction's pooled
principal balance has been reduced by approximately 21.3% to $1.67
billion from $2.12 billion at issuance.  Since Fitch's last rating
action, two loans in the top 10 repaid without losses to the trust
(Ala Moana Center and NNN WellPoint Operations Center), while one
loan, Four Points Sheraton, repaid with a realized loss of 1%.
Interest shortfalls are affecting classes E through P.

The largest contributor to losses is the IRET Portfolio Loan
(7.3%). The loan is secured by a portfolio of nine office
buildings located in Nebraska (four), Missouri (two), Minnesota
(two), and Kansas (one) with a total of 936,720 square feet (sf).
Portfolio occupancy has declined to 82.5% as of July 2012 and cash
flow has declined since Fitch's last rating action. Fitch is
modeling the loan to default during the term.

The next largest contributor to losses is the One and Two
Securities Center Loan (4.1%).  The loan is secured by a 521,957-
sf office property located in Atlanta, GA.  The loan transferred
to the special servicer in December 2010 for imminent default when
several tenants vacated upon lease expiration.  The loan became
REO in November 2011.  The property is 79% leased as of Sept.
2012. Recent valuations indicate significant losses.

The third largest contributor to losses is the Courtyard Atlanta
Roswell loan (0.4%) which is secured by a 154-room hotel located
in Roswell, GA.  The property became REO in March, 2011.  The
special servicer is preparing the asset for disposition as soon as
possible.  Recent valuations indicate significant losses.

Fitch downgrades the following classes and revises the Outlooks
and Recovery Estimates (RE) as indicated:

  -- $172.6 million class A-J to 'BBsf' from 'BBBsf'; Outlook to
     Negative from Stable;
  -- $42.5 million class B to 'CCCsf' from 'BBsf'; RE 75%;
  -- $21.2 million class C to 'CCCsf' from 'Bsf'; RE 0%;
  -- $26.5 million class D to 'CCsf' from 'CCCsf'; RE 0%;
  -- $29.2 million class E to 'Csf' from 'CCsf'; RE 0%.

Fitch affirms the following classes:

  -- $65.7 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $92.8 million class A-SB at 'AAAsf'; Outlook Stable;
  -- $774.3 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $201.7 million class A-1A at 'AAAsf' Outlook Stable;
  -- $212.4 million class A-M at 'AAAsf'; Outlook Stable
  -- $26.5 million class F at 'Csf'; RE 0%;
  -- $21.2 million class G at 'Csf'; RE 0%.

Classes A-1, A-2, AMP-1, AMP-2, and AMP-3 have paid in full.
Classes H through O have realized losses and remain at 'Dsf' RE
0%.  Fitch does not rate class P.


CITIGROUP MORTGAGE 2004-2: Moody's Cuts 4 Tranch Ratings to 'B3'
----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of four
tranches from Citigroup Mortgage Loan Trust Inc. Series 2004-2.

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.

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: Citigroup Mortgage Loan Trust Inc. Series 2004-2

Cl. I-A1, Downgraded to B3 (sf); previously on Mar 14, 2011
Downgraded to Ba3 (sf)

Cl. IO-1, Downgraded to B3 (sf); previously on Mar 14, 2011
Downgraded to Ba3 (sf)

Cl. PO-1, Downgraded to B3 (sf); previously on Mar 14, 2011
Downgraded to Ba3 (sf)

Cl. I-A2, Downgraded to B3 (sf); previously on Mar 14, 2011
Downgraded to Ba3 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF304654

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


COAST INVESTMENT 2002-1: S&P Affirms 'CC' Rating on 3 Debt Classes
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
A notes from Coast Investment Grade 2002-1 Ltd. "In addition, we
affirmed our ratings on the class C-1, C-2, and D notes," S&P
said.

Coast Investment Grade 2002-1 Ltd. is a collateralized debt
obligation (CDO) of corporate CDO transaction, managed by Crescent
Capital Group L.P.

"The upgrade reflects the principal paydowns to the class A notes
and an improvement in the credit quality of the transaction's
underlying assets since our last rating actions in April 2011. The
affirmations reflect our belief that the credit support available
is commensurate with the current ratings," S&P said.

"On Jul. 30, 2012, class A notes received $27.70 million principal
paydown. Since April 2011, the transaction has paid down the class
A notes by $73.68 million and reduced the outstanding balance to
21.47% of the original balance," S&P said.

"According to the Sept. 28, 2012 trustee report, the transaction
held $33 million defaulted collateral, down from $79 million noted
in the Feb. 28, 2011, trustee report, which we referenced for our
April 2011 rating actions," 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

Coast Investment Grade 2002-1 Ltd.
Class          Rating
          To            From
A         BB+ (sf)      B (sf)
C-1       CC (sf)       CC (sf)
C-1       CC (sf)       CC (sf)
D         CC (sf)       CC (sf)


COLUMBUSNOVA CLO: Moody's Raises Rating on Cl. E Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by ColumbusNova CLO Ltd. 2006-II:

U.S.$30,000,000 Class B Senior Notes Due April 4, 2018, Upgraded
to Aaa (sf); previously on Aug 5, 2011 Upgraded to Aa3 (sf)

U.S.$22,000,000 Class C Deferrable Mezzanine Notes Due April 4,
2018, Upgraded to A1 (sf); previously on Aug 5, 2011 Upgraded to
Baa2 (sf)

U.S.$20,000,000 Class D Deferrable Mezzanine Notes Due April 4,
2018, Upgraded to Baa2 (sf); previously on Aug 5, 2011 Upgraded to
Ba1 (sf)

U.S.$15,000,000 Class E Deferrable Junior Notes Due April 4, 2018,
Upgraded to Ba1 (sf); previously on Aug 5, 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 February 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, higher Diversity and higher
spread levels compared to the levels assumed at the last rating
action in August 2011. Moody's modeled a WARF of 2584, WAS of
3.43%, and Diversity of 87 compared to 2667, 2.70% and 75,
respectively, 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 $494 million, no
defaulted par, a weighted average default probability of 17.23%
(implying a WARF of 2584), a weighted average recovery rate upon
default of 50.51%, and a diversity score of 87. 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.

ColumbusNova CLO Ltd. 2006-II, 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% (2067)

Class A: 0
Class B: 0
Class C: +3
Class D: +3
Class E: +1

Moody's Adjusted WARF + 20% (3101)

Class A: 0
Class B: -2
Class C: -2
Class D: -2
Class E: -2

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

Sources of additional performance uncertainties are described
below :

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


COLUMN CANADA 2006-WEM: S&P Cuts Rating on Class K Certs. to 'BB+'
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on eight
classes of multiclass pass-through certificates from Column Canada
Issuer Corp.'s series 2006-WEM, a Canadian commercial mortgage-
backed securities (CMBS) transaction, and removed them from
CreditWatch with positive implications, where S&P's placed them on
Sept. 5, 2012. "Concurrently, we lowered our rating on class K and
removed it from CreditWatch with negative implications. In
addition, we affirmed our 'AAA (sf)' ratings on three other
classes from the same transaction," S&P said.

"The rating actions follow our analysis of the transaction using
our recently updated criteria for rating U.S. and Canadian CMBS
transactions, and the application of the criteria was the primary
driver of the rating actions. The analysis of stand-alone (single
borrower) transactions is predominantly a recovery-based approach
that assumes a loan default. Reflecting this approach, our
property-level analysis included a revaluation of the shopping and
entertainment complex totaling 4.2 million sq. ft. (which includes
a 2.5 million-sq.-ft. super regional mall, a 12-story, 355-room
hotel, and entertainment and amusement facilities totaling 557,037
sq. ft.) in Edmonton, Alberta, Canada securing the first mortgage
bond in the trust. Based on our analysis, we derived our
sustainable net cash flow, which we then divided by a weighted
average capitalization rate of 6.93% to determine our expected-
case value. This yielded a loan-to-value ratio of 54.6%," S&P
said.

"We based the downgrade of class K to 'BB+ (sf)' on our recently
updated criteria for rating U.S. and Canadian CMBS transactions,
which applies a credit enhancement minimum equal to 1% of the
transaction or loan amount to address the potential for unexpected
trust expenses that may be incurred during the life of the loan or
transaction. These potential unexpected trust expenses may include
servicer fees, servicer advances, workout or corrected mortgage
fees, and potential trust legal fees," S&P said.

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

"We based our analysis, in part, on a review of the borrower's
operating statements for the collateral for the years ended July
31, 2012 and 2011, and the July and October 2012, rent rolls for
the retail portion. The reported occupancy was 91.7% as of the
Oct. 15, 2012, rent roll for the retail portion and 76.9%
according to the July 31, 2012, borrower's statements for the
hotel portion. The master servicer, Midland Loan Services,
reported a debt service coverage (DSC) of 2.18x for the year ended
July 31, 2012," S&P said.

"As of the Nov. 15, 2012, trustee remittance report, the first
mortgage bond has a trust and whole-loan balance of C$565.4
million. The first mortgage bond amortizes on a 30-year schedule,
with IO payments for the first two years, and pays interest based
on 5.66% per annum. The mortgage bond matures on Sept. 15, 2016,"
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 RAISED AND REMOVED FROM CREDITWATCH POSITIVE

Column Canada Issuer Corp.
Multiclass pass-through certificates series 2006-WEM
                 Rating
Class     To             From
B         AAA (sf)       AA+ (sf)/Watch Pos
C         AAA (sf)       AA (sf)/Watch Pos
D         AAA (sf)       AA- (sf)/Watch Pos
E         AA+ (sf)       A+ (sf)/Watch Pos
F         AA (sf)        A (sf)/Watch Pos
G         A+ (sf)        A- (sf)/Watch Pos
H         A- (sf)        BBB+ (sf)/Watch Pos
J         BBB+ (sf)      BBB (sf)/Watch Pos

RATING LOWERED AND REMOVED FROM CREDITWATCH NEGATIVE

Column Canada Issuer Corp.
Multiclass pass-through certificates series 2006-WEM
                 Rating
Class     To             From
K         BB+ (sf)       BBB- (sf)/Watch Neg

RATINGS AFFIRMED

Column Canada Issuer Corp.
Multiclass pass-through certificates series 2006-WEM
Class     Rating
A-1       AAA (sf)
A-2       AAA (sf)
A-X       AAA (sf)


COMM 2006-C7: Fitch Cuts Ratings on 2 Cert. Classes to 'Csf'
------------------------------------------------------------
Fitch Ratings has affirmed the super senior classes of COMM 2006-
C7, commercial mortgage pass-through certificates at 'AAA' and
downgraded four classes.

The downgrades reflect an increase in Fitch expected losses
largely attributed to increased loss expectations associated with
the specially serviced assets, particularly the Granite Run Mall.
The asset is the fourth largest in the pool; the most recent
valuation is significantly lower than that at Fitch's last rating
action in February 2012.  Fitch modeled losses of 15.0% of the
remaining pool; expected losses of the original pool including
losses to date are 14.3%.

Fitch designated 40 loans (35.3%) as Fitch Loans of Concern, which
includes 16 specially serviced loans (18.8%).  Additionally, four
of the top 15 loans (12.6%) are currently in special servicing,
two of which (7.1%), are amongst the top three largest
contributors to Fitch modeled losses.  Interest shortfalls in the
amount of $19 million are currently affecting classes A-J thru P.

The largest contributor to Fitch expected losses is secured by The
Granite Run Mall, a 1,032,843 square foot (sf) super regional mall
located in Media, PA, approximately 12 miles from the central
business district (CBD) of Philadelphia.  The mall is anchored by
Sears, Boscov's, JC Penney, and Kohl's.  Sears and JC Penney own
their stores but are subject to ground leases.  The loan
transferred to special servicing in October 2010 due to imminent
default and is currently real estate owned (REO).  The special
servicer has installed leasing and management teams and developed
a capital plan and 2012 budget. As of September 2012, the inline
occupancy is 67% leased and 48% leased excluding temporary.
Leasing negotiations continue with several junior anchors.  The
life safety issues and deferred maintenance issues at the property
have all been corrected.

The second largest contributor to loss is secured by an enclosed
regional mall consisting of 554,334 sf.  The mall is anchored by
Sears, JC Penney, and Macy's, which is not part of the collateral.
The collateral includes a 6,863 sf outparcel and 255,878 sf of
inline space. The property is located in Battle Creek, MI.  The
loan was transferred back to special servicing in August 2010 due
to imminent default. General Growth Properties (GGP) and the
special servicer could not agree on terms for a modification.  A
deed in lieu of foreclosure occurred in February 2011.  The
special servicer has engaged third parties for management and
leasing.  As of September 2012, inline occupancy at the property
is 78%; excluding temporary tenants occupancy is 68%. The property
is currently being marketed for sale and closing is expected in
2012.

The third largest contributor to loss is secured by a 305,858 sf
retail property built in 1986, renovated in 2004 and located in
Westminster, CO, just north of Denver.  The loan was transferred
to special servicing in April 2011 for monetary default.  The
property was 74% occupied as of January 2012.  The loan was
foreclosed upon in October 2011.  The special servicer has engaged
a leasing team, which has made some progress.  Prior to
foreclosure, the receiver negotiated a new lease with a restaurant
tenant and drafted a renewal with an existing tenant.  The special
servicer is in the process of reviewing the 2012 budget and
determining capital needs for the next 12 months.

Fitch downgrades, revises Outlooks, and assigns or revises
Recovery Estimates (RE) for the following classes as indicated:

  -- $244.7 million class A-M to 'A' from 'AAA'; Outlook to
     Negative from Stable;
  -- $189.7 million class A-J to 'CCC' from 'B'; RE 75%;
  -- $52 million class B to 'C' from 'CCC'; RE 0%;
  -- $24.5 million class C to 'C' from 'CC'; RE 0%;

Additionally, Fitch affirms the following classes as indicated:

  -- $16.2 million class A-3 at 'AAA'; Outlook Stable;
  -- $68.4 million class A-AB at 'AAA'; Outlook Stable;
  -- $1,052.7 million class A-4 at 'AAA'; Outlook Stable;
  -- $262.4 million class A-1A at 'AAA'; Outlook Stable;
  -- $36.7 million class D at 'C'; RE 0%;
  -- $21.4 million class E at 'C'; RE 0%;
  -- $30.6 million class F at 'C'; RE 0%;
  -- $24.5 million class G at 'C'; RE 0%;
  -- $30.6 million class H at 'C'; RE 0%;
  -- $12.2 million class J at 'C', RE 0%;
  -- $6.1 million class K at 'C', RE 0%;
  -- $9.2 million class L at 'C', RE 0%;
  -- $3.1 million class M at 'C', RE 0%;
  -- $6.1 million class N at 'C', RE 0%;
  -- $9.2 million class O at 'C', RE 0%.


Fitch had previously withdrawn the rating on the interest-only
class X.

Fitch does not rate the $87,148 class P certificates.  Classes A-1
and A-2 have paid in full.


COMMONWEALTH REIT: Moody's Cuts Preferred Stock Rating to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has downgraded the senior unsecured debt
rating of CommonWealth REIT (CWH) to Baa3 from Baa2. The rating
agency also downgraded the office REIT's preferred stock rating to
Ba1 from Baa3. The outlook has been revised to stable from
negative.

Ratings Rationale

The ratings downgrade reflects CWH's continued weak operating
performance and the associated impact on key credit metrics, such
as leverage and fixed charge coverage. Moody's expects these
metrics will improve as the REIT executes on its plan to address
challenged assets, and CWH's size, diversity, liquidity, and large
unencumbered asset pool all support the Baa3 rating and stable
outlook. Moody's also notes that CWH has a long history of
supporting its balance sheet via common equity issuance.

CWH's consolidated portfolio was 84.5% leased as of 3Q12, with the
wholly-owned portfolio (excluding its 70% stake in Select Income
REIT) only 80% leased. The REIT's weak occupancy is being driven
by $1.5 billion of assets (17% of total gross book value) it has
identified as challenged and plans to aggressively address via
dispositions and/or capital investment. CWH recently took the
prudent step of reducing its common dividend by 50% in order to
generate incremental cash flow needed to lease up these
properties. The Baa3 rating with a stable outlook anticipates that
CWH will demonstrate good progress in executing sales and
improving occupancy in 2013, with a concurrent improvement in key
credit metrics. Net Debt/EBITDA and fixed charge coverage remain
weak at 7.3x and 2.2x for 3Q12, respectively and thus provides
little cushion for the stable rating outlook.

Moody's notes positively that the remaining portion of CWH's
wholly-owned portfolio is 91% occupied, with good diversification
by geography and tenant base. The REIT has been growing rapidly in
recent years in an effort to increase its presence in CBD markets
and improve its long-term growth trajectory. CBD office assets
comprised 54% of CWH's wholly-owned portfolio NOI as of 3Q12 and
the planned dispositions will help it to achieve further progress
with its objective. Moody's also commented that the REIT's large
majority stake in SIR, which is 95% leased and comprises stable,
high-quality assets, supports CWH's credit profile as it continues
its portfolio transformation.

CWH's liquidity position is sound, with $9 million of debt
maturities in 2013 and $265 million in 2014. Moody's views these
amounts as manageable considering the REIT's $750 million
unsecured credit facility ($160 million drawn as of 3Q12) that
matures in 2015. CWH's $7.6 billion unencumbered asset pool
provides further financial flexibility, as does the recent common
dividend reduction.

A ratings upgrade would likely reflect substantial, sustained
improvement in core occupancy trends and an improved long-term
growth profile. Fixed charge coverage comfortably above 2.5x and
Net Debt/EBITDA below 6x would also be necessary for an upgrade.

A downgrade would be precipitated by continued negative operating
trends or strategic missteps, with fixed charge coverage expected
to remain below 2.2x or Net Debt/EBITDA above 7x on a sustained
basis.

The following ratings were downgraded with a stable outlook:

CommonWealth REIT -- senior unsecured debt to Baa3 from Baa2;
preferred stock to Ba1 from Baa3; senior unsecured shelf to
(P)Baa3 from (P)Baa2; preferred stock shelf to (P)Ba1 from
(P)Baa3.

Moody's last rating action for CommonWealth was on March 2, 2012
when the ratings were affirmed with a negative outlook.

The principal methodology used in this rating was Global Rating
Methodology for REITs and Other Commercial Property Firms
published in July 2010.

CommonWealth REIT (NYSE: CWH) is an office and industrial REIT
that owns properties throughout the United States. CWH owns 70% of
the common shares of Select Income REIT, a publicly traded REIT
which owns primarily net leased, single tenant office and
industrial properties. Both REITs are externally managed by Reit
Management & Research, LLC, based in Newton, MA.


CREDIT SUISSE 2001-CP4: S&P Cuts Rating on Class F Certs. to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on three
classes of commercial mortgage pass-through certificates from
Credit Suisse First Boston Mortgage Securities Corp.'s series
2001-CP4, a U.S. CMBS transaction. "Concurrently, we placed two
ratings on CreditWatch with negative implications. Finally, we
withdrew our rating on the interest-only class A-X," S&P said.

S&P's downgrades and negative CreditWatch placements reflect
$611,720 of interest shortfalls to the trust, $142,617 of which
was reflected as a principal loss to the H certificates. These
interest shortfalls were primarily composed of:

-- $268,750 of interest not advanced by the master servicer,
    Midland Loan Services (Midland), on four of the six specially
    serviced assets that Midland has declared nonrecoverable; and

-- $255,705 of interest recovered by Midland on two of the six
    specially serviced assets that it has declared nonrecoverable.

"As of the Nov. 19, 2012, remittance report, the trust experienced
interest shortfalls and principal losses totaling $611,720. The
reported monthly interest shortfalls affected all of the classes
subordinate to and including class D, as well as the interest-only
class A-X, and are primarily owed to the items. Furthermore,
$721,370 of outstanding advances related to the Somerset Center &
Somerset Place ($13.3 million, 18.6%) and Somerset Park ($12.8
million, 17.8%) specially serviced loans remain outstanding.
Midland has declared these assets to be nonrecoverable and has
informed us that it intends to recover the outstanding advances
over the next few months. Our analysis, based on available
information, indicates the deal is likely to experience a
significant amount of interest shortfalls going forward," S&P
said.

"We downgraded class D to 'A+ (sf)' and placed the rating on
CreditWatch negative because the bond experienced an interest
shortfall this past reporting period and we expect this bond to
experience at minimum one additional month of interest shortfalls
before it is potentially paid back in full. We also downgraded
class E to 'BBB (sf)' and placed the rating on CreditWatch
negative for similar reasons; however, we believe interest
shortfalls are likely to continue for a slightly longer period for
this class before any potential repayment. We lowered the rating
on class F to 'D (sf)' to reflect accumulated interest shortfalls
that we believe will remain outstanding for the foreseeable
future. Finally, we withdrew our rating on the interest-only class
A-X, to reflect our current criteria for rating IO securities,"
S&P said.

"As of the Nov. 19, 2012, remittance report, the transaction
collateral comprised 12 commercial real estate assets, including
six that are with the special servicer. The reported payment
status of the specially serviced assets is: three assets ($25.5
million, 35.6%) are real estate owned (REO), one loan ($13.3
million, 18.6%) is in foreclosure, and two loans ($13.2 million,
18.4%) are nonperforming matured balloon loans," S&P said.

"Standard & Poor's will resolve the CreditWatch negative
placements as more information concerning the recovery of advances
becomes available and after we review the credit characteristics
of the remaining assets in the pool as well as available liquidity
remaining in the pool," S&P said.

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED AND PLACED ON CREDITWATCH NEGATIVE

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CP4

                                     Credit            Reported
              Rating            Enhancement Interest Shortfalls($)
Class  To                 From          (%)  Current Accumulated
D      A+ (sf)/Watch Neg  AAA (sf)   78.67   84,100     84,100
E      BBB (sf)/Watch Neg A (sf)     56.04   94,247     94,247

RATING LOWERED

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CP4

                                     Credit            Reported
            Rating              Enhancement Interest Shortfalls($)
Class  To       From                    (%)  Current Accumulated
F      D (sf)   CCC- (sf)         33.40      95,598     191,195

RATING WITHDRAWN

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-CP4

                                     Credit            Reported
              Rating            Enhancement Interest Shortfalls($)
Class  To       From                   (%)  Current  Accumulated
A-X    NR       AAA (sf)           N/A       56,148    56,148

N/A - Not applicable.
NR - Not rated.


CREDIT SUISSE 2003-C4: Moody's Affirms 'C' Rating on Cl. L Certs.
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 13 classes of
Credit Suisse First Boston Mortgage Securities Corp., Commercial
Mortgage Pass-Through Certificates, Series 2003-C4 as follows:

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

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

Cl. D, Affirmed at Aa2 (sf); previously on Dec 10, 2010 Confirmed
at Aa2 (sf)

Cl. E, Affirmed at A1 (sf); previously on Dec 10, 2010 Confirmed
at A1 (sf)

Cl. F, Affirmed at Baa2 (sf); previously on Dec 10, 2010
Downgraded to Baa2 (sf)

Cl. G, Affirmed at Ba3 (sf); previously on Dec 10, 2010 Downgraded
to Ba3 (sf)

Cl. H, Affirmed at Caa1 (sf); previously on Dec 10, 2010
Downgraded to Caa1 (sf)

Cl. J, Affirmed at Caa2 (sf); previously on Dec 10, 2010
Downgraded to Caa2 (sf)

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

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

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

Ratings Rationale

The affirmations for the 12 principal bonds 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 A-X, is consistent with the
credit performance of its referenced classes and thus is affirmed.

Moody's rating action reflects a base expected loss of 4.2% of the
current pooled balance compared to 4.9% at last review. The deal's
cumulative realized losses have increased by $12 million since
Moody's last review. Moody's current based expected loss plus
cumulative realized losses is 5.2% of the original pooled balance
compared to 5.1% at last review. Moody's provides a current list
of base expected losses for conduit and fusion CMBS transactions
on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 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 28, compared to 32 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 December 1, 2011.

DEAL PERFORMANCE

As of the October 17, 2012 distribution date, the transaction's
aggregate pooled certificate balance has decreased by 36% to $851
million from $1.3 billion at securitization. The Certificates are
collateralized by 133 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten loans representing 40%
of the pool. Twenty-one loans, representing 19% of the pool, have
been defeased and are collateralized with U.S. Government
Securities. Two loans, representing 13% of the pool, have
investment grade credit assessments.

Thirty-two loans, representing 32% 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.

Twenty-one loans have been liquidated from the pool at a loss,
resulting in an aggregate realized loss of $34 million (33%
average loss severity). Four loans, representing 4% of the pool,
are currently in special servicing. The largest specially serviced
loan is loan is the 800 Apollo Loan ($17 million -- 2.0%), which
is secured by a 190,000 square foot (SF) office building located
in El Segundo, California. The property has been completely vacant
since April 2011. The servicer is dual tracking foreclosure and a
possible workout. The loan is less than one month delinquent and
the servicer has not recognized an appraisal reduction.

The servicer has recognized an aggregate $3 million appraisal
reduction for two of the four specially serviced loans, while
Moody's estimates an aggregate $9 million loss (30% expected loss
overall) from all four specially serviced loans.

Moody's has assumed a high default probability for 13 poorly
performing loans representing 9% of the pool and has estimated an
$11 million aggregate loss (15% 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 97% and 94% of the pool's non-defeased
loans, respectively. Moody's weighted average conduit LTV is 83%
compared to 79% at Moody's prior review. The conduit portion of
the pool excludes specially serviced, troubled and defeased loans
as well as the two loans with credit assessments. 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 9.6%.

Moody's actual and stressed conduit DSCRs are 1.48X and 1.36X,
respectively, compared to 1.64X and 1.48X 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 Circle Centre
Mall Loan ($67 million -- 7.8% of the pool), which is secured by a
leasehold interest in an 800,000 SF regional mall located in
Indianapolis, Indiana. Simon Property Group, which is
headquartered in Indianapolis, is the loan sponsor. The mall is
anchored by Carson Pirie Scott. Nordstrom, a previous anchor
tenant, vacated the mall in July 2011 and terminated its lease in
December 2011. The total mall is only 69% leased as of June 2012
compared to 96% as of September 2011. Despite Nordstrom's
departure, the in-line space remains well leased at 91%. Moody's
current credit assessment and stressed DSCR are Baa2 and 1.68X,
respectively, compared to Baa2 and 1.60X at last review.

The second loan with a credit assessment is the 540 Madison Avenue
Loan ($43 million -- 5.1% of the pool), which is secured by a
281,000 SF office building located in the Plaza District office
submarket of New York City. The property is 91% leased as of June
2012 compared to 97% at last review. The property's largest
tenant, SAC Capital, vacated at its September 2012 lease
expiration. Loan sponsor, Boston Properties, is building out some
of the vacated space for a replacement tenant and converting some
into marketing and showroom space. Moody's current credit
assessment and stressed DSCR are Aaa and 3.08X, respectively,
compared to Aaa and 3.02X at last review.

The top three performing conduit loans represent 16% of the pool
balance. The largest loan is Wanamaker Building Loan ($56 million
-- 6.6% of the pool), which is secured by a 974,000 SF office
property located in Philadelphia, Pennsylvania. The property is
also encumbered by a $7 million B-note. The building also contains
a 435,000 SF retail condominium, solely occupied by Macy's, which
is not part of the collateral. The property is 99% leased as of
June 2012, which is the same as at last review. Moody's A-Note LTV
and stressed DSCR are 62% and 1.66X, respectively, compared to 63%
and 1.63X at last review.

The second largest loan is the Jefferson Pointe Shopping Center
Loan ($55 million -6.4%), which is secured by a 410,000 SF retail
property located in Fort Wayne, Indiana. The property was 90%
leased as of September 2012 compared with 88% as of June 2011. The
loan matures in August 2013. The debt yield is 7.6% based on 2011
net operating income (NOI). The annualized June 2012 NOI indicates
a slight cash flow improvement, which may be necessary to fully
refinance the loan by maturity. Moody's LTV and stressed DSCR are
129% and 0.79%, respectively, compared to 145% and 0.71X at last
review.

The third largest loan is the Town & Country Apartments Loan ($22
million -- 2.5% of the pool), which is secured by a 618 unit
multifamily property located near the University of Illinois
Champaign campus in Urbana, Illinois. The property was 96% leased
as of June 2012 compared to 99% at last review. Moody's LTV and
stressed DSCR are 84% and 1.15X, respectively, compared to 95% and
1.03X at last review.


CREDIT SUISSE 2004-C5: Moody's Keeps 'C' Ratings on 3 Certs.
------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 18 classes of
Credit Suisse First Boston Securities Corp., Commercial Mortgage
Pass-Through Certificates, Series 2004-C5 as follows:

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

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

Cl. A-4, 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-J, Affirmed at Aa2 (sf); previously on Dec 17, 2010
Downgraded to Aa2 (sf)

Cl. B, Affirmed at A2 (sf); previously on Dec 17, 2010 Downgraded
to A2 (sf)

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

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

Cl. E, Affirmed at Ba2 (sf); previously on Dec 17, 2010 Downgraded
to Ba2 (sf)

Cl. F, Affirmed at B1 (sf); previously on Dec 17, 2010 Downgraded
to B1 (sf)

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

Cl. H, Affirmed at Caa2 (sf); previously on Dec 17, 2010
Downgraded to Caa2 (sf)

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

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

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

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

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

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

Ratings Rationale

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.
The IO Class, Class IO, is affirmed since it is consistent with
the credit performance of its referenced classes.

Moody's rating action reflects a base expected loss of 4.8% of the
current balance compared to 6.5% 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 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 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 16, the same as at last review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.5 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 certificate balance has decreased 29% to $1.3 billion
from $1.9 billion at securitization. The Certificates are
collateralized by 178 mortgage loans ranging in size from less
than 1% to 23% of the pool. Nine loans, representing 4.0% of the
pool, have defeased and are backed by U.S. Government securities.
There are no loans with an investment grade credit assessment.

There are presently 47 loans, representing 19% 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.

Twenty-four loans have been liquidated from the pool since
securitization, resulting in an aggregate $33.2 million loss (21%
loss severity on average). Currently eight loans, representing 4%
of the pool, are in special servicing. Moody's has estimated a
$20.5 million loss (39% expected loss on average) for the
specially serviced loans.

Moody's has assumed a high default probability for five poorly
performing loans representing 2% of the pool and has estimated a
$4.4 million aggregate loss (22% expected loss based on a 50%
probability of default) from these troubled loans.

Moody's was provided with full year 2011 and partial year 2012
operating results for 99% and 91% of the performing pool,
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average conduit LTV is 93% compared to 94% at
last review. Moody's net cash flow reflects a weighted average
haircut of 11.1% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 8.9%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed conduit DSCRs are 1.27X and 1.1X, respectively,
compared to 1.26X and 1.07X, 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 top three performing loans represent 30% of the pool balance.
The largest loan is the Time Warner Retail Loan ($299.3 million --
22.6% of the pool), which is secured by a 343,000 square foot (SF)
retail center located at Columbus Circle between West 58th and
West 60th Street in New York City. The largest tenants are Whole
Foods (17% of the net rentable area (NRA); lease expiration
January 2024) and Equinox (12% of the NRA; lease expiration
February 2019). The property was 85% leased as of June 2012
compared to 99% at last review. Despite the decline in occupancy,
financial performance increased in 2011. This loan has amortized
6.5% since securitization. Moody's LTV and stressed DSCR are 92%
and 0.94X, respectively, compared to 95% and 0.92X at last review.

The second largest loan is the AT&T Consumer Services Headquarters
Loan ($49.6 million -- 3.7% of the pool), which is secured by a
387,000 SF office building located in Morris Township, New Jersey.
The property is 100% leased to AT&T Consumer Services (Moody's
senior unsecured rating - A2, on watch for possible downgrade)
through September 2014. AT&T has been in the building since it was
built in 1979 and has renewed its lease multiple times but has no
remaining options to extend the lease beyond the currently
scheduled 2014 lease expiration date. The loan was interest only
until its anticipated repayment date (ARD) of October 2009 at
which point the interest rate increased from 5.35% to 7.35%. The
loan began to amortize and all excess cash flow is applied to
reduce the outstanding principal balance. Since the ARD date, the
loan has amortized 14%. The loan is on the servicer's watchlist
for missing its ARD but is performing. The final maturity date is
in October 2034. Moody's analysis incorporated a stressed cash
flow due to the tenancy risk associated with the single tenant
exposure, the near-term lease expiration and lack of extension
options. Moody's LTV and stressed DSCR are 119% and 0.82X,
respectively, compared to 122% and 0.8X at last review.

The third largest exposure is the BECO Portfolio Loan ($45.8
million -- 3.5% of the pool), which consists of three cross-
collateralized and cross-defaulted loans secured by 14 adjacent
office buildings located 10 miles northeast of Washington, D.C. in
Lanham, Maryland. As of June 2012, the portfolio was 74% leased
compared to 76% at last review and 89% at securitization. Two of
the three loans are on the master servicer's watchlist for low
DSCR. The loan matures in September 2014. This loan has amortized
12% since securitization. Moody's LTV and stressed DSCR are 119%
and 0.91X, respectively, compared to 108% and 0.9X at last review.


CRESS 2008-1: S&P Lowers Ratings on 8 Note Classes to 'D'
---------------------------------------------------------
Standard & Poor's Ratings Services lowered our ratings on eight
classes from CRESS 2008-1 Ltd., a commercial real estate
collateralized debt obligation (CRE CDO) transaction, and removed
them from CreditWatch with negative implications. "At the same
time, we affirmed our ratings on six classes from the same
transaction removed them from CreditWatch with negative
implications," S&P said.

"The downgrades and affirmations reflect our analysis of the
transaction's liability structure and the credit characteristics
of the underlying collateral using our criteria for global CDOs of
pooled structured finance assets. We also considered the amount of
defaulted assets in the transaction and their expected recoveries
in our analysis. We lowered our ratings on classes G through O to
'D (sf)' from 'CCC- (sf)' because we determined that the classes
were unlikely to be repaid in full," S&P said.

"The global CDOs of pooled structured finance assets criteria,
which we published on Feb. 21, 2012, include revisions to our
assumptions on correlations, recovery rates, and default patterns
and timings of the collateral. Specifically, correlations on
commercial real estate assets increased to 70%. The criteria also
include supplemental stress tests (largest obligor default test
and largest industry default test) in our analysis," S&P said.

"According to the Oct. 31, 2012, trustee report, the transaction's
collateral totaled $241.8 million, which includes $347,494 of
unfunded future commitment on one asset in the transaction.  The
transaction's liabilities totaled $396.8 million, including
deferred interest on classes C and below. The liability balance at
issuance was originally $750.0 million.  The transaction's current
asset pool consists of nine whole loans ($151.6 million, 62.7%),
four subordinate mortgage loans ($18.6 million, 7.7%), and eight
commercial mortgage-backed securities (CMBS) ($71.6 million,
29.6%)," S&P said.

"The trustee report noted six defaulted assets ($49.9 million,
20.6%), comprising five defaulted CMBS ($46.9 million, 19.4%) and
one defaulted loan, 500 Davis Center ($3 million, 1.2%), in the
collateral pool. Standard & Poor's estimated no recovery to the
defaulted loan. We based our recovery analysis on information
provided by the collateral manager, special servicer, and third-
party data providers," S&P said.

"We applied asset specific recovery rates in our analysis of the
12 performing loans ($167.2 million, 69.2%) using our updated
methodology and assumptions for rating U.S. and Canadian CMBS and
our CMBS global property evaluation methodology, both published
Sept. 5, 2012. We also considered qualitative factors, such as the
near-term maturities of the loans, refinancing prospects, and
loans modifications," S&P said.

"According to the trustee report, the deal is failing all four
principal coverage tests, but passing all four interest coverage
tests," 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 determines necessary.

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED AND REMOVED FROM CREDITWATCH

CRESS 2008-1, Ltd.
                  Rating
Class     To                   From
G         D (sf)               CCC- (sf)/Watch Neg
H         D (sf)               CCC- (sf)/Watch Neg
J         D (sf)               CCC- (sf)/Watch Neg
K         D (sf)               CCC- (sf)/Watch Neg
L         D (sf)               CCC- (sf)/Watch Neg
M         D (sf)               CCC- (sf)/Watch Neg
N         D (sf)               CCC- (sf)/Watch Neg
O         D (sf)               CCC- (sf)/Watch Neg

RATINGS AFFIRMED AND REMOVED FROM CREDITWATCH

CRESS 2008-1, Ltd.
                  Rating
Class     To                   From

A2        B (sf)               B (sf)/Watch Neg
B         CCC (sf)             CCC (sf)/Watch Neg
C         CCC- (sf)            CCC- (sf)/Watch Neg
D         CCC- (sf)            CCC- (sf)/Watch Neg
E         CCC- (sf)            CCC- (sf)/Watch Neg
F         CCC- (sf)            CCC- (sf)/Watch Neg


CSFB MORTGAGE 2003-10: Moody's Cuts Rating on One Tranche to C
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 26
tranches from three RMBS transactions, backed by prime jumbo
loans, issued by Credit Suisse.

Complete rating actions are as follows:

Issuer: CSFB Mortgage-Backed Pass-Through Certificates, Series
2003-10

Cl. I-A-2, Downgraded to A1 (sf); previously on May 6, 2011
Downgraded to Aa3 (sf)

Cl. I-A-3, Downgraded to Baa3 (sf); previously on May 6, 2011
Downgraded to A2 (sf)

Cl. I-A-4, Downgraded to Baa1 (sf); previously on May 6, 2011
Downgraded to Aa3 (sf)

Cl. I-P, Downgraded to Baa2 (sf); previously on May 6, 2011
Downgraded to A1 (sf)

Cl. II-A-1, Downgraded to Baa1 (sf); previously on May 6, 2011
Downgraded to A1 (sf)

Cl. IV-A-1, Downgraded to Aa2 (sf); previously on May 27, 2003
Assigned Aaa (sf)

Cl. A-P, Downgraded to Baa1 (sf); previously on May 6, 2011
Downgraded to A1 (sf)

Cl. III-A-10, Downgraded to Aa2 (sf); previously on May 27, 2003
Assigned Aaa (sf)

Cl. III-A-11, Downgraded to A1 (sf); previously on May 24, 2012
Confirmed at Aaa (sf)

Cl. III-A-12, Downgraded to A1 (sf); previously on May 24, 2012
Confirmed at Aaa (sf)

Cl. III-P, Downgraded to A1 (sf); previously on May 27, 2003
Assigned Aaa (sf)

Cl. C-B-1, Downgraded to B3 (sf); previously on May 6, 2011
Downgraded to Ba1 (sf)

Cl. C-B-2, Downgraded to C (sf); previously on May 6, 2011
Downgraded to Caa2 (sf)

Issuer: CSFB Mortgage-Backed Pass-Through Certificates, Series
2003-1

Cl. I-A-1, Downgraded to Aa2 (sf); previously on Feb 25, 2003
Assigned Aaa (sf)

Cl. I-X, Downgraded to B2 (sf); previously on May 24, 2012
Confirmed at Ba3 (sf)

Cl. I-P, Downgraded to Aa2 (sf); previously on Feb 25, 2003
Assigned Aaa (sf)

Cl. D-B-1, Downgraded to Baa1 (sf); previously on May 24, 2012
Downgraded to Aa3 (sf)

Cl. D-B-2, Downgraded to B2 (sf); previously on May 24, 2012
Confirmed at Ba1 (sf)

Cl. II-P, Downgraded to Aa2 (sf); previously on Feb 25, 2003
Assigned Aaa (sf)

Cl. A-X, Downgraded to B2 (sf); previously on May 24, 2012
Confirmed at Ba3 (sf)

Issuer: CSFB Mortgage-Backed Pass-Through Certificates, Series
2003-7

Cl. I-A-4, Downgraded to Aa2 (sf); previously on Mar 27, 2003
Assigned Aaa (sf)

Cl. I-A-25, Downgraded to A1 (sf); previously on Mar 27, 2003
Assigned Aaa (sf)

Cl. I-P, Downgraded to A1 (sf); previously on Mar 27, 2003
Assigned Aaa (sf)

Cl. I-A-28, Downgraded to Aa2 (sf); previously on Mar 27, 2003
Assigned Aaa (sf)

Cl. I-B-2, Downgraded to Baa1 (sf); previously on May 24, 2012
Downgraded to Aa2 (sf)

Cl. I-B-3, Downgraded to Ba3 (sf); previously on May 24, 2012
Downgraded to A3 (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 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 pools with fewer than 100 loans, Moody's
first estimates a "baseline" average rate of new delinquencies for
the pool that is set at 3% for Jumbo and which is typically higher
than the average rate of new delinquencies for larger pools. Once
the baseline rate is set, further adjustments are made based on 1)
the number of loans remaining in the pool and 2) the level of
current delinquencies in the pool. The fewer the number of loans
remaining in the pool, the higher the volatility in performance.
Once the loan count in a pool falls below 76, the rate of
delinquency is increased by 1% for every loan less than 76. For
example, for a pool with 75 loans, the adjusted rate of new
delinquency would be 3.03%. In addition, if current delinquency
levels in a small pool is low, future delinquencies are expected
to reflect this trend. To account for that, the rate calculated
above is multiplied by a factor ranging from 0.75 to 2.5 for
current delinquencies ranging from less than 2.5% to greater than
10% respectively. Delinquencies for subsequent years and ultimate
expected losses are projected using the approach described in the
methodology publication listed above.

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

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF306486

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


CSFB MORTGAGE 2004-CF1: Moody's Cuts Rating on Cl. B Certs to 'C'
-----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of Class M-1
and Class B from CSFB Mortgage Pass-Through Certificates, Series
2004-CF1, backed by Scratch and Dent Loans.

Ratings Rationale

The action is a result of the recent performance review of Scratch
and Dent pools and reflect Moody's updated loss expectations on
this pool. The downgrades are primarily due to deteriorating
collateral performance.

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 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 Pass-Through Certificates, Series 2004-CF1

Cl. M-1, Downgraded to B1 (sf); previously on May 19, 2011
Downgraded to Ba1 (sf)

Cl. B, Downgraded to C (sf); previously on Mar 30, 2009 Downgraded
to Ca (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF307880

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


GALAXY IV CLO: S&P Raises Rating on 2 Note Classes From 'BB-'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, D fixed, and D floating-rate notes from Galaxy IV CLO Ltd.
and removed them from CreditWatch, where S&P placed them with
positive implications in August 2012. "At the same time, we
affirmed our ratings on the class A-1, A-1VB, and A-2 notes.
Galaxy IV CLO Ltd. is a collateralized loan obligation (CLO)
transaction that is managed by PineBridge Investments LLC," S&P
said.

"The transaction entered its amortization phase in April 2011. As
a result of paydowns and improved portfolio performance, we
upgraded all seven classes in January 2012. Since then, the
transaction has paid down an additional $118 million to the class
A-1, A-1VB, and A-2 notes on a pro rata basis. The upgrades
reflect these paydowns and the subsequent increase in
overcollateralization ratios," S&P said.

"As of the Oct. 4, 2012, trustee report, the transaction has
roughly $6.7 million of loans that mature- after the legal final
maturity of the transaction in April 2017. Exposure to these long-
dated assets subjects the transaction to potential market value
risk, as the manager may have to liquidate these securities when
the transaction matures in order to pay down the notes on their
final maturity date. The rating actions reflect this potentially
negative exposure," S&P said.

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

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

RATINGS AFFIRMED

Galaxy IV CLO Ltd.
Class               Rating
A-1                 AAA (sf)
A-1VB               AAA (sf)
A-2                 AAA (sf)


GALAXY VII CLO: S&P Affirms 'BB' Rating on Class E Notes
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, and C notes from Galaxy VII CLO Ltd., a
collateralized loan obligation (CLO) transaction managed by
PineBridge Investments LLC. "At the same time, we affirmed our
ratings on the class C and D notes," S&P said.

The upgrades reflect increased credit support to the notes at the
prior rating levels. The affirmations reflect the availability of
adequate credit support at their current rating levels.

"In December 2010, we upgraded the class B, C, D, and E notes, and
affirmed the ratings on the class A-1 and A-2 notes. Since then,
the percentage of higher-rated assets has increased, resulting in
an improvement in the credit quality of the assets in the
underlying portfolio. For instance, the percentage of assets rated
'A-' and above had increased to about 3.0% as of the October 2012
trustee report, up from 0.4% as of the November 2010 trustee
report, which we used for our December 2010 analysis. Similarly,
the percentage of the collateral rated 'BBB-' and above was 6.4%
in October 2012, up from 2.1% in November 2010," S&P said.

"This improvement in the credit quality of the underlying assets,
coupled with a shortening of the weighted average maturity of the
underlying asset pool, has reduced the scenario default rates
(SDRs) of the portfolio," S&P said.

"In addition, the weighted average spread (WAS) of the collateral
has increased since our last rating action. As per the monthly
trustee report as of October 2012, the WAS is 3.87%, up from 3.54%
in November 2010," S&P said.

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

RATING ACTIONS

Galaxy VII CLO Ltd.
                  Rating
Class         To          From
A-1           AAA (sf)    AA+ (sf)
A-2           AAA (sf)    AA+ (sf)
B             AA+ (sf)    AA (sf)
C             A+ (sf)     A (sf)

RATINGS AFFIRMED

Galaxy VII CLO Ltd.
Class         Rating
D             BBB (sf)
E             BB (sf)


GE CAPITAL 2007-C1: Moody's Cuts Ratings on 2 Cert. Classes to Ba1
------------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes,
affirmed nine classes and confirmed five classes of GE Capital
Commercial Mortgage Corporation Commercial Mortgage Pass-Through
Certificates, Series 2007-C1 as follows:

Cl. A-2, 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-AB, Affirmed at Aaa (sf); previously on Mar 9, 2011
Confirmed at Aaa (sf)

Cl. A-4, Downgraded to A1 (sf); previously on Aug 23, 2012 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. A-1A, Downgraded to A1 (sf); previously on Aug 23, 2012 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. A-M, Downgraded to Ba1 (sf); previously on Aug 23, 2012 Baa1
(sf) Placed Under Review for Possible Downgrade

Cl. A-MFL, Downgraded to Ba1 (sf); previously on Aug 23, 2012 Baa1
(sf) Placed Under Review for Possible Downgrade

Cl. A-J, Confirmed at Caa1 (sf); previously on Aug 23, 2012 Caa1
(sf) Placed Under Review for Possible Downgrade

Cl. A-JFL, Confirmed at Caa1 (sf); previously on Aug 23, 2012 Caa1
(sf) Placed Under Review for Possible Downgrade

Cl. B, Confirmed at Caa2 (sf); previously on Aug 23, 2012 Caa2
(sf) Placed Under Review for Possible Downgrade

Cl. C, Confirmed at Caa3 (sf); previously on Aug 23, 2012 Caa3
(sf) Placed Under Review for Possible Downgrade

Cl. D, Affirmed at C (sf); previously on Aug 23, 2012 Downgraded
to C (sf)

Cl. E, Affirmed at C (sf); previously on Aug 23, 2012 Downgraded
to C (sf)

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

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

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

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

Cl. X-C, Confirmed at B1 (sf); previously on Aug 23, 2012 B1 (sf)
Placed Under Review for Possible Downgrade

Cl. X-P, Downgraded to A1 (sf); previously on Aug 23, 2012 Aa3
(sf) Placed Under Review for Possible Downgrade

Ratings Rationale

On August 23, 2012, Moody's placed ten classes on review for
possible downgrade in order to further evaluate the ongoing risk
of future interest shortfalls and the timing and severity of
losses from the largest specially serviced loan in the pool, the
Skyline Portfolio Loan. While there is still a significant amount
of uncertainty concerning the loan at this point in time is does
not look like the expected resolution strategy will lead to a
large spike in recurring interest shortfalls. This action
concludes Moody's review.

The downgrades are due to higher than expected realized and
anticipated losses from specially serviced and troubled loans. The
affirmations and confirmations 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 and confirmed are
sufficient to maintain their ratings.

The downgrades of the interest only Class XP is due to the decline
in credit quality of its referenced classes.

The rating of the interest only Class XC is consistent with the
credit performance of its referenced classes and thus is
confirmed.

Moody's rating action reflects a base expected loss of 14.5% of
the current balance compared to 14.3% at last review. Due to an
increase in realized losses, base expected loss plus realized
losses increased from 14.8% of the outstanding balance at last
review to 15.6% at this 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 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 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 32 compared to 35 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 September 15, 2011.

DEAL PERFORMANCE

As of the November 13, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 26% to $2.99
billion from $3.95 billion at securitization. The Certificates are
collateralized by 161 mortgage loans ranging in size from less
than 1% to 8% of the pool. The pool does not include any defeased
loans or loans with credit assessments.

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

Twenty-nine loans have been liquidated from the pool since
securitization, resulting in an aggregate $185.3 million loss (27%
loss severity on average). Currently 28 loans, representing 21% of
the pool, are in special servicing. The largest specially serviced
loan is the Skyline Portfolio Loan ($203.4 million -- 6.8% of the
pool), which represents a 30% pari passu interest in a $678.0
million first mortgage loan with the other pieces securitized in
JPMCC 2007-LDP10 and BACM 2007-1. The loan is secured by eight
cross-collateralized and cross-defaulted office properties
totaling 2.6 million square feet (SF) which are located outside of
Washington, DC in Falls Church, Virginia. At securitization, over
55% of the net rentable area (NRA) was leased by the General
Services Administration (GSA). The GSA has been vacating its space
as leases expire. The portfolio was 62% leased as of November
2012. The portfolio was appraised at $296.6 million as of July
2012 compared to $872 million at securitization. The special
servicer is in discussions with the borrower regarding a possible
loan modification. The loan sponsor is Vornado Realty Trust
(Senior Unsecured Rating Baa2, Stable Outlook). The servicer has
recognized a $126 million appraisal reduction for this loan.

The second largest specially serviced loans in the Galleria
Officentre Loan ($85.6 million - 2.9% of the pool). The loan is
secured by four class A office buildings located in Southfield,
Michigan. The loan transferred to special servicing in August 2011
due to imminent default as the result of cash flow problems. The
loan matured in April 2012 and the borrower was unable to pay off
the loan at maturity. The servicer has received a preliminary
restructuring proposal and it is under review. As of January 2012,
the property was 66% occupied.

The remaining specially serviced properties are secured by a mix
of property types. Moody's estimates an aggregate $310.2 million
loss for the specially serviced loans (50% expected loss on
average).

Moody's has assumed a high default probability for 15 poorly
performing loans representing 8% of the pool and has estimated an
aggregate $84.6 million loss (36% expected loss based on a 62%
probability default) from these troubled loans.

Moody's was provided with full year 2011 and partial year 2012
operating results for 97% and 78% of the performing pool
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 118% compared to 115% at last full
review. Moody's net cash flow reflects a weighted average haircut
of 8.4% 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 1.65X and 1.03X, respectively, compared to
1.42X and 0.88X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing loans represent 22% of the pool. The
largest loan is the 666 Fifth Avenue A-note Loan Pool Loan ($225.4
million --7.5% of the pool), which represents a 20.5% pari-passu
interest in a $1.21 billion first mortgage loan (original loan
prior to loan modification). The loan is secured by a 1.5 million
SF Class A office building located in Midtown Manhattan, New York.
The property was 77% leased as of December 2011 compared to 86% at
year-end 2009 and 98% at securitization. The loan transferred to
special servicing in March 2010 due to imminent monetary default.
The borrower requested a loan modification after the borrower
exhausted its $100 million reserve. In December 2011, the borrower
and special servicer successfully executed a modification. Terms
of the modification include a bifurcation of the original loan
into a $1.15 billion A-Note and $115 million B-Note, interest
reduction on the A-Note, $110 million equity infusion that is
senior in payment priority to the B-Note, and an extension of the
maturity date by two years. Based on the new structure, the
interest rate reduction has created interest shortfalls in the
amount of $629,000 per month in 2012 and will create approximately
$441,000 in interest shortfalls per month in 2013. The loan
returned to the master servicer in March 2012 and is performing
under the modified terms. Moody's LTV and stressed DSCR for the
modified A note are 137% and 0.67X, respectively compared to 167%
and 0.52X at last review.

The second largest loan is the Wolfchase Galleria Loan ($225
million -- 7.5% of the pool), which is secured by the borrower's
interest in a 1.3 million SF enclosed regional mall located in
Memphis, Tennessee. The loan sponsor is Simon Property Group, Inc.
The mall is anchored by Macy's, Dillard's, Sears and J.C. Penney,
none of which are part of the loan collateral. The property was
98% leased as of December 2011, up from 90% at last review.
Moody's LTV and stressed DSCR are 135% and 0.66X, respectively,
compared to 139% and 0.64X at last review.

The third largest loan is the JP Morgan Portfolio Loan ($198.5
million -- 6.6% of the pool), which is secured by a 732,922 SF
office building and a 1,900 space parking garage located in
Phoenix, Arizona and a 429,000 SF office building located in
Houston, Texas. The loan sponsor is Vornado Realty Trust who has a
payment guaranty on the loan through March 2015. The loan is
current and the properties are 100% leased to JP Morgan through
March 31, 2021. The loan is interest-only throughout the term.
Moody's LTV and stressed DSCR are 130% and 0.73X, respectively,
compared to 125% and 0.76X at last review.


GS COMMERCIAL 2012-GCJ9: Moody's Rates Class F Certs. '(P)B2'
-------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to
twelve classes of CMBS securities, issued by GS Commercial
Mortgage Trust 2012-GCJ9, Commercial Mortgage Pass-Through
Certificates, Series 2012-GCJ9.

Cl. A-1, Assigned (P)Aaa (sf)

Cl. A-2, Assigned (P)Aaa (sf)

Cl. A-3, Assigned (P)Aaa (sf)

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

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

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

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

Cl. B, Assigned (P)Aa3 (sf)

Cl. C, Assigned (P)A3 (sf)

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

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

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

Ratings Rationale

The Certificates are collateralized by 74 fixed rate loans secured
by 135 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 1.57X is greater than the 2007
conduit/fusion transaction average of 1.31X. The Moody's Stressed
DSCR of 1.03X is greater than the 2007 conduit/fusion transaction
average of 0.92X.

Moody's Trust LTV ratio of 101.8% is lower than the 2007
conduit/fusion transaction average of 110.6%. Moody's Total LTV
ratio (inclusive of subordinated, mezzanine and debt-like
preferred equity financing) of 105.6% is also considered when
analyzing various stress scenarios for the rated debt.

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 2.10, which is lower
than the indices calculated in most multi-borrower transactions
since 2009. The low weighted average grade is indicative of the
strong market composition of the pool and the stability of the
cash flows underlying the assets.

The pool's small market percentage is 22.8%, which is in line than
other multi-borrower deals rated by Moody's since the financial
crisis and implies that the assets in the pool are generally in
major markets. Properties situated in major markets tend to
exhibit more cash flow and capitalization rate stability over time
compared to assets located in smaller or tertiary markets.

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
24.3. 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 29.2. 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-S to mitigate the potential increased
severity to class A-S.

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

Moody's analysis employs the excel-based CMBS Conduit Model v2.61
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 ver1.0, which references
the following inputs to calculate the proposed IO rating based on
the published methodology: original and current bond ratings and
credit estimates; original and current bond balances grossed up
for losses for all bonds the IO(s) reference(s) within the
transaction; and IO type corresponding to an IO type as defined in
the published methodology.

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

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

Moody's Parameter Sensitivities: If Moody's value of the
collateral used in determining the initial rating were decreased
by 5%, 14%, and 22%, 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, Aa2, and Aa3, 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.


GS MORTGAGE 2004-GG2: Moody's Cuts Rating on Class H Certs. to 'C'
------------------------------------------------------------------
Moody's Investors Service downgraded the ratings of five classes
and affirmed nine classes of GS Mortgage Securities Corp. II,
Commercial Mortgage Pass-Through Certificates, Series 2004-GG2:

Cl. A-5, Affirmed at Aaa (sf); previously on Mar 9, 2011 Confirmed
at Aaa (sf)

Cl. A-6, Affirmed at Aaa (sf); previously on Mar 9, 2011 Confirmed
at Aaa (sf)

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

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

Cl. C, Affirmed at A1 (sf); previously on Dec 9, 2010 Downgraded
to A1 (sf)

Cl. D, Downgraded to Baa3 (sf); previously on Dec 9, 2010
Downgraded to Baa2 (sf)

Cl. E, Downgraded to Ba2 (sf); previously on Dec 9, 2010
Downgraded to Ba1 (sf)

Cl. F, Downgraded to B3 (sf); previously on Nov 17, 2011
Downgraded to B2 (sf)

Cl. G, Downgraded to Caa3 (sf); previously on Nov 17, 2011
Downgraded to Caa2 (sf)

Cl. H, Downgraded to C (sf); previously on Nov 17, 2011 Downgraded
to Ca (sf)

Cl. J, Affirmed at C (sf); previously on Nov 17, 2011 Downgraded
to C (sf)

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

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

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

Ratings Rationale

The downgrades are due to higher than expected realized and
anticipated losses from specially serviced and troubled loans as
well as increased interest shortfalls.

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 its
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, X-1, is consistent with the credit
performance of its referenced classes and thus is affirmed.

Moody's rating action reflects a base expected loss of 4.9% of the
current balance compared to 5.7% at last review. However, base
expected losses plus realized losses is 5.8% compared to 5.3% at
last review. Moody's provides a current list of base expected
losses for conduit and fusion CMBS transactions on moodys.com at
http://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 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 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 assessment 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 28, 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 17, 2011.

DEAL PERFORMANCE

As of the October 17, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 32% to $1.78
billion from $2.6 billion at securitization. The Certificates are
collateralized by 108 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten loans representing 41%
of the pool. There are two loans with investment-grade credit
assessments, representing approximately 15% of the pool. There are
nine fully defeased loans, representing 18% of the pool, that are
securitized by U.S. Government securities.

Twenty-nine loans are on the master servicer's watchlist,
representing approximately 13% of the pool. 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.

Fourteen loans have been liquidated since securitization,
generating a loss of $64.7 million (56% average loss severity).
Currently, there are seven loans in special servicing,
representing approximately 5% of the pool balance. The largest
specially serviced loan is the University Mall Loan ($35.4 million
-- 1.7% of the pool), which is secured by a 560,000 square foot
(SF) mall located in Carbondale, Illinois. The loan was
transferred to special servicing in July 2008 due to imminent
default and became REO in September 2010. As of October 2012, the
property was 63% leased. To date, the master servicer recognized a
$21.5 million appraisal reduction for this loan. The remaining
specially serviced loans are a mix of retail, industrial and
office properties. Moody's estimate an aggregate loss of $34.8
million (43% expected loss) from the specially serviced loans.

Moody's has assumed a high default probability for eight poorly
performing loans representing 5% of the pool and has estimated a
$24.7 million loss (28% expected loss based on a 65% probability
default) from these troubled loan.

Based on the most recent remittance statement, Classes F through P
have experienced cumulative interest shortfalls totaling $14.4
million. At last review, interest shortfalls totaled $8.4 million.
Moody's anticipates that the pool will continue to experience
interest shortfalls because of the exposure to specially serviced
loans. Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, appraisal subordinate
entitlement reductions (ASERs), extraordinary trust expenses and
loan modifications.

Excluding defeased loans and specially serviced loans, Moody's was
provided with full year 2011 and partial year 2012 operating
results for 99% and 88% of the pool. Excluding defeased and
troubled loans, Moody's weighted average conduit LTV is 92%
compared to 93% at Moody's prior. Moody's net cash flow (NCF)
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 9.6%.

Excluding defeased and troubled loans, Moody's actual and stressed
conduit DSCRs are 1.38X and 1.20X, respectively, compared to 1.42X
and 1.20X at last review. Moody's actual DSCR is based on Moody's
net cash flow 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 Daily News
Building Loan ($135.1 million -- 7.6% of the pool), which is
secured by a 1.1 million SF office building located on 42nd Street
between Second and Third Avenue in New York City. The property is
also encumbered by a $56.0 million B-note held outside the trust.
As of June 2012, the property was 94% leased compared to 90% at
last review. The largest tenants are Omnicom Group (45% of the net
rentable area (NRA); lease expiration in April 2017) and WPIX Inc
(9.2% of the NRA; lease expiration in December 2020). Several
entities related to the United Nations occupy approximately 15% of
the NRA with various lease expiration dates. The property's in-
place average rent is approximately $40 per square foot. Per CBRE
Economic Advisors, the Grand Central sub-market base rent and
vacancy rate are $60 per square foot and 6%. The loan has
amoritized 11% since securitization and matures in November 2013.
The sponsor is SL Green. Moody's credit assessment and stressed
DSCR are Baa1 and 1.70X, respectively, essentially the same as at
last review.

The second loan with a credit assessment is the Garden State Plaza
Loan ($130 million -- 6.3% of the pool), which represents a 25%
pari-passu interest in a $520 million first mortgage. The loan is
secured by the borrower's interest in a 2.0 million SF super-
regional mall located in Paramus, New Jersey. The mall is anchored
by Macy's, Nordstrom, J.C. Penney, Neiman Marcus and Lord &
Taylor. A $62 million expansion that added 150,000 SF to the
collateral was completed in early 2007. As of December 2011, the
property was 97% leased, which is the essentially the same as at
last review. Property performance has improved slightly since last
review. The loan sponsors are Westfield America Inc. and
affiliates of Prudential Assurance Co. Ltd. Moody's credit
assessment and stressed DSCR are Aa3 and 1.58X, respectively,
compared to Aa3 and 1.52X at last review.

The top three conduit loans represent 13% of the pool balance. The
largest conduit loan is the Stony Point Fashion Park Loan ($102.0
million -- 5.7% of the pool), which is secured by the borrower's
interest in a 665,000 SF regional mall located in Richmond,
Virginia. The collateral for the loan is approximately 383,000 SF.
The mall is anchored by Dillard's, Dick's Sporting Goods, and Saks
Fifth Ave. As of November 2012, the in-line space was 90% leased
compared to 84% at last review. The loan is current, but is on the
watchlist for low DSCR. The loan has amortized 11% since
securitization. Moody's LTV and stressed DSCR are 124% and 0.76X,
respectively, compared to 125% and 0.76X last review.

The second largest loan is the Destin Commons Loan ($74.2 million
-- 4.2% of the pool), which is secured by a 480,000 SF regional
shopping center located in Destin, Florida. The shopping center is
anchored by Belk Resort Store, Rave Motion Pictures, and Bass Pro
Shops. As of July 2012, the property was 100% leased, the same as
at last review. Performance remains stable and the loan has
amortized 12% since securitization. Moody's LTV and stressed DSCR
are 88% and 1.11X, respectively, compared to 90% and 1.08X at last
review.

The third largest loan is the Mall at Barnes Crossing Loan ($59.9
million -- 3.4% of the pool), which is secured by a 584,000 SF
regional mall located in Tupelo, Mississippi. The property is
shadow anchored by a 100,000 SF Belk's, which is not part of the
collateral. As of July 2012, the property was 96% leased,
essentially the same as at last review. Performance remains stable
and loan is has amortized approximately 12% since securitization.
Moody's LTV and stressed DSCR are 99% and 1.03X, respectively,
compared to 100% and 1.03X at last review.


GSRPM MORTGAGE 2007-1: Moody's Cuts Class A Cert. Rating to 'Caa3'
------------------------------------------------------------------
Moody's Investors Service has downgraded the rating of Class A
from GSRPM Mortgage Pass-Through Certificates, Series 2007-1,
backed by Scratch and Dent Loans.

Ratings Rationale

The action is a result of the recent performance review of Scratch
and Dent pools and reflect Moody's updated loss expectations on
this pool. The downgrade is primarily due to deteriorating
collateral performance.

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 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: GSRPM Mortgage Loan Trust 2007-1

Cl. A, Downgraded to Caa3 (sf); previously on May 4, 2009
Downgraded to Caa1 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF307881

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


HALCYON LOAN 2012-2: S&P Gives Prelim 'BB' Rating on Class E Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Halcyon Loan Advisors Funding 2012-2 Ltd./Halcyon Loan
Advisors Funding 2012-2 LLC's $406.5 million floating-rate notes.

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

The preliminary ratings are based on information as of Nov. 20,
2012. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

"The preliminary ratings reflect our view of," S&P said:

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

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

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

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

    The collateral manager's experienced management team.

    "Our projections regarding the timely interest and ultimate
    principal payments on the preliminary rated notes, which we
    assessed using our cash flow analysis and assumptions
    commensurate with the assigned preliminary ratings under
    various interest-rate scenarios," 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

PRELIMINARY RATINGS ASSIGNED
Halcyon Loan Advisors Funding 2012-2 Ltd./Halcyon Loan Advisors
Funding 2012-2 LLC

Class                           Rating                Amount
                                                     (mil. $)
X                               AAA (sf)                3.00
A                               AAA (sf)              278.00
B (deferrable)                  AA (sf)                39.50
C (deferrable)                  A (sf)                 38.25
D (deferrable)                  BBB (sf)               19.50
E (deferrable)                  BB (sf)                18.25
Subordinated notes              NR                     43.50
Combination notes (deferrable)(i)      A-p (sf)(NRi)(ii)
10.00

(i) The combination notes comprise components representing an
    aggregate initial principal amount of $5 million of class C
    notes and $5 million of class D notes.

(ii)The 'p' subscript indicates that the rating addresses only the
    principal portion of the obligation. 'NRi' indicates that the
    interest is not rated.

NR - Not rated.


HARTFORD MEZZANINE: Moody's Raises Rating on Cl. G Notes to 'B1'
----------------------------------------------------------------
Moody's has upgraded the ratings of seven classes of Notes issued
by Hartford Mezzanine Investors -- CRE CDO 2007-1, Ltd. due to
rapid amortization and greater than expected recoveries on the
underlying collateral as well as improvement in the credit quality
of the underlying collateral as evidenced by the weighted average
rating factor (WARF) and the weighted average recovery rate (WARR)
since last review. The affirmations are due to the key transaction
parameters performing within levels commensurate with the existing
ratings levels. The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation (CRE CDO CLO) transactions.

Moody's rating action is as follows:

Cl. A-3, Upgraded to Aaa (sf); previously on Dec 9, 2010
Downgraded to A2 (sf)

Cl. B, Upgraded to A2 (sf); previously on Dec 9, 2010 Downgraded
to Baa2 (sf)

Cl. C, Upgraded to Baa1 (sf); previously on Dec 9, 2010 Downgraded
to Ba1 (sf)

Cl. D, Upgraded to Baa2 (sf); previously on Dec 9, 2010 Downgraded
to Ba2 (sf)

Cl. E, Upgraded to Baa3 (sf); previously on Dec 9, 2010 Downgraded
to Ba3 (sf)

Cl. F, Upgraded to Ba3 (sf); previously on Dec 9, 2010 Downgraded
to B3 (sf)

Cl. G, Upgraded to B1 (sf); previously on Dec 9, 2010 Downgraded
to Caa1 (sf)

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

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

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

Ratings Rationale

Hartford Mezzanine Investors I -- CRE CDO 2007-1, Ltd. is a
currently static (the reinvestment period ended in August 2012)
cash transaction backed by a portfolio of a-notes and whole loans
(68.6% of the pool balance), mezzanine loans (22.1%), b-notes
(4.9%), and commercial mortgage backed securities (CMBS) (4.4%).
As of the October 23, 2012 Trustee report, the aggregate Note
balance of the transaction, including preferred shares, has
decreased to $262.3 million from $500.0 million at issuance, with
the paydown currently directed to the Class A-3 Notes, as a result
of amortization and pay-offs to the underlying collateral. The
Class A-1 and Class A-2 Notes are fully paid-off.

There are two assets with a par balance of $17.4 million (7.7% of
the current pool balance) that are considered defaulted securities
as of the October 23, 2012 Trustee report. While there have been
limited realized losses on the underlying collateral to date,
Moody's does expect 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: 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. Moody's modeled a bottom-dollar WARF of 4,829
compared to 6,871 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Ba1-Ba3 (4.4% compared to 0.0% at last
review), B1-B3 (49.9% compared to 17.7% at last review), and Caa1-
C (45.7% compared to 82.3% at last review).

Moody's modeled a WAL of 5.2 years compared to 5.8 years at last
review. The current modeled WAL incorporates updated assumptions
about extensions on the loan collateral.

Moody's modeled a fixed WARR of 37.2% compared to 31.2% at last
review.

Moody's modeled a MAC of 30.1% compared to 99.9% 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. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
37.2% to 27.2% or up to 47.2% would result in a modeled rating
movement on the rated tranches of 0 to 7 notches downward and 0 to
8 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.


INTEGRAL FUNDING: Moody's Raises Rating on Cl. D Notes to 'Ba3'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Integral Funding Ltd.:

U.S. 72,000,000 Class B Deferrable Floating Rate Notes Due
September 27, 2017, Upgraded to Aaa (sf); previously on September
22, 2011 Upgraded to A1 (sf);

U.S. 42,000,000 Class C Deferrable Floating Rate Notes Due
September 27, 2017, Upgraded to A1 (sf); previously on September
22, 2011 Upgraded to Ba1 (sf);

U.S. 46,000,000 Class D Deferrable Floating Rate Notes Due
September 27, 2017, Upgraded to Ba3 (sf); previously on September
22, 2011 Upgraded to B3 (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 in full, by approximately $145
million since the last rating action. In addition, the Class A-2
Notes have paid down by approximately 62% or $142.9 million since
the last rating action. Based on the latest trustee report dated
October 3, 2012, the Class A, Class B, and Class C
overcollateralization ratios are reported at 193.6%, 142.9%, and
124.0% respectively, versus the August 2011 levels of 145.2%,
124.5%, 115.0%, respectively. Moody's notes that the trustee
reported overcollateralization ratios as of October 3, 2012 do not
reflect the distributions made on the October 15 payment date. In
addition to the deleveraging and increased collateral coverage,
the Weighted Average Spread ("WAS") has increased to 3.44% from
2.99% based on the same trustee reports.

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 Moody's analysis, securities
that mature after the maturity date of the notes currently make up
approximately 5.37% 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, weighted average spread, 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 $322 million, defaulted par of $28.5 million,
a weighted average default probability of 16.14% (implying a WARF
of 2726), a weighted average recovery rate upon default of 49.44%,
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.

Integral Funding Ltd, issued in September 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% (2181)

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

Moody's Adjusted WARF + 20% (3271)

Class A-2: 0
Class A-3: 0
Class B: 0
Class C: -3
Class D: -2

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

Sources of additional performance uncertainties are described
below

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

2) Recovery of defaulted assets: Market value fluctuations in
defaulted assets reported by the trustee and those assumed to be
defaulted by Moody's may create volatility in the deal's
overcollateralization levels. Further, the timing of recoveries
and the manager's decision to work out versus sell defaulted
assets create additional uncertainties. 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) Weighted average life: The notes' ratings are sensitive to the
weighted average life assumption of the portfolio, which may be
extended due to the manager's decision to reinvest into new issue
loans or other loans with longer maturities and/or participate in
amend-to-extend offerings.


JP MORGAN 2002-C3: Moody's Cuts Rating on Cl. F Certs. to 'Caa2'
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of four classes and
downgraded six classes of J.P. Morgan Chase Commercial Mortgage
Securities Corp., Commercial Mortgage Pass-Through Certificates,
Series 2002-C3. The downgraded classes were placed on review for
possible downgrade. The rating action is as follows:

Cl. A-2, Affirmed at Aaa (sf); previously on Mar 9, 2011 Confirmed
at Aaa (sf)

Cl. B, Downgraded to Aa3 (sf) and Placed Under Review for Possible
Downgrade; previously on Mar 9, 2011 Confirmed at Aaa (sf)

Cl. C, Downgraded to A2 (sf) and Placed Under Review for Possible
Downgrade; previously on Mar 9, 2011 Confirmed at Aaa (sf)

Cl. D, Downgraded to B1 (sf) and Placed Under Review for Possible
Downgrade; previously on Nov 10, 2011 Downgraded to Ba1 (sf)

Cl. E, Downgraded to B3 (sf) and Placed Under Review for Possible
Downgrade; previously on Nov 10, 2011 Downgraded to B1 (sf)

Cl. F, Downgraded to Caa2 (sf) and Placed Under Review for
Possible Downgrade; previously on Nov 10, 2011 Downgraded to Caa1
(sf)

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

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

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

Cl. X-1, Downgraded to B3 (sf) and Placed Under Review for
Possible Downgrade; 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 its current base expected loss, the
credit enhancement levels for the affirmed classes are sufficient
to maintain their current ratings.

The downgrades of the principal classes are primarily due to
increased interest shortfalls. Due to the uncertainty regarding
the continuing level of interest shortfalls, Moody's has placed
the downgraded classes on review for possible downgrade. Moody's
expects interest shortfalls to rise further in the capital stack,
and for shortfalls to have more than a temporary impact on several
tranches in the deal in advance of expected paydowns from maturing
loans.

The rating of the IO Class, Class X-1, is downgraded to reflect
the deterioration in credit performance for its referenced
classes. This class is also on review for possible downgrade.

Moody's rating action reflects a base expected loss of
approximately $34.6 million or 16% of the current deal balance
compared to $33.2 million or 6% at last review. The increase in
base expected loss on a percentage basis since last review is
largely due to the signifant paydown of the pool since last review
(58%). 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, "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 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 its analysis. Based on the model
pooled credit enhancement levels at Aa2 (sf) and B2 (sf), the
remaining conduit classes are either interpolated between these
two data points or determined based on a multiple or ratio of
either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade underlying ratings is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit 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 16 compared to a Herf of 31 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 November 10, 2011.

DEAL PERFORMANCE

As of the October 12, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 71% to $216 million
from $745 million at securitization. The Certificates are
collateralized by 38 mortgage loans ranging in size from less than
1% to 8% of the pool, with the top ten loans (excluding
defeasance) representing 36% of the pool. There are no loans with
investment-grade credit assessments. Ten loans, representing
approximately 44% of the pool, are defeased and are collateralized
by U.S. Government securities.

Nineteen loans, representing 30% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of 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 liquidated from the pool, resulting in an
aggregate realized loss of $45 million (56% average loan loss
severity). Currently, five loans, representing 22% of the pool,
are in special servicing. The largest specially serviced loan is
the 78 Corporate Center Loan ($17 million -- 8% of the pool). The
loan is secured by a 185,000 square foot, two-building office
complex located in Lebanon, New Jersey, approximately 50 miles
west of New York City. The loan transferred to special servicing
in January 2009 due to delinquency. The servicer assumed title in
a deed-in-lieu of foreclosure transaction in August 2009 and the
property is now real estate owned (REO). The property was 23%
leased in September 2012 and has remained near that level of
occupancy for more than one year, despite efforts to lease up the
property.

The remaining four specially serviced loans are secured by a mix
of office and multifamily property types. Moody's estimates an
aggregate $32 million loss (67% expected loss on average) for all
specially serviced loans.

Excluding specially serviced and defeased loans, Moody's was
provided with full-year 2011 and partial year 2012 operating
results for 96% and 87% of the performing pool, respectively.
Excluding specially serviced loans, Moody's weighted average LTV
is 73% compared to 77% at last full review. Moody's net cash flow
reflects a weighted average haircut of 10.6% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 9.6%.

Excluding specially serviced loans, Moody's actual and stressed
DSCRs are 1.49X and 1.53X, respectively, compared to 1.42X and
1.43X 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 9% of the pool.
The largest loan is the Lakeside Center Loan ($8 million -- 4% of
the pool), which is secured by an 81,000 square foot office
property located in Columbia, Maryland. The loan is on the master
servicer's watchlist for upcoming ARD maturity. Property
performance has improved steadily. Moody's current LTV and
stressed DSCR are 67% and 1.62X, respectively, compared to 69% and
1.58X at last review.

The second largest loan is the Acuity Financial Center Loan ($7
million -- 3% of the pool), which is secured by a 56,000 square
foot office property located in Las Vegas, Nevada. The loan is on
the master servicer's watchlist for upcoming ARD maturity. The
property was 99% leased as of March 2012 reporting, up from 95% in
December 2010. Moody's current LTV and stressed DSCR are 81% and
1.33X, respectively, compared to 89% and 1.21X at last review.

The third largest loan is the Two Paragon Centre Loan ($5 million
-- 2% of the pool). The loan is secured by a 49,000 square foot
office property located in Ridgeland, Mississippi, a suburb of
Jackson. The property was 98% leased in December 2011. The largest
tenant is the Bomgar Corporation, which occupies approximately 53%
of the property NRA through March 2015. Property performance has
been stable. Moody's current LTV and stressed DSCR are 68% and,
1.60X respectively, compared to 65% and 1.67X at last review.


JP MORGAN 2007-1: Fitch Cuts Ratings on 2 Debt Classes
------------------------------------------------------
Fitch Ratings has downgraded two classes from the pooled portion
of J.P. Morgan Chase Commercial Mortgage Securities Corp. Series
2007-1.

The downgrade of class A-2 to 'A' from 'AA' is based on interest
shortfalls affecting the class.  According to Fitch's criteria,
ratings at 'AAA' and 'AA' should not incur interest shortfalls.
The interest shortfalls began in October 2012, primarily due to
the claw back of interest advances to the Resort International
loan.  Class K has been downgraded to 'D' from 'C' as a result of
incurred losses.  The Negative Rating Outlooks reflect the
possibility of further negative credit migration of the underlying
collateral.

Fitch affirmed the remainder of the pooled transaction and the
non-pooled junior component certificates were also affirmed based
on Fitch's loss expectations on the Resorts International loan.
Fitch's performance expectation incorporates prospective views
regarding commercial real estate values and cash flow declines.

The rating action reflects Fitch's base case loss expectation of
11.5%. Under Fitch's updated analysis, 100% of the pooled and non-
pooled components are modeled to default in the base case stress
scenario, defined as the 'B' stress.  Fitch estimates that average
recoveries on the pooled loans will be approximately 88.5% in the
base case.  In its review, Fitch analyzed servicer reported
operating statements, STR reports and rent rolls, updated property
valuations, and recent lease and sales comparisons.

As of the November 2012 distribution report, the transaction is
collateralized by eight loans, including six that are secured by
hotels (75.3%), one by casino (18.7%), and one by office (6%).
All eight loans are currently in special servicing, including two
(24.5%) real estate owned (REO) assets, four (57.7%) in
delinquency and two (17.8%) in forbearance.

All eight remaining loans have been identified as Fitch Loans of
Concern. Fitch's analysis resulted in loss expectations for three
A-notes, and each of the B-note non-pooled components in the 'B'
stress scenario.  The three pooled contributors to losses in the
'B' stress scenario are: PHOV Portfolio (19.3%), Resorts
International (13.5%) and Sofitel Minneapolis (2.8%).

The PHOV Portfolio loan is secured by 11 full-service hotels
(following the previous release of the Hilton Rockville), located
in FL, CA, SC, IL and NJ.  Flags include Hilton, Doubletree,
Courtyard by Marriott, Sheraton and two non-flagged hotels.  The
loan was transferred to special servicing in January 2012 due to
imminent maturity default.  The loan has passed its final maturity
date in May 2012 and the special servicer is working with the
borrower for a loan modification.

Four of the 11 properties were severely impacted by Hurricane
Katrina and Wilma in 2005, with the hotels coming back on line in
late 2006 and mid 2007.  While year-end (YE) 2011 net operating
income improved significantly over YE 2010 and YE 2009, it remains
below issuance expectations.  For YE 2011, the revenue per
available room (RevPAR) was $80.26, compared to $74.3 at YE 2010,
$67.58 at YE 2009 and $87.58 at issuance.

The Resorts International loan was originally collateralized by
four casino/hotel properties located in Atlantic City, NJ, East
Chicago, IN, Robinsonville, MS and Tunica, MS.  The Resorts East
Chicago property was released from the portfolio in September
2007, paying down the senior trust component by approximately 47%.
The loan was foreclosed in November 2011 and the Atlantic City
Hilton property was released to the borrower due to negative
property value.  The remaining two properties became REO assets.
The loan secures two additional non-trust pari passu A notes of
$32.4 million each, an $87.7 million non-pooled senior
participation included in the transaction and a $233 million
junior participation held outside the trust.  The current
appraisal value obtained by the special servicer indicated losses
upon liquidation of the assets.

The Sofitel Minneapolis loan is secured by a 282 room Sofitel
Hotel in Bloomington, MN.  The loan transferred to the special
servicer in February 2012 due to payment default.  The loan
matured in July 2012. Borrower indicated that occupancy is
insufficient to meet debt obligation.  The borrower reported
September 2012 trailing 12 month (TTM) occupancy, ADR and RevPar
are 65.2%, $113.22, and $73.85, respectively.  The special
servicer is pursuing foreclosure and the appointment of a
receiver.  The current appraisal value obtained by the special
servicer indicated losses upon liquidation of the assets.

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

  -- $243.1 million class A-2 to 'Asf' from 'AAsf'; Outlook to
     Negative from Stable;
  -- $15 million class K to 'Dsf' from 'Csf'; RE0%.

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

  -- $111.8 million class A-1 at 'AAAsf'; Outlook Stable;
  -- $45.4 million class B at 'Asf'; Outlook to Negative from
     Stable;
  -- $32.4 million class C at 'Asf'; Outlook Negative;
  -- $30.8 million class D at 'BBBsf'; Outlook Negative;
  -- $37.3 million class E at 'Bsf'; Outlook Negative
  -- $26 million class F at 'CCCsf'; RE100%';
  -- $26 million class G at 'CCsf'; RE40%;
  -- $35.7 million class H at 'Csf'; RE0%;
--$32.5 million class J at 'Csf'; RE0%;
--$0 million class L at 'Dsf'; RE0%;
--$11.9 million class RS-1 at 'Csf'; RE0%;
--$12.8 million class RS-2 at 'Csf'; RE0%;
--$15.6 million class RS-3 at 'Csf'; RE0%;
--$11.1 million class RS-4 at 'Csf'; RE0%;
--$15.4 million class RS-5 at 'Csf'; RE0%;
--$13.2 million class RS-6 at 'Csf'; RE0%;
--$7.6 million class RS-7 at 'Csf'; RE0%.

The interest-only class X-1 has paid in full. Fitch withdrew its
rating on the interest-only class X-2 at prior review.


JP MORGAN 2007-LDP10: Moody's Cuts Ratings on 2 Cert. Classes to C
------------------------------------------------------------------
Moody's Investors Service downgraded the ratings of 13 classes,
affirmed 14 classes and confirmed one class of J.P. Morgan
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2007-LDP10 as follows:

Cl. A-2, Affirmed at Aaa (sf); previously on Apr 10, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-2S, Affirmed at Aaa (sf); previously on Apr 10, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-2SFL, Affirmed at Aaa (sf); previously on Apr 10, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-2SFX, Affirmed at Aaa (sf); previously on Aug 3, 2010
Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Apr 10, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3S, Affirmed at Aaa (sf); previously on Apr 10, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Apr 10, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Downgraded to Baa2 (sf); previously on Aug 23, 2012 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-MS, Downgraded to Baa2 (sf); previously on Aug 23, 2012 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-J, Downgraded to Caa1 (sf); previously on Aug 23, 2012 B1
(sf) Placed Under Review for Possible Downgrade

Cl. A-JFL, Downgraded to Caa1 (sf); previously on Aug 23, 2012 B1
(sf) Placed Under Review for Possible Downgrade

Cl. A-JS, Downgraded to Caa1 (sf); previously on Aug 23, 2012 B1
(sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to Caa2 (sf); previously on Jan 20, 2012
Downgraded to Caa1 (sf)

Cl. B-S, Downgraded to Caa2 (sf); previously on Jan 20, 2012
Downgraded to Caa1 (sf)

Cl. C, Downgraded to Caa3 (sf); previously on Feb 16, 2011
Downgraded to Caa2 (sf)

Cl. C-S, Downgraded to Caa3 (sf); previously on Feb 16, 2011
Downgraded to Caa2 (sf)

Cl. D, Downgraded to Ca (sf); previously on Feb 16, 2011
Downgraded to Caa3 (sf)

Cl. D-S, Downgraded to Ca (sf); previously on Feb 16, 2011
Downgraded to Caa3 (sf)

Cl. E, Downgraded to C (sf); previously on Feb 16, 2011 Downgraded
to Ca (sf)

Cl. E-S, Downgraded to C (sf); previously on Feb 16, 2011
Downgraded to Ca (sf)

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

Cl. F-S, Affirmed at C (sf); previously on Feb 16, 2011 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Feb 25, 2010 Downgraded
to C (sf)

Cl. G-S, Affirmed at C (sf); previously on Feb 25, 2010 Downgraded
to C (sf)

Cl. H, Affirmed at C (sf); previously on Feb 25, 2010 Downgraded
to C (sf)

Cl. H-S, Affirmed at C (sf); previously on Feb 25, 2010 Downgraded
to C (sf)

Cl. J, Affirmed at C (sf); previously on Feb 25, 2010 Downgraded
to C (sf)

Cl. X, Confirmed at Ba3 (sf); previously on Aug 23, 2012 Ba3 (sf)
Placed Under Review for Possible Downgrade

Ratings Rationale

On August 23, 2012 Moody's placed six classes on review for
possible downgrade in order to further evaluate the ongoing risk
of future interest shortfalls and the timing and severity of
losses from the two largest specially serviced loans in the pool
-- the Skyline Portfolio Loan and the Solana Loan. While there is
still a significant amount of uncertainty concerning the ultimate
resolution two loans, at this point in time is does not appear
that the expected resolution strategy will lead to a large spike
in recurring interest shortfalls. This action concludes Moody's
review.

The downgrades are due to an increase in expected losses from
specially serviced and troubled loans.

The affirmations of the 14 principal bonds 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 confirmed.

Moody's rating action reflects a base expected loss of 13.0% of
the current pooled balance compared to 11.1% at Moody's last full
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, 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 48 compared to 54 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 full
transaction review is summarized in a press release dated January
20, 2012.

Deal Performance

As of the October 15, 2012 distribution date, the transaction's
aggregate pooled certificate balance has decreased by 15% to $4.55
billion from $5.33 billion at securitization. The Certificates are
collateralized by 190 mortgage loans ranging in size from less
than 1% to 5% of the pool, with the top ten loans representing 37%
of the pool. The pool does not contain any defeased loans. One
loan, representing 2% of the pool, has an investment grade credit
assessment.

Forty-seven loans, representing 26% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of 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 at a loss,
resulting in an aggregate realized loss of $134 million (34%
average loss severity). Cumulative realized losses have increase
by $93M since last review. Thirty-six loans, representing 18% of
the pool, are currently in special servicing. The largest
specially serviced loan is the Skyline Portfolio Loan ($203
million -- 4.5% of the pool), which represents a 30% pari passu
interest in a $678 million first mortgage loan with the other
pieces securitized in GECMC 2007-C1 and BACM 2007-1. The loan is
secured by eight cross-collateralized and cross-defaulted office
properties totaling 2.6 million square feet (SF) which are located
outside of Washington, DC in Falls Church, Virginia. At
securitization, over 55% of the net rentable area (NRA) was leased
by the General Services Administration (GSA). The GSA has been
vacating its space as leases expire. The portfolio was 62% leased
as of November 2012. The portfolio was appraised at $296.6 million
as of July 2012 compared to $872 million at securitization. The
special servicer is in discussions with the borrower regarding a
possible loan modification. The loan sponsor is Vornado Realty
Trust (Senior Unsecured Rating Baa2, Stable Outlook). The servicer
has recognized a $126 million appraisal reduction for this loan.

The second largest specially serviced loan is the Solana Loan
($140 million --3.1% of the pool), which represents a 39% pari
passu interest in a $360 million first mortgage loan. The loan is
secured by a 1.9 million SF mixed use complex consisting of
office, retail and a 198-room full service hotel located in
Westlake, Texas. The non-hotel component is 67% leased, down from
84% in December 2011 as a result of the lease expiration and
departure of a major tenant (Sabre, 20% of NRA). Loan modification
discussions commenced, but there is no firm modification proposal
being discussed at this time. The servicer is dual tracking
foreclosure and a modification. A receiver was appointed in
November 2011 and 133,000 SF of new leases and renewals have been
executed since then. The servicer has recognized a $69 million
appraisal reduction for this loan.

The servicer has recognized an aggregate $376 million appraisal
reduction for 29 of the 36 specially serviced loans and one loan
on the servicer's watchlist. Moody's has estimated an aggregate
$347 million loss (49% average loss severity) for 33 of the 36
specially serviced loans.

Moody's has assumed a high default probability for 22 poorly
performing loans representing 17% of the pool and has estimated a
$122 million aggregate loss (17% 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 89% and 70% of the pool's loans,
respectively. Moody's weighted average conduit LTV is 123%, which
is the same as at Moody's prior review. The conduit portion of the
pool excludes specially serviced and troubled loans and the one
loan with a credit assessment. 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%.

Moody's actual and stressed conduit DSCRs are 1.27X and 0.85X,
respectively, compared to 1.31X and 0.85X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

Based on the most recent remittance statement, Classes C-S through
NR and Classes H through NR have experienced cumulative interest
shortfalls totaling $36 million. Moody's anticipates that the pool
will continue to experience interest shortfalls because of the
high exposure to specially serviced loans. Interest shortfalls are
caused by special servicing fees, including workout and
liquidation fees, appraisal subordinate entitlement reductions
(ASERs), extraordinary trust expenses, loan modifications that
include either an interest rate reduction or a non-accruing note
component, and non-recoverability determinations by the servicer
that involve a decision to stop making future advances as well as
the potential clawback of previously made advances.

The loan with a credit assessment is the Center West Loan ($90
million -- 2.0% of the pool), which is secured by a 345,000 SF
office property located in Los Angeles, California. The property
was 68% leased as of December 2011 compared to 67% as of December
2010. Twenty-six percent of the leases expire by December 2013.
The loan sponsor appears to be selective in his leasing efforts.
Consequently, the property commands premium rents relative to the
CBRE Econometric Advisors submarket average of $32.10 PSF, but
also has a higher vacancy than the submarket average of 12.7%.
Moody's current credit assessment and stressed DSCR are Baa3 and
1.28X, respectively, essentially the same as at last full review.

The top three performing conduit loans represent 14% of the pool
balance. The largest loan is the Coconut Point Loan ($230 million
-- 5.1% of the pool), which is secured by a 835,000 SF retail
center located near Fort Meyers in Estero, Florida. The collateral
consists of three retail components: a cinema-anchored village, a
community center primarily consisting of big box retail, and a
lakefront component comprising of casual restaurants. The
collateral was 95% leased as of June 2012, which is the same as at
last review. The in-line space is 87% leased. Moody's LTV and
stressed DSCR are 128% and 0.72X, respectively, which is the same
as at last full review.

The second largest loan is the 599 Lexington Loan ($225 million -
4.5% of the pool), which is secured by a 1.0 million SF office
building located in Midtown Manhattan in New York City. The loan
represents a 30% pari-passu interest in a $750 million loan. The
property was 98% leased as of June 2012, compared to 96% at last
full review. The largest tenant is Shearman & Sterling LLP, which
leases 45% of the NRA through 2022. Only 1% of the leases expire
in 2012-13. Despite the increase in occupancy, performance
declined slightly due to increased expenses. Moody's LTV and
stressed DSCR are 133% and 0.69X, respectively, compared to 129%
and 0.71X at last full review.

The third largest loan is the Lafayette Property Trust Portfolio
Loan ($203 million -- 4.5% of the pool), which is secured by nine
cross defaulted and cross collateralized office properties
containing 840,000 SF located in Alexandria, Virginia. The
portfolio contains one property that is only 53% leased. However,
portfolio occupancy is 83%, which compares favorably to CBRE
Econometric Advisor's submarket average of 76%. Moody's LTV and
stressed DSCR are 123% and 0.84X, respectively, compared to 122%
and 0.85X at last full review.


L2L EDUCATION 2006-1: S&P Affirms 'B+' Rating on Class C Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on the
notes issued by L2L Education Loan Trust 2006-1, an asset-backed
securities (ABS) transaction backed by private student loans.

"The affirmations reflect our view of the collateral's performance
trends, the current available remaining credit enhancement, the
current collateral characteristics, and our revised expected base-
case cumulative lifetime gross defaults and net losses for the
trust. tHE rating actions also reflect our views of the future
collateral performance, as well as the trust's structure, payment
priority and our cashflow modeling assumptions and results," S&P
said.

                     COLLATERAL AND CREDIT RISK

These private credit student loans were originated under EduCap
Inc.'s "loan to learn" student loan program underwriting
guidelines and are not guaranteed or reinsured by the federal
government.

At issuance, the pool characteristics were:

-- 87.4% of the loans were cosigned.

-- The weighted average FICO score for the entire pool was 739.
    13.5% of the loans were made to borrowers or coborrowers with
    FICO scores of less than 680 but with minimum FICO scores of
    640.

-- 37.7% of the loans were made to borrowers or coborrowers with
    FICO scores that were greater than 760.

-- None of the loans were originated through the school channel
    (the schools' financial aid office was not involved in the
    loan origination process).

-- 99.7% of the loans were in repayment status while the
    remaining 0.3% was in forbearance.

S&P has typically observed that loans with comparable loan and
obligor characteristics may perform:

    Cosigned loans are more likely to perform better than non-
    cosigned loans.

    Obligors with higher FICO scores are likely to perform better
    than obligors with lower FICO scores.

    Obligors with demonstrated payment behaviors are less likely
    to exhibit early payment default post securitization than
    obligors whose loans have not entered repayment.

    Loans that are originated through a school channel are less
    likely to be the result of fraudulent applications than loans
    that are directly originated to consumers.

    Loans that receive predefault special servicing (servicing
    efforts aimed at educating the borrower and co-borrower of
    their repayment obligations and contacting them early in the
    repayment cycle) are more likely to perform better than loans
    that do not receive predefault special servicing.

                        POOL PERFORMANCE

"As part of our analytical review and in accordance with our
student loan criteria, we compare a transaction's remaining credit
enhancement with our projection of remaining net losses by
reviewing a trust's collateral performance and the current pool
collateral characteristics, including but not limited to, gross
cumulative defaults and levels of forbearance, deferments, and
delinquencies. Based on our analysis, we believe the current
remaining credit enhancement for series 2006-1 is commensurate
with the current ratings," S&P said.

"We also believe the trust will benefit from increasing recoveries
from loans that were charged off but subsequently became current
and are now performing. The trust charges off defaulted
receivables 119 days past the original due date of the loan
payment. The issuer has indicated that some of the defaulted
loans became current after they were charged off. The issuer
believes that the trust's charge-off policy, which is tighter than
the industry standard of 179 days past due, has caused loans to be
charged off before the servicer can successfully reach borrowers
and their respective cosigners," S&P said.

"Although total parity (the total asset balance including the
reserve account over the total balance of notes outstanding)
remains approximately 250 basis points (bps) below the starting
parity of 99.6% at issuance (at 97.12 as of September 2012), the
stabilizing trend of defaults and increasing recoveries helped to
improve total parity by 145 bps during the last 12 months," S&P
said.

          DEFAULT EXPECTATIONS AND NET LOSS PROJECTIONS

"Based on our view of the current and projected performance of
this trust, we revised our base-case lifetime cumulative defaults
to between 25% and 27% (of the original pool balance from our
previous expected base case of 23%-25%. Although the rate of
acceleration of the cumulative defaults has been decreasing since
our last review, we believe based on the current monthly rate of
defaults and size of the remaining pool balance that the
cumulative defaults will be greater than our previous assumption.
We maintained our future stressed recovery rates assumption of
approximately 25%-30%, depending on the rating scenario, of the
dollar amount of cumulative defaults, which results in our
expectation for remaining cumulative net losses of 7.25%-11.00%
of the current principal balance," S&P said.

Table 1
Projections
Projected lifetime cumulative defaults %(i)               25-27
Recovery assumption (%)                                   25-30
Projected remaining cumulative net loss %(ii)         7.25-11.0

(i)  As a percent of the initial principal balance plus prefunding
     account.

(ii) As a percent of current principal balance including accrued
     interest to be capitalized.

                       PAYMENT STRUCTURE

"All of the notes were offered as floating-rate notes at a spread
over one-month LIBOR. Given the underlying student loans are
indexed to the prime rate, all notes are exposed to basis risk. To
address this risk, the trust entered into a basis risk swap
agreement with HSBC Bank USA N.A.('AA-/A-1+') in which the trust
pays prime rate to HSBC and HSBC pays one-month LIBOR plus
2.74125% to the trust. Currently, our rating on HSBC is
commensurate or higher than the ratings on the series 2006-1
notes. We would review the notes if we downgraded HSBC below the
ratings on the notes," S&P said.

"The 2006-1 transaction employs a senior-subordinate structure
whereby the class A, B, and C notes each benefit from the
subordination provided by its lower-rated classes and
overcollateralization, if any. The initial overcollateralization
was 0% and is required under the transaction documents to build to
a target of the greater of 2.00% of the current loan balance and
1.00% of the initial (plus prefunded) loan balance if cumulative
realized losses on the trust's student loans exceed certain
thresholds. The trust also benefits from a fully funded non-
amortizing 0.60% reserve account," S&P said.

"The transaction had a five-year lockout period during which time
principal was paid sequentially to the class A, B, and C notes.
After the  lockout (the step-down date in December 2011), the
principal payments  switched to pro rata as long as cumulative
realized losses on the underlying student loans did not exceed
certain specified limits (see table 2) and the total priority
principal distribution amount was equal to or less than zero
(i.e., the sum of all the classes of notes is equal to or less
than the loan balance plus prefunding amount). The principal
payment priority  will switch back to sequential whenever the
cumulative realized losses exceed such limits or the total
priority principal distribution amount is greater than zero. As of
the Sept. 30, 2012, reporting period, the transactions cumulative
realized losses are below the limits in table 2, however the
structure continues paying sequentially as the total priority
principal distribution amount always has been greater than zero,"
S&P said.

Table 2
Cumulative Realized Loss Test
Period
                                                  % of initial
                                                  Pool balance
Closing through May 2009 distribution date                  10
June 2009 dist. date through Nov 2011 dist. date            15
Dec 2011 through Nov. 2014 distribution date                18
Dec 2014 distribution date and thereafter                   20

"In addition, the transaction pays principal sequentially within
the subclasses of the class A notes, provided that if the class A
notes become undercollateralized (i.e., class A parity falls below
100%), the class A notes outstanding would be paid pro rata (based
on their outstanding balances) until their principal balances have
been reduced to zero or the class A notes become collateralized
again," S&P said.

"Each class of notes has a required credit enhancement target.
When class A reaches its overcollateralization target (15% of the
current loan balance), the class B notes can begin to receive
principal; when class A and B reach their targets (3% of the
current loan balance), the class C notes can begin to receive
principal. Once these credit enhancement targets are reached,
principal payments will be made from the remaining available funds
in reverse order to the class C, B, and A notes. As of Sept. 30,
2012, the overcollateralization targets have not been met," S&P
said.

"The transaction employs a subordinate interest reprioritization
structure. Generally, if any class' parity falls below 100%, then
the transaction will make the necessary principal payments to the
most senior class to restore parity to 100% before making any
interest payments due to the next lower rated class. The funds
that would otherwise be available to pay subordinate note interest
could be allocated to pay principal to the most senior class of
notes. The trust has the ability to use any upcoming period
collections to pay the current period's interest and priority
principal distribution payments ('next period borrowings')," S&P
said.

"Principal payable to the notes will generally be equal to the
excess of the note balance over the total assets plus the amount
sufficient to first reach and then maintain the required
overcollateralization. The excess spread, if any, will be used to
reach overcollateralization targets for each class," S&P said.

             BREAK-EVEN CASH FLOW MODELING ASSUMPTIONS

S&P ran break-even cash flows under various interest rate
scenarios and rating stress assumptions. These cash flow runs
provided break-even percentages (break-evens) that represent the
projected maximum amount of remaining cumulative net losses a
transaction can absorb (as a percent of the pool balance as of the
cash flow cutoff date) before failing to pay full and timely
interest and ultimate principal. These are some of the major
assumptions S&P modeled as the loans enter repayment:

    Straight-line default curves that covered a period of four
    years;

    Recovery rates of 25%-30% depending on the rating scenario;
    Prepayment speeds starting at approximately 3 CPR (constant
    prepayment rate, an annualized prepayment speed stated as a
    percentage of the current loan balance) and ramping up 1% per
    year to a maximum rate of 5-8 CPR, depending on the rating
    scenario. "We held the applicable maximum rate constant for
    the remaining life of the deal," S&P said; and

    S&P assumed that next period drawings would be drawn anytime
    that available funds cannot pay items 1 through 9 in the
    waterfall.

       BREAK-EVEN CASH FLOW MODELING RESULTS AND RATING ACTIONS

"Based on our cash flow runs, which consider the collateral pool
balance as of the July 30, 2012, cutoff date, the class A through
class C notes are projected to be able to absorb remaining
cumulative net losses as noted in table 3 below before
experiencing a payment default. Based on the break-evens, per the
cash flow runs, and the remaining expected net losses of 7.25%-
11.00% (based on the current pool balance), we affirmed our
ratings on all three classes of notes to reflect our view of the
current loss coverage levels," S&P said.

Table 3
Class    Approximate            Affirmed rating
         remaining              based on current
         BE CNLs*               loss coverage levels
A        24.75% - 26.00%        AA- (sf)
B        17.75% - 19.50%        BBB (sf)
C        13.00% - 13.50%        B+ (sf)

* Based on the current pool balance.
CNL - Cumulative net losses.

"Standard & Poor's will continue to monitor the performance of the
student loan receivables backing this transaction relative to our
revised cumulative default expectations and our assessment of the
credit enhancement available to each class," S&P said.

              STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

          http://standardandpoorsdisclosure-17g7.com

RATINGS AFFIRMED

L2L Education Loan Trust 2006-1
Class     Rating
A-2        AA- (sf
A-3        AA- (sf
B          BBB (sf
C          B+ (sf)



LEGG MASON CDO I: S&P Cuts Rating on Class G to 'CCC-'; Off Watch
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on seven
classes from Legg Mason Real Estate CDO I Ltd. (Legg Mason I CRE
CDO), a commercial real estate collateralized debt obligation (CRE
CDO) transaction, and removed them from CreditWatch with negative
implications. "At the same time, we affirmed our ratings on two
additional classes from the same transaction and removed them from
CreditWatch with negative implications," S&P said.

"The downgrades and affirmations reflect our analysis of the
transaction's liability structure and the credit characteristics
of the underlying collateral using our criteria for rating global
CDOs backed by pooled structured finance (SF) assets. We also
considered the amount of defaulted assets in the transaction and
their expected recoveries in our analysis," S&P said.

"Our CDO of SF criteria include revisions to our assumptions on
correlations, recovery rates, and default patterns and timings of
the collateral. Specifically, correlations on commercial real
estate assets increased to 70%. The criteria also include
supplemental stress tests (largest obligor default test and
largest industry default test) in our analysis," S&P said.

"According to the Oct. 25, 2012, trustee report, the transaction's
collateral totaled $485.6 million, and the transaction's
liabilities totaled $481.4 million, which is down from $525
million at issuance. The transaction's current asset pool
included," S&P said:

    27 whole and senior-participation loans ($430.6 million,
    88.7%);
    Three subordinate-interest loans ($34.2 million, 7.0%); and
    Four commercial mortgage-backed securities (CMBS) tranches
    ($20.9 million, 4.3%).

The trustee report noted three defaulted loans ($42.7 million,
8.8%):

    The 200 Building senior interest loan ($19.6 million, 4.0%);
    The Taylor's Crossing senior interest loan ($15.2 million,
    3.1%); and
    The Hamilton senior interest loan ($7.9 million, 1.6%).

In addition, Standard & Poor's determined one loan, the Tradewinds
senior interest loan ($18.0 million, 3.7%) to be credit impaired.

"Standard & Poor's estimated a 68.7% weighted average asset-
specific recovery rate for the defaulted and credit impaired
loans. We based the recovery rates on information from the
collateral manager, special servicer, and third-party data
providers," S&P said.

"We applied asset specific recovery rates in our analysis of the
26 performing loans ($404.0 million, 83.2%) using our criteria and
property evaluation methodology for U.S. and Canadian CMBS and our
CMBS global property evaluation methodology, both published Sept.
5, 2012. We also considered qualitative factors such as the near-
term maturities of the loans, refinancing prospects, and loans
modifications," S&P said.

According to the Oct. 25, 2012, trustee report, the deal is
passing all overcollateralization coverage tests and interest
coverage tests.

"In addition, our analysis considers the prior cancellations of
subordinate notes. According to the Nov. 25, 2011, trustee report,
as well as a notice from the trustee, Wells Fargo Bank N.A.,
certain subordinate notes were cancelled before they were repaid
through the transaction's payment waterfall. Our ratings reflect
our assessment of any risks and credit stability considerations
regarding the subordinate note cancellations," 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 it determines necessary.

              STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED AND REMOVED FROM CREDITWATCH

Legg Mason Real Estate CDO I Ltd.
                  Rating
Class     To                   From
A2        B- (sf)              BB+ (sf)/Watch Neg
B         CCC+ (sf)            BB+ (sf)/Watch Neg
C         CCC+ (sf)            BB (sf)/Watch Neg
D         CCC+ (sf)            B+ (sf)/Watch Neg
E         CCC+ (sf)            B (sf)/Watch Neg
F1        CCC (sf)             B- (sf)/Watch Neg
G         CCC- (sf)            CCC+ (sf)/Watch Neg

RATINGS AFFIRMED AND REMOVED FROM CREDITWATCH

Legg Mason Real Estate CDO I Ltd.
                  Rating
Class     To                   From
A-R       BBB+ (sf)            BBB+ (sf)/Watch Neg
A-1T      BBB+ (sf)            BBB+ (sf)/Watch Neg


LEGG MASON CDO II: S&P Lowers Ratings on 2 Debt Classes to 'CCC-'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes from Legg Mason Real Estate CDO II Corp. (Legg Mason II
CRE CDO), a commercial real estate collateralized debt obligation
(CRE CDO) transaction, and removed them from CreditWatch with
negative implications.

"The downgrades reflect our analysis of the transaction's
liability structure and the credit characteristics of the
underlying collateral using our criteria for rating global CDOs
backed by pooled structured finance (SF) assets. We also
considered the amount of defaulted assets in the transaction and
their expected recoveries in our analysis," S&P said.

"Our CDO of SF criteria include revisions to our assumptions on
correlations, recovery rates, and default patterns and timings of
the collateral. Specifically, correlations on commercial real
estate assets increased to 70%. The criteria also include
supplemental stress tests (largest obligor default test and
largest industry default test) in our analysis," S&P said.

"According to the Oct. 25, 2012, trustee report, the transaction's
collateral totaled $527.0 million, and the transaction's
liabilities totaled $503.9 million, which is down from $525
million at issuance. The transaction's current asset pool
included," S&P said:

    36 whole and senior-participation loans ($415.8 million,
    78.9%);
    Two subordinate-interest loans ($25.2 million, 4.8%);
    Five commercial mortgage-backed securities (CMBS) tranches
    ($59.6 million, 11.3%); and
    Five CRE CDO securities ($26.4 million, 5.0%).

The trustee report noted eight defaulted loans ($85.4 million,
16.2%):

    The JPMorgan Portfolio subordinate interest loan
    ($15.6 million, 2.0%)
    The Bella Vista senior interest loan ($14.6 million, 2.8%);
    The Sun Terrace Independent Living senior interest loan ($13.0
    million, 2.5%);
    The Oakwood senior interest loan ($10.7 million, 2.0%);
    The Hamilton senior interest loan ($8.6 million, 1.6%);
    The Huntington Ridge Apartments senior interest loan ($8.5
    million, 1.6%);
    The Fairway Estates senior interest loan ($8.2 million, 1.6%);
    and
    The Time Square senior interest loan ($6.2 million, 1.2%).

"Standard & Poor's estimated a 43.2% weighted average asset-
specific recovery rate for the defaulted loans. We based the
recovery rates on information from the collateral manager, special
servicer, and third-party data providers," S&P said.

"We applied asset specific recovery rates in our analysis of the
30 performing loans ($355.6 million, 67.5%) using our criteria and
property evaluation methodology for U.S. and Canadian CMBS and our
CMBS global property evaluation methodology, both published Sept.
5, 2012. We also considered qualitative factors such as the near-
term maturities of the loans, refinancing prospects, and loans
modifications," S&P said.

According to the Oct. 25, 2012, trustee report, the deal is
passing all overcollateralization coverage tests and interest
coverage tests.

"In addition, our analysis considers the prior cancellations of
subordinate notes. According to the April 25, 2011, trustee
report, as well as a notice from the trustee, Wells Fargo Bank
N.A., certain subordinate notes were cancelled before they were
repaid through the transaction's payment waterfall. Our ratings
reflect our assessment of any risks and credit stability
considerations regarding the subordinate note cancellations," 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 determines necessary.

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

           http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED AND REMOVED FROM CREDITWATCH

Legg Mason Real Estate CDO II Corp.
                  Rating
Class     To                   From
A-1R      B+ (sf)              BBB+ (sf)/Watch Neg
A-1t      B+ (sf)              BBB+ (sf)/Watch Neg
A-2       B- (sf)              BB+ (sf)/Watch Neg
B         CCC+ (sf)            BB+ (sf)/Watch Neg
C         CCC- (sf)            B+ (sf)/Watch Neg
D         CCC- (sf)            B+ (sf)/Watch Neg


LEHMAN BROTHERS: Moody's Cuts Rating on Class X-2 CMBS to 'B3'
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of four classes,
upgraded four classes and downgraded one IO class of Lehman
Brothers Floating Rate Commercial Mortgage Trust 2007-LLF C5.

Moody's rating action is as follows:

Cl. C, Upgraded to Aaa (sf); previously on Jun 28, 2012 Upgraded
to A3 (sf)

Cl. D, Upgraded to Aa2 (sf); previously on Jun 28, 2012 Upgraded
to Baa2 (sf)

Cl. E, Upgraded to A1 (sf); previously on Jun 28, 2012 Upgraded to
Baa3 (sf)

Cl. F, Upgraded to Baa3 (sf); previously on Jun 28, 2012 Upgraded
to Ba2 (sf)

Cl. G, Affirmed at Ba3 (sf); previously on Jun 28, 2012 Upgraded
to Ba3 (sf)

Cl. H, Affirmed at B3 (sf); previously on Jun 28, 2012 Upgraded to
B3 (sf)

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

Cl. X-2, Downgraded to B3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

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

Ratings Rationale

The affirmations are due to key parameters, including Moody's loan
to value (LTV) ratio and Moody's stressed debt service coverage
ratio (DSCR) remaining within acceptable ranges. The upgrades are
due to loan payoffs and resulting build up of credit support. The
downgrade of one IO class is due to the decrease of the weighted
average rating factor of its referenced 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 CMBS Large Loan/Single Borrower Transactions" published in
July 2000, and "Moody's Approach to Rating Structured Finance
Interest-Only Securities" published in February 2012.

Moody's review incorporated the use of the excel-based Large Loan
Model v 8.5. 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. The model
incorporates 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
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 ratings are determined by a committee process that
considers both quantitative and qualitative factors. Therefore,
the rating outcome may differ from the model output.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(R) (Moody's Surveillance Trends) Reports and
Remittance Statements. On a periodic basis, Moody's also performs
a full transaction review that involves a rating committee and a
press release. Moody's prior transaction review is summarized in a
press release dated June 28, 2012.

Deal Performance

As of the November 15, 2012 Payment Date, the transaction's
aggregate certificate balance decreased by approximately 59% from
last review to approximately $294 million. The Certificates are
collateralized by eight floating rate whole loans and senior
interests in whole loans. The loans range in size from 6% to 36%
of the pooled balance, with the top three loans representing 64%
of the pooled balance. The trust Herfindahl Index is five.

Moody's weighted average pooled LTV ratio is 93% compared to 95%
at last review, and Moody's weighted average pooled stressed DSCR
is 1.12X compared to 1.07X at last review.

The largest loan in the pool is secured by fee interests in The
Normandy Office Portfolio Loan (36% of pooled balance plus $12.5
million rake bonds) that transferred to special servicing in
October 2011 due to imminent maturity default. According to the
special servicer (TriMont Real Estate Advisors) basic terms for a
loan modification have been agreed by all parties, and the
negotiations are under way. The portfolio is comprised of ten
class A/B office and industrial buildings totaling approximately
1.4 million square feet (SF) located in the greater Boston area
and northern New Jersey. As of the September 2012 rent roll, the
portfolio was 69% leased. For the trailing twelve month period
ending March 2012, the property achieved a NCF of $8.6 million up
from $7.7 million achieved in calendar year 2011. Moody's weighted
average LTV for the pooled portion is greater than 100%. Moody's
current credit assessment for the pooled portion is Caa3, the same
as last review. Moody's does not rate the three rake bonds
associated with this loan (NOP-1, NOP-2, NPO-3).

The second largest loan in the pool is secured by fee interests in
The Interstate Office Portfolio Loan (18% of pooled balance plus a
$2.8 million rake bond class INO ). A loan modification was
completed in April 2012, and the loan was returned to the master
servicer as a Corrected Loan in July 2012. The maturity date for
this loan was extended to October 2014 with principal pay down of
$3.5 million and reserves established. The collateral for the loan
consist of a 960,000 SF office park with 11 office buildings and
three development sites located outside of Atlanta, Georgia in
Cobb County. As of the March 2012 rent roll, the office portfolio
was 78% leased. Net cash flow for year-end 2011 was $6.0 million
and NCF for the first quarter 2012 was $1.7 million. Moody's
weighted average LTV for the pooled portion is 83%. Moody's
current credit assessment for the pooled portion is B2, the same
as last review.

The Park Hyatt Beaver Creek Loan (11% of pooled balance) is the
third largest loan in the pool. The loan modification was
completed in October 2012. The final maturity date for this loan
was extended to September 2013 with principal pay down of $2.0
million. As part of the modification, all of the mezzanine loan
($52 million) was retired. Net cash flow for year-end 2011 was
$1.4 million. For the first nine months of 2011, NCF was $1.6
million whereas NCF for the same period in 2012 was up to $2.6
million. Moody's weighted average LTV for the pooled portion is
80%. Moody's current credit assessment for the pooled portion is
B2 same as last review.

All the remaining loans in the pool are in special servicing, and
are at various stages of modification or negotiations. As of the
Novermber 2012 remittance report, the cumulated bond loss totals
$91,458 and interest shortfalls total $546,193 as of the current
distribution date. The majority of the bond losses affect pooled
Class J, and a rake bond class INO (B3). The interest shortfalls
affect pooled Class J, as well as rake bond classes INO (B3), NOP-
1(NR), NOP-2(NR), NOP-3(NR), and VIS (NR). There are no
outstanding advances.


MBIA INSURANCE: Moody's Lowers Ratings of 179 Securities
--------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 179
classes of US structured finance securities wrapped by MBIA
Insurance Corporation. The impacted securities are backed by first
or second lien-US residential mortgages, private student loans,
RMBS, CMBS and ABS.

A list of the Affected Credit Ratings is available at:

                        http://is.gd/RyBCJV

Ratings Rationale

This action is solely driven by Moody's announcement on
November 19, 2012 that it has downgraded the insurance financial
strength rating of MBIA Insurance Corporation to Caa2 from B3.

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".

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 downgrade of MBIA's rating and
is not a result of change in key assumptions, expected losses,
cash flows and stress scenarios on the underlying assets.


MERRILL LYNCH 2007-C1: Fitch Cuts Rating on 6 Cert. Classes
-----------------------------------------------------------
Fitch Ratings has downgraded six and affirmed 17 classes of
Merrill Lynch Mortgage Trust (MLMT), series 2007-C1 (MLMT 2007-
C1), commercial pass-through certificates.

The downgrades reflect both an increase in modeled losses on the
specially-serviced loans, as well as continued underperformance of
many of the larger loans not in special servicing since Fitch's
December 2011 rating action.  Fitch modeled losses of 21.8% of the
remaining pool; modeled losses are 21.2% of the original pool.

The Negative Outlooks on classes A-4 and A-M reflect the
possibility for further performance deterioration of the
underlying pool.  Fitch has designated 88 loans (55.1% of the pool
balance) as Fitch Loans of Concern, which includes 20 specially-
serviced loans (36.6%).  The Negative Outlook on the multifamily-
directed class A-1A reflects the possibility for continued
underperformance of the multifamily collateral in the pool.  The
multifamily collateral comprises 30.4% of the pool and includes
the two largest loans (21.6%) which are both in special servicing.
The loans have recently been modified into A/B notes.  Fitch
modeled the B-notes to be full losses.

As of the October 2012 distribution date, the pool's aggregate
principal balance has been reduced by approximately $746 million
(18.4%) to $3.304 billion from $4.050 billion at issuance; of
which $608 million (15%) were paydowns and $138 million (3.4%)
were realized losses.  No loans have defeased since issuance.
Interest shortfalls totaling $23.3 million are currently affecting
classes A-J through Q.

The largest two contributors to Fitch modeled losses are the
Empirian Portfolio Pool 1 (11.6% of the pool) and Pool 3 (10%)
loans.  Both loans were transferred to special servicing in
November 2010 due to payment default.  Pool 1 is secured by 78
multifamily properties (7,964 units) located across eight states.
Pool 3 is secured by 79 multifamily properties (6,864 units)
located across eight states.  The properties within the two
portfolios are generally class B and C complexes, many of which
were constructed in the 1980s and lack common amenities.  All of
the properties suffer significant deferred maintenance.

During the fourth quarter of 2011, both loans were modified and
bifurcated into an A and a B note. As of November, the occupancy
for Pool 1 and Pool 3 was 84.2% and 84.6%, respectively,
representing a decline from the 93% and 90.9% reported at
issuance.  Net-operating income (NOI) for the portfolios have
continued to decline as expected.  For the first 11 months of
2012, NOI has approximately declined by greater than 10% for Pool
1 and greater than 20% for Pool 3 when compared to year-end 2010.

The third largest contributor to Fitch modeled losses is a real
estate owned (REO) asset (3.5%) consisting of 566,908 square feet
(sf) of a 1.28 million sf regional mall located in Duluth, GA.
The loan was transferred to special servicing in October 2011 for
imminent payment default.  As of March 2012, occupancy was 52%,
down significantly from 81% at issuance.  The property is
currently being marketed for sale with other retail assets.  The
most recent appraisal value indicates significant losses upon
liquidation.

Fitch has downgraded the following classes:

  -- $405 million class A-M to 'B-sf' from 'BBsf'; Outlook
     Negative;
  -- $86.1 million class B to 'Csf' from 'CCCsf'; 'RE 0%';
  -- $40.5 million class C to 'Csf' from 'CCsf'; 'RE 0%';
  -- $45.6 million class D to 'Csf' from 'CCsf'; 'RE 0%';
  -- $45.6 million class E to 'Csf' from 'CCsf'; 'RE 0%';
  -- $50.6 million class F to 'Csf' from 'CCsf'; 'RE 0%'.

In addition, Fitch has affirmed and revised Rating Outlooks to the
following classes, as indicated:

  -- $1.14 billion class A-1A at 'AAAsf'; Outlook to Negative from
     Stable;
  -- $60.7 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $40.6 million class A-2FL at 'AAAsf'; Outlook Stable;
  -- $322.2 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $130 million class A-3FL at 'AAAsf'; Outlook Stable;
  -- $86.4 million class A-SB at 'AAAsf'; Outlook Stable;
  -- $442.2 million class A-4 at 'AAAsf'; Outlook Negative;
  -- $134.1 million class AJ at 'CCCsf'; RE 0%';
  -- $200 million class AJ-FL at 'CCCsf'; RE 0%';
  -- $40.5 million class G at 'Csf'; 'RE 0%';
  -- $29.4 million class H at 'Dsf'; 'RE 0%';
  -- $0 class J at 'Dsf'; 'RE 0%';
  -- $0 class K at 'Dsf'; 'RE 0%';
  -- $0 class L at 'Dsf'; 'RE 0%';
  -- $0 class M at 'Dsf'; 'RE 0%';
  -- $0 class N at 'Dsf'; 'RE 0%';
  -- $0 class P at 'Dsf'; 'RE 0%'.


MORGAN STANLEY 2005-IQ9: Fitch Cuts Rating on 2 Certs. to 'CCCsf'
-----------------------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed 16 classes
of Morgan Stanley Capital I Trust's commercial mortgage pass-
through certificates, series 2005-IQ9.

The downgrades of the junior classes reflect greater certainty of
losses.  Fitch modeled losses of 3.2% of the remaining pool;
expected losses on the original pool balance total 3.4%, including
losses already incurred.  The pool has experienced $14.2 million
(0.9% of the original pool balance) in realized losses to date.
Fitch has designated 67 loans (18.6%) as Fitch Loans of Concern,
which includes eight specially serviced assets (2.4%).

As of the October 2012 distribution date, the pool's aggregate
principal balance has been reduced by 22.8% to $1.18 billion from
$1.53 billion at issuance.  Per the servicer reporting, three
loans (1.5% of the pool) are defeased. Interest shortfalls are
currently affecting classes M through P.

The largest contributor to expected losses is the Okeechobee
Industrial Park loan (0.8% of the pool), which is secured by a
147,377 sf industrial facility consisting of 11 buildings located
in West Palm Beach, Florida.  The loan was transferred back to the
master servicer in January 2012.  The loan modification included
an interest rate reduction and interest-only payments through
maturity, among other terms.  As of June 2012, occupancy at the
property was 58%, down from 87.7% reported at issuance.

Fitch downgrades the following classes:

  -- $11.5 million class G to 'Bsf' from 'BBsf', Outlook Negative;
  -- $5.7 million class L to 'Csf' from 'CCsf', RE 0%;
  -- $5.7 million class M to 'Csf' from 'CCsf', RE 0%.

In addition, Fitch affirms the following classes as indicated:

  -- $217.8 million class A-1A at 'AAAsf', Outlook Stable;
  -- $121.2 million class A-3 at 'AAAsf', Outlook Stable;
  -- $94.4 million class A-4 at 'AAAsf', Outlook Stable;
  -- $11.2 million class A-AB at 'AAAsf', Outlook Stable;
  -- $446.2 million class A-5 at 'AAAsf', Outlook Stable;
  -- $130.2 million class A-J at 'AAsf', Outlook Stable;
  -- $32.6 million class B at 'Asf', Outlook Stable;
  -- $11.5 million class C at 'Asf', Outlook Stable;
  -- $26.8 million class D at 'BBB+sf', Outlook Negative;
  -- $15.3 million class E at 'BBBsf', Outlook Negative;
  -- $15.3 million class F at 'BBsf', Outlook Negative;
  -- $17.2 million class H at 'CCCsf', RE 100%;
  -- $5.7 million class J at 'CCCsf', RE 100%;
  -- $7.7 million class K at 'CC', RE 10%;
  -- $3.8 million class N at 'Csf', RE 0%;
  -- $3 million class O at 'Dsf', RE 0%.

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


NATIONAL COLLEGIATE: Moody's Reviews Ratings on 92 Tranches
-----------------------------------------------------------
Moody's Investors Service placed under review for downgrade the
ratings of 90 tranches and placed under review for upgrade the
ratings of two tranches in 15 National Collegiate student loan
trusts backed by private (i.e. not government guaranteed) student
loans. U.S. Bank, N.A. is the special servicer and Goal Structured
Solutions, a wholly owned subsidiary of Goal Financial, LLC, is
the administrator of all trusts.

The primary reason for the reviews for downgrade is performance
deterioration of the underlying student loan collateral.
Delinquencies and defaults on the loans originated through both
school financial aid offices and the direct-to-consumer (DTC)
channel that entered repayment after 2006 have been increasing.
Cumulative defaults during the first year of repayment on the
pools of loans that entered repayment in 2007 or later are almost
twice as high as cumulative defaults on the pools of loans that
entered repayment in 2006 or earlier. The negative performance of
the post-2006 repayment vintages affects primarily 2006 and 2007
securitizations, which include a large percentage of the post-2006
vintage loans. The 90+ delinquencies as a percentage of loans in
active repayment (i.e. not in school, grace, deferment or
forbearance) in the 2006 and 2007 securitizations is approximately
3%, a whole percent higher than the 90+ delinquencies in the pre-
2006 securitizations. Similarly, monthly defaults as a percentage
of loans in active repayment for 2006 and 2007 securitizations
have been above 0.75%, while monthly defaults in the pre-2006
securitizations have ranged between 0.25% and 0.5%.

The reviews for downgrade were also prompted by correction of the
static pool default information that the transaction sponsor,
First Marblehead Corporation, provided to Moody's. The information
that served as a basis for the May 2011 rating actions did not
include defaults on rehabilitated loans. The most recent
information correctly included rehabilitated loans and indicated
substantially higher cumulative defaults. Rehabilitated loans are
loans that have defaulted but subsequently returned to repayment
and repurchased by the trusts.

Finally, several tranches rated A3 and above were placed on review
for downgrade because Moody's is re-evaluating its view on the
tranches' senior position in the distribution of cash. Currently,
principal payments are made sequentially among all Class A notes.
However, upon an event of default the principal distribution among
the Class A notes will switch to pro-rata.

Moody's placed two classes of notes in the Master Trust on review
for possible upgrade due to the substantial pay down of the notes
and the resulting increase in credit enhancement supporting them.

The principal methodology used in National Collegiate Student Loan
Trust rating actions was "Moody's Approach to Rating U.S. Private
Student Loan-Backed Securities", published on 6 January 2010 and
available at www.moodys.com in the Rating Methodologies sub-
directory under the Research & Ratings tab. Other methodologies
and factors that may have been considered in the process of rating
this issue can also be found in the Rating Methodologies sub-
directory on Moody's website. In addition, Moody's publishes a
weekly summary of structured finance credit, ratings and
methodologies, available to all registered users of its website,
at www.moodys.com/SFQuickCheck.

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.

RATINGS

Complete actions are as follows:

Issuer: National Collegiate Student Loan Trust 2003-1 (The)

Cl. A-7, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Caa1 (sf)

Cl. IO, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Caa1 (sf)

Cl. B-1, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. B-2, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2004-1

Cl. A-2, A3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at A3 (sf)

Cl. A-3, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. A-4, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Caa3 (sf)

Cl. A-IO-2, Caa3 (sf) Remains On Review for Possible Downgrade;
previously on Sep 30, 2010 Downgraded to Caa3 (sf) and Remained On
Review for Possible Downgrade

Cl. B-1, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. B-2, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: The National Collegiate Student Loan Trust 2004-2

Cl. A-3, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 11, 2009 Downgraded to Aa1 (sf)

Cl. A-4, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at A1 (sf)

Cl. A-5-1, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa2 (sf)

Cl. A-IO, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa2 (sf)

Cl. B, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Caa1 (sf)

Cl. C, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2005-1

Cl. A-3, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 11, 2009 Downgraded to Aa1 (sf)

Cl. A-4, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at A1 (sf)

Cl. A-5-1, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. A-5-2, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. B, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Caa2 (sf)

Cl. C, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2005-2

Cl. A-3, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Aa1 (sf)

Cl. A-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa1 (sf)

Cl. A-5, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. B, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Caa3 (sf)

Cl. C, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-5-2, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Issuer: National Collegiate Student Loan Trust 2005-3

Cl. A-3, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 11, 2009 Downgraded to Aa1 (sf)

Cl. A-4, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at A1 (sf)

Cl. A-5-1, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. A-5-2, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. B, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Caa1 (sf)

Cl. C, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2006-1

Cl. A-3, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 11, 2009 Downgraded to Aa1 (sf)

Cl. A-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa1 (sf)

Cl. A-5, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. B, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Caa2 (sf)

Cl. C, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2006-2

Cl. A-2, Aa3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Aa3 (sf)

Cl. A-3, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa1 (sf)

Cl. A-4, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at B1 (sf)

Cl. B, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Caa2 (sf)

Cl. C, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2006-3

Cl. A-2, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 11, 2009 Downgraded to Aa1 (sf)

Cl. A-3, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 11, 2009 Downgraded to Aa1 (sf)

Cl. A-4, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa1 (sf)

Cl. A-5, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa2 (sf)

Cl. B, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba2 (sf)

Cl. C, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Caa2 (sf)

Cl. D, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2006-4

Cl. A-2, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at A1 (sf)

Cl. A-3, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa1 (sf)

Cl. A-4, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. B, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at B2 (sf)

Cl. C, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Ca (sf)

Cl. D, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2007-1

Cl. A-2, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at A1 (sf)

Cl. A-3, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa3 (sf)

Cl. A-4, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at B1 (sf)

Cl. B, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at B2 (sf)

Cl. C, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Ca (sf)

Cl. D, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2007-2

Cl. A-2, A1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at A1 (sf)

Cl. A-3, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Baa1 (sf)

Cl. A-4, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. B, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at B1 (sf)

Cl. C, Caa3 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Downgraded to Caa3 (sf)

Cl. D, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: National Collegiate Student Loan Trust 2007-3

Cl. A-3-L, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-2, Caa2 (sf) Placed Under Review for Possible
Downgrade; previously on Jun 16, 2011 Downgraded to Caa2 (sf)

Cl. A-3-AR-3, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-4, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-5, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-6, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-7, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl-A-IO, Ca (sf) Placed Under Review for Possible Downgrade;

Issuer: National Collegiate Student Loan Trust 2007-4

Cl. A-3-L, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-2, Caa3 (sf) Placed Under Review for Possible
Downgrade; previously on Jun 16, 2011 Downgraded to Caa3 (sf)

Cl. A-3-AR-3, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-4, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-5, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-6, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-3-AR-7, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Cl. A-IO, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ca (sf)

Issuer: The National Collegiate Master Student Loan Trust I (2001
Indenture)

NCT-2002-AR9, Ba1 (sf) Placed Under Review for Possible Upgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

NCT-2002-AR-10, Ba2 (sf) Placed Under Review for Possible Upgrade;
previously on Jun 16, 2011 Confirmed at Ba2 (sf)

NCT-2003AR-12, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 8, 2011 Downgraded to Ca (sf)

NCT-2003AR-13, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 8, 2011 Downgraded to Ca (sf)

NCT-2003AR-14, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 8, 2011 Downgraded to Ca (sf)

NCT-2005AR-15, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 8, 2011 Downgraded to Ca (sf)

NCT-2005AR-16, Ca (sf) Placed Under Review for Possible Downgrade;
previously on Apr 8, 2011 Downgraded to Ca (sf)


NOMURA ASSET 2007-S2: Moody's Hikes Rating on A Tranche From 'C'
----------------------------------------------------------------
Moody's Investors Service has upgraded the rating and placed under
review for possible downgrade one tranche from Nomura Asset
Acceptance Corporation, Alternative Loan Trust, Series 2007-S2.
The transaction is backed primarily by fixed-rate closed-end
second-lien mortgages.

Issuer: Nomura Asset Acceptance Corporation, Alternative Loan
Trust, Series 2007-S2

Cl. A, Upgraded to Aa3 (sf) and Placed Under Review for Possible
Downgrade; previously on Nov 8, 2012 Downgraded to C (sf)

Financial Guarantor: Assured Guaranty Municipal Corp (Aa3 placed
on review for possible downgrade on Mar 20, 2012)

Underlying Rating: Currently at C (sf); previously on Oct 28, 2010
Downgraded to C (sf)

Ratings Rationale

The rating on the Class A tranche benefits from a financial
guaranty insurance policy provided by Assured Guaranty Municipal
Corp. The action reflects that the certificate insurance was
previously novated to Assured Guaranty Municipal Corp. from
Syncora Guarantee Inc. Moody's Investors Service anticipates
resolving its review for downgrade of the Class A tranche once
action is taken on Assured Guaranty group ratings. Moody's
announced on October 30, 2012 that the Assured Guaranty group
review is expected to be completed during the first half of
November.

In deriving the final ratings, Moody's considered the updated pool
losses relative to the total credit enhancement available from
subordination, as well as excess spread and external enhancement
such as pool insurance policies, reserve accounts, and guarantees.
In addition, Moody's considered the volatility of the projected
losses and the timing of the expected defaults.

The methodologies used in this rating were "Moody's Approach to
Rating US Residential Mortgage-Backed Securities" published in
December 2008, and "Second Lien RMBS Loss Projection Methodology:
April 2010" published in April 2010.

For securities insured by a financial guarantor, the rating on the
securities is the higher of (i) the guarantor's financial strength
rating and (ii) the current underlying rating (i.e., absent
consideration of the guaranty) on the security. The principal
methodology used in determining the underlying rating is the same
methodology for rating securities that do not have a financial
guaranty and is as described earlier.

The primary 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 8.9% in October 2011 to 7.9 % in October 2012.
Moody's forecasts a unemployment central range of 7.5% to 8.5% for
the 2013 year. Moody's expects housing prices to remain stable
through the remainder of 2012 before gradually rising towards the
end of 2013. Performance of RMBS continues to remain highly
dependent on servicer activity such as modification-related
principal forgiveness and interest rate reductions. Any change
resulting from servicing transfers or other policy or regulatory
change can also impact the performance of these transactions.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF307624

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


NORTHSTAR 2012-1: S&P Gives 'B' Rating on Class F Certificates
--------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
NorthStar 2012-1 Mortgage Trust's $351.4 million commercial
mortgage pass-through certificates.

The note issuance is a commercial mortgage-backed securities
transaction backed by 14 commercial mortgage loans with an
aggregate principal balance of $351.4 million, secured by the fee
interest in 19 properties across eight states.

"The ratings reflect our view of the credit support provided by
the transaction structure, our view of the economics of the
underlying collateral, the trustee-provided liquidity, the
relative diversity of the collateral pool, 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

RATINGS ASSIGNED
NorthStar 2012-1 Mortgage Trust

Class       Rating            Amount
                                 ($)
A           AAA (sf)     152,864,000
X-WAC(ii)   BBB (sf)  227,540,000(i)
X-LF(ii)    NR        290,987,400(i)
B           AA (sf)       30,310,000
C           A (sf)        24,160,000
D           BBB (sf)      20,206,000
E(ii)       BB (sf)       25,917,000
F(ii)       B (sf)        12,299,000
G(ii)       NR            85,657,751
R(ii)       NR                   N/A
LR(ii)      NR                   N/A

(i) Notional balance. Interest losses are allocated to the class
    X-WAC and X-LF certificates based on their respective
    entitlements pro rata.
(ii)Non-offered certificates.
NR - Not rated.
N/A - Not applicable.


NYLIM FLATIRON 2004-1: S%P Affirms 'B+' Rating on Class D Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
C notes from NYLIM Flatiron CLO 2004-1 Ltd., a U.S. collateralized
loan obligation (CLO) transaction managed by New York Life
Investment Management LLC. "At the same time, we affirmed our
ratings on the class B and D notes and removed our ratings on the
class C and D notes from CreditWatch with positive implications,
where we placed them on Sept. 24, 2012," S&P said.

"The upgrade reflects paydowns to the class A and B notes and a
subsequent improvement in the credit enhancement available to
support the notes since February 2012, when we last upgraded the
class C notes. Since that time, the transaction has paid the class
A notes in full and paid down the class B notes to 28.9% of their
original balance," S&P said.

"The upgrade also reflects an improvement in the
overcollateralization (O/C) available to support the notes,
primarily due to the paydowns. The trustee reported these O/C
ratios in the October 2012 monthly report," S&P said:

    The class B O/C ratio was 388.77%, compared with a reported
    ratio of 167.45% in January 2012;
    The class C O/C ratio was 182.86%, compared with a reported
    ratio of 133.27% in January 2012; and
    The class D O/C ratio was 113.02%, compared with a reported
    ratio of 107.63% in January 2012.

"We affirmed our ratings on the class B and D notes to reflect the
availability of credit support at the current rating levels.
Furthermore, the affirmation of the class D notes was driven by
our application of the largest obligor default test, a
supplemental stress test we introduced as part of our 2009
corporate criteria update," 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

NYLIM Flatiron CLO 2004-1 Ltd.
                   Rating
Class         To           From
B             AAA (sf)     AAA (sf)
C             AAA (sf)     AA+ (sf)/Watch Pos
D             B+ (sf)      B+ (sf)/Watch Pos

TRANSACTION INFORMATION
Issuer:             NYLIM Flatiron CLO 2004-1 Ltd.
Coissuer:           NYLIM Flatiron CLO 2004-1 Inc.
Collateral manager: New York Life Investment Management LLC
Underwriter:        Goldman Sachs & Co.
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CDO



NZCG FUNDING: S&P Says 'CCC'-Rated Collateral Down to $8.03-Mil.
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
B notes from NZCG Funding Ltd., a U.S. collateralized loan
obligation (CLO) managed by Guggenheim Investment Management LLC.
"In addition, we affirmed our rating on the class A notes," S&P
said.

The upgrade reflects the improvement in the credit quality of the
transaction's underlying assets since the effective date in
January 2011.

"According to the Oct. 16, 2012, trustee report, the transaction
held $8.03 million in 'CCC' rated collateral, down from $37.26
million noted in the Jan. 20, 2011, trustee report, which we used
for our effective date analysis. Furthermore, the amount of
defaulted obligations has decreased to $6.39 million from $9.27
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% threshold. On Oct 16, 2012, the haircut
was $0.75 million, compared with $4.08 million noted in the Jan.
20, 2011, trustee report," S&P said.

"During the transaction's reinvestment period, which ends Sep. 25,
2014, the transaction has an interest diversion test, which if the
class B notes O/C ratio is less than 130%, after paying the
deferred interest of class B notes, 50% of the remaining interest
proceeds will be transferred to the collection account for the
purchase of additional collateral obligations. The class B notes
O/C ratio was 140.61% in the Oct. 16, 2012, trustee report," S&P
said.

"The affirmation of class A notes reflects our belief that the
credit support available is commensurate with the 'AAA (sf)'
rating," 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 Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at:

              http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

NZCG Funding Ltd.
Class          Rating
          To            From
A         AAA (sf)      AAA (sf)
B         A+ (sf)       BBB (sf)


OAK HILL IV: S&P Raises Ratings on 3 Note Classes From 'BB+'
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B-1, B-2, C-1, C-2, and C-3 notes from Oak Hill Credit Partners IV
Ltd., a U.S. collateralized loan obligation (CLO) transaction
managed by Oak Hill Advisors LP. "At the same time, we removed our
ratings on the class B-1, B-2, C-1, C-2, and C-3 notes from
CreditWatch, where we placed them with positive implications on
Sep. 24, 2012. We also affirmed our ratings on the class A-1a, A-
1b, A-2a, and A-2b notes," S&P said.

"The upgrades reflect the principal paydowns to the class A-1a and
A-1b notes and improvement in the credit quality of the
transaction's underlying assets since our last rating actions in
February 2012," S&P said.

"On the Aug. 17, 2012, payment date, class A-1a and A-1b notes
received $29.7 million pro rata principal pay down. Since our last
rating actions in February 2012, class A-1a and A-1b notes have
paid down by $69.8 million and reduced the outstanding balance to
83% of the original balance," S&P said.

According to the Oct. 1, 2012 trustee report, the transaction held
approximately $13 million in assets from obligors rated in the
'CCC' category; down from $33.24 million noted in Feb. 1, 2012,
trustee report, which we referenced for our February 2012 rating
actions," S&P said.

"The affirmations reflect our belief that the credit support
available is commensurate with the current ratings," S&P said.

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

RATING ACTIONS

Oak Hill Credit Partners IV Ltd.
Class                   Rating
                   To           From
A-1a               AAA (sf)     AAA (sf)
A-1b               AAA (sf)     AAA (sf)
A-2a               AA+ (sf)     AA+ (sf)
A-2b               AA+ (sf)     AA+ (sf)
B-1                AA- (sf)     A+ (sf)/Watch Pos
B-2                AA- (sf)     A+ (sf)/Watch Pos
C-1                BBB- (sf)    BB+ (sf)/Watch Pos
C-2                BBB- (sf)    BB+ (sf)/Watch Pos
C-3                BBB- (sf)    BB+ (sf)/Watch Pos


PSSA FLOATING: Moody's Cuts Rating on $90.2-Mil. Certs. to Caa2
---------------------------------------------------------------
Moody's Investors Service has downgraded the rating of the
following certificates issued by PSSA Floating Rate Pass-Through
Trust, Series 1998-1:

US$90,200,000 Floating Rate Pass-Through Certificates Series
1998-1 (current balance: $35,218,535) , Downgraded to Caa2;
previously on December 20, 2011 B3 Placed Under Review for
Possible Downgrade.

Ratings Rationale

The transaction is a structured note whose rating is based on the
legal structure of the transaction, on the rating of The Chase
Manhattan Bank, N.A. (the "Swap Counterparty") and MBIA-insured
Senior Term Notes, Series A-1-A, issued by Basketball Properties,
Ltd. ("the Promissory Note"). The rating action is a result of the
downgrade by Moody's of MBIA Insurance Corporation's Insurance
Financial Strength rating to Caa2 on November 19, 2012.

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

Moody's conducted no additional cash flow analysis or stress
scenarios because the rating is a pass-through of the rating of
MBIA Insurance Corporation.

Moody's says that MBIA Insurance Corporation is subject to a high
level of macroeconomic uncertainty, which is manifest in uncertain
credit conditions across the general economy. Because these
conditions could negatively affect the rating of MBIA Insurance
Corporation, they could also negatively impact the rating on the
certificates.


RAAC SERIES 2007-SP2: Moody's Lifts Rating on A-1 Tranche to Caa1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of three
tranches issued by RAAC Series Trust in 2006 and 2007, backed by
Scratch and Dent Loans.

Ratings Rationale

The action is a result of the recent performance review of Scratch
and Dent pools and reflect Moody's updated loss expectations on
these pools. The upgrades are due to faster-than-expected pay-down
on certain tranches owing mainly to liquidations.

The methodologies used in these ratings 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 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: RAAC Series 2006-SP4 Trust

Cl. A-2, Upgraded to B3 (sf); previously on May 4, 2009 Downgraded
to Caa2 (sf)

Issuer: RAAC Series 2007-SP1 Trust

Cl. A-2, Upgraded to B2 (sf); previously on May 4, 2009 Downgraded
to Caa2 (sf)

Issuer: RAAC Series 2007-SP2 Trust

Cl. A-1, Upgraded to Caa1 (sf); previously on May 4, 2009
Downgraded to Caa3 (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF307882

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


RESTRUCTURED ASSET 2004-13-E: Moody's Hikes Cert. Rating to Ba2
---------------------------------------------------------------
Moody's Investors Service has upgraded the rating of the following
certificates issued by Restructured Asset Certificates with
Enhanced Returns, Series 2004-13-E:

U.S. $50,000,000 RACERS, Series 2004-13-E Deferrable Certificates,
Upgraded to Ba2 (sf); previously on August 4, 2009 Downgraded to
B2 (sf).

Ratings Rationale

Restructured Asset Certificates with Enhanced Returns, Series
2004-13-E is a repackaged security whose rating is based primarily
upon the transaction's structure and the credit quality of the
Underlying Assets which include (i) $50MM SFA CABS II CDO Ltd.,
Class B Notes that are currently rated Ca by Moody's and (ii) a
credit default swap that references corporate obligors as the
reference portfolio and collateralized by a zero coupon bond
issued by Citigroup Global Markets Holdings Inc. rated Baa2 by
Moody's.

According to Moody's, the rating action taken on the certificates
is primarily a result of an increase in the deal's reserve account
to $4.3 million from $3.3 million since the last rating action in
August 2009. The interest and principal distributions received on
the Class B Notes of SFA CABS II CDO Ltd. are passed through to
RACERS, Series 2004-13-E, and used to pay interest on the
certificates. The excess interest and principal received from SFA
CABS II CDO Ltd. Class B Notes is deposited into the deal's
reserve account and can be drawn to pay for interest shortfalls on
the certificates on future payment dates. On the final maturity
date, the amounts in the reserve account can be drawn to pay for
interest and principal on the certificates. The increase in the
reserve account is due to principal amortizations of the Class B
Notes in SFA CABS II CDO Ltd. Moody's notes that due to this
increase in the reserve account, the deal's risk from interest
shortfall on the certificates has been reduced since the last
rating action. In addition, the deal benefits from the shortened
time to maturity on the credit default swap. The principal on the
certificates is backed by $50 million of collateral from the
credit default swap.

The methodologies used in this rating were "Moody's Approach to
Rating SF CDOs" published in May 2012, "Rating CDO Repacks: An
Application Of The Structured Note Methodology" published in
February 2004, and "Moody's Approach to Rating Corporate
Collateralized Synthetic Obligations" published in September 2009.

Moody's analysis for this transaction is based on CDOROM v2.8.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios, discussed below. Results are given in terms
of the number of notches' difference versus the base case, where
higher notches correspond to lower expected losses, and vice-
versa:

* Moody's reviews a scenario consisting of reducing the maturity
of the CSO by six months, keeping all other things equal. The
results of this run is comparable to the base case.

* Market Implied Ratings ("MIRS") are modeled in place of the
corporate fundamental ratings to derive the default probability of
the reference entities in the portfolio. The gap between an MIR
and a Moody's corporate fundamental rating is an indicator of the
extent of the divergence in credit view between Moody's and the
market. The result of this run is comparable to the base case.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Corporate Synthetic
Obligations", key model inputs used by Moody's in its analysis may
be different from the manager/arranger's reported numbers. In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

Moody's does not run a separate loss and cash flow analysis other
than the one already done by the CDOROM model. For a description
of the analysis, refer to the methodology and the CDOROM user's
guide on Moody's website.

Moody's analysis of CSOs is subject to uncertainties, the primary
sources of which include complexity, governance and leverage.
Although the CDOROM model captures many of the dynamics of the
Corporate CSO structure, it remains a simplification of the
complex reality. Of greatest concern are (a) variations over time
in default rates for instruments with a given rating, (b)
variations in recovery rates for instruments with particular
seniority/security characteristics and (c) uncertainty about the
default and recovery correlations characteristics of the reference
pool. Similarly on the legal/structural side, the legal analysis
although typically based in part on opinions (and sometimes
interpretations) of legal experts at the time of issuance, is
still subject to potential changes in law, case law and the
interpretations of courts and (in some cases) regulatory
authorities. The performance of this CSO is also dependent on on-
going decisions made by one or several parties. Although the
impact of these decisions is mitigated by structural constraints,
anticipating the quality of these decisions necessarily introduces
some level of uncertainty in Moody's assumptions. Given the
tranched nature of CSO liabilities, rating transitions in the
reference pool may have leveraged rating implications for the
ratings of the CSO liabilities, thus leading to a high degree of
volatility. All else being equal, the volatility is likely to be
higher for more junior or thinner liabilities.

The base case scenario modeled fits into the central macroeconomic
scenario predicted by Moody's of a sluggish recovery scenario in
the corporate universe. Should macroeconomics conditions evolve,
the CSO ratings will change to reflect the new economic
developments.


ROCK 1 CRE: Moody's Affirms Caa3 Ratings on 7 Note Classes
----------------------------------------------------------
Moody's Investors Service has affirmed the ratings of fifteen
classes of Notes issued by ROCK 1 - CRE CDO 2006, Ltd. The
affirmations are due to key transaction parameters performing
within levels commensurate with the existing ratings levels and
the existing level of cash reserves (approximately 23% of the
current total pool balance including cash) available for
reinvestment. 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 Aa1 (sf); previously on Dec 9, 2010
Downgraded to Aa1 (sf)

Cl. A-2, Affirmed at Baa1 (sf); previously on Apr 7, 2009
Downgraded to Baa1 (sf)

Cl. B, Affirmed at Ba1 (sf); previously on Apr 7, 2009 Downgraded
to Ba1 (sf)

Cl. C, Affirmed at B2 (sf); previously on Apr 7, 2009 Downgraded
to B2 (sf)

Cl. D, Affirmed at B3 (sf); previously on Apr 7, 2009 Downgraded
to B3 (sf)

Cl. E, Affirmed at Caa1 (sf); previously on Apr 7, 2009 Downgraded
to Caa1 (sf)

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

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

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

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

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

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

RATINGS RATIONALE

ROCK 1 CRE CDO 2006, Ltd. is a revolving (the reinvestment period
ends in December 2012) CRE CDO backed by a portfolio of whole
loans (55.4% of the pool balance), commercial mortgage backed
securities (CMBS) (26.3%), and CRE CDOs (18.3%). As of the October
11, 2012 Trustee report, the aggregate Note balance of the
transaction, including preferred shares, has decreased to $320.0
million from $500.0 million at issuance, due to a special
amortization pro-rata condition which reduced the balances of all
rated classes. The transaction is passing all its par value
coverage and interest coverage ratio tests.

There is one asset with a par balance of $12.1 million (5.3% of
the current pool balance) that is considered defaulted security as
of the October 11, 2012 Trustee report, compared to two assets
with a par balance of $25.8 million (8.0% of the current pool
balance) at last review. Moody's expects low to moderate losses to
realize from this collateral.

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 2,435
compared to 3,784 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Aaa- Aa3 (22.5% compared to 16.7% at
last review), A1- A3 (6.6% compared to 0.0% at last review), Baa1-
Baa3 (7.2% compared to 7.1% at last review), Ba1-Ba3 (16.6%
compared to 2.6% at last review), B1-B3 (4.6% compared to 3.2% at
last review), and Caa1-C (42.5% compared to 70.4% at last review).

Moody's modeled a WAL of 7.2 years compared to 8.0 years at last
review. The current WAL is based on the assumption about
extensions.

Moody's modeled a fixed WARR of 47.6% compared to 52.7% at last
review.

Moody's modeled a MAC of 8.8% 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 47.6% to 37.6% or up to 57.6% would result in rating
movement on the rated Notes of 0 to 5 notches downward and 0 to 6
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.


SALOMON BROTHERS: Moody's Cuts Rating on Cl. X-1 Certs. to Caa3
---------------------------------------------------------------
Moody's Investors Service affirmed the ratings of three classes
and downgraded one class of Salomon Brothers Mortgage Securities
VII, Inc., Commercial Mortgage Pass-Through Certificates, Series
2002-KEY2 as follows:

Cl. P, Affirmed at B1 (sf); previously on Sep 26, 2002 Definitive
Rating Assigned B1 (sf)

Cl. Q, Affirmed at Caa1 (sf); previously on Feb 16, 2011
Downgraded to Caa1 (sf)

Cl. S, Affirmed at Caa3 (sf); previously on Feb 16, 2011
Downgraded to Caa3 (sf)

Cl. X-1, Downgraded to Caa3 (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 its current base expected loss, the
credit enhancement levels for the affirmed classes are sufficient
to maintain their current ratings.

The IO class is downgraded to reflect the credit performance of
its current referenced classes, following the payoff of several
highly-rated reference bonds.

Moody's rating action reflects a base expected loss of
approximately $6.2 million or 32.9% of the current deal balance
compared to $13.7 or 3.2% at last review. The sharp increase in
base expected loss on a percentage basis is primarily due to the
large paydown of the pool balance since Moody's prior review
(96%). 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, "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 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 its analysis. Based on the model
pooled credit enhancement levels at Aa2 (sf) and B2 (sf), the
remaining conduit classes are either interpolated between these
two data points or determined based on a multiple or ratio of
either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade underlying ratings is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit 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 3 compared to a Herf of 12 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 February 9, 2012.

DEAL PERFORMANCE

As of the October 18, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $19 million
from $933 million at securitization. The Certificates are
collateralized by four mortgage loans ranging in size from 9% to
43% of the pool. The pool contains no defeased loans and no loans
with investment-grade credit assessments.

Five loans have liquidated from the pool, resulting in an
aggregate realized loss of $7 million (21% average loan loss
severity). Currently, three loans, representing 80% of the pool,
are in special servicing. The largest specially serviced loan, and
the largest loan in the pool, is the Commons at Sauk Trail
Shopping Center Loan ($8 million -- 43% of the pool). The loan is
secured by a 97,000 square foot (SF) retail property located in
Saline, Michigan. The loan transferred to special servicing in
August 2010 following a drop in occupancy. The largest tenant
(Country Market supermarket; 56% of property NRA) is on a month-
to-month lease. The grocery store anchor is believed to have
ceased operations at the center, leaving the property 26%
occupied. The borrower has submitted to the special servicer
several discounted payoff offers, all of which have been rejected.

The second loan in special servicing is the Oak Tree Plaza
Shopping Center Loan ($5 million -- 29% of the pool). The loan is
secured by a 70,000 SF retail center located in Denton, Texas,
approximately 30 miles northwest of downtown Dallas. The loan
transferred to special servicing on August 12, 2012, due to
maturity default. Property occupancy was 100% leased as of June
2012, the same as at Moody's last review.

The third specially serviced loan is secured by a vacant 120,000
SF industrial property located in Hicksville, New York, which
represents 9% of the pool balance. Moody's estimates an aggregate
$15 million loss (40% expected loss on average) for all specially
serviced loans.

The single performing loan is the pool is the Northbrook Atrium
Plaza Office Building Loan ($4 million -- 20% of the pool), which
is secured by a 140,000 SF office property located in Dallas,
Texas. The loan had recently been on the master servicer's
watchlist for low DSCR, but was removed from the watchlist in
October 2012 following improvement in property performance and a
loan modification which reduced the loan interest from 7.9% to
6.5%. The property has benefitted from recent leasing activity and
a concurrent uptick in occupancy. Moody's was provided with full-
year 2011 and partial year 2012 operating results for this loan.
Moody's current LTV and stressed DSCR are 89% and 1.28X,
respectively, compared to 82% and 1.38X at last review. Moody's
stressed DSCR is based on Moody's NCF and a 9.25% stressed rate
applied to the loan balance.


SALT VERDE: Moody's Reviews 'B2' Bond Rating for Downgrade
----------------------------------------------------------
Moody's Investors Service has placed on watch for downgrade the B2
rating of Salt Verde Financial Corporation Subordinate Gas Revenue
Bonds, Series 2007 following the downgrade of MBIA, Inc. to Caa1
from B2. The bonds have exposure to MBIA, Inc. through a
guaranteed investment agreement (GIC) provided by MBIA Inc. (Caa1)
that is also insured by MBIA Insurance Corporation (Caa2). The
rating of the Senior Gas Revenue Bond, Series 2007 is currently
Baa2 and is not affected by the action on the subordinate bonds.

The principal methodology used in rating this issue was Gas
Prepayment Bonds published in December 2008.


SCHOONER TRUST 2006-5: Moody's Affirms 'B3' Rating on Cl. L Certs.
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 14 classes of
Schooner Trust Commercial Mortgage Pass-Through Certificates,
Series 2006-5 as follows:

Cl. A-1, Affirmed at Aaa (sf); previously on Feb 28, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Feb 28, 2006
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Feb 28, 2006 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed at A2 (sf); previously on Feb 28, 2006 Definitive
Rating Assigned A2 (sf)

Cl. D, Affirmed at Baa2 (sf); previously on Feb 28, 2006
Definitive Rating Assigned Baa2 (sf)

Cl. E, Affirmed at Baa3 (sf); previously on Feb 28, 2006
Definitive Rating Assigned Baa3 (sf)

Cl. F, Affirmed at Ba1 (sf); previously on Feb 28, 2006 Definitive
Rating Assigned Ba1 (sf)

Cl. G, Affirmed at Ba2 (sf); previously on Feb 28, 2006 Definitive
Rating Assigned Ba2 (sf)

Cl. H, Affirmed at Ba3 (sf); previously on Feb 28, 2006 Definitive
Rating Assigned Ba3 (sf)

Cl. J, Affirmed at B1 (sf); previously on Feb 28, 2006 Definitive
Rating Assigned B1 (sf)

Cl. K, Affirmed at B2 (sf); previously on Feb 28, 2006 Definitive
Rating Assigned B2 (sf)

Cl. L, Affirmed at B3 (sf); previously on Feb 28, 2006 Definitive
Rating Assigned B3 (sf)

Cl. XP, Affirmed at Aaa (sf); previously on Feb 28, 2006
Definitive Rating Assigned Aaa (sf)

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

Ratings Rationale

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.
The rating of the IO Classes, X-P and X-C, are consistent with the
credit performance of their referenced classes and thus are
affirmed.

Moody's rating action reflects a base expected loss of 2.0% of the
current balance compared to 1.9% at last review. Moody's provides
a current list of base expected losses for conduit and fusion CMBS
transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of 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 Canadian CMBS" published in May 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 assessment 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 38, 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 December 1, 2011.

DEAL PERFORMANCE

As of the November 13th, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 20% to
$387.6.1million from $486.1 million at securitization. The
Certificates are collateralized by 78 mortgage loans ranging in
size from less than 1% to 7% of the pool, with the top ten loans
representing 38% of the pool. There are two loans with investment-
grade credit assessments, representing approximately 10% of the
pool. There are five defeased loans, representing 18% of the pool,
that are secured by Canadian Government securities.

Six loans are on the master servicer's watchlist, representing
approximately 8% of the pool. 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.

The pool has not experienced any losses to date and there are no
loans currently in special servicing.

Moody's has assumed a high default probability for three poorly
performing loans representing approximately 3% of the pool and has
estimated a $2.1 million loss (20% expected loss based on a 50%
probability default) from these troubled loan.

Excluding defeased and troubled loans, Moody's was provided with
full year 2011 operating results for 89% of the pool. Excluding
defeased and troubled loans, Moody's weighted average conduit LTV
is 76% compared to 79% at Moody's prior. Moody's net cash flow
(NCF) reflects a weighted average haircut of 11.5% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.2%.

Excluding defeased and troubled loans, Moody's actual and stressed
conduit DSCRs are 1.52X and 1.39X, essentially the same as at last
review. Moody's actual DSCR is based on Moody's net cash flow 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 Briton House Loan
($26.0 million -- 6.7% of the pool), which is secured by a 220-
unit retirement home located in Toronto, Ontario. As of April
2011, the property was 100% leased compared to 98% at last review.
Performance has been stable and the loan is benefitting from
amortization. Moody's current credit assessment and stressed DSCR
are Baa2 and 1.52X, essentially the same as at last review.

The second loan with a credit assessment is the Greenwood Beach
Retail Centre loan ($11.9 million -- 2.9% of the pool), which is
secured by three retail properties totaling 105,148 square feet
and located in Toronto, Ontario. Major tenants include Ontario
Jockey Club, Alliance Atlantis (movie theater), Beach Fitness
Centre and Bank of Montreal. As of August 2011, the complex was
93% leased compared to 95% at last review. The loan is amortizing
on a 20-year schedule and is 100% recourse to the borrower. The
sponsor is EMM Financial Corp. Moody's current credit assessment
and stressed DSCR are A3 and 1.72X, essentially the same as at
last review.

The top three performing conduit loans represent 13% of the pool
balance. The largest loan is the Lindsay Square loan ($17.9
million -- 4.6% of the pool), which is secured by 193,933 square
foot anchored retail mall located in Lindsay, Ontario. As of March
2012, the property was 97% leased compared to 94% at last review.
The loan is benefiting from amortization and is partial recourse
to the borrower. The sponsor is the Montez Retail Fund. Moody's
LTV and stressed DSCR are 89% and 1.1X, respectively, compared to
93% and 1.05X at last review.

The second largest loan is the 380 & 400 Waterloo Avenue loan
($16.6 million -- 4.3% of the pool), which is secured by 262-unit
multifamily property located in Guelph, Ontario. As of September
2011, the property was 100% leased compared to 98% at last review.
However, the loan is on the watch list for deferred maintenance
issues. Per the master servicer, the borrower is in the process of
remedying the issues. The loan is benefiting from amortization and
is 100% recourse. The sponsor is Homestead Land Holdings. Moody's
LTV and stressed DSCR are 85% and 0.99X, respectively, compared to
89% and 0.94X, respectively at last review.

The third largest loan is the Springdale Square loan ($15.5
million -- 3.8% of the pool), which is secured by a 105,453 square
foot anchored retail property located in Brampton, Ontario. As of
March 2012, the property was 92% leased compared to 100% at last
review. The loan is benefiting from amortization and is 100%
recourse. The sponsor is Heritage Court Holdings. Moody's LTV and
stressed DSCR are 94% and 1.01X, respectively, compared to 90% and
1.06X at last review.


SEQUOIA MORTGAGE: Moody's Cuts Cl. B-3 Tranche Rating to 'Caa3'
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of four
tranches from one RMBS transaction, backed by Prime Loans, issued
by Sequoia Mortgage Trust in 2002.

Complete rating actions are as follows:

Issuer: Sequoia Mortgage Trust 6

Cl. A, Downgraded to Baa2 (sf); previously on Apr 27, 2011
Downgraded to Aa1 (sf)

Cl. B-1, Downgraded to Ba3 (sf); previously on Apr 27, 2011
Downgraded to A2 (sf)

Cl. B-2, Downgraded to Caa1 (sf); previously on Apr 27, 2011
Downgraded to Baa3 (sf)

Cl. B-3, Downgraded to Caa3 (sf); previously on Apr 27, 2011
Downgraded to B1 (sf)

Ratings Rationale

The actions are a result of the recent performance of the
underlying pool and reflect Moody's updated loss expectation on
the pool. The rating action consists of a number of downgrades.
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_SF306385

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



SHACKLETON II: S&P Gives 'BB' Rating on Class E Deferrable Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
Shackleton II CLO Ltd./Shackleton II CLO Corp.'s $366.5 million
floating- and fixed-rate notes.

The note issuance is a CLO 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.

    "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 0.31% to 11.67%," S&P said.

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

    The transaction's interest diversion test, a failure of which
    will lead to the reclassification of excess interest proceeds
    that are available prior to paying uncapped administrative
    expenses; deferred senior, income, and incentive management
    fees; hedge payments; and income 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/1123.pdf

RATINGS ASSIGNED

Shackleton II CLO Ltd./Shackleton II CLO Corp.

Class            Rating      Interest           Amount
                             rate             (Mil. $)

A-1              AAA (sf)    Floating            254.0
A-X              AAA (sf)    Floating              7.5
B-1              AA (sf)     Floating             15.0
B-2              AA (sf)     Fixed                25.0
C (deferrable)   A (sf)      Floating             24.0
D (deferrable)   BBB (sf)    Floating             20.0
E (deferrable)   BB (sf)     Floating             21.0
Income notes     NR          N/A                  40.0


SOUTHPORT CLO: S&P Ups Rating on Class D Notes to 'BB+'; Off Watch
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, D, and 2 notes and removed its ratings on the class B, C,
and D notes from CreditWatch with positive implications from
Southport CLO Ltd., a collateralized loan obligation (CLO)
transaction currently managed by Pacific Investment Management Co.
LLC. "At the same time, we affirmed our ratings on the class A-1
and A-3 notes," S&P said.

"The rating actions follow our performance review of the
transaction and primarily reflect $81.9 million in paydowns on the
class A-1, A-2, and A-3 notes, to 13%, 0%, and 63% of their
original balances. The paydowns have led to a significant increase
in overcollateralization (O/C) available to support the notes
since our February 2012 rating actions, when we raised our ratings
on five classes of notes. The class A, B, C, and D O/C ratios have
increased by absolute differences of 65.3%, 19.1%, 6.2%, and 2.3%,
respectively, since the January 2012 trustee report which we
referenced for our February 2012 rating actions," S&P said.

"The increased credit support is primarily due to the increased
O/C. The amount of defaulted obligations ($0 million) and 'CCC'
rated obligations ($23.4 million) held in the transaction's
underlying portfolio has not changed significantly since our last
rating actions," S&P said.

"Other positive factors in our analysis include a decrease in the
portfolio weighted average life from 2.5 to 2.0 years and an
increase in the weighted-average spread from 2.7% to 2.9%," S&P
said.

"The transaction is in its amortization phase and continues to use
its principal proceeds to pay down the senior notes in the payment
sequence, as specified in the indenture," S&P said.

"The transaction's payment structure pays interest pari passu to
all three class A tranches; however, class A-2 receives principal
payments ahead of class A-3. As a result, the transaction paid
down the class A-2 note in full on the July 2012 payment date,"
S&P said.

"The class 2 note is a combination security backed by the class B
and C notes and a portion of the class D note and equity
tranches," S&P said.

"The obligor concentration supplemental test (which is part of our
criteria for rating corporate CDO transactions) affected the
ratings on the class C, D, and 2 notes," S&P said.

"We will continue to review our ratings on the notes and assess
whether, in our view, the ratings remain consistent with the
credit enhancement available to support them and take rating
actions as we deem necessary," S&P said.

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

              http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Southport CLO Ltd.
                              Rating
Class                   To           From
B                       AAA (sf)     A+ (sf)/Watch Pos
C                       BBB+ (sf)    BB+ (sf)/Watch Pos
D                       B+ (sf)      CCC+ (sf)/Watch Pos
2                       A+ (sf)      BBB+ (sf)

RATINGS AFFIRMED

Southport CLO Ltd.

Class                   Rating
A-1                     AAA (sf)
A-3                     AAA (sf)


STUDENT LOAN 2007-1: Moody's Reviews 'Caa2' Rating on 2 Certs.
--------------------------------------------------------------
Moody's Investors Service placed on review for downgrade eight
certificates in Student Loan ABS Repackaging Trust 2007-1 and one
certificate in Student Loan ABS Repackaging Trust 2007-2. Deutsche
Bank Trust Company Americas is the administrator and indenture
trustee for both transactions.

Complete rating actions are as follows:

Issuer: Student Loan ABS Repackaging Trust, Series 2007-1

Cl. 3-A-1, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Caa1 (sf)

Cl. 3-A-IO, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Caa1 (sf)

Cl. 4-A-1, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Caa2 (sf)

Cl. 4-A-IO, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Caa2 (sf)

Cl. 5-A-1, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. 5-A-IO, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. 6-A-1, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Cl. 6-A-IO, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Jun 16, 2011 Confirmed at Ba1 (sf)

Issuer: Student Loan ABS Repacking Trust, Series 2007-2

Cl. IO, B2 (sf) Placed Under Review for Possible Downgrade;
previously on Feb 22, 2012 Upgraded to B2 (sf)

Ratings Rationale

The review of the certificates was primarily due to the review of
the underlying securities referenced in these transactions. The
ratings of the certificates issued by Student Loan Repackaging
Trust, Series 2007-1, are based on the ratings of the underlying
securities and the payment timing swap provided by Deutsche Bank
AG, New York Branch. The payment timing swap covers any interest
shortfalls on the certificates if the interest accrual period for
the certificates is longer than the interest accrual period for
the underlying securities on the related underlying distribution
date. Below is a list of the underlying securities referenced in
this transaction:

Group 3 Certificates: National Collegiate Student Loan Trust 2003-
1, Class A-7 (current rating Caa1 (sf) on review for downgrade)
and Class IO Notes (current rating Caa1 (sf) on review for
downgrade);

Group 4 Certificates: National Collegiate Student Loan Trust 2004-
1, Class A-4 (current rating Caa3 (sf) on review for downgrade)
and Class A-IO-2 Notes (current rating Caa3 (sf) on review for
downgrade);

Group 5 Certificates: National Collegiate Student Loan Trust 2005-
1, Class A-5-1 (current rating Ba1 (sf) on review for downgrade)
and Class A-5-2 Certificates (current rating Ba1 (sf) on review
for downgrade);

Group 6 Certificates: National Collegiate Student Loan Trust 2005-
3, Class A-5-1 Certificates (current rating Ba1 (sf) on review for
downgrade).

The assets of the Student Loan Repackaging Trust, Series 2007-2
consist primarily of the Class 1-A-IO, Class 2-A-IO, Class 3-A-IO,
Class 4-A-IO, Class 5-A-IO, Class 6-A-IO and Class 7-A-IO
Certificates issued by the Student Loan ABS Repackaging Trust,
Series 2007-1. The rating of the Class IO in the Student Loan
Repackaging Trust, Series 2007-2 was determined based on the
weighted average rating of the underlying IO bonds. As a
consequence of the confirmation of the ratings on Class 3-A-IO,
Class 4-A-IO, Class 5-A-IO and Class 6-A-IO, Class IO was also
confirmed.

The reviews were also prompted by correction of the static pool
default information that was used to assess the ratings of the
above referenced Group 3 to Group 6 underlying securities during
the May 2011 rating actions. The use of incorrect static pool
default data for those rating actions led to an input error in
connection with the 16 June 2011 rating actions on the Series
2007-1 and 2007-2 repackaging trust.

The principal methodologies used in these ratings were "Moody's
Approach to Rating U.S. Private Student Loan-Backed Securities"
published on January 2010 and "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published on February
22 2012.


SUFFIELD CLO: Fitch Affirms Junk Ratings on Three Note Classes
--------------------------------------------------------------
Fitch Ratings has upgraded one class and affirmed three classes of
notes issued by Suffield CLO, Ltd./Corp. (Suffield CLO) as
follows:

  -- $11,658,265 class IV notes upgraded to 'BBBsf' from 'Bsf';
     Outlook Stable;
  -- $5,607,983 class V-A notes affirmed at 'Csf'; RE 5%;
  -- $14,019,957 class V-B notes affirmed at 'Csf'; RE 5%;
  -- $14,700,000 (original stated balance) class L combination
     securities affirmed at 'Csf'.

The upgrade of the class IV notes reflects the stable portfolio
performance and the increasing credit enhancement available to
these notes via continued amortization of the underlying
collateral.  The Rating Outlook is Stable, reflecting Fitch's
expectation of stable performance over the next one to two years.

Since Fitch's last rating action in January 2012, the class III-A
and class III-B notes, which then had a combined balance of
approximately $20.9 million, have been paid in full.  The class IV
notes are now the senior-most remaining class and have received
principal payments totaling approximately $23.3 million, or about
67% of their initial balance.  These notes are supported by
performing portfolio of roughly $21.9 million, in addition to $1.6
million of available principal proceeds, as of the Oct. 19, 2012
trustee report.

While the class IV notes now benefit from improved par coverage
levels due to the collateral and capital structure amortization,
these notes are also exposed to remaining risks in the portfolio.
In particular, the remaining portfolio consists of loans from just
18 unique obligors generally rated in the 'B' and 'CCC' rating
categories.  Additionally, over 45% of the performing loans are
scheduled to mature after the stated maturity date of the
transaction in September 2014, introducing a dimension of market
value risk to the transaction if the loans have not been amortized
or sold by that time.  Fitch incorporated stresses on the assumed
liquidation values of the long-dated loans in its cash flow model
analysis.

Fitch's cash flow modeling results indicated passing ratings
higher than 'BBBsf' for the class IV notes; however, the extent of
the upgrade accounts for the improved position of the class IV
notes since Fitch's last rating action while acknowledging the
remaining portfolio risks described above.  Additionally, the
degree of obligor concentration in the portfolio led Fitch to
consider its rating cap criteria, which generally calls for a
rating cap for a class of notes that Fitch deems to be reliant on
the performance of a concentrated portfolio.  Given these
considerations, a rating of 'BBBsf' was assigned reflecting the
view that capacity for payment of financial commitments is
adequate but adverse business or economic conditions are more
likely to impair this capacity.

The class V-A and V-B (collectively, class V) notes are
undercollateralized, as demonstrated by a reported class V
overcollateralization (OC) ratio of 71.1%.  These notes continue
to partially defer their scheduled interest payments; at the Sept.
19, 2012 payment date the notes received a total of $148 thousand
in interest payments, compared to their scheduled combined
interest payment of $775 thousand.  Fitch expects these notes to
experience a principal loss at maturity and has therefore affirmed
the 'Csf' ratings.  Their recovery estimates (REs) indicated above
reflect Fitch's expectation of minimal future principal payments
being received by these notes in a base-case scenario.

The rating of the class L combination securities addresses the
likelihood that investors will receive the stated balance of
principal by the final maturity date, as well as a yield of 8.4%
on the original investment.  The class L combination notes
received approximately 4.8% of distributions to the class III-A
notes (which are now paid-in-full), 28.6% of distributions to the
class IV notes, and 7.4% of distributions to the preferred shares
(which are not expected to receive any future distributions).  The
floating-rate class III-A and class IV notes have historically
received coupons significantly lower than the required 8.4% yield
on the class L combination securities, which has been exacerbated
by the low interest rate environment.  As a result, the class L
combination securities are not expected to be able to achieve this
yield, and are affirmed at 'Csf'.

In order to account for the portfolio's concentration risk, Fitch
modeled the transaction using the Obligor Concentration Uplift
(OCU) feature in its Portfolio Credit Model (PCM) as the base case
scenario.  The default and recovery level outputs from PCM were
then utilized in Fitch's cash flow model under various default
timing and interest rate stress scenarios, as described in the
report 'Global Criteria for Cash Flow Analysis in CDOs'.  While
Fitch's cash flow analysis indicated higher passing rating levels
for the class IV notes, the extent of the upgrade captures the
improvement in credit enhancement while accounting for other risks
in the remaining portfolio, as described above.

Suffield CLO is a cash flow collateralized loan obligation (CLO)
that closed on Sept. 13, 2000 and is managed by Babson Capital
Management LLC.  Suffield CLO exited its reinvestment period in
September 2005 and currently has a portfolio primarily consisting
of senior secured loans.  The CLO is scheduled to mature on
September 26, 2014.


UBS-CITIGROUP: Moody's Affirms 'B2' Rating on Cl. G Certificates
----------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 13
classes of UBS-Citigroup Commercial Mortgage Trust Commercial
Mortgage Pass-Through Certificates 2011-C1 as follows:

Cl. A-1, Affirmed at Aaa (sf); previously on Jan 4, 2012
Definitive Rating Assigned Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Jan 4, 2012
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jan 4, 2012
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Jan 4, 2012
Definitive Rating Assigned Aaa (sf)

Cl. A-S, Affirmed at Aaa (sf); previously on Jan 4, 2012
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Jan 4, 2012 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed at A2 (sf); previously on Jan 4, 2012 Definitive
Rating Assigned A2 (sf)

Cl. D, Affirmed at Baa1 (sf); previously on Jan 4, 2012 Definitive
Rating Assigned Baa1 (sf)

Cl. E, Affirmed at Baa3 (sf); previously on Jan 4, 2012 Definitive
Rating Assigned Baa3 (sf)

Cl. F, Affirmed at Ba2 (sf); previously on Jan 4, 2012 Definitive
Rating Assigned Ba2 (sf)

Cl. G, Affirmed at B2 (sf); previously on Jan 4, 2012 Definitive
Rating Assigned B2 (sf)

Cl. X-A, Affirmed at Aaa (sf); previously on Jan 4, 2012
Definitive Rating Assigned Aaa (sf)

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

Ratings Rationale

This is the first full review of the trust since securitization.
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
Classes, Class X-A and X-B, are consistent with the credit
performance of their respective referenced classes and thus are
affirmed.

Moody's rating action reflects a base expected loss of 2.0% 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.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.61 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 18, the same as at securitization.

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.

Deal Performance

As of the November 13, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$669 million from $674 million at securitization. The Certificates
are collateralized by 32 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten loans representing
63% of the pool.

There are no loans on the master servicer's watchlist or in
special servicing.

Moody's was provided with 2011 trailing-twelve month or full year
2011 operating results for 100% of the pool's loans. Moody's
weighted average LTV is 97% compared to 98% at securitization.
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 9.6%.

Moody's actual and stressed DSCRs are 1.34X and 1.08X,
respectively, compared to 1.34X and 1.07X at securitization.
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 loans represent 29% of the pool. The largest loan is
the Trinity Centre Loan ($72.0 million -- 10.8% of the pool),
which is a pari-passu interest in a $160.0 million first mortgage
loan. The loan is secured by two adjacent pre-war office buildings
containing 900,744 square feet (SF) located in Downtown Manhattan,
New York. The property is also encumbered with $25.0 million of
mezzanine financing. The largest tenant is the Port Authority of
NY & NJ (17.5% of the net rentable area (NRA)) with lease
expirations in July 2015 and December 2016. The property was 84%
leased as of April 2012, compared to 85% at securitization.
Moody's LTV and stressed DSCR are 109% and 1.12X, respectively,
the same as at securitization.

The second largest loan is the Poughkeepsie Galleria Loan ($69.1
million -- 10.3% of the pool), which is a pari-passu interest in a
$153.7 million first mortgage loan. The loan is secured by a
691,000 SF portion of a 1.2 million SF regional mall located in
Poughkeepsie, New York. The property is also encumbered with $20.9
of mezzanine financing. The Mall's anchors include JCPenney, Regal
Cinemas, Dick's Sporting Goods, Macy's (non-collateral), Best Buy
(non-collateral), Target (non-collateral) and Sears (ground only).
The property is the dominant mall in its trade area and as of
March 2012 the collateral and total mall were approximately 87%
and 93% leased, respectively, essentially the same as at
securitization. Moody's LTV and stressed DSCR are 111% and 1.02X,
respectively, compared to 112% and 1.01X at securitization.

The third largest loan is the Portofino at Biscayne Loan ($55.1
million -- 8.2% of the pool), which is secured by a 868 unit high
rise multifamily property with 1,260 surface lot parking spaces
located in North Miami, Florida. The property was constructed in
phases between 1974 and 1980 and most recently renovated in 2011.
As of April 2012, the property was 98% leased compared to 97% at
securitization and the property has maintained an occupancy level
at or above 96% since 2009. Property performance has improved due
to an increase in rental income. Moody's LTV and stressed DSCR are
89% and 1.03X, respectively, compared to 95% and 0.97X at
securitization.


WACHOVIA BANK 2007-C34: Moody's Cuts Ratings on 2 Notes to 'Csf'
----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of ten classes
and affirmed 12 classes of Wachovia Bank Commercial Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series 2007-
C34 as follows:

Cl. A-2, Affirmed at Aaa (sf); previously on Nov 27, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-PB, Affirmed at Aaa (sf); previously on Nov 27, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Nov 27, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Nov 27, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Downgraded to A1 (sf); previously on Dec 10, 2010
Downgraded to Aa2 (sf)

Cl. A-J, Downgraded to Ba1 (sf); previously on Dec 10, 2010
Downgraded to Baa1 (sf)

Cl. B, Downgraded to Ba2 (sf); previously on Dec 10, 2010
Downgraded to Baa2 (sf)

Cl. C, Downgraded to Ba3 (sf); previously on Dec 10, 2010
Downgraded to Baa3 (sf)

Cl. D, Downgraded to Caa1 (sf); previously on Dec 10, 2010
Downgraded to B1 (sf)

Cl. E, Downgraded to Caa2 (sf); previously on Dec 10, 2010
Downgraded to B2 (sf)

Cl. F, Downgraded to Caa3 (sf); previously on Dec 10, 2010
Downgraded to B3 (sf)

Cl. G, Downgraded to Ca (sf); previously on Dec 10, 2010
Downgraded to Caa1 (sf)

Cl. H, Downgraded to C (sf); previously on Dec 10, 2010 Downgraded
to Caa2 (sf)

Cl. J, Downgraded to C (sf); previously on Dec 10, 2010 Downgraded
to Ca (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. 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 primarily to higher realized and expected
losses from specially serviced and troubled loans as well as
anticipated increases in interest shortfalls.

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.

The rating of the IO Class 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
approximately 10% of the current deal balance. At last review,
Moody's cumulative base expected loss was approximately 8%.
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 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 underlying ratings 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 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 compared to 32 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 $1.33
billion from $1.48 billion at securitization. The Certificates are
collateralized by 109 mortgage loans ranging in size from less
than 1% to 12% of the pool, with the top ten loans (excluding
defeasance) representing 44% of the pool. The pool includes one
loan with an investment-grade credit assessment, representing 1%
of the pool. There are no defeased loans in the pool.

Twenty-five loans, representing 22% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of its
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Four loans have liquidated from the pool, resulting in an
aggregate realized loss of $22 million (19% average loan loss
severity). Currently, 13 loans, representing 22% of the pool, are
in special servicing. The largest specially serviced loan is the
Nestle 94 Pool ($106 million -- 8% of the pool), which is secured
by three cross-collateralized, cross-defaulted industrial
properties located in Pennsylvania, California and Indiana. The
properties are triple-net, 100% leased to Nestle through December
31, 2012. New leases have been signed for the Pennsylvania and
California properties, however the Indiana property (30% of
portfolio NRA) is expected to be vacant following the current
lease expiration. The loan, originally scheduled to mature in
August 2012, was modified and extended for three years, interest
only. In connection with the loan modification, the B-note was
paid off, and a $9.5 million reserve has been funded by the
borrower.

The remaining 12 specially serviced loans are secured by a mix of
office, retail and hotel property types. Moody's estimates an
aggregate $75 million loss (40% expected loss overall) for all
specially serviced loans.

Moody's has assumed a high default probability for ten poorly-
performing loans representing 12% of the pool. Moody's analysis
attributes to these troubled loans an aggregate $23 million loss
(15% expected loss based on a 50% probability default).

Moody's was provided with full-year 2011 and partial year 2012
operating results for 98% and 62% of the performing pool,
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 106% compared to 111% at last full
review. Moody's net cash flow reflects a weighted average haircut
of 12% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.7%

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.41X and 1.19X, respectively, compared to
1.45X and 1.06X 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 Greentree Shopping Center
Loan ($10 million -- 1% of the pool), which is secured by a
173,000 square foot grocery-anchored shopping center located in
Naples, Florida. The lead tenant is Sweetbay Supermarket and
Liquor Store, which leases 30% of the shopping center NRA through
March 2026. The loan is on the master servicer's watchlist for low
DSCR. The second largest tenant, Naples Community Hospital, leases
24% of property NRA through April 2013. Property occupancy was 96%
in June 2012. Moody's credit assessment and stressed DSCR are Baa1
and 1.49X, respectively, compared to A2 and 1.64X at last review.

The top three performing conduit loans represent 20% of the pool.
The largest loan is the Ashford Hospitality Pool 5 Loan ($157
million -- 12% of the pool). The loan is secured by a portfolio of
five hotels, including three Marriott-flagged hotels in New
Jersey, Texas, and North Carolina, a Sheraton-flagged hotel in
Pennsylvania, and an Embassy Suites-flagged hotel in Arizona.
Portfolio performance has improved in recent years, with a notable
11% jump in RevPAR from 2010 to 2011. Nevertheless, portfolio
performance lags the sector recovery, and compares unfavorably to
portfolio performance at securitization. Moody's current LTV and
stressed DSCR are 125% and 0.95X, respectively, compared to 136%
and 0.87X at last review.

The second largest loan is the Integrated Health Center Campus
Loan ($59 million -- 4% of the pool). The loan is secured by a
302,000 square-foot medical office property located in the
Allentown-Bethlehem, Pennsylvania area. Occupancy was 97% as of
year-end 2011 reporting compared to 100% occupancy reported in
2010, and up significantly from the 81% occupancy reported at
securitization. Moody's current LTV and stressed DSCR are 113% and
0.86X, respectively, compared to 130% and 0.79X at last review.

The third largest loan ($47 million -- 4% of the pool) is a
portfolio of 14 cross-collateralized loans secured by 13 retail
properties and one industrial property. The properties are
distributed across 11 U.S. states, primarily in the eastern half
of the country. Two loans, secured by retail properties in
Reading, Pennsylvania and Rapid City, South Dakota, are on the
master servicer's watchlist, in each case as a result of the
departure of now-defunct bookstore retailer Borders Books. The
vacant spaces have recently been filled by JoAnn's Fabrics and
Books-a-Million, returning the portfolio to 100% occupancy.
Moody's current LTV and stressed DSCR are 97% and 1.04X
respectively, compared to 91% and 1.13X at last review.


WACHOVIA CRE: Moody's Lifts Ratings on 2 Note Classes to 'Caa2'
---------------------------------------------------------------
Moody's has upgraded the ratings of twelve classes of Notes issued
by Wachovia CRE CDO 2006-1, Ltd. due to rapid amortization and
recoveries on the underlying collateral since last review. The
affirmations are due to the key transaction parameters performing
within levels commensurate with the existing ratings levels. The
rating action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO
CLO) transactions.

Moody's rating action is as follows:

Cl. A-1A, Upgraded to Aa2 (sf); previously on Nov 23, 2011
Upgraded to Aa3 (sf)

Cl. A-1B, Upgraded to Baa3 (sf); previously on Nov 23, 2011
Upgraded to Ba1 (sf)

Cl. A-2A, Affirmed at Aaa (sf); previously on Apr 7, 2009
Confirmed at Aaa (sf)

Cl. A-2B, Upgraded to A3 (sf); previously on Nov 23, 2011 Upgraded
to Baa1 (sf)

Cl. B, Upgraded to Ba2 (sf); previously on Nov 23, 2011 Upgraded
to Ba3 (sf)

Cl. C, Upgraded to Ba3 (sf); previously on Nov 23, 2011 Upgraded
to B1 (sf)

Cl. D, Upgraded to B1 (sf); previously on Nov 23, 2011 Upgraded to
B2 (sf)

Cl. E, Upgraded to B1 (sf); previously on Nov 23, 2011 Upgraded to
B2 (sf)

Cl. F, Upgraded to B2 (sf); previously on Nov 23, 2011 Upgraded to
B3 (sf)

Cl. G, Upgraded to B3 (sf); previously on Nov 23, 2011 Upgraded to
Caa1 (sf)

Cl. H, Upgraded to Caa1 (sf); previously on Nov 23, 2011 Upgraded
to Caa2 (sf)

Cl. J, Upgraded to Caa2 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

Cl. K, Upgraded to Caa2 (sf); previously on Apr 7, 2009 Downgraded
to Caa3 (sf)

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

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

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

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

Ratings Rationale

Wachovia CRE CDO 2006-1, Ltd. is currently static cash transaction
(the reinvestment period ended in September 2011) backed by a
portfolio of a-notes and whole loans (90.0% of the pool balance),
commercial mortgage backed securities (CMBS) (6.6%), real estate
investment trust (REIT) debt (2.2%), b-notes (1.0%) and mezzanine
loans (0.3%). As of the September 25, 2012 Note Valuation report,
the aggregate Note balance of the transaction, including preferred
shares, has decreased to $1.04 billion from $1.30 billion at
issuance, with the paydown directed to the Class A-1A and Class A-
2A Notes, as a result of amortization and pay-offs to the
underlying collateral.

There are six assets with a par balance of $104.3 million (10.5%
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 low to moderate 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 3,259
compared to 3,476 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Aaa-Aa3 (1.0% compared to 3.3% at last
review), A1-A3 (3.1% compared to 2.9% at last review), Baa1-Baa3
(13.9% compared to 3.3% at last review), Ba1-Ba3 (27.8% compared
to 23.6% at last review), B1-B3 (28.4% compared to 49.7% at last
review), and Caa1-C (25.8% compared to 17.2% at last review).

Moody's modeled a WAL of 5.0 years, the same as that at last
review. The current modeled WAL incorporates updated assumptions
about extensions on the loan collateral.

Moody's modeled a fixed WARR of 53.6% compared to 54.4% at last
review.

Moody's modeled a MAC of 17.1% compared to 18.8% 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
53.6% to 43.6% or up to 63.6% would result in a modeled rating
movement on the rated tranches of 0 to 5 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.


WELLS FARGO 2004: Moody's Lowers Ratings on Two Tranches to 'C'
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 23
tranches from seven RMBS transactions, backed by Prime Loans,
issued from 2001 to 2004 by Wells Fargo.

Complete rating actions are as follows:

Issuer: Wells Fargo Mortgage Backed Securities 2003-B Trust

Cl. A-1, Downgraded to Baa2 (sf); previously on Apr 10, 2012
Downgraded to A3 (sf)

Cl. A-2, Downgraded to Baa2 (sf); previously on Apr 10, 2012
Downgraded to A3 (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2003-G Trust

Cl. A-1, Downgraded to Baa1 (sf); previously on Apr 18, 2011
Downgraded to A1 (sf)

Cl. A-IO, Downgraded to Baa1 (sf); previously on Apr 18, 2011
Downgraded to A1 (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2004-4 Trust

Cl. A-PO, Downgraded to Ba1 (sf); previously on Apr 18, 2011
Downgraded to Baa2 (sf)

Cl. A-7, Downgraded to Baa3 (sf); previously on Apr 18, 2011
Downgraded to A3 (sf)

Cl. A-8, Downgraded to Ba2 (sf); previously on Apr 18, 2011
Downgraded to Baa2 (sf)

Cl. A-9, Downgraded to Ba1 (sf); previously on Apr 18, 2011
Downgraded to Baa2 (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2004-AA Trust

Cl. A-3, Downgraded to Baa1 (sf); previously on Apr 18, 2011
Downgraded to A2 (sf)

Cl. A-4, Downgraded to Ba2 (sf); previously on Apr 18, 2011
Downgraded to Baa3 (sf)

Cl. B-1, Downgraded to Caa1 (sf); previously on Apr 18, 2011
Downgraded to B1 (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2004-G Trust

Cl. A-2, Downgraded to Ba1 (sf); previously on Apr 10, 2012
Downgraded to A3 (sf)

Cl. A-3, Downgraded to A2 (sf); previously on Apr 10, 2012
Downgraded to Aa1 (sf)

Cl. A-4, Downgraded to Ba3 (sf); previously on Apr 10, 2012
Downgraded to Baa2 (sf)

Cl. B-1, Downgraded to Caa1 (sf); previously on Apr 10, 2012
Downgraded to Ba3 (sf)

Cl. B-2, Downgraded to C (sf); previously on Apr 10, 2012
Downgraded to Ca (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2004-I Trust

Cl. I-A-1, Downgraded to Baa3 (sf); previously on Apr 18, 2011
Downgraded to A1 (sf)

Cl. II-A-1, Downgraded to Ba1 (sf); previously on Apr 18, 2011
Downgraded to Baa2 (sf)

Cl. I-A-2, Downgraded to Baa3 (sf); previously on Apr 18, 2011
Downgraded to A1 (sf)

Cl. B-1, Downgraded to Caa2 (sf); previously on Apr 18, 2011
Downgraded to B2 (sf)

Cl. B-2, Downgraded to C (sf); previously on Apr 18, 2011
Downgraded to Ca (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2004-L Trust

Cl. A-8, Downgraded to Baa2 (sf); previously on Apr 10, 2012
Downgraded to Aa2 (sf)

Cl. A-9, Downgraded to Ba3 (sf); previously on Apr 10, 2012
Downgraded to A3 (sf)

Ratings Rationale

The actions are a result of the recent performance of Prime jumbo
pools originated before 2005 and reflect Moody's updated loss
expectations on the pools. 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 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 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_SF306382

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


* S&P Lowers Ratings on 5 JC Penney-Related Transactions to 'B-'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
J.C. Penney Co. Inc.-related transactions to 'B-' from 'B+'.

"Our ratings on the five transactions are based on our rating on
the underlying security, J.C. Penny Co. Inc.'s 7.625% debentures
due March 1, 2097 ('B-')

"The rating actions reflect the Nov. 9, 2012, lowering of our
rating on the underlying security to 'B-' from 'B+'. We may take
subsequent rating actions on these transactions due to changes in
our rating assigned to the underlying security," S&P said.

              STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

       http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED

CABCO Trust for JC Penney Debentures
US$52.65 mil ser: trust certificates due 03/01/2097

        Rating
Class  To   From
Certs  B-   B+

Corporate Backed Callable Trust Certificates J C Penney Debenture-
Backed
Series 2006-1
US$27.5 mil

        Rating
Class  To   From
A-1    B-   B+
A-2    B-   B+

Corporate Backed Callable Trust Certificates J.C. Penney Debenture
Backed
Series 2007-1 Trust
US$55 mil corporate backed callable trust certificates J.C. Penney
debentures-backed series 2007-1

        Rating
Class  To   From
A-1    B-   B+
A-2    B-   B+

CorTS Trust For J.C. Penney Debentures
US$100 mil corporate-backed trust securities (CorTS) certificates

        Rating
Class  To   From
Certs  B-   B+

Structured Asset Trust Unit Repackaging (SATURNS) J.C. Penny
Company
US$54.5 mil units Series 2007-1
        Rating
Class  To   From
A      B-   B+
B      B-   B+


* S&P Lowers Ratings on 232 Classes From 103 US RMBS Transactions
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 232
classes from 103 U.S. residential mortgage-backed securities
(RMBS) transactions and removed five of them from CreditWatch with
negative implications and 36 of them from CreditWatch with
developing implications. "We also raised our ratings on 16 classes
from 12 transactions and removed three of them from CreditWatch
positive. We also affirmed our ratings on 567 classes from 159
transactions and removed six from CreditWatch developing, and one
from CreditWatch positive. We also withdrew our ratings on eight
classes from six transactions. Two of the withdrawn ratings were
on CreditWatch negative, two were on CreditWatch positive, and
one was on CreditWatch developing," S&P said.

The complete CreditWatch list is available for free at:

    http://www.bankrupt.com/misc/S&P_RMBS_RA_11_19_12.pdf

"The transactions in this review were issued between 2004 and 2007
and are backed by adjustable- and fixed-rate Alternative-A (Alt-A)
and negatively amortizing (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 56 classes from 22
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
placements accounted for approximately 57% of the actions,
CreditWatch developing placements accounted for approximately 36%,
and CreditWatch positive placements accounted for approximately
7%. We completed our review using the updated methodology and
assumptions, and 's rating actions resolve some of the Aug. 15
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          1          2        0        1        0
Watch Neg          0          0        3        0        2
Watch Dev          6          0       36        0        0

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

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

    "An increase in our default and loss multiples at higher
    investment-grade rating levels," S&P said;
    A substantial portion of nondelinquent 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 (roll
    rates indicate the rate at which loans progress from one stage
    of delinquency to the next);
    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: 54%
    of the Alt-A and 69% of the Neg-am transactions had loss
    severities that were greater than the default loss severity
    for its respective cohort," S&P said.

                                                    # Deals/
Shelf                                               Structures
Name                                                Reviewed
American Home Mortgage Assets Trust (AHA0)           7/7
Bank of America Funding Trust(BAF0)                  1/2
Bear Stearns Mortgage Funding Trust (BSF0)           3/5
BellaVista Mortgage Trust (BVM0)                     1/1
ChaseFlex Trust (CFX0)                               1/1
Alternative Loan Trust (CWA0)                       48/48
CHL Mortgage Pass-Through Trust (CWF0)               5/7
Deutsche Alt-A Securities Mortgage Loan Trust (DAA0) 1/1
DSLA Mortgage Loan Trust (DSLA)                      3/3
First Horizon Alternative Mtg Sec Tr (FHA0/FHAT)     3/3
First Horizon Mortgage Pass-Through Trust (FHMT)     1/1
GreenPoint Mortgage Funding Trust (GPM0)             5/6
GSAA Home Equity Trust (GSAA)                        2/2
GSR Mortgage Loan Trust (GSR0)                       1/1
HSI Asset Loan Obligation Trust (HALO)               1/1
HarborView Mortgage Loan Trust (HVML)               16/16
Impac CMB Trust (IMHE)                               1/2
IndyMac INDX Mortgage Loan Trust (INX0)              8/8
JPMorgan Alternative Loan Trust (JMA0)               1/1
Luminent Mortgage Trust (LUM0)                       6/8
Lehman XS Trust (LXS0)                               1/2
Nomura Asset Acceptance Corporation(NAA0)            2/2
Opteum Mortgage Acceptance Corporation Trust (OMAC)  1/1
Residential Asset Securitization Trust (RAS0)        2/2
RALI Trust (RFC0)                                   37/41
RBSGC Mortgage Loan Trust (RGC0)                     1/1
Structured Adjustable Rate Mortgage Loan Tr (SAR0)  14/27
Sequoia Alternative Loan Trust (SQA0)                1/1
SunTrust Alternative Loan Trust(STA0)                1/1
STARM Mortgage Loan Trust (STR0)                     1/1
Specialty Underwriting and Resi Finance Tr (SURF)    1/1
TBW Mortgage-Backed Trust (TBW0)                     2/2
Terwin Mortgage Trust (TWM0)                         1/1
Washington Mutual Mortgage(WAL0)                    15/17
Wells Fargo Alternative Loan Trust (WFA0)            4/4
Wells Fargo Mortgage Backed Securities Trust (WFM0)  1/1

The lists provide various vintage- and shelf-specific information
as of September 2012.

Structure Count

Vintage   Alt-A   Neg-Am
2004      5      4
2005     47     18
2006     55     45
2007     26     29

Total Delinquency (%)

Vintage   Alt-A   Neg-Am
2004     24.5   33.9
2005     20.8   52.6
2006     28.6   48.2
2007     31.8   45.1

Severe Delinquency (%)

Vintage   Alt-A   Neg-Am
2004     18.9   28.6
2005     16.0   47.8
2006     22.8   43.1
2007     26.0   40.4

Losses And Delinquencies*

Shelf     Avg. Pool    Cum. Loss   Serious DQ    Total DQ
Name      Factor (%)   Avg. (%)    Avg. (%)      Avg. (%)
AHA0      39.30        23.76       32.00         35.68
BAF0      43.19        11.14       28.02         34.11
BSF0      42.30        30.30       42.20         46.20
BVM0      14.40         3.46       28.31         33.47
CFX0      38.04         5.60       21.71         24.73
CWA0      37.59        14.15       43.00         48.22
CWF0      20.96        11.11       51.62         56.39
DAA0      56.58        20.00       45.35         48.67
DSLA      33.70        22.33       18.83         25.80
FHA0      39.84         6.07       16.25         20.72
FHAT      39.38         3.83       13.38         17.32
FHMT      32.93         2.94       12.82         14.60
GPM0      39.34        27.43       32.51         36.34
GSAA      37.60         6.90       18.94         21.53
GSR0      45.95        21.18       42.78         48.02
HALO      36.52        11.74       32.39         36.34
HVML      33.89        17.37       39.42         42.79
IMHE      39.10         8.53        6.79          8.80
INX0      36.75        19.60       28.46         36.21
JMA0      32.99        13.60       28.04         35.75
LUM0      30.20        19.00       35.13         40.33
LXS0      24.75        13.79       26.55         29.52
NAA0      22.89        11.35       31.94         36.13
OMAC      36.58        14.32       15.47         20.14
RAS0      34.61         9.33       21.97         30.39
RFC0      34.95         9.88       17.13         23.38
RGC0      34.97         3.36       18.20         24.02
SAR0      39.31        13.82       28.00         33.18
SQA0      29.63        12.43       46.45         48.79
STA0      33.27        12.86       20.84         26.76
STR0      43.01         7.38       19.58         23.37
SURF      36.61        21.48       44.69         48.22
TBW0      41.84        17.37       21.73         27.64
TWM0      30.79        22.27       15.67         18.35
WAL0      39.68         9.22       19.50         26.03
WFA0      48.53        18.48       20.53         24.85
WFM0      32.47         3.38       10.37         12.94

"Newer vintages are experiencing higher total and severe
delinquencies than older ones. The CHL Mortgage Pass-Through
Trust, Sequoia Alternative Loan Trust, Deutsche Alt-A Securities
Mortgage Loan Trust, and Specialty Underwriting and Residential
Finance Trust transactions are among those in this review with the
highest average delinquencies. Based on cumulative losses and
delinquencies, the Impac CMB Trust, Wells Fargo Mortgage Backed
Securities Trust, and First Horizon Mortgage Pass-Through Trust
transactions are among the better performing transactions in this
review," S&P said.

"In line with the factors, we revised our remaining loss
projections for all of the transactions in this review. Because we
increased our loss projections for many of the reviewed
transactions, 28% of the rating actions in this review were
downgrades. 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 16 classes from 11 Alt-A
transactions and one Neg-am transaction. The upgrades reflect
sufficient credit enhancement to support projected losses at the
respective rating levels. Some of these classes are the most
senior tranches outstanding in their respective transactions. Our
rating 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. We upgraded
other classes due to extended loss curves that increase the amount
of excess spread available for credit support in our projections.
Lastly, we upgraded some senior classes that receive principal and
interest from a particular loan group because of better projected
group-level performance," S&P said.

"We affirmed our ratings on 567 classes from 159 transactions and
removed six of them from CreditWatch developing, and one of them
from CreditWatch positive. Of these, 550 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 232 classes from 103 transactions. Of
the lowered ratings, we downgraded one class from investment-
grade. We downgraded class A-13 from Residential Asset
Securitization Trust 2005-A8CB to 'CCC (sf)' from 'AAA (sf)'
because there was not enough projected interest from the
collateral to cover projected interest payments owed to the
securities in the transaction, resulting in the diversion of
principal to pay interest. The remaining downgraded classes
already had speculative-grade ratings prior to 's actions. We
downgraded six classes from GSAA Home Equity Trust 2006-7 and one
class from RALI Series 2005-QA2 Trust to 'D (sf)' due to interest
shortfalls. We downgraded another 97 classes to 'D (sf)' due to
observed principal write-downs," S&P said.

"Senior tranches accounted for the bulk of the lowered ratings
(227); 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 nondelinquent loans. Also, ratings that
we lowered but remain at investment-grade levels were primarily
driven by our increased stress multiples applied to ratings 'A
(sf)' and above," S&P said.

"While most of the rating actions are either affirmations or
remained within several notches, there are two ratings that we are
lowering by three or more notches, and 11 ratings that we are
raising by three or more notches. The affirmations and changes of
less than three notches may have resulted from loss projections
that were relatively similar to our previous loss projections, or
cash flow dynamics that offset the impact of increased or
decreased loss projections. For instance, in transactions with
lowered loss projections, longer liquidation timelines may have
eroded projected credit support that would have otherwise been
available under our prior loss assumptions. Also, the application
of higher loss multiples at higher rating levels may have also
resulted in minimal upward rating movements and even downward
rating movements for these transactions. Conversely, increases in
projected losses may have been offset by additional excess spread
credit as a result of longer loss curves for those rating
scenarios below 'BBB-,'" S&P said.

"We withdrew our ratings on two classes from Residential Asset
Securitization Trust 2005-A8CB in accordance with our interest-
only criteria because the referenced classes no longer sustained
ratings above 'A+ (sf)'. Two classes from First Horizon Mortgage
Pass-Through Trust 2006-4 were withdrawn because they were part of
a loan group with fewer than 20 loans. We withdrew our rating on
class 2-AP from Structured Adjustable Rate Mortgage Loan Trust
Series 2007-7 because it was a prepayment penalty class no longer
entitled to receive further payments. We withdrew our ratings on
three classes from three other transactions due to principal
paydowns," S&P said.

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

"Subordination, overcollateralization (when available), and excess
interest as applicable generally provide credit support for these
Alt-A and Neg-am 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


* S&P Lowers Ratings on 1,036 Classes From 347 US RMBS Deals
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 1,036
classes from 347 U.S. residential mortgage-backed securities
(RMBS) transactions and removed 781 of them from CreditWatch with
negative implications, 185 of them from CreditWatch with
developing implications, and one of them from CreditWatch with
positive implications. "We also raised our ratings on 47 classes
from 34 transactions and removed 20 of them from CreditWatch with
positive implications and 26 of them from CreditWatch with
developing implications. We also affirmed our ratings on 1,518
classes from 381 transactions and removed 241 of them from
CreditWatch negative, 169 of them from CreditWatch developing, and
64 of them from CreditWatch positive. We also withdrew our ratings
on 20 classes because they were paid in full," S&P said.

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

   http://bankrupt.com/misc/S&P_RMBS_395_Classes_11_16_12.pdf

"The transactions in this review were issued between 1999 and 2007
and are backed by a mix of adjustable- and fixed-rate subprime,
'scratch-and-dent', and FHA/VA 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 1,506 classes from 389
of the transactions within this review on CreditWatch negative,
positive, or developing, along with ratings from a group of other
RMBS securities due to the implementation of our recently revised
criteria for surveilling pre-2009 U.S. RMBS ratings. We completed
our review of the transactions herein using the revised
assumptions and these rating actions resolve some of the
CreditWatch placements. The directional movements of the
CreditWatch resolutions within this review are," S&P said:

                              3 or fewer       More than 3
From Watch   Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos         64         14        1        6        0
Watch Neg        241          0      311        0      470
Watch Dev        169         25      165        1       20

*An additional 19 classes whose ratings are being withdrawn were
also on CreditWatch status

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

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

    "An increase in our default and loss multiples at higher
    investment-grade rating levels," S&P said;

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

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

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

    A continued elevated level of observed severities.

"In line with the factors described above, we increased our
remaining loss projections for the majority of the transactions in
this review from our previous projections. The remaining projected
losses ranged from a low of 0.16% for Aames Mortgage Trust 2001-2
to a high of 244.16% for Chase Funding Trust Series 2004-1," S&P
said.

"We lowered our ratings on 1,036 classes from 347 transactions. Of
the lowered ratings, we lowered our ratings on 266 classes out of
investment-grade, including 18 that we downgraded to 'CCC (sf)' or
lower. Of the classes we downgraded out of investment-grade, seven
classes from six transactions had ratings in the 'AAA (sf)'
categories before 's actions. Some of the downgrades to
speculative-grade from 'AAA (sf)' reflect significant increases to
our updated loss severities for the related transactions. Another
429 ratings remain at investment-grade after the downgrades. The
remaining classes with lowered ratings were already speculative-
grade before the actions," S&P said.

"In addition, we lowered our ratings on 26 classes based on our
interest shortfall criteria. These can be identified in the rating
table," S&P said.

"Despite the increase in remaining projected losses, we upgraded
47 classes from 34 transactions. In general, the upgrades reflect
two general trends we've seen in these types of transactions," S&P
said:

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

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

"All of the upgrades affected classes from transactions issued in
2003 through 2007 and were originally rated in an investment-grade
category. All of the raised ratings have sufficient projected
credit support to absorb the projected remaining losses associated
with those rating stresses," S&P said.

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

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

"We affirmed 230 'AAA (sf)' ratings from 130 transactions to
reflect the," S&P said:

    The classes have more than sufficient credit support to absorb
    the projected remaining losses associated with this rating
    stress; and

    Benefit from permanently failing cumulative loss triggers.

"The 138 affirmations from 101 transactions in the 'AA (sf)' and
'A (sf)' categories reflect," S&P said:

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

    Benefit from permanently failing cumulative loss triggers.

"In addition, we affirmed the ratings on 130 classes from 105
transactions in the 'BBB (sf)' through 'B (sf)' rating categories.
The projected credit support on these particular bonds remained
relatively in line with prior projections," S&P said.

"Lastly, we affirmed our ratings on 1,020 additional classes in
the 'CCC (sf)' or 'CC (sf)' rating categories. We believe that the
projected credit support for these classes will remain
insufficient to cover the revised projected losses to these
classes," S&P said.

"Mezzanine and lower tranches accounted for nearly 71% of the
lowered ratings (733); the remaining downgrades affected senior
classes. Contrary to the characteristics that distinguished the
upgrades and affirmations highlighted, all of these tranches with
lowered ratings did not exhibit either a high priority in payment
or a short-projected average life," S&P said.

"We withdrew our ratings on 20 classes because they were paid in
full," S&P said.

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

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

               STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

           http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS BASED ON INTEREST SHORTFALL CRITERIA

Aames Mortgage Investment Trust 2004-1
Series 2004-1
                               Rating
Class      CUSIP       To                   From
M8         00252FAM3   D (sf)               CC (sf)
M9         00252FAN1   D (sf)               CC (sf)
B1A        00252FAP6   D (sf)               CC (sf)
B1F        00252FAQ4   D (sf)               CC (sf)
B2         00252FAR2   D (sf)               CC (sf)
B3         00252FAS0   D (sf)               CC (sf)

Aames Mortgage Investment Trust 2005-2
Series 2005-2
                               Rating
Class      CUSIP       To                   From
M8         126673L75   D (sf)               CC (sf)
M9         126673L83   D (sf)               CC (sf)

Aames Mortgage Investment Trust 2005-4
Series 2005-4
                               Rating
Class      CUSIP       To                   From
M7         00252FCZ2   D (sf)               CC (sf)

ACE Securities Corp. Home Equity Loan Trust Series 1999-LB2
Series 1999-LB2
                               Rating
Class      CUSIP       To                   From
A          004421AD5   AA+ (sf)             AAA (sf)/Watch Neg

Amortizing Residential Collateral Trust 2002-BC7
Series 2002-BC7
                               Rating
Class      CUSIP       To                   From
A1         86358R7H4   AA+ (sf)             AAA (sf)/Watch Neg

Asset Backed Securities Corporation Home Equity Loan Trust, Series
2003-HE4
Series 2003-HE4
                               Rating
Class      CUSIP       To                   From
M4         04541GEX6   D (sf)               CC (sf)

Carrington Mortgage Loan Trust Series 2005-FRE1
Series 2005-FRE1
                               Rating
Class      CUSIP       To                   From
A-5        144531ED8   BBB+ (sf)            AA+ (sf)/Watch Neg
M-1        144531EF3   B+ (sf)              BBB+ (sf)/Watch Neg

C-BASS Mortgage Loan Asset-Backed Certificates Series 2007-SP1
Series 2007-SP1
                               Rating
Class      CUSIP       To                   From
A-3        1248MAAC1   AA+ (sf)             AAA (sf)/Watch Neg

Fieldstone Mortgage Investment Trust Series 2005-2
Series 2005-2
                               Rating
Class      CUSIP       To                   From
M5         31659TDY8   D (sf)               CC (sf)
M6         31659TDZ5   D (sf)               CC (sf)

GSAMP Trust 2005-WMC1
Series 2005-WMC1
                               Rating
Class      CUSIP       To                   From
A-4        362341PT0   AA+ (sf)             AAA (sf)/Watch Neg

Long Beach Mortgage Loan Trust 2004-3
Series 2004-3
                               Rating
Class      CUSIP       To                   From
A-1        542514GF5   AA+ (sf)             AAA (sf)/Watch Neg

People's Choice Home Loan Securities Trust Series 2005-1
Series 2005-1
                               Rating
Class      CUSIP       To                   From
B1         71085PBQ5   D (sf)               CC (sf)
B2         71085PBR3   D (sf)               CC (sf)

People's Choice Home Loan Securities Trust Series 2005-3
Series 2005-3
                               Rating
Class      CUSIP       To                   From
M6         71085PCW1   D (sf)               CC (sf)
M7         71085PCX9   D (sf)               CC (sf)
M8         71085PCY7   D (sf)               CC (sf)

Quest Trust 2002-X1
Series 2002-X1
                               Rating
Class      CUSIP       To                   From
M-1        748351AC7   A+ (sf)              AAA (sf)/Watch Neg

Quest Trust 2003-X4
Series 2003-X4
                               Rating
Class      CUSIP       To                   From
M-2        03072SMJ1   D (sf)               CC (sf)


* S&P Lowers Ratings on 461 Classes From 204 US RMBS Transactions
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 461
classes from 204 U.S. residential mortgage-backed securities
(RMBS) transactions and removed 250 of them from CreditWatch with
negative implications, 145 of them from CreditWatch with
developing implications, and three of them from CreditWatch with
positive implications. "We also raised our ratings on 24 classes
from 21 transactions and removed 11 of them from CreditWatch with
positive implications and 11 of them from CreditWatch with
developing implications. We also affirmed our ratings on 1,400
classes from 345 transactions and removed 104 of them from
CreditWatch negative, 164 of them from CreditWatch developing, and
136 of them from CreditWatch positive. We also withdrew our
ratings on 13 classes because they were paid in full, or in
conjunction with our criteria regarding either interest-only
classes or structures with low number of remaining loans
outstanding," S&P said.

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

       http://bankrupt.com/misc/S&P_RMBS_RA_11_16_12.pdf

"On Aug. 15, 2012, we placed our ratings on 836 classes from 352
of the transactions within this review on CreditWatch negative,
positive or developing, along with ratings from a group of other
RMBS securities due to the implementation of our recently revised
criteria for surveilling pre-2009 U.S. RMBS ratings. We completed
our review of the transactions herein using the revised
assumptions and these rating actions resolve some of the
CreditWatch placements. The directional movements of the
CreditWatch resolutions within this review are," S&P said:

                              3 or fewer       More than 3
From Watch   Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos        136          2        0        9        3
Watch Neg        104          0      113        0      137
Watch Dev        164          4      132        7       13

*An additional 12 classes whose ratings are being withdrawn were
also on CreditWatch status

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

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

    "An increase in our default and loss multiples at higher
    investment-grade rating levels," S&P said;

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

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

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

    A continued elevated level of observed severities.

"In line with the factors described above, we increased our
remaining loss projections for the majority of the transactions in
this review from our previous projections. The increased remaining
projected loss ranged from a low of 0.38% for Bear Stearns Asset
Backed Securities I Trust 2006-HE9 to a high of 147.46% for
Soundview Home Loan Trust 2003-2," S&P said.

"We lowered our ratings on 461 classes from 204 transactions. Of
the lowered ratings, we lowered our ratings on 113 classes out of
investment-grade, including 23 that we downgraded to 'CCC (sf)' or
lower. Of the classes we downgraded out of investment-grade, three
classes from two transactions had ratings in the 'AAA (sf)'
categories before the actions. For a certain number of these
downgrades to speculative-grade from 'AAA (sf)', the actions
reflect the application of our interest shortfall criteria.
Another 87 ratings remain at investment-grade after being lowered.
The remaining lowered ratings were on classes that already had
speculative-grade ratings before being lowered," S&P said.

"Despite the increase in remaining projected losses, we upgraded
24 classes from 21 transactions. In general, the upgrades reflect
two general trends we've seen in these types of transactions," S&P
said:

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

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

"All of the upgrades affected classes from transactions issued in
2003 through 2007 and were originally rated in an investment-grade
category. All of the raised ratings have sufficient projected
credit support to absorb the projected remaining losses associated
with those rating stresses," S&P said.

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

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

"The 68 'AAA (sf)' ratings from 32 transactions that we affirmed
affect bonds that reflect," S&P said:

    Have more than sufficient credit support to absorb the
    projected remaining losses associated with this rating stress;
    and
    Benefit from permanently failing cumulative loss triggers.

The 83 affirmations from 59 transactions in the 'AA (sf)' and 'A
(sf)' categories reflect:

    Classes that are currently in first, second, or third payment
    priority; and
    Benefit from permanently failing cumulative loss triggers.

"In addition, we affirmed the ratings on 262 classes from 167
transactions in the 'BBB (sf)' through 'B (sf)' rating categories.
The projected credit support on these particular bonds remained
relatively in line with prior projections," S&P said.

"Lastly, we affirmed our ratings on 987 additional classes in the
'CCC (sf)' or 'CC (sf)' rating categories. We believe that the
projected credit support for these classes will remain
insufficient to cover the revised projected losses to these
classes," S&P said.

"We withdrew our ratings on 13 classes because they were paid in
full, or in conjunction with our criteria regarding either
interest-only classes or structures with low number of remaining
loans outstanding," S&P said.

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

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com


* S&P Takes Various Rating Actions on 23 Classes From 4 CMBS Deals
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on three
classes from one commercial mortgage-backed securities (CMBS)
transaction and removed them from CreditWatch with positive
implications. "Concurrently, we lowered our ratings on 18 other
classes from three transactions and removed 11 of these ratings
from CreditWatch with negative implications. Finally, we affirmed
our ratings on two other classes from one CMBS transaction and
removed them from CreditWatch with negative implications. The
CreditWatch resolutions are related to our Sept. 5, 2012,
CreditWatch placements," 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. The upgraded of class A-
4FL from Wachovia Bank Commercial Mortgage Trust 2006-C28 also
considers our current counterparty criteria. Wells Fargo Bank
N.A., (AA-/Negative/A-1+) is the swap counterparty for the subject
class. Following the application of our counterparty criteria for
structured finance transactions, the 'AA (sf)' rating on the
subject class is one notch above our rating on Wells Fargo Bank
N.A., and is based primarily on our understanding that the
derivative obligations contain counterparty replacement
frameworks. The raised rating is consistent with the consideration
of this criteria," 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. We also took into
consideration interest shortfalls and liquidity available to the
classes. We downgraded classes E through H from the Wachovia Bank
Commercial Mortgage Trust 2006-C27 transaction to 'D (sf)' due to
accumulated interest shortfalls, which we expect to remain
outstanding for the foreseeable future," 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," S&P said.

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS AND CREDITWATCH ACTIONS

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates
Series 2006-C26
         Rating
Class  To         From                Credit enhancement (%)
A-J    B+ (sf)    BB+ (sf)/Watch Neg                13.75
B      B  (sf)    BB (sf)/Watch Neg                 11.61
C      B- (sf)    BB- (sf)/Watch Neg                10.39
D      B- (sf)    B   (sf)/Watch Neg                 8.40
E      CCC (sf)   B- (sf)                            7.03

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates
Series 2006-C27
         Rating
Class  To         From                Credit enhancement (%)
A-J    B+  (sf)   BB (sf)/Watch Neg                 12.20
B      CCC (sf)   B+ (sf)/Watch Neg                  9.26
C      CCC- (sf)  B  (sf)/Watch Neg                  7.95
D      CCC- (sf)  B- (sf)                            7.62
E      D   (sf)   CCC+ (sf)                          5.99
F      D   (sf)   CCC  (sf)                          4.84
G      D   (sf)   CCC- (sf)                          3.20
H      D   (sf)   CCC- (sf)                          1.73

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates
Series 2006-C28
         Rating
Class  To         From                Credit enhancement (%)
A-4    AA  (sf)   A+ (sf) /Watch Pos                32.11
A-4FL  AA  (sf)   A+ (sf) /Watch Pos                32.11
A-1A   AA  (sf)   A+ (sf) /Watch Pos                32.11
A-J    B+  (sf)   B+ (sf)/Watch Neg                 12.21
B      B   (sf)   B  (sf)/Watch Neg                 11.51

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates
Series 2006-C29
         Rating
Class  To         From                Credit enhancement (%)
A-M    BBB- (sf)  A- (sf) /Watch Neg                21.47
A-J    B    (sf)  BB (sf) /Watch Neg                11.15
B      B-   (sf)  BB- (sf)/Watch Neg                10.29
C      CCC  (sf)  B+ (sf) /Watch Neg                 9.14
D      CCC- (sf)  B-  (sf)                           8.14


* S&P Takes Various Rating Actions on 25 Classes From 5 CMBS Deals
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on four
classes from three commercial mortgage-backed securities (CMBS)
transactions, and removed them from CreditWatch with positive
implications. "Concurrently, we lowered our ratings on 14 classes
from four CMBS transactions and removed 10 of them from
CreditWatch with negative implications, including two classes
which we lowered to 'D' because we believe the accumulated
interest shortfalls will remain outstanding for the foreseeable
future. In addition, we affirmed our ratings on seven classes from
two transactions. The CreditWatch resolutions are related to
CreditWatch placements that we initiated on Sept. 5, 2012," S&P
said.

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

"The downgrades reflect our expected available credit enhancement
for the affected tranches, which we believe is less than our most
recent estimate of necessary credit enhancement for the most
recent rating levels. The downgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions. Furthermore, we lowered
the ratings on classes D and E from GE Commercial Mortgage Corp.
Series 2006-C1 Trust to 'D (sf)' due to these classes experiencing
interest shortfalls for four months or more and our expectation is
that they will continue to xperience interest shortfalls for the
foreseeable future," S&P said.

"The affirmations of the principal and interest certificates
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 transaction," S&P said.

"The affirmations of 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

Banc of America Commercial Mortgage Trust 2006-3
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-3    AAA(sf)    AAA (sf)                            28.60
A-4    BBB+(sf)   A+(sf)/Watch Neg                    28.60
A-1A   BBB+(sf)   A+(sf)/Watch Neg                    28.60
A-M    B(sf)      BB(sf)/Watch Neg                    16.39
A-J    CCC-(sf)   CCC+(sf)                             6.92
XW     AAA(sf)    AAA (sf)                              N/A

COBALT CMBS Commercial Mortgage Trust 2006-C1
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-2   AAA(sf)     AAA(sf)                             35.53
A-AB  AAA(sf)     AAA(sf)                             35.53
A-3   AAA(sf)     AAA (sf)                            35.53
A-4   AA+(sf)     AA-(sf)/Watch Pos                   35.53
A-1A  AA+(sf)     AA-(sf)/Watch Pos                   35.53
A-M   BB+(sf)     BBB(sf)                             22.61
A-J   CCC-(sf)    CCC-(sf)                            11.96
IO    AAA (sf)    AAA (sf)                              N/A

GE Commercial Mortgage Corp. Series 2006-C1 Trust
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-M    AAA(sf)    AA-(sf)/Watch Pos                    21.07
A-J    BB (sf)    BBB-(sf)/Watch Neg                   10.08
B      CCC (sf)   BB(sf)/Watch Neg                      7.37
C      CCC-(sf)   B+(sf)/Watch Neg                      6.32
D      D (sf)     CCC(sf)                               4.51
E      D (sf)     CCC-(sf)                               3.46

JPMorgan Chase Commercial Mortgage Securities Trust 2006-CIBC16
Commercial mortgage pass-through certificates
Rating
Class  To         From               Credit enhancement (%)

A-J   B(sf)       BB(sf)/Watch Neg                     8.63
B     B-(sf)      BB-(sf)/Watch Neg                    6.38
C     B-(sf)      B+(sf)/Watch Neg                     5.48
D     CCC(sf)     B(sf)/Watch Neg                      3.82

ML-CFC Commercial Mortgage Trust 2006-2
Commercial mortgage pass-through certificates
Rating
Class  To         From               Credit enhancement (%)

AM     AA+(sf)    A+(sf)/Watch Pos                    20.36


* S&P Takes Various Rating Actions on 19 Classes From 2 CMBS Deals
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on four
classes from two U.S. commercial mortgage-backed securities (CMBS)
transactions and removed them from CreditWatch with positive
implications. "Concurrently, we lowered our ratings on 13 classes
from the two U.S. CMBS transactions and removed four of them
from CreditWatch with negative implications. We also affirmed our
ratings on two other classes from one of the two U.S. CMBS
transactions and removed them from CreditWatch with positive
implications. The CreditWatch resolutions are related to
CreditWatch placements that we initiated on Sept. 5, 2012," S&P
said.

"The upgrades reflect Standard & Poor's expected available credit
enhancement for the affected tranches, which we believe is greater
than our most recent estimate of necessary credit enhancement for
the most recent rating levels. The upgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions. We raised our rating on
the class A-AB certificates from Morgan Stanley Capital I Trust
2007-IQ14 to reflect the results of our cash flow analysis. Our
cash flow analysis indicates that this class should receive its
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 the ratings on the class J, K, and
L bonds from Morgan Stanley Capital I Trust 2007-HQ11 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
transaction," 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 AND CREDITWATCH ACTIONS

Morgan Stanley Capital I Trust 2007-IQ14
Commercial mortgage pass-through certificates
           Rating
Class  To          From               Credit enhancement (%)
A-AB   AAA (sf)    BBB+ (sf)/Watch Pos             30.67
A-M    B (sf)      BB (sf)/Watch Neg               19.16
A-MFX  B (sf)      BB (sf) 19.16

Morgan Stanley Capital I Trust 2007-HQ11
Commercial mortgage pass-through certificates
           Rating
Class  To          From              Credit enhancement (%)
A-4    AA+ (sf)    A (sf)/Watch Pos                32.89
A-4FL  AA+ (sf)    A (sf)/Watch Pos                32.89
A-1A   AA+ (sf)    A (sf)/Watch Pos                32.89
A-M    BBB (sf)    BBB (sf)/Watch Pos              21.17
A-MFL  BBB (sf)    BBB (sf)/Watch Pos              21.17
A-J    B+ (sf)     BB (sf)                         11.94
B      B (sf)      BB- (sf)                        11.06
C      B (sf)      B+ (sf)                          9.31
D      B- (sf)     B+(sf)/ Watch Neg                8.13
E      B- (sf)     B+ (sf)/Watch Neg                7.55
F      B- (sf)     B (sf)/Watch Neg                 6.52
G      CCC (sf)    CCC+ (sf)                        5.35
H      CCC- (sf)   CCC (sf)                         4.03
J      D (sf)      CCC- (sf)                        2.86
K      D (sf)      CCC- (sf)                        1.25
L      D (sf)      CCC- (sf)                        0.81


* S&P Takes Various Rating Actions on 32 Classes From 6 CMBS Deals
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on nine
classes from five commercial mortgage-backed securities (CMBS)
transactions and removed six of them from CreditWatch with
positive implications and removed three from CreditWatch with
developing implications. "Concurrently, we lowered our ratings on
three other classes from one transaction and removed two of them
from CreditWatch with negative implications. Furthermore, we
affirmed our ratings on 19 other classes from three transactions
and removed three of them from CreditWatch with negative
implications. Finally, we withdrew our rating on one class
following the full repayment of the class' principal balance, as
noted in the trustee remittance report. The CreditWatch
resolutions are related to CreditWatch placements that we
initiated on Sept. 5, 2012," S&P said.

"The upgrades of the pooled classes 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 the A-4 and A-1A classes
from the GS Mortgage Securities Trust 2006-GG6 transaction to 'AAA
(sf)' to reflect the results of our cash flow analysis, which
indicates that these classes should receive their full repayment
of principal due to 'time tranching,'" S&P said.

"The upgrades of the 'NBT' raked classes in the LB-UBS Commercial
Mortgage Trust 2006-C3 transaction also reflect our analysis of
the $8.3 million junior nonpooled portion of the Northborough
Tower loan and follow our recently updated criteria for rating
U.S. and Canadian CMBS transactions. The raked certificates derive
100% of their cash flows from the junior nonpooled portion of the
loan," S&P said.

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

"The affirmations of the principal and interest certificates
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 transaction," S&P said.

"The affirmations of the interest-only (IO) certificates reflect
our current criteria for rating IO securities," S&P said.

"The withdrawal of our rating on the A-3B class from the J.P.
Morgan Chase Commercial Mortgage Securities Trust 2006-LDP6
transaction follows the full repayment of the class' principal
balance, as noted in the trustee remittance report," 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, CREDITWATCH ACTIONS, AND RATING WITHDRAWAL

Banc of America Commercial Mortgage Trust 2006-1
Commercial mortgage pass-through certificates
                Rating
Class     To             From           Credit Enhancement (%)
A-M       AA (sf)        A+ (sf)/Watch Pos         19.53

GS Mortgage Securities Trust 2006-GG6
Commercial mortgage pass-through certificates
                Rating
Class     To             From           Credit Enhancement (%)
A-4       AAA (sf)       AA- (sf)/Watch Pos        38.04
A-1A      AAA (sf)       AA- (sf)/Watch Pos        38.04
A-M       A+ (sf)        BBB+ (sf)/Watch Pos       24.01

Greenwich Capital Commercial Funding Corp.
Commercial mortgage pass-through certificates series 2006-GG7
                Rating
Class     To             From           Credit Enhancement (%)
A-J       B+ (sf)        B+ (sf)/Watch Neg          9.70
B         B+ (sf)        B+ (sf)/Watch Neg          8.79
C         B (sf)         B (sf)/Watch Neg           6.95

JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP6
Commercial mortgage pass-through certificates
                Rating
Class     To             From           Credit Enhancement (%)
A-3B      NR             AAA (sf)                    N/A
A-4       AAA (sf)       AAA (sf)                  32.83
A-SB      AAA (sf)       AAA (sf)                  32.83
A-1A      AAA (sf)       AAA (sf)                  32.83
A-M       A+ (sf)        BBB+ (sf)/Watch Pos       18.46
A-J       BB (sf)        BB (sf)                    7.50
B         B+ (sf)        B+ (sf)                    4.27
C         CCC+ (sf)      CCC+ (sf)                  3.01
X-1       AAA (sf)       AAA (sf)                    N/A
X-2       AAA (sf)       AAA (sf)                    N/A

LB-UBS Commercial Mortgage Trust 2006-C3
Commercial mortgage pass-through certificates
                Rating
Class     To             From           Credit Enhancement (%)
NBT-2     A+ (sf)        BB (sf)/Watch Dev           N/A
NBT-3     A- (sf)        B (sf)/Watch Dev            N/A
NBT-4     BBB+ (sf)      B- (sf)/Watch Dev           N/A

LB-UBS Commercial Mortgage Trust 2006-C7
Commercial mortgage pass-through certificates
                Rating
Class     To             From           Credit Enhancement (%)
A-2       AAA (sf)       AAA (sf)                  33.92
A-AB      AAA (sf)       AAA (sf)                  33.92
A-3       AAA (sf)       AAA (sf)                  33.92
A-1A      AAA (sf)       AAA (sf)                  33.92
A-M       A+ (sf)        BBB+ (sf)/Watch Pos       22.17
A-J       B- (sf)        BB- (sf)/Watch Neg        10.71
B         CCC (sf)       B+ (sf)/Watch Neg          9.83
C         CCC- (sf)      CCC+ (sf)                  8.65
D         CCC- (sf)      CCC- (sf)                  7.48
X-CL      AAA (sf)       AAA (sf)                    N/A
X-CP      AAA (sf)       AAA (sf)                    N/A
X-W       AAA (sf)       AAA (sf)                    N/A

N/A - Not applicable.
NR - Not rated.


* S&P Raises Ratings on 15 Classes From 5 CMBS Transactions
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 15
classes from five U.S. commercial mortgage-backed securities
(CMBS) transactions and removed nine of these ratings from
CreditWatch with positive implications and removed five of these
ratings from CreditWatch with negative implications.
"Concurrently, we lowered our ratings on 18 other classes from
five transactions and removed 14 of these ratings from CreditWatch
with negative implications. Furthermore, we affirmed our ratings
on 21 other classes from four transactions and removed two 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 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. The upgrade of several
classes to 'AAA (sf)' also considers the results of our cash flow
analysis, which indicates that these classes should receive their
full repayment of principal due to time tranching," S&P said.

"We raised our ratings on six classes from the Morgan Stanley
Capital I Trust 2006-TOP21 transaction due to the full repayment
of the Mervyns-Roll-up loan (totaling $59.4 million), which was
previously the fifth largest loan in the transaction. The full
repayment of this loan resulted in lower losses for the
transaction than we had previously anticipated. The Mervyns-Roll-
up loan comprised 25 single- tenant, Mervyns-occupied properties
on long-term, absolute net leases. Mervyns filed for Chapter 11
bankruptcy on July 29, 2008, and on Oct. 18, 2008, Mervyns
announced that it was closing all its stores in the U.S. The loan
repayments resulted in a deleveraging of class A-2 and credit
enhancement increase of classes A-2 through F," S&P said.

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

"The affirmations of the principal and interest certificates
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 transaction," S&P said.

"The affirmations of 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 AND CREDITWATCH ACTIONS

Banc of America Commercial Mortgage Trust 2006-6
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-2    AAA(sf)    AAA(sf)                             33.44
A-3    AAA(sf)    AAA(sf)/Watch Neg                   33.44
A-SB   AAA(sf)    AAA(sf)                             33.44
A-4    A(sf)      A(sf)                               33.44
A-1A   A(sf)      A(sf)                               33.44
A-M    BB-(sf)    BBB-(sf)/Watch Neg                  21.85
A-J    B-(sf)     B+(sf)/Watch Neg                    12.72
B      CCC(sf)    CCC(sf)                             10.41
XP     AAA(sf)    AAA(sf)                               N/A
XC     AAA(sf)    AAA(sf)                               N/A

Credit Suisse Commercial Mortgage Trust Series 2006-C4
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-AB   AAA(sf)    AAA(sf)                             30.59
A-3    AAA(sf)    AAA(sf)                             30.59
A-1-A  AA(sf)     AAA(sf)/Watch Neg                   30.59
A-4FL  AA(sf)     AAA(sf)/Watch Neg                   30.59
A-M    BBB-(sf)   BB(sf)/Watch Pos                    19.29
A-J    B-(sf)     B-(sf)                              10.25
B      CCC+(sf)   CCC+(sf)                             9.54
C      CCC(sf)    CCC(sf)                              7.84
A-SP   AAA(sf)    AAA(sf)                               N/A
A-X    AAA(sf)    AAA(sf)                               N/A
A-Y    AAA(sf)    AAA(sf)                               N/A

JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP7
Commercial mortgage pass-through certificates

           Rating
Class  To         From               Credit enhancement (%)
A-4    AAA(sf)    AA-(sf)/Watch Pos                   31.68
A-SB   AAA(sf)    AA-(sf)/Watch Pos                   31.68
A-1A   AAA(sf)   AA-(sf)/Watch Pos                    31.68
A-J    B+(sf)     BB(sf)/Watch Neg                    10.57
B      B(sf)      BB-(sf)/Watch Neg                    8.21
C      B-(sf)     B+(sf)/Watch Neg                     6.88
D      B-(sf)     B(sf)/Watch Neg                      6.43
E      B-(sf)     B(sf)/Watch Neg                      5.25
F      CCC(sf)    B-(sf)                               4.07

ML-CFC Commercial Mortgage Trust 2006-4
Commercial mortgage pass-through certificates
           Rating
Class  To         From               Credit enhancement (%)
A-2    AAA(sf)    AAA(sf)                             33.75
A-3    AAA(sf)    A+(sf)/Watch Pos                    33.75
A-SB   AAA(sf)    A+(sf)/Watch Pos                    33.75
A-1A   AAA(sf)    A+(sf)/Watch Pos                    33.75
AM     A-(sf)     BBB-(sf)/Watch Pos                  20.77
AJ     B(sf)      B+(sf)/Watch Neg                     9.89
AJ-FL  B(sf)      B+(sf)/Watch Neg                     9.89
B      B-(sf)     B+(sf)/Watch Neg                     9.57
C      B-(sf)     B(sf)/Watch Neg                      7.29
D      CCC(sf)    B-(sf)                               6.32
E      CCC-(sf)   B-(sf)                               4.37
F      CCC-(sf)   CCC(sf)                              3.24
G      D(sf)      CCC-(sf)                             1.78
XC     AAA(sf)    AAA(sf)                               N/A
XP     AAA(sf)    AAA(sf)                               N/A

Merrill Lynch Mortgage Trust 2006-C1
Commercial mortgage pass-through certificates

Rating
Class  To         From               Credit enhancement (%)
AM     AA(sf)     A(sf)/Watch Pos                     22.61

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

          Rating
Class  To         From               Credit enhancement (%)
A-M    AAA(sf)    AA-(sf)                             22.18
A-J    A(sf)      BBB+(sf)/Watch Neg                  12.85
B      BBB+(sf)   BBB(sf)/Watch Neg                   10.25
C      BBB-(sf)   BB+(sf)/Watch Neg                    8.70
D      BB+(sf)    BB(sf)/Watch Neg                     6.63
E      BB(sf)     BB-(sf)/Watch Neg                    5.59
F      B+(sf)     B+(sf)/Watch Neg                     4.21
G      B-(sf)     B(sf)/Watch Neg                      3.17

N/A - Not applicable.


* S&P Withdraws Ratings on 61 Classes From 46 CMBS Transactions
---------------------------------------------------------------
Standard & Poor's Ratings Services  withdrew its ratings on 61
classes from 46 commercial mortgage-backed securities (CMBS)
transactions.

"We withdrew our ratings on 53 principal and interest paying
classes from 43 CMBS transactions following the full repayment of
each class' principal balance, as noted in each transaction's
respective October 2012 trustee remittance report. We withdrew our
ratings on three interest-only (IO) classes from three CMBS
transactions following the reduction of the classes' notional
balances, as noted in each transaction's respective trustee
remittance report," S&P said.

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

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

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

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2005-5
                                 Rating
Class                  To                  From
XP                     NR                  AAA (sf)


Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2005-6
                                 Rating
Class                  To                  From
A-3                    NR                  AAA (sf)


Banc of America Commercial Mortgage Trust 2006-1
Commercial mortgage pass-through certificates series 2006-1
                                 Rating
Class                  To                  From
A-2                    NR                  AAA (sf)


Banc of America Large Loan Inc.
Commercial mortgage pass-through certificates series 2006-BIX1
                                 Rating
Class                  To                  From
D                      NR                  AAA (sf)


Bear Stearns Commercial Mortgage Securities Trust 2007-TOP28
Commercial mortgage pass-through certificates
                                 Rating
Class                  To                  From
A-2                    NR                  AAA (sf)

CD 2007-CD5 Mortgage Trust
Commercial mortgage pass-through certificates
                                 Rating
Class                  To                  From
A-AB                   NR                  AAA (sf)


COMM 2000-C1 Mortgage Trust
Commercial mortgage pass-through certificates
                                 Rating
Class                  To                  From
F                      NR                  BBB+ (sf)


Commercial Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates
1998-C1
                                 Rating
Class                  To                  From
F                        NR                  AA- (sf)


Credit Suisse Commercial Mortgage Trust Series 2006-C3
Commercial mortgage pass-through certificates
                                 Rating
Class                   To                  From
A-2                      NR                  AAA (sf)


Credit Suisse Commercial Mortgage Trust Series 2007-C3
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-CKN2
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-CKS4
                                 Rating
Class                    To                  From
B                        NR                  AAA (sf)
C                        NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-CP5
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

CRESI Finance Limited Partnership 2006-A
commercial real estate synthetic investment notes series 2006-A
                                 Rating
Class                    To                  From
G                        NR                  BBB- (sf)

First Union-Lehman Brothers Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 1997-C2
                                 Rating
Class                    To                  From
F                        NR                  AA (sf)

GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2002-2
                                 Rating
Class                    To                  From
K                        NR                  BBB (sf)
L                        NR                  BBB- (sf)
M                        NR                  BB+ (sf)

GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2002-3
                                 Rating
Class                    To                  From
E                        NR                  AAA (sf)
F                        NR                  AA+ (sf)
G                        NR                  A+ (sf)
H                        NR                  A (sf)

GMAC Commercial Mortgage Securities, Inc.
Commercial mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
D                        NR                  CCC- (sf)

GMAC Commercial Mortgage Securities, Inc.
Commercial mortgage pass-through certificates series 2002-C3
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Greenwich Capital Commercial Funding Corp.
2004-GG1
                                 Rating
Class                    To                  From
A-6                      NR                  AAA (sf)


GS Mortgage Securities Corp. II
Commercial mortgage pass-through certificates series 1999-C1
                                 Rating
Class                    To                  From
F                        NR                  BB- (sf)


JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-C1
                                 Rating
Class                    To                  From
D                        NR                  AA (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2006-FL1
                                 Rating
Class                    To                  From
F                        NR                  AAA (sf)


LB-UBS Commercial Mortgage Trust 2001-C7
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
K                        NR                  BB (sf)

LB-UBS Commercial Mortgage Trust 2002-C4

Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
E                        NR                  AA (sf)
F                        NR                  AA- (sf)

LB-UBS Commercial Mortgage Trust 2003-C3
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2005-C7
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
X-CP                     NR                  AAA (sf)


LB-UBS Commercial Mortgage Trust 2007-C1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Merrill Lynch Mortgage Trust 2005-CKI1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-4FL                    NR                  A (sf)

Morgan Stanley Capital I Inc.
Commercial mortgage pass-through certificates series 1998-CF1
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)

Morgan Stanley Capital I Inc.
Commercial mortgage pass-through certificates series 1998-WF1
                                 Rating
Class                    To                  From
J                        NR                  A (sf)

Morgan Stanley Capital I Inc.
Commercial mortgage pass-through certificates series 1998-WF2
                                 Rating
Class                    To                  From
E                        NR                  AA+ (sf)

Morgan Stanley Capital I Trust 2004-HQ4
Commercial mortgage pass-through certificates series 2004-HQ4
                                 Rating
Class                    To                  From
X-2                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2004-IQ7
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2005-HQ7
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2008-TOP29
Commercial mortgage pass-through certificates
                                Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Morgan Stanley Dean Witter Capital I Trust 2001-PPM
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
E                        NR                  A (sf)

Prudential Commercial Mortgage Trust 2003-PWR1
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Prudential Securities Secured Financing Corp.
Commercial mortgage pass-through certificates series 1998-C1
                                 Rating
Class                    To                  From
G                        NR                  A (sf)

Salomon Brothers Commercial Mortgage Trust 2002-KEY2
Commercial mortgage pass-through certificates
                                 Rating
Class                    To                  From
N                        NR                  BB- (sf)

UBS Commercial Mortgage Trust 2007-FL1
Commercial mortgage pass-through certificates
                                 Rating
Class                   To                  From
A-1                     NR                  AA+ (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2002-C2
                                 Rating
Class                    To                  From
E                        NR                  AA+ (sf)
F                        NR                  AA (sf)
G                        NR                  AA- (sf)
H                        NR                  A (sf)


Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C23
                                 Rating
Class                  To                  From
A-PB                   NR                  AAA (sf)

RATINGS WITHDRAWN AND NEGATIVE OUTLOOK REMOVED

World Financial Properties Tower D Finance Corp.
Pass-through certificates series 1996 WFP-D
                                 Rating
Class                  To                  From
A                      NR                  A- (sf)/Negative

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

GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2002-3
                                 Rating
Class                  To                  From
X-1                    NR                  AAA (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-C1
                                 Rating
Class                  To                  From
X-1                    NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2002-C4
Commercial mortgage pass-through certificates
                                 Rating
Class                  To                  From
X-CL                   NR                  AAA (sf)

UBS Commercial Mortgage Trust 2007-FL1
Commercial mortgage pass-through certificates
                                 Rating
Class                  To                  From
X                      NR                  AA+ (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2002-C2
                                 Rating
Class                  To                  From
IO-I                   NR                  AAA (sf)


* S&P Withdraws Ratings on 982 Classes From 205 RMBS Transactions
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 982
classes from 205 U.S. residential mortgage-backed securities
(RMBS) transactions and removed 648 of them from CreditWatch with
negative implications, 84 from CreditWatch with developing
implications, and one from CreditWatch with positive implications.
"The downgrade of the class with the rating on CreditWatch
positive was due to our analysis using updated loss severity
information. We also raised our ratings on 154 classes from 31
transactions and removed 49 of them from CreditWatch positive, 75
from CreditWatch developing, and 18 from CreditWatch negative
because we obtained additional loan-level information that was not
available at the time of the CreditWatch placements. We also
affirmed our ratings on 966 classes from 258 transactions and
removed 67 of them from CreditWatch negative, 57 from CreditWatch
developing, and seven from CreditWatch positive. We subsequently
withdrew five of the lowered ratings and seven of the affirmed
ratings because of our view of the potential for performance
volatility associated with collateral groups that contain fewer
than 20 loans. In addition, we withdrew our ratings on 26 classes
from 19 transactions, 22 of which were on CreditWatch negative,
one on CreditWatch developing, and three on CreditWatch positive.
We withdrew 21 of these ratings in accordance with our current
interest-only criteria and five of them because they have been
paid in full," S&P said.

"Of the 340 structures from 301 transactions reviewed: 289 are
prime jumbo, 45 are synthetic risk transfer, four are Alt-A, one
is Neg-am, and one is subprime. The 45 U.S. residential mortgage-
backed securities (RMBS) synthetic risk transfer transactions
reviewed were issued by RESI Finance (RESI) and RESIX Finance Ltd.
(RESIX)," S&P said.

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

       http://bankrupt.com/misc/S&P_RMBS_RA_11_21_12.pdf

The transactions in this review were issued between 1987 and 2007
and are backed by adjustable- and fixed-rate mortgage loans
secured primarily by first liens on one- to four-family
residential properties.

"On Aug. 15, 2012, we placed our ratings on 1,032 classes from 131
of these transactions on CreditWatch negative, positive, or
developing, along with ratings from a group of other RMBS
securities due to the implementation of our recently revised
criteria for surveilling pre-2009 U.S. RMBS ratings. CreditWatch
negative placements accounted for approximately 73% of the
resolved CreditWatch actions in this review, CreditWatch
developing placements accounted for approximately 21%, and
CreditWatch positive placements accounted for approximately 6%. We
completed our review on these transactions using the revised
assumptions, and these rating actions resolve some of the
CreditWatch placements," S&P said.

                              3 or fewer       More than 3
From         Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos          7         29        1       20        0
Watch Neg         67         18      355        0      293
Watch Dev         57         53       61       22       23

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

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

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

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

-- S&P's extended liquidation curves that eroded projected credit
    support prior to when it would be needed.

Shelf                                               # Deals
                                                    /Structures
Name                                                Reviewed
American Housing Trust (AHM)                        1/1
Banc of America Funding (BAF)                       2/2
Banc of America Mortgage Trust (BAM)                5/6
CHL Mortgage Pass Through Trust (CHL)               46/48
Chase Mortgage Finance Trust (CMF)                  7/7
Citigroup Mortgage Loan Trust Inc. (CML)            7/14
Collateralized Mortgage Securities Corp. (COL)      2/2
CSMC Mortgage-Backed Trust (CSM)                    3/6
First Horizon Mortgage Pass Through Trust (FHM)     9/9
Fannie Mae REMIC Trust (FNM)                        2/2
GMACM Mortgage Loan Trust (GMC)                     6/6
GreenPoint Mortgage Loan Trust (GPM)                1/1
GSR Mortgage Loan Trust (GSR)                       26/27
HarborView Mortgage Loan Trust (HBV)                8/8
IndyMac IMJA Mortgage Loan Trust (IND)              1/1
JPMorgan Mortgage Trust (JPM)                       8/9
Lehman Mortgage Trust (LMT)                         3/5
MortgageIT Securities Corp. (MIT)                   1/1
Merrill Lynch Mortgage Investors Trust (MLM)        5/5
Morgan Stanley Mortgage Loan Trust (MSM)            3/3
MASTR Asset Securitization Trust (MST)              4/4
Prime Mortgage Trust (PMT)                          3/3
RAAC Trust (RAC)                                    1/1
RFSC Trust (RFC)                                    1/2
RFMSI Trust (RFM)                                   35/40
RAMP Trust (RPM)                                    5/6
RESI Finance Limited Partnership (RSI)              8/8
RESIX Finance Limited (RSX)                         37/37
Structured Asset Securities Corp. (SAS)             4/4
Saxon Mortgage Securities Corp. (SAX)               1/1
Structured Adjustable Rate MLT (SRM)                14/17
Thornburg Mortgage Securities Trust (THR)           2/2
Wachovia Mortgage Loan Trust (WAC)                  1/1
WaMu Mortgage Pass-Through Certificates (WAM)       20/25
Wells Fargo Mortgage Backed Securities (WFM)        19/20

The lists detail information on shelves S&P reviewed as of
September 2012.

Losses And Delinquencies*
(for shelves where a significant number of transactions were
reviewed)

Shelf     Avg. Pool    Cum. Loss   Serious DQ    Total DQ
Name      Factor (%)   Avg. (%)    Avg. (%)      Avg. (%)
BAM       30.98        3.44        17.11         19.52
CHL       36.69        4.39        18.27         22.14
CMF       30.92        3.29        10.43         11.92
CML       36.14        5.87        14.10         17.84
FHM       34.61        4.73        9.33          12.05
GMC       33.53        4.75        7.40          11.82
GSR       25.22        1.81        9.46          11.72
HBV       16.49        2.69        18.52         22.08
JPM       34.87        4.36        15.17         19.53
MLM       27.55        3.31        16.87         19.70
RFM       29.84        3.64        8.15          12.18
RPM       11.98        1.18        10.89         15.26
SRM       30.48        5.21        15.01         19.66
WAM       18.90        1.84        7.68          10.21
WFM       11.96        0.50        3.01          4.08

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

Shelf-Level Affirmations/Rating Movement

Shelf     # IG         # Non-IG    # IG to       # Down/Up
Name      Affirmed     Affirmed    Non-IG        >3 notches
AHM       4            0           0             0/0
BAF       0            3           0             0/0
BAM       0            10          0             0/0
CMF       0            27          4             11/0
CML       0            11          0             1/0
COL       3            0           0             0/0
CSM       0            23          0             0/0
CHL       2            137         2             24/2
FHM       0            26          0             0/1
FNM       0            2           1             3/0
GMC       0            22          0             0/0
GNP       0            1           1             0/0
GSR       20           69          5             61/27
HBV       3            17          2             4/6
IND       0            0           0             0/0
JPM       0            45          0             0/0
LMT       0            32          0             0/0
MST       0            57          0             0/0
MIT       0            1           0             0/0
MLM       5            11          0             0/0
MSM       2            7           0             0/0
PMT       0            1           0             0/0
RSI       2            36          10            14/0
RSX       0            31          2             2/0
RFC       3            3           4             10/0
RFM       4            88          11            40/3
RMP       7            18          0             13/2
RAC       0            2           0             1/0
SRM       10           57          0             18/2
SAS       5            10          2             21/0
SAX       0            0           0             0/0
THR       0            8           0             0/0
WFM       16           50          9             65/5
WAC       0            10          0             0/0

IG - Investment grade.

"In risk transfer transactions, the owner of a pool of mortgage
loans (the 'protection buyer') enters into a financial guarantee
contract with the issuer (the 'protection seller') of the
securities. Pursuant to the guarantee agreement, the protection
seller guarantees to pay the protection buyer an amount equal to
certain losses realized on the underlying pool of mortgage loans,
known as the reference portfolio. The mortgage pools we reviewed
in the eight RESI transactions consist primarily of first-lien,
fixed-rate and adjustable-rate prime jumbo mortgage loans. The 37
RESIX transactions contain credit-linked notes that replicate the
cash flow of subordinate tranches issued within certain RESI
transactions," S&P said.

"In risk transfer transactions, unlike traditional mortgage-backed
securitizations, the actual cash flow from the reference portfolio
is not paid to the issuer and ultimately to the transactions'
security holders. Rather, the proceeds from the issuance of the
securities are deposited in an eligible account and are then
invested in eligible investments. The interest payable to the
security-holders is paid from income earned on these investments,
as well as from payments made by the protection buyer under the
financial guarantee contract. The principal payable to the
security-holders is paid from funds initially deposited into the
eligible account. Principal payments on the securities mirrors the
principal payments made on the reference portfolio," S&P said.

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

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

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

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

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

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

"We reviewed and subsequently withdrew our ratings on 12 classes
from three transactions because these classes are backed by
collateral groups that contain fewer than 20 loans. While the
groups on an aggregate basis may contain greater than 20 loans at
the respective transaction level, we expect our base case loss to
breach the amount of subordination in the near term, at which
point each group will be independent. If any of the remaining
loans in this pool were to default, the resulting loss could have
a greater effect on the pool's performance than if the pool
consisted of a larger number of loans. Because this performance
volatility may have an adverse effect on the stability of our
outstanding ratings, we subsequently withdrew seven of the lowered
ratings and five of the affirmed ratings due to the small number
of loans remaining," S&P said.

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

"Of the downgraded classes, we lowered our ratings on 68 classes
to speculative-grade from investment-grade. Of these classes, we
lowered 58 to ratings between 'BB+ (sf)' and 'B- (sf)' and lowered
10 to 'CCC (sf)' or 'CC (sf)'. Additionally, 537 of the lowered
ratings remain at investment-grade. The remaining 377 downgraded
classes already had speculative-grade ratings prior to the
downgrades," S&P said.

"We affirmed our ratings on 835 classes in the 'CCC (sf)' or 'CC
(sf)' categories. We believe that the projected credit support for
these classes will remain insufficient to cover the revised base-
case projected losses to these classes," S&P said.

"In addition to the 12 ratings we withdrew because the related
pools contain fewer than 20 loans, we withdrew our ratings on 26
other classes from 19 transactions. We withdrew 21 of these
ratings in accordance with our interest-only (IO) criteria because
the referenced classes no longer sustain ratings above 'A+ (sf)'
and we withdrew five ratings because the classes have been paid in
full," S&P said.

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

"Credit support is generally provided by subordination for the
prime jumbo transactions reviewed while overcollateralization
(prior to its depletion) and excess spread, when applicable,
provide support for additional structures reviewed," S&P said.

"When reviewing the risk transfer transactions, we applied our
criteria described in 'Methodology: U.S. RMBS Synthetic Risk
Transfers,' published Feb. 6, 2009. We looked at several factors,
including the recent performance of the prime collateral backing
these transactions, our current projected losses, the projected
credit support to cover those losses, and the rating of the
applicable party responsible for making certain interest payments
(i.e. protection buyer)," 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.


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