TCR_Public/121202.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, December 2, 2012, Vol. 16, No. 335

                            Headlines

AMERICAN CREDIT 2012-3: S&P Gives Prelim BB Rating on Cl. D Notes
APIDOS CLO I: S&P Affirms 'B+' Rating on Class D Notes; Off Watch
ARES XV CLO: S&P Assigns Prelim. 'BB' Rating on Class E Notes
ATLAS SENIOR II: S&P Rates $16.75MM Class E Deferrable Notes 'BB'
BANC OF AMERICA 2005-2: Moody's Affirms 'Caa3' Rating on O Certs.

CABCO TRUST: Moody's Lowers Rating on MTN Program to 'Caa1'
CFCRE COMMERCIAL 2011-C2: Moody's Affirms 'B2' Rating on G Certs.
CHL MORTGAGE: Moody's Cuts Ratings on 12 Tranches to 'Caa3'
CITIGROUP COMMMERCIAL: Fitch Cuts Rating on 10 Cert. Classes
COLTS 2007-1: S&P Hikes Rating on Class E Notes to 'BB'; Off Watch

COMM COMMERCIAL: Moody's Cuts Ratings on 3 CMBS Classes to 'C'
COMM MORTGAGE 2005-FL10: Fitch Keeps 'C' Rating on 2 Debt Classes
CONCORD REAL ESTATE: Moody's Affirms 'Caa3' Rating on Cl. F Notes
EMPORIA PREF I: S&P Affirms 'BB' Ratings on Two Note Classes
GALAXY III: S&P Raises Ratings on 3 Note Classes to 'B'; Off Watch

GRAMERCY REAL 2007-1: Moody's Junks Rating on Class A-2 Notes
GREYROCK CDO: S&P Affirms 'BB+' Ratings on 2 Note Classes
GS MORTGAGE: Moody's Affirms 'Ba1' on Class J Certificates
HALCYON LOAN 2012-1: S&P Affirms 'BB' Rating on $15MM Cl. D Notes
HALCYON LOAN 2012-2: S&P Gives 'BB' Rating on $18.2MM Cl. E Notes

ING IM 2012-4: S&P Assigns 'BB' Rating on Class D Deferrable Notes
JC PENNEY 2007-1: Moody's Cuts Ratings on Two Certs to 'Caa1'
JFIN 2007: S&P Affirms 'BB+' Rating on Class D Notes; Off Watch
JP MORGAN 2002-CIBC4: Moody's Cuts Rating on C Certs. to 'Caa1'
JP MORGAN 2007-LDP11: Moody's Cuts Rating on B Certs. to 'Caa3'

JP MORGAN 2012-PHH: S&P Rates $8.2MM Class E Certificates 'BB+'
KINGSLAND I: Moody's Hikes Rating on Class D Notes to 'Ba2'
LCM XII: S&P Affirms 'BB' Rating on Class E Deferrable Notes
MAGNETITE V: S&P Affirms 'B+' Rating on Class D Notes
NATIONAL COLLEAGIATE: Moody's Corrects Nov. 20 Rating Release

NEWSTAR COMMERCIAL: Moody's Rates $24.1MM Class F Notes '(P)B2'
NORTHWOODS CAPITAL IV: Moody's Ups Ratings on 2 CLO Notes to Ba1
NORTHSTAR 2012-1: Moody's Assigns 'B2' Rating to Class F Certs.
OCTAGON INVESTMENT XIV: S&P Gives 'B' Rating on Class E Def Notes
PHOENIX CDO II: Fitch Affirms 'Csf' Rating on Two Class Notes

PREFERREDPLUS BLC-2: S&P Raises Rating on $33.5MM Certs. to 'BB'
SATURNS 2007-1: Moody's Cuts Ratings on 2 Cert. Classes to 'Caa1'
SCHOONER TRUST: Moody's Affirms 'B3' Rating on Class K Certs.
SORIN REAL ESTATE: Moody's Lifts Rating on Cl. A-3 Notes to 'B3'
THORNBURG MORTGAGE 2005-4: Moody's Cuts 2 Tranche Ratings to Caa2

US AIRWAYS: Moody's Assigns 'B1' Rating to Cl. B Certificates
UTAH HOUSING: Moody's Cuts Rating on Revenue Bonds to 'Caa1'
WACHOVIA BANK 2006-C26: Moody's Cuts Rating on G Certs. to 'Ca'
WFRBS 2012-C10: Moody's Rates Class F Certificates '(P)B2'

* Fitch Cuts Rating on 6 Security Classes From 9 CRE CDOs
* Fitch Downgrades 54 Bonds on 33 CMBS Transactions to 'D'
* Moody's Lowers Ratings on $1-Bil. 2005-2007 Prime Jumbo RMBS
* S&P Puts Ratings on 26 Tranches From 25 Synthetic CDOs on Watch
* S&P Takes Various Rating Actions on 1,163 RMBS Classes

* S&P Takes Various Rating Actions on 19 Classes From 3 CMBS Deals


                            *********

AMERICAN CREDIT 2012-3: S&P Gives Prelim BB Rating on Cl. D Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to American Credit Acceptance Receivables Trust 2012-3's
$205 million asset-backed notes series 2012-3.

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

The preliminary ratings are based on information as of Nov. 26,
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 availability of approximately 45%, 42%, 35%, and 30% of
    credit support for the class A, B, C, and D notes based on
    break-even stressed cash flow scenarios (including excess
    spread), which provide coverage of more than 1.95x, 1.80x,
    1.50x, and 1.25x our expected net loss range of 21.65%-22.15%
    for the class A, B, C, and D notes," S&P said.

    "The timely interest and principal payments made to the
    preliminary rated notes by the assumed legal final maturity
    dates under our stressed cash flow modeling scenarios that we
    believe are appropriate for the assigned preliminary ratings,"
    S&P said.

    "Our expectation that under a moderate, or 'BBB', stress
    scenario the ratings on the class A, B, and C notes would
    remain within one rating category of our preliminary 'A+
    (sf)', 'A (sf)', and 'BBB (sf)' ratings. These potential
    rating movements are consistent with our credit stability
    criteria, which outline the outer bound of credit
    deterioration equal to a two-category downgrade within the
    first year for 'A through 'BB' rated securities under moderate
    stress conditions," S&P said.

    The collateral characteristics of the subprime automobile
    loans securitized in this transaction.

    The backup servicing arrangement with Wells Fargo Bank N.A.
    (Wells Fargo).

    The transaction's payment and credit enhancement structures,
    which include performance triggers.

    The transaction's legal structure.

              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/1131.pdf

PRELIMINARY RATINGS ASSIGNED

American Credit Acceptance Receivables Trust 2012-3

Class   Rating    Type          Interest         Amount
                                rate        (mil. $)(i)
A       A+ (sf)   Senior        Fixed            153.76
B       A (sf)    Subordinate   Fixed              9.52
C       BBB (sf)  Subordinate   Fixed             20.86
D       BB (sf)   Subordinate   Fixed             20.86

(i) The actual size of these tranches will be determined on the
     pricing date.


APIDOS CLO I: S&P Affirms 'B+' Rating on Class D Notes; Off Watch
-----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-2, B, and C notes from Apidos CDO I, a U.S. collateralized
loan obligation (CLO) managed by Apidos Capital Management LLC.
"At the same time, we affirmed our rating on the class D notes,"
S&P said.

"The upgrades reflect paydowns to the class A-1 notes since March
2012. The affirmed ratings reflect our belief that the credit
support available is commensurate with the current rating level,"
S&P said.

Apidos CDO I Ltd. ended its reinvestment period on July 18, 2011.
Since our last rating action, the class A-1 notes have paid down
more than $92 million and have a current outstanding balance of
$148.7 million, which is about 56% of their original balance.

As a result of the paydowns, the overcollateralization (O/C)
ratios have improved significantly. The senior O/C ratio, the
class A-2 O/C, has improved 7.3% while the subordinate class D O/C
ratio has improved 1.3%.

"We note that according to the Oct. 16, 2012, trustee report, the
transaction held $3.15 million defaulted assets, slightly higher
than the $2.21 million noted in the Feb. 21, 2012, trustee report,
which we used for our March actions," S&P said.

"We did not upgrade the class D notes at this point primarily
because the transaction is subject to potential market value risks
due to its exposure to long-dated securities. The transaction
currently has approximately $7.66 million in underlying collateral
that matures after the legal final maturity of the transaction,"
S&P said.

Standard & Poor's will continue to review whether, in its view,
the ratings 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

Apidos CDO I
                       Rating
Class              To           From
A-1                AAA (sf)     AA+ (sf)/Watch Pos
A-2                AAA (sf)     AA+ (sf)/Watch Pos
B                  AA- (sf)     A (sf)/Watch Pos
C                  BBB+ (sf)    BBB- (sf)/Watch Pos
D                  B+ (sf)      B+ (sf)/Watch Pos


ARES XV CLO: S&P Assigns Prelim. 'BB' Rating on Class E Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to ARES XXV CLO Ltd./Ares XXV CLO LLC's $507.25 million
fixed- and floating-rate notes.

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

The preliminary ratings are based on information as of Nov. 29,
2012. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect S&P's view of:

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

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

    The transaction's legal structure, which is expected to be
    bankruptcy remote.
    The diversified collateral portfolio, which consists primarily
    of broadly syndicated speculative-grade senior secured term
    loans.

    The asset manager's experienced management team.

    S&P's projections regarding the timely interest and ultimate
    principal payments on the preliminary rated notes, which it
    assessed using its cash flow analysis and assumptions
    commensurate with the assigned preliminary ratings under
    various interest-rate scenarios, including LIBOR ranging from
    0.3100%-12.5332%.

    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/1143.pdf

PRELIMINARY RATINGS ASSIGNED

Ares XXV CLO Ltd./Ares XXV CLO LLC

Class                         Rating          Amount
                                            (mil. $)
A                             AAA (sf)        339.50
B-1                           AA (sf)          45.00
B-2                           AA (sf)          23.75
C                             A (sf)           42.25
D                             BBB (sf)         29.00
E                             BB (sf)          24.75
Subordinated notes            NR (sf)          60.25

NR - Not rated.


ATLAS SENIOR II: S&P Rates $16.75MM Class E Deferrable Notes 'BB'
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Atlas
Senior Loan Fund II Ltd./Atlas Senior Loan Fund II LLC's $367
million floating-rate notes.

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

The ratings reflect S&P's view of:

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

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

    The timely interest and ultimate principal payments on the
    rated notes, which we assessed using our cash flow analysis
    and assumptions commensurate with the assigned ratings under
    various interest-rate scenarios, including LIBOR ranging from
    0.34%-12.60%.

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

    The transaction's interest diversion test, a failure of which,
    during the reinvestment period, will lead to the
    reclassification of up to 50% of excess interest proceeds that
    are available prior to curing an effective date rating agency
    confirmation failure or paying subordinated, deferred, and
    incentive management fees; uncapped administrative expenses;
    hedge payments; and subordinated note payments into principal
    proceeds for the purchase of additional collateral assets or
    to pay down the notes sequentially, at the option of the
    collateral manager.

                STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATINGS ASSIGNED
Atlas Senior Loan Fund II Ltd./Atlas Senior Loan Fund II LLC

Class                 Rating              Amount
                                        (mil. $)
A                     AAA (sf)            257.00
B                     AA (sf)              32.00
C (deferrable)        A (sf)               41.00
D (deferrable)        BBB (sf)             20.25
E (deferrable)        BB (sf)              16.75
Subordinated notes    NR                   46.50

NR - Not rated.


BANC OF AMERICA 2005-2: Moody's Affirms 'Caa3' Rating on O Certs.
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 18 classes of
Banc of America, Commercial Mortgage Pass-Through Certificates,
Series 2005-2 as follows:

Cl. A-AB, Affirmed at Aaa (sf); previously on Jul 5, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-5, Affirmed at Aaa (sf); previously on Jul 5, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aaa (sf); previously on Jul 5, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-J, Affirmed at Aaa (sf); previously on Aug 27, 2009
Confirmed at Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Aug 27, 2009 Confirmed
at Aa2 (sf)

Cl. C, Affirmed at Aa3 (sf); previously on Aug 27, 2009 Confirmed
at Aa3 (sf)

Cl. D, Affirmed at A3 (sf); previously on Aug 27, 2009 Downgraded
to A3 (sf)

Cl. E, Affirmed at Baa1 (sf); previously on Aug 27, 2009
Downgraded to Baa1 (sf)

Cl. F, Affirmed at Baa2 (sf); previously on Aug 27, 2009
Downgraded to Baa2 (sf)

Cl. G, Affirmed at Baa3 (sf); previously on Aug 27, 2009
Downgraded to Baa3 (sf)

Cl. H, Affirmed at Ba2 (sf); previously on Aug 27, 2009 Downgraded
to Ba2 (sf)

Cl. J, Affirmed at Ba3 (sf); previously on Aug 27, 2009 Downgraded
to Ba3 (sf)

Cl. K, Affirmed at B1 (sf); previously on Aug 27, 2009 Downgraded
to B1 (sf)

Cl. L, Affirmed at B2 (sf); previously on Aug 27, 2009 Downgraded
to B2 (sf)

Cl. M, Affirmed at Caa2 (sf); previously on Aug 27, 2009
Downgraded to Caa2 (sf)

Cl. N, Affirmed at Caa2 (sf); previously on Aug 27, 2009
Downgraded to Caa2 (sf)

Cl. O, Affirmed at Caa3 (sf); previously on Aug 27, 2009
Downgraded to Caa3 (sf)

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

Ratings Rationale

The affirmations are due to key parameters, including Moody's loan
to value (LTV) ratio, Moody's stressed debt service coverage ratio
(DSCR) and the Herfindahl Index (Herf), remaining within
acceptable ranges. Based on 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-C, is consistent with the credit performance of its
referenced classes and thus is affirmed.

Moody's rating action reflects a cumulative base expected loss of
2.9% of the current balance compared to 3.2% at last review.
Moody's provides a current list of base losses for conduit and
fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

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

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

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

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

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

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 22 compared to 26 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 16, 2011.

Deal Performance

As of the November 13, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 40% to $978.7
million from $1.64 billion at securitization. The Certificates are
collateralized by 67 mortgage loans ranging in size from less than
1% to 11% of the pool, with the top ten loans representing 55% of
the pool. Two loans, representing 3% of the pool, have defeased
and are secured by U.S. Government securities.

Eleven loans, representing 11% 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.

Six loans have been liquidated from the pool, resulting in a
realized loss of $6 million (16% loss severity). There are
currently no loans in special servicing.

Moody's has assumed a high default probability for eight poorly
performing loans representing 8% of the pool and has estimated an
aggregate $12 million loss (17% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2011 operating results for 99%
of the pool. Excluding troubled loans, Moody's weighted average
LTV is 91% compared to 95% at Moody's prior review. Moody's net
cash flow reflects a weighted average haircut of 12% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.0%.

Excluding troubled loans, Moody's actual and stressed DSCRs are
1.65X and 1.17X, respectively, compared to 1.60X and 1.11X at last
review. Moody's actual DSCR is based on Moody's net cash flow
(NCF) and the loan's actual debt service. Moody's stressed DSCR is
based on Moody's NCF and a 9.25% stressed rate applied to the loan
balance.

The top three performing loans represent 29% of the pool. The
largest loan is the NYU Housing -- 80 Lafayette Street Loan ($110
million -- 11.2% of the pool), which is secured by a 264-unit
student housing property located in the Tribeca submarket of New
York City. The property is 100% master leased to New York
University through August 2017. Performance has increased since
securitization due to annual rent increases. Moody's LTV and
stressed DSCR are 94% and 0.93X, respectively, compared to 96% and
0.90X, at last review.

The second largest loan is the Canyon Ranch Loan ($95 million --
9.7% of the pool), which is secured by two spa/resort hotels
containing a total of 315 rooms. The resorts are located in
Tucson, Arizona and Lenox, Massachusetts. Performance continues to
improve due to increases in occupancy and total revenue per guest
night. Both of the collateral properties derive a large percentage
of revenue from spa services, therefore, total revenue per guest
night is considered a more appropriate performance metric than
revenue per available room (RevPAR) is. Moody's LTV and stressed
DSCR 68% and 1.68X, respectively, compared to 80% and 1.42X at
last review.

The third largest loan is the 589 Fifth Avenue Loan ($73.5 million
-- 7.5% of the pool), which is secured by a 165,000 square foot
office property located in the Diamond District of Manhattan, New
York. The property has a bank branch on the ground level and
approximately 80 jewelry related tenants. The property was 89%
leased as of June 2012 compared to 87% at last review. The loan is
current, but is on the watchlist for low debt service coverage.
Moody's LTV and stressed DSCR are 114% and 0.88X respectively,
compared to 110% and 0.91X at last review.


CABCO TRUST: Moody's Lowers Rating on MTN Program to 'Caa1'
-----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of the
following certificates issued by CABCO Trust for J. C. Penney
Debentures:

Issuer: Corporate Asset Backed Corporation

Trust Certificates MTN Program, Downgraded to Caa1; previously on
August 13, 2009 Downgraded to Ba3;

Ratings Rationale

The transaction is a structured note whose ratings is based on the
rating of the Underlying Securities and the legal structure of the
transaction. The rating actions are a result of the change of the
rating of J.C. Penney Corporation, Inc. 7.625% Debentures due
March 1, 2097, which was downgraded to Caa1 from Ba3 on November
20, 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
the underlying security.

Moody's says that the underlying securities are 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 ratings on the underlying
securities, they could also negatively impact the ratings on the
note.


CFCRE COMMERCIAL 2011-C2: Moody's Affirms 'B2' Rating on G Certs.
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 13 classes of
CFCRE Commercial Mortgage Trust 2011-C2 Commercial Mortgage Pass-
Through Certificates, Series 2011-C2 as follows:

Cl. A-1, Affirmed at Aaa (sf); previously on Dec 16, 2011
Definitive Rating Assigned Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Dec 16, 2011
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Dec 16, 2011
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Dec 16, 2011
Definitive Rating Assigned Aaa (sf)

Cl. A-J, Affirmed at Aaa (sf); previously on Dec 16, 2011
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa2 (sf); previously on Dec 16, 2011 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed at A2 (sf); previously on Dec 16, 2011 Definitive
Rating Assigned A2 (sf)

Cl. D, Affirmed at Baa1 (sf); previously on Dec 16, 2011
Definitive Rating Assigned Baa1 (sf)

Cl. E, Affirmed at Baa3 (sf); previously on Dec 16, 2011
Definitive Rating Assigned Baa3 (sf)

Cl. F, Affirmed at Ba2 (sf); previously on Dec 16, 2011 Definitive
Rating Assigned Ba2 (sf)

Cl. G, Affirmed at B2 (sf); previously on Dec 16, 2011 Definitive
Rating Assigned B2 (sf)

Cl. X-A, Affirmed at Aaa (sf); previously on Dec 16, 2011
Definitive Rating Assigned Aaa (sf)

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

Ratings Rationale

The affirmations are due to key parameters, including Moody's loan
to value (LTV) ratio, Moody's stressed debt service coverage ratio
(DSCR) and the Herfindahl Index (Herf), remaining within
acceptable ranges. Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings. The ratings 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 2.5% 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, and "Moody's Approach to Rating Structured Finance Interest-
Only Securities" published in February 2012.

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

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 20, the same as at securitization.

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 19, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 1% to $765.5
million from $774.1 million at securitization. The Certificates
are collateralized by 51 mortgage loans ranging in size from less
than 1% to 13% of the pool, with the top ten loans representing
57% of the pool.

There are no loans on the master servicer's watchlist. One loan,
representing 1.5% of the pool, is currently in the special
servicing. The loan is secured by a 384-unit apartment complex
located in Blacklick, Ohio. The loan was transferred to the
special servicer on July 7th, 2012 due to the guarantor being
investigated by the SEC for an alleged Ponzi scheme. The loan's
performance has been stable. Moody's doesn't expect any loss from
this loan at this time.

Moody's was provided with full year 2011 and partial year 2012
operating results for 89% and 81%, respectively, of the pool.
Moody's weighted average LTV is 93%, the same as at
securitization. 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 9.4%.

Moody's actual and stressed DSCRs are 1.46X and 1.13X,
respectively, compared 1.46X and 1.12X 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 31% of the pool balance. The largest
loan is the RiverTown Crossings Mall Loan ($98.1 million -- 12.8%
of the pool), which is a pari-passu interest in a $153.3 million
first mortgage loan. The loan is secured by a 691,000 square foot
(SF) portion of a 1.2 million SF regional mall located in
Grandville, Michigan. The property is also encumbered with $12.9
of mezzanine financing. The Mall's anchors include Macy's,
Younkers, Sears, Kohl's, JCPenney, (all non-collateral) and Dick's
Sporting Goods and Celebration Cinemas. As of June 2012 the total
mall was 92% leased, essentially the same as at securitization.
Performance has been stable. The loan sponsor is GGP Limited
Partnership. Moody's LTV and stressed DSCR are 82% and 1.15X,
respectively, the same as at securitization.

The second largest loan is the Plaza Mexico Loan ($80.8 million --
10.6% of the pool), which is secured by a 394,772 SF retail
community center located in Lynwood, California. The anchors are
Food 4 Less, La Curacao, and Rite Aid. As of August 2012, the
property was 92% leased compared to 93% at securitization.
Property performance has slightly declined due to higher expenses.
Moody's LTV and stressed DSCR are 87% and 1.08X, respectively,
compared to 85% and 1.1X at securitization.

The third largest loan is the GSA -- FBI Portfolio Loan ($58.5
million -- 7.6% of the pool), which is secured by two single-
tenant office buildings that are 100% leased to the General
Services Administration to the United States federal government.
The properties are located in Las Vegas, Nevada and Louisville,
Kentucky and are occupied by the Federal Bureau of Investigation.
Both the properties were built to suit for the FBI. The two tenant
leases are scheduled to expire beyond the loan term, with the
earliest expiration occurring in 2021. Moody's LTV and stressed
DSCR are 101% and 0.96X, respectively, the same as at
securitization.


CHL MORTGAGE: Moody's Cuts Ratings on 12 Tranches to 'Caa3'
-----------------------------------------------------------
Moody's Investors Service has downgraded eleven tranches and
upgraded one tranche issued by Countrywide. The collateral backing
these deals primarily consists of first-lien, fixed and
adjustable-rate Prime Jumbo residential mortgages. The actions
impact approximately $301 million of RMBS issued from 2005 to
2006.

Complete rating actions are as follows:

Issuer: CHL Mortgage Pass-Through Trust 2005-31

Cl. 2-A-1, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Confirmed at B3 (sf)

Cl. 2-A-2, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 2-A-3, Upgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Ca (sf)

Cl. 3-A-1, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 4-A-1, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Confirmed at B3 (sf)

Cl. 4-A-2, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Issuer: CHL Mortgage Pass-Through Trust 2006-14

Cl. A-3, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to B2 (sf)

Cl. A-4, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. A-5, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. A-6, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. PO, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. X, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to B2 (sf)

Ratings Rationale

The actions are a result of the recent performance of the pools
backing the transactions 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 certain bonds than previously
anticipated.

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

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

Loan Modifications

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

Small Pool Volatility

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

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

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

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_SF308105

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

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


CITIGROUP COMMMERCIAL: Fitch Cuts Rating on 10 Cert. Classes
------------------------------------------------------------
Fitch Ratings has downgraded 10 classes and affirmed 16 classes of
Citigroup Commercial Mortgage Trust's commercial mortgage pass-
through certificates, series 2007-C6.

The downgrades reflect an increase in Fitch modeled losses across
the pool. Fitch modeled losses of 14.3% of the original pool
(including losses of 1.1% incurred to date), compared to 11%
modeled at the previous rating action.  The increase is
predominantly due to declining pool performance and an increased
volume of loans in special servicing.  There are currently 45
specially serviced loans (14.5%) in the pool, compared to 24 loans
(7.9%) at the previous rating action.

As of the November 2012 distribution date, the pool's aggregate
principal balance was $4.4 billion, down from $4.8 billion at
issuance.  There is one defeased loan (0.03%).  There are
cumulative interest shortfalls in the amount of $21.4 million
currently affecting classes H through S.

Fitch has identified 109 loans (26.5%) as Fitch Loans of Concern,
which includes 45 specially serviced loans (14.5%).  Thirteen
loans within the top 15 have Fitch loan to values (LTVs) in excess
of 90%, including two loans in special servicing, which can impact
a loan's ability to refinance at maturity.

The largest contributor to losses was the Hyde Park Apartment
Portfolio, representing 2.84% of the outstanding pool balance.
The loan is secured by 43 properties, consisting of 951 units. The
latest reported debt service coverage ratio (DSCR) was 0.71x, as
of June 30, 2012, with occupancy of 82%.  The borrower completed
$26 million of renovations in 2011, updating kitchens, baths,
walls, ceilings and floor coverings, as well as improving common
areas.

The second largest contributor to losses was Moreno Valley Mall
(1.92% of the pool).  The collateral consists of 472,844 square
feet (sf) of a 1.1 million sf regional mall in Moreno Valley, CA,
just east of Riverside, CA.  The mall is anchored by J.C. Penney,
Macys, and Sears, and contains a 150,000 sf vacant anchor space,
which are not part of the collateral.  The property was originally
transferred to special servicing as part of the GGP bankruptcy and
was modified. The loan re-defaulted and became REO through a deed
in lieu of foreclosure in February 2011.  Recent leasing efforts
have resulted in increased occupancy at the mall. According to a
Sept. 30, 2012 rent roll, the property is approximately 82%
occupied, whereas it was 53.8% occupied on Nov. 30, 2011.

The third largest contributor to losses was the Southeast
Apartment Portfolio (0.85% of the pool).  The loan is
collateralized by seven multifamily properties located in South
Carolina and Georgia.  The portfolio, which is REO, had an average
occupancy of 77.4%, as of Nov. 1, 2012.

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

  -- $425.6 million class A-M to BBBsf from AAAsf; Outlook Stable;
  -- $50 million class A-MFL to BBBsf from AAAsf; Outlook Stable;
  -- $248.3 million class A-J to CCCsf from BBsf; RE 80%;
  -- $150 million class A-JFL to CCCsf from BBsf; RE 80%;
  -- $23.8 million class B to CCsf from Bsf; RE 0%;
  -- $71.3 million class C to CCsf from CCCsf; RE 0%;
  -- $35.7 million class D to CCsf from CCCsf; RE 0%;
  -- $29.7 million class E to Csf from CCsf; RE 0%;
  -- $35.7 million class F to Csf from CCsf; RE 0%;
  -- $47.6 million class G to Csf from CCsf; RE 0%.

In addition, Fitch affirms the following classes, maintains
Outlooks and revises REs as follows:

  -- $71.5 million class A-2 at AAAsf; Outlook Stable;
  -- $387 million class A-3 at AAAsf; Outlook Stable;
  -- $126.3 million class A-3B at AAAsf; Outlook Stable;
  -- $125.4 million class A-SB at AAAsf; Outlook Stable;
  -- $1,573 million class A-4 at AAAsf; Outlook Stable;
  -- $200 million class A-4FL at AAAsf; Outlook Stable;
  -- $477.4 million class A-1A at AAAsf; Outlook Stable;
  -- $53.5 million class H at Csf; RE 0%;
  -- $65.4 million class J at Csf; RE 0%;
  -- $53.5 million class K at Csf; RE 0%;
  -- $11.9 million class L at Csf; RE 0%;
  -- $11.9 million class M at Csf; RE 0%;
  -- $17.8 million class N at Csf; RE 0%;
  -- $11.9 million class O at Csf; RE 0%;
  -- $5.9 million class P at Csf; RE 0%;
  -- $5.9 million class Q at Csf; RE 0%.

Fitch does not rate class S. Class A-1 is paid in full.  The
rating on class X was previously withdrawn.


COLTS 2007-1: S&P Hikes Rating on Class E Notes to 'BB'; Off Watch
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C, D, and E notes from Colts 2007-1 Ltd., a U.S. collateralized
loan obligation (CLO) managed by Ares Management LLC. "In
addition, we affirmed our ratings on the class A and B notes," S&P
said.

"The upgrades reflect paydowns to the class A notes and
improvement in the credit quality of the underlying assets since
our last upgrade in February 2012. The affirmed ratings reflect
our belief that the credit support available is commensurate with
the current rating level," S&P said.

"Colts 2007-1 Ltd. has ended its reinvestment period since our
last rating action on Feb. 9, 2012, and has been amortizing since
March 20, 2012," S&P said.

"Since our last rating action, the class A notes have paid down
more than $51 million and have a current outstanding balance of
$108 million, which is about 42% of their original balance. As a
result, the overcollateralization (O/C) ratios have improved
significantly. The senior class B o/c ratio has improved 23.88%
while the subordinate class E ratio has improved 2.89%. The
average O/C improvement in the transaction is about 10.62% across
the four B, C, D, and E O/C ratios in the transaction," S&P said.

"The improvements are also reflected in the reduction in the
defaulted assets held. According to the Oct. 5, 2012, trustee
report, the transaction held $20.99 million defaulted assets, down
from $27.55 million noted in the January 6, 2012, trustee report,
which we used for our February actions," S&P said.

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Colts 2007-1 Ltd.
                       Rating
Class              To           From
A                  AAA (sf)     AAA (sf)
B                  AAA (sf)     AAA (sf)
C                  AA+ (sf)     AA- (sf)/Watch Pos
D                  A+ (sf)      BBB+ (sf)/Watch Pos
E                  BB (sf)      B+ (sf)/Watch Pos


COMM COMMERCIAL: Moody's Cuts Ratings on 3 CMBS Classes to 'C'
--------------------------------------------------------------
Moody's Investors Service affirmed the ratings of five classes,
downgraded nine classes and placed three CMBS classes on review
for possible downgrade of COMM Commercial Mortgage Pass-Through
Certificates, Series 2004-LNB4 as follows:

Cl. A-4, Affirmed at Aaa (sf); previously on Feb 3, 2011 Upgraded
to Aaa (sf)

Cl. A-5, Downgraded to Baa3 (sf) and Placed Under Review for
Possible Downgrade; previously on Aug 4, 2011 Downgraded to A1
(sf)

Cl. A-1A, Downgraded to Baa3 (sf) and Placed Under Review for
Possible Downgrade; previously on Aug 4, 2011 Downgraded to A1
(sf)

Cl. B, Downgraded to B2 (sf); previously on Dec 2, 2011 Downgraded
to Ba1 (sf)

Cl. C, Downgraded to Caa2 (sf); previously on Dec 2, 2011
Downgraded to B2 (sf)

Cl. D, Downgraded to Caa3 (sf); previously on Dec 2, 2011
Downgraded to Caa1 (sf)

Cl. E, Downgraded to C (sf); previously on Dec 2, 2011 Downgraded
to Caa2 (sf)

Cl. F, Downgraded to C (sf); previously on Aug 4, 2011 Downgraded
to Caa3 (sf)

Cl. G, Downgraded to C (sf); previously on Aug 4, 2011 Confirmed
at Ca (sf)

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

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

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

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

Cl. X-C, Downgraded to B2 (sf) and Placed Under Review for
Possible Downgrade; 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 downgrades are due to increased interest shortfalls and
deteriorating credit support resulting from anticipated losses
from loans in special servicing. Two classes were placed on review
for possible downgrade due to concerns about increases to future
interest shortfalls. As of the most recent remittance statement,
the pool has experienced cumulative interest shortfalls totaling
$11.6 million impacting classes P through B.

The IO Class, Class XC, is downgraded and placed on review for
possible downgrade due to deteriorating credit support from its
referenced classes and the potential for future downgrades to its
referenced classes.

Moody's rating action reflects a cumulative base expected loss of
12.0% of the current balance compared to 8.9% at last review.
Moody's provides a current list of base expected losses for
conduit and fusion CMBS transactions on moodys.com at
http://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 28 compared to 29 at last review.

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

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

Deal Performance

As of the November 15, 2012 distribution date, the transaction's
aggregate certificate balance has decreased 38% to $763.9 million
from $1.2 billion at securitization. The Certificates are
collateralized by 91 mortgage loans ranging in size from less than
1% to 10% of the pool. Seven loans, representing 6.7% of the pool,
have defeased and are backed by U.S. Government securities. The
pool does not contain any loans with an investment grade credit
assessment.

There are presently 14 loans, representing 16% of the pool, on the
master servicer's watchlist. The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the CRE Finance Council (CREFC) monthly reporting package. As part
of its ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Nine loans have been liquidated from the pool since
securitization, resulting in an aggregate $32.2 million loss (49%
loss severity on average). Currently nine loans, representing 18%
of the pool, are in special servicing. Moody's has estimated an
aggregate $73.0 million loss (62% expected loss overall) from the
specially serviced loans.

Moody's has assumed a high default probability for five poorly
performing loans representing 6% of the pool and has estimated an
$8.0 million aggregate loss (17% 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 98% and 70% of the performing pool,
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average conduit LTV is 88% compared to 87% at
last review. Moody's net cash flow reflects a weighted average
haircut of 10.8% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.4%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed conduit DSCRs are 1.33X and 1.24X, respectively,
compared to 1.33X and 1.26X, respectively, at last full review.
Moody's actual DSCR is based on Moody's net cash flow (NCF) and
the loan's actual debt service. Moody's stressed DSCR is based on
Moody's NCF and a 9.25% stressed rate applied to the loan balance.

The loan with a credit assessment is the 731 Lexington Avenue Loan
($57.2 million -- 7.5% of the pool), which is a 23.6%
participation interest in a $242.5 million loan. The property is
also encumbered by an $86 million junior loan which is held
outside the trust. The loan is secured by a 694,634 square foot
(SF) office building located in New York City. The property is
100% leased to Bloomberg, LP until 2028. Performance has been
stable. Moody's current credit assess.e,t and stressed DSCR are A3
and 2.33X, respectively, compared to A3 and 2.05X at last review.

The top three performing conduit loans represent 18% of the pool
balance. The largest loan is the Crossings at Corona-Phase I & II
Loan ($73.7 million -- 9.7% of the pool), which is secured by a
503,037 SF retail power center located in Corona, California. The
property was 99% leased as of June 2012 versus 98% at last review.
Property performance has steadily increased over the past two
years. This loan has amortized 7% since securitization. Moody's
LTV and stressed DSCR are 96% and 0.96X, respectively, compared to
102% and 0.9X at last review.

The second largest loan is the Woodyard Crossing Shopping Center
Loan ($35.2 million -- 4.6% of the pool), which is secured by a
483,724 SF retail power center located in Washington, DC. The
property was 99% leased, the same as last review. The largest
tenants are Wal-Mart, Lowe's and Safeway. Performance increased
since last review. The loan has amortized 27% since
securitization. Moody's LTV and stressed DSCR are 67% and 1.44X,
respectively, compared to 74% and 1.31X at last review.

The third largest loan is the 280 Trumbull Street Loan ($30.9
million -- 4.0% of the pool), which is secured by a 664,479 SF
office property located in Hartford, Connecticut. The property was
70% leased as of December 2011, the same as at last review. The
loan is on the servicer's watchlist due to high vacancy and a
decline in income. Although performance has declined over the past
two years, the property generates sufficient cash flow to cover
debt service payments. Year-end 2011 DSCR was 1.36X. Moody's LTV
and stressed DSCR are 110% and 0.93X, respectively, compared to
88% and 1.16X at last review.


COMM MORTGAGE 2005-FL10: Fitch Keeps 'C' Rating on 2 Debt Classes
-----------------------------------------------------------------
Fitch Ratings has affirmed four classes of COMM Mortgage Trust
2005-FL10.  The affirmations of the distressed ratings are due to
continued high credit risk associated with the remaining loan.
As of the November 2012 remittance, the pool has paid down by 98%
since issuance, with only one loan remaining.  Since Fitch's last
rating action, the 10 MetroTech Center loan was disposed of for a
$7.9 million loss.

The remaining loan, Berkshire Mall (100%), is secured by 589,146
square feet (sf) of a 715,146-sf regional mall located in
Lanesboro, MA, about 30 miles east of Albany, NY.  The collateral
consists of 192,793 sf of in-line space and 396,353 sf of
anchor/major tenant space.  The non-collateral anchor space
(Target) totals approximately 126,000 sf.  The property has
suffered from a tertiary location and weak in-line / junior anchor
occupancy.

In March 2012, a two-year forbearance through March 2014 was
executed after the borrower was unable to refinance the loan at
its extended maturity.  Per the forbearance agreement, the
borrower contributed $250,000 in new equity to a rollover reserve.
In addition, the loan is subject to hard cash management requiring
excess cash flow be applied to an excess cash flow reserve (up to
$300,000), then to a rollover reserve (up to $4 million), and then
to amortize the loan.  As of Nov. 9, 2012, the loan had
approximately $4.2 million in total reserves.  After being in
special servicing since February 2010, the loan was returned to
the master servicer in September 2012 and was current as of the
November remittance.

Fitch has affirmed the following classes:

  -- $6.4 million class J at 'CCCsf'; RE 100%;
  -- $19.8 million class K at 'Csf'; RE 95%;
  -- $6.5 million class L at 'Csf'; RE 0%;
  -- $4.3 million class M at 'Dsf'; RE 0%.

The following classes originally rated by Fitch have paid in full:
A-1, A-J1, A-J2, X-1, MOAX-1, MOAX-2, MOAX-3, B, C, D, E, F, MOA-
1, MOA-2, N-PC, O-PC, P-PC, Q-PC, N-DEL and O-DEL.

Fitch does not rate the class A-J3, G, H and MOA-3 certificates.

In addition, Fitch previously withdrew the ratings on the
interest-only classes X-2-DB, X-2-NOM, X-2-SG, X-3-DB, X-3-NOM and
X-3-SG.


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

Moody's rating action is as follows:

Cl. A-1, Affirmed at A1 (sf); previously on Dec 9, 2010 Downgraded
to A1 (sf)

Cl. A-2, Affirmed at Baa3 (sf); previously on Dec 9, 2010
Downgraded to Baa3 (sf)

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

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

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

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

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

Ratings Rationale

Concord Real Estate CDO 2006-1, Ltd. is a static (the reinvestment
period ended in December 2011) cash transaction backed by a
portfolio of B-Note debt and rake bonds (30.5% of the pool
balance), commercial mortgage backed securities (CMBS) (25.6%),
whole loans (21.1%), mezzanine loans (20.0%), and CRE CDO bonds
(2.8%). As of the October 25, 2012 payment date, the aggregate
Note balance of the transaction, including Preference Shares, has
decreased to $311.7 million from $465.0 million at issuance, as a
result of the combination of the junior notes cancellation to
Classes C through H Notes and of the paydown directed to the Class
A-1 Notes from regular amortization of collateral, and resolution
and subsequent sales of defaulted collateral. In general, holding
all key parameters static, the junior note cancellations results
in slightly higher expected losses and longer weighted average
lives on the senior Notes, while producing slightly lower expected
losses on the mezzanine and junior Notes. However, this does not
cause, in and of itself, a downgrade or upgrade of any outstanding
classes of Notes. The transaction is passing all its par value
tests and its interest coverage tests. Currently, the transaction
is over-collateralized by $45.7 million.

There are five assets with par balance of $47.2 million (13.2% of
the current pool balance) that are considered defaulted securities
as of the October 25, 2012 payment date, compared to four
defaulted securities totaling $54.5 million par amount (13.9%) at
last review. Moody's does expect moderate to high losses to occur
from these defaulted securities once they are realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 4,417 compared to 4,950 at last review. The
current distribution of Moody's rated collateral and assessments
for non-Moody's rated collateral is as follows: Aaa-Aa3 (10.7%
compared to 10.4% at last review), A1-A3 (6.0% compared to 4.5% at
last review),Baa1-Baa3 (0.0%, same as that at last review), Ba1-
Ba3 (5.4% compared to 0.0% at last review), B1-B3 (26.5% compared
to 27.1% at last review), and Caa1-Ca/C (51.4% compared to 58.0%
at last review).

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

Moody's modeled a fixed 24.8% WARR, compared to 24.0% at last
review.

Moody's modeled a MAC of 14.1%, compared to 13.3% 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 24.8% to 14.8% or up to 34.8% would result in modeled
rating movement on the rated Notes of 2 to 4 notches downward and
0 to 4 notches upward, respectively.

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

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

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

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

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


EMPORIA PREF I: S&P Affirms 'BB' Ratings on Two Note Classes
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B-1, B-2, C, and D notes from Emporia Preferred Funding I Ltd.,
a U.S. collateralized loan obligation (CLO) transaction managed by
A.C. Corp. "In addition, we affirmed our ratings on the class E-1
and E-2 notes," S&P said.

"The upgrades reflect paydowns to the senior notes since we
affirmed our ratings on seven classes in June 2011. The
affirmation of the ratings on the class E-1 and E-2 notes reflect
our belief that the credit support available is commensurate with
the current rating levels," S&P said.

"Emporia Preferred Funding I Ltd. ended its reinvestment period on
Oct. 12, 2011, and has been paying down the class A notes since
that time. Since our June 2011 rating actions, the transaction has
paid down the class A notes more than $144 million, and this class
has a current outstanding balance of $130.57 million, which is
about 47% of its original balance," S&P said.

"As a result of the paydowns, the transaction's
overcollateralization (O/C) ratios have improved significantly. On
average the O/C ratios have improved about 4.7%. The senior class
B-2 O/C ratio has improved 9.3%, while the subordinate class E-2
ratio has improved 1.5%," S&P said.

"According to the Oct. 5, 2012, trustee report, the transaction
currently holds about $11.48 million in defaulted assets, slightly
more than the $8.64 million noted in the May 2, 2011, trustee
report, which we used for our June 2011 actions," S&P said.

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

               STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Emporia Preferred Funding I Ltd.
                       Rating
Class              To           From
A                  AAA (sf)     AA+ (sf)/Watch Pos
B-1                AAA (sf)     AA- (sf /Watch Pos
B-2                AAA (sf)     AA- (sf)/Watch Pos
C                  AA (sf)      A- (sf)/Watch Pos
D                  BBB- (sf)    BB+ (sf)/Watch Pos
E-1                BB (sf)      BB (sf)/Watch Pos
E-2                BB (sf)      BB (sf)/Watch Pos


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

The transaction is in its amortization phase and paid down the
class A-2, B, C, and D notes in full on its most recent payment
date on Nov. 19, 2012. It also paid down the class E-1, E-2, and
E-3 notes - which are pari passu - to 14.4% of their original
balances.

"We raised our ratings on the class E notes based on the
improvement in their overcollateralization levels and the credit
quality of the underlying loans supporting the class E notes," S&P
said.

"We withdrew our ratings on the class A-2, B, C, and D notes
following their paydowns," S&P said.

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

          http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Galaxy III CLO Ltd.
                  Rating
Class         To      From
A-2           NR      AAA (sf)
B             NR      AAA (sf)
C             NR      AA+ (sf)/Watch Pos
D             NR      BBB+ (sf)/Watch Pos
E-1           B (sf)  CCC- (sf)/Watch Pos
E-2           B (sf)  CCC- (sf)/Watch Pos
E-3           B (sf)  CCC- (sf)/Watch Pos

NR - Not rated.


GRAMERCY REAL 2007-1: Moody's Junks Rating on Class A-2 Notes
-------------------------------------------------------------
Moody's Investors Service has downgraded the rating of one class
of Notes issued by Gramercy Real Estate CDO 2007-1, Ltd. The
downgrade is solely driven by Moody's announcement on November 19,
2012 that it had downgraded the insurance financial strength
rating of MBIA Insurance Corporation to Caa2 from B3. This rating
action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO and
Re-REMIC) transactions.

Moody's rating action is as follows:

Cl. A-2, Downgraded to Caa2 (sf); previously on Nov 23, 2011
Downgraded to B3 (sf)

Ratings Rationale

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 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.

The rating implementation guidelines used in this rating were
"Assignment of Wrapped Ratings When Financial Guarantor Falls
Below Investment Grade" published in May, 2008 and "Moody's
Modifies Approach to Rating Structured Finance Securities Wrapped
by Financial Guarantors" published in November 2008.


GREYROCK CDO: S&P Affirms 'BB+' Ratings on 2 Note Classes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2L, A-3L, B-1F, and B-1L notes from Greyrock CDO Ltd., a
collateralized loan obligation (CLO) transaction currently managed
by Aladdin Capital Management LLC. "We also we affirmed our
ratings on the class A-1L, B-2F, and B-2L notes. Concurrently, we
removed our ratings on the class A-2L, A-3L, B-1F, B-1L, B-2F, and
B-2L notes from CreditWatch with positive implications," S&P said.

"The rating actions follow our performance review of the
transaction and primarily reflect $67.4 million in paydowns on the
class A-1L notes to 54.5% of their original balance. 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 seven classes of notes. The
senior class A, class A, B-1, and B-2 O/C ratios have increased by
absolute differences of 10.4%, 5.7%, 3.0%, and 1.5%, respectively,
since the January 2012 trustee report which we referenced for our
February 2012 rating actions," S&P said.

"Other positive factors in our analysis include a decrease in the
portfolio weighted average life from 3.8 to 3.4 years and an
increase in the weighted-average spread from 3.76% to 4.02%," S&P
said.

The transaction is in its amortization phase and continues to use
its principal proceeds to pay down the A-1L notes.

"We will continue to review our ratings on the notes and assess
whether, in our view, the ratings remain consistent with the
credit enhancement available to support them and take rating
actions as we deem necessary," S&P said.

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

          http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Greyrock CDO Ltd.
                            Rating
Class                   To           From
A-2L                    AAA (sf)     AA+ (sf)/Watch Pos
A-3L                    AA+ (sf)     A+ (sf)/Watch Pos
B-1F                    A- (sf)      BBB+ (sf)/Watch Pos
B-1L                    A- (sf)      BBB+ (sf)/Watch Pos
B-2F                    BB+ (sf)     BB+ (sf)/Watch Pos
B-2L                    BB+ (sf)     BB+ (sf)/Watch Pos

RATING AFFIRMED

Greyrock CDO Ltd.

Class                   Rating
A-1L                    AAA (sf)


GS MORTGAGE: Moody's Affirms 'Ba1' on Class J Certificates
----------------------------------------------------------
Moody's Investors Service affirmed the ratings of ten classes of
GS Mortgage Securities Corporation II, Pass-Through Certificates
Series 2005-ROCK as follows:

Cl. A, Affirmed at Aaa (sf); previously on Jun 1, 2005 Definitive
Rating Assigned Aaa (sf)

Cl. A-FL, Affirmed at Aaa (sf); previously on Jun 1, 2005
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aa1 (sf); previously on Jun 1, 2005 Definitive
Rating Assigned Aa1 (sf)

Cl. C-1, Affirmed at A1 (sf); previously on Mar 4, 2009 Downgraded
to A1 (sf)

Cl. E, Affirmed at A3 (sf); previously on Mar 4, 2009 Downgraded
to A3 (sf)

Cl. F, Affirmed at Baa1 (sf); previously on Mar 4, 2009 Downgraded
to Baa1 (sf)

Cl. G, Affirmed at Baa2 (sf); previously on Mar 4, 2009 Downgraded
to Baa2 (sf)

Cl. H, Affirmed at Baa3 (sf); previously on Mar 4, 2009 Downgraded
to Baa3 (sf)

Cl. J, Affirmed at Ba1 (sf); previously on Mar 4, 2009 Downgraded
to Ba1 (sf)

Cl. X-1, Affirmed at A1 (sf); previously on Feb 22, 2012
Downgraded to A1 (sf)

Ratings Rationale

The affirmations of the principal certificate classes are due to
the stable performance of the real estate collateral and key
parameters including Moody's loan to value (LTV) ratio and Moody's
stressed debt service coverage (DSCR) remaining within acceptable
ranges. The rating of the IO Class, Class X-1 is consistent with
the performance of its referenced classes and is thus affirmed.

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 February 2, 2012.

DEAL PERFORMANCE

The $1,685.0 million Rockefeller Center loan is secured by a
$1,210.0 million first lien mortgage on the borrower's fee
interest and leasehold interests in the property; the additional
$475.0 million in debt is secured by a pledge of 100% of the
equity interest in the borrower. The fixed-rate interest-only loan
has a 20-year term maturing in May 2025. Non-trust subordinate
debt consists of a $320 million mezzanine loan, also maturing in
May 2025.

Rockefeller Center is a 10-building office, retail and
entertainment complex, located in midtown Manhattan, New York
City. The landmark development consists of approximately 6.7
million square feet of office, retail, entertainment and
commercial area. Amenities include the Top of the Rock observation
deck, plaza areas, a skating rink and Radio City Music Hall. As of
June 2012, the 5.3 million square feet of office space was 93%
leased, the same as at securitization. The total property,
including Radio City Music Hall, was 94% leased, compared to 92%
at last review and the same as at securitization.

The ten largest office tenants lease approximately 45% of total
office net rentable area (NRA) and contribute approximately 39% of
total rent. The largest office tenant is Lazard Freres & Co.
leasing approximately 474,558 square feet at 30 Rockefeller Plaza
and 600 Fifth Avenue with the majority of its space expiring in
2033. The second largest tenant is Deloitte, LLP with
approximately 430,000 square feet. Deloitte, LLP signed an 18-year
lease in January 2011 at 30 Rockefeller Plaza. Deloitte currently
occupies approximately 126,868 square feet with occupancy and
lease commencement on the balance of the space scheduled for 2014
and 2015. Deloitte is expanding into space currently occupied by
Chadbourne & Parke whose lease expires in September 2014. Other
significant tenants include Bank of America, N.A. that leases
337,134 square feet at 50 Rockefeller Plaza through January 2021;
Simon & Schuster, Inc. that leases 292,391 square feet at 1230
Avenue of the Americas through November 2019; and Christie's Inc.
that leases 185,310 square feet at various locations through July
2028.

Significant retail tenants include Radio City Music Hall that
leases 545,250 square feet with lease expiration in February 2023.
Radio City Music Hall's rent accounts for approximately 14% of
total retail rent. Other significant retail tenants include
Equinox Rockefeller Center (85,474 square feet), Banana Republic
(34,075 square feet), NBC Universal (19,924 square feet) and
Faconnable USA Corp. (14,500 square feet). Banana Republic's rent
contribution is equal to 11% of total retail rent, second to Radio
City Music Hall.

Moody's loan to value (LTV) ratio is 71%, the same as last review.
Moody's stressed debt service coverage (DSCR) is 1.29X. compared
to 1.30X at last review. Moody's credit assessment is Ba1, the
same as last review.


HALCYON LOAN 2012-1: S&P Affirms 'BB' Rating on $15MM Cl. D Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on Halcyon
Loan Advisors Funding 2012-1 Ltd./Halcyon Loan Advisors Funding
2012-1 LLC's $322 million floating-rate notes following the
transaction's effective date as of Oct. 5, 2012.

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

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

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

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

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

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

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

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

          http://standardandpoorsdisclosure-17g7.com

RATINGS AFFIRMED
Halcyon Loan Advisors Funding 2012-1 Ltd./Halcyon Loan Advisors
Funding 2012-1
LLC

Class                  Rating          Amount
                                     (mil. $)
A-1                    AAA (sf)       230.000
A-2                    AA (sf)         32.000
B (deferrable)         A (sf)          30.000
C (deferrable)         BBB (sf)        15.000
D (deferrable)         BB (sf)         15.000


HALCYON LOAN 2012-2: S&P Gives 'BB' Rating on $18.2MM Cl. E Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Halcyon
Loan Advisors Funding 2012-2 Ltd./Halcyon Loan Advisors Funding
2012-2 LLC's 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 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 collateral manager's experienced management team.

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

    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/1125.pdf

RATINGS ASSIGNED

Halcyon Loan Advisors Funding 2012-2 Ltd./Halcyon Loan Advisors
Funding 2012-2
LLC

Class                  Rating                 Amount
                                            (mil. $)
X                      AAA (sf)                3.000
A                      AAA (sf)              278.000
B (deferrable)         AA (sf)                39.500
C (deferrable)         A (sf)                 38.250
D (deferrable)         BBB (sf)               19.500
E (deferrable)         BB (sf)                18.250
Subordinated notes     NR                     43.500
Combination notes(i)   A-p(sf)(NRi)(ii)       10.000

(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.


ING IM 2012-4: S&P Assigns 'BB' Rating on Class D Deferrable Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to ING IM
CLO 2012-4 Ltd./ING IM CLO 2012-4 LLC's $371.2 million floating-
rate notes and $10.0 million combination securities.

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

The ratings reflect S&P's view of:

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

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

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

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

    The collateral manager's experienced management team.

    S&P's projections regarding the timely interest and ultimate
    principal payments on the rated notes, which it assessed using
    its cash flow analysis and assumptions commensurate with the
    assigned ratings under various interest-rate scenarios,
    including LIBOR ranging from 0.31%-11.19%.

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

              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.

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

         http://standardandpoorsdisclosure-17g7.com

RATINGS ASSIGNED

ING IM CLO 2012-4 Ltd./ING IM CLO 2012-4 LLC

Class                       Rating            Amount
                                            (mil. $)
A-1                         AAA (sf)          262.00
A-2                         AA (sf)            45.20
B (deferrable)              A (sf)             28.80
C (deferrable)              BBB (sf)           19.20
D (deferrable)              BB (sf)            16.00
Combination securities      A-p(sf) NRi(i)     10.00
Income notes                NR                 42.75

(i) 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.


JC PENNEY 2007-1: Moody's Cuts Ratings on Two Certs to 'Caa1'
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of the
following certificates issued by Corporate Backed Callable Trust
Certificates J.C. Penney Debenture-Backed Series 2007-1 Trust:

Class A-1 Certificates, Downgraded to Caa1; previously on August
13, 2012 Downgraded to Ba3

Class A-2 Certificates, Downgraded to Caa1; previously on August
13, 2012 Downgraded to Ba3

Ratings Rationale

The transaction is a structured note whose ratings are based on
the rating of the underlying security and the legal structure of
the transaction. The rating actions are a result of the change of
the rating of J.C. Penney Corporation, Inc. 7.625% Debentures due
March 1, 2097, which was downgraded to Caa1 from Ba3 on November
20, 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
the underlying security.

Moody's says that the underlying securities are 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 ratings on the underlying
securities, they could also negatively impact the ratings on the
note.


JFIN 2007: S&P Affirms 'BB+' Rating on Class D Notes; Off Watch
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1B, A-2, B, and C notes from JFIN CLO 2007 Ltd.'s series I, a
U.S. collateralized loan obligation (CLO) transaction managed by
Jefferies Finance LLC. "Concurrently, we affirmed our ratings on
the class A-1A and D notes. At the same time, we removed the
ratings on the class A-1B, A-2, B, C, and D notes from CreditWatch
with positive implications, where we placed them on Sept. 24,
2012," S&P said.

"The upgrades primarily reflect the improved performance of the
transaction's underlying asset portfolio since October 2011, when
we raised our rating on the class C notes. We affirmed our ratings
on the class A-1A and D notes to reflect the credit support
available at the current rating levels," S&P said.

As of the October 2012 trustee report, the transaction had $0.48
million of defaulted assets. This was down from the $6.99 million
we referenced for our October 2011 rating actions. Furthermore,
assets from obligors rated in the 'CCC' category were reported at
$22.84 million in October 2012, down from the $37.66 million we
referenced in our last rating action," S&P said.

"The upgrades also reflect a slight increase in the
overcollateralization (O/C) available to support the notes since
the October 2011 rating action. The trustee reported these O/C
ratios in the October 2012 monthly report," S&P said:

    The class A/B O/C ratio was 134.36%, compared with a reported
    ratio of 132.05% in October 2011;

    The class C O/C ratio was 120.50%, compared with a reported
    ratio of 118.43% in October 2011; and

    The class D O/C ratio was 111.28%, compared with a reported
    ratio of 109.37% in October 2011.

JFIN CLO 2007 Ltd. is currently in its reinvestment period, where
S&P expects it to remain until July 2013.

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

JFIN CLO 2007 Ltd.
Series I
                   Rating
Class         To           From
A-1A          AAA (sf)     AAA
A-1B          AAA (sf)     AA+ (sf)/Watch Pos
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

TRANSACTION INFORMATION
Issuer:             JFIN CLO 2007 Ltd.
Coissuer:           JFIN CLO 2007 LLC
Collateral manager: Jefferies Finance LLC
Underwriter:        Wachovia Securities Inc.
Trustee:            State Street Bank and Trust Co.
Transaction type:   Cash flow CDO


JP MORGAN 2002-CIBC4: Moody's Cuts Rating on C Certs. to 'Caa1'
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of two classes
and affirmed three classes of J.P. Morgan Chase Commercial
Mortgage Securities Corp, Commercial Mortgage Pass-Through
Certificates, Series 2002-CIBC4 as follows:

Cl. B, Downgraded to B1 (sf); previously on Aug 2, 2012 Downgraded
to A2 (sf) and Placed Under Review for Possible Downgrade

Cl. C, Downgraded to Caa1 (sf); previously on Aug 2, 2012
Downgraded to B3 (sf)

Cl. D, Affirmed at Caa2 (sf); previously on Aug 2, 2012 Downgraded
to Caa2 (sf)

Cl. E, Affirmed at C (sf); previously on Aug 2, 2012 Downgraded to
C (sf)

Cl. X-1, Affirmed at Caa3 (sf); previously on Aug 2, 2012
Downgraded to Caa3 (sf)

Ratings Rationale

The downgrades are due to increased interest shortfalls. The
master servicer, Midland Loan Services (Midland), will continue to
recover outstanding advances from the previously largest loan in
the pool, Highland Mall. The loan was liquidated at a 120% loss
severity in April 2012 with $8 million of advances outstanding on
the loan. Midland has informed Moody's that it intends to continue
to recover the remaining $5 million outstanding advances from
principle and interest payments due the certificateholders. It is
anticipated that the recoup of outstanding advances will continue
until August 2013.

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

Moody's rating action reflects a base expected loss of 11.7% of
the current balance. At last review, Moody's cumulative base
expected loss was 57.3%. The current base expected loss is
significantly lower than at last review because last review
included expected losses from The Highland Mall. Base expected
loss plus the realized losses are 12.4%, which is essentially the
same at last review. Moody's provides a current list of base
losses for conduit and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

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

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

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

The methodologies used in this rating were "Moody's Approach to
Rating U.S. CMBS Conduit Transactions" published in September
2000, "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 ver 1.1,
which uses the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology. The calculator
then returns a calculated IO rating based on both a target and
mid-point . For example, a target rating basis for a Baa3 (sf)
rating is a 610 rating factor. The midpoint rating basis for a
Baa3 (sf) rating is 775 (i.e. the simple average of a Baa3 (sf)
rating factor of 610 and a Ba1 (sf) rating factor of 940). If the
calculated IO rating factor is 700, the CMBS IO calculator ver1.0
would provide both a Baa3 (sf) and Ba1 (sf) IO indication for
consideration by the rating committee.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 11 compared to 3 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 August 1, 2012.

Deal Performance

As of the November 13, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 93% to $52.7
million from $799 million at securitization. The Certificates are
collateralized by 18 mortgage loans ranging in size from less than
1% to 17% of the pool, with the top ten non-defeased loans
representing 81% of the pool. One loan, representing 4% of the
pool, has defeased and is secured by U.S. Government securities.

Six loans, representing 47% 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.

Seventeen loans have been liquidated from the pool, resulting in a
realized loss of $106 million (93% loss severity). This severity
includes The Highland Mall loan, which was liquidated at a 120%
severity. Currently three loans, representing 15% of the pool, are
in special servicing and are secured by a mix of property types.
Moody's estimates an aggregate $4 million loss for the specially
serviced loans (55% expected loss on average).

Moody's has assumed a high default probability for one poorly
performing loan representing 9% of the pool and has estimated an
aggregate $700,000 loss (15% expected loss based on a 50%
probability default) from this troubled loan.

Moody's was provided with full year 2011 operating results for 97%
of the pool. Excluding special serviced and troubled loans,
Moody's weighted average LTV is 58% compared to 67% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 11% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.37X and 1.95X, respectively, compared to
1.26X and 1.72X 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 three largest conduit loans represent 40% of the outstanding
pool balance. The performance of these loans has remained stable
since the last review.


JP MORGAN 2007-LDP11: Moody's Cuts Rating on B Certs. to 'Caa3'
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of seven classes
and affirmed 17 classes of J.P. Morgan Chase Commercial Mortgage
Securities Corp., Commercial Mortgage Pass-Through Certificates,
Series 2007-LDP11 as follows:

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

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

Cl. A-3, Affirmed at Aaa (sf); previously on Aug 1, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Downgraded to A3 (sf); previously on May 5, 2010
Downgraded to Aa2 (sf)

Cl. A-SB, Downgraded to A3 (sf); previously on May 5, 2010
Downgraded to Aa2 (sf)

Cl. A-1A, Downgraded to A3 (sf); previously on May 5, 2010
Downgraded to Aa2 (sf)

Cl. A-M, Downgraded to Ba1 (sf); previously on May 5, 2010
Downgraded to A3 (sf)

Cl. A-J, Downgraded to Caa1 (sf); previously on May 5, 2010
Downgraded to B2 (sf)

Cl. B, Downgraded to Caa3 (sf); previously on May 5, 2010
Downgraded to Caa2 (sf)

Cl. C, Affirmed at Ca (sf); previously on May 5, 2010 Downgraded
to Ca (sf)

Cl. D, Affirmed at Ca (sf); previously on May 5, 2010 Downgraded
to Ca (sf)

Cl. E, Affirmed at Ca (sf); previously on May 5, 2010 Downgraded
to Ca (sf)

Cl. F, Affirmed at Ca (sf); previously on May 5, 2010 Downgraded
to Ca (sf)

Cl. G, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. H, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. J, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. K, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. L, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. M, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. N, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. P, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. Q, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. T, Affirmed at C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. X, Downgraded to B1 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

Ratings Rationale

The downgrades of the six principal classes are due to higher
realized and anticipated losses from specially serviced and
troubled loans. The downgrade of the IO Class, Class X, is a
result of the decline in 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 cumulative base expected loss of
17.4% of the current balance. At last review, Moody's cumulative
base expected loss was 12.1%. Realized losses have increased from
0.3% of the original balance to 1.0% since the prior review.
Moody's provides a current list of base losses for conduit and
fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

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

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

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

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

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

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 53 compared to 60 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 15, 2011.

DEAL PERFORMANCE

As of the November 15, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 12% to $4.8 billion
from $5.4 billion at securitization. The Certificates are
collateralized by 238 mortgage loans ranging in size from less
than 1% to 6% of the pool, with the top ten loans representing 36%
of the pool. There are no defeased loans or loans with an
investment grade credit assessment.

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

Thirteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $51.0 million (39% loss severity on
average). There is an additional $4.6 million aggregate loss due
to modifications on several loans, resulting in a total
certificate realized loss of $55.6 million. Forty-four loans,
representing 33% of the pool, are currently in special servicing.
The largest specially serviced loan is the GSA Portfolio Loan
($284.0 million -- 6.0% of the pool), which is secured by nine
office properties located in West Virginia (4 properties), New
York (2), Colorado (1), Pennsylvania (1) and Kansas (1). The loan
was originally scheduled to mature in May 2012 and transferred to
special servicing due to imminent maturity. The portfolio totals
1.1 million square feet (SF) and was 95% leased as of March 2012
compared to 100% at last review. The Mineral Wells, West Virginia
property (3% of the net rentable area (NRA)) is completely vacant
after the tenant exercised its termination option in October 2012.
Six additional tenants (approximately 17% of the NRA) currently
have termination rights and over 67% of the NRA expires within the
next five years. Despite historic stable performance and
occupancy, Moody's is concerned about the ability to refinance
this loan due to the tenant termination options and near term
rollover risk. The special servicer indicated that it is currently
in negotiations with the borrower on a potential loan
modification.

The second largest specially serviced loan is the 315 Park Avenue
South Loan ($219.0 million -- 4.6% of the pool), which is secured
by a 334,000 SF office building located in New York, New York. The
loan was originally transferred to special servicing in October
2011 due to the borrower's request for a discounted payoff, but
was transferred back to the master servicer in January 2012 after
the sale of the property fell through. The loan then returned to
special servicing in April 2012 due to imminent maturity default
as the loan was scheduled to mature in June 2012. Foreclosure
documents were filed in July 2012. The property was 100% leased as
of March 2012, the same as last review. Over 95% of the NRA
expires in 2017 including the largest tenant, which represents 81%
of the NRA. The special servicer is discussing workout options
with the borrower, but a final resolution has not been determined.

The third largest specially serviced loan is the Franklin Mills
Loan ($174.0 million -- 3.6% of the pool), which is a pari-passu
interest in a $290.0 million first mortgage loan. The loan is
secured by a 1.6 million SF regional mall located in Philadelphia,
Pennsylvania. The loan was transferred to special servicing in
April 2012 due to imminent monetary default. The mall is anchored
by Burlington Coat Factory (8% of the NRA; lease expiration
October 2013), J.C. Penney (6% of the NRA; lease expiration
February 2022) and Marshalls (5% of the NRA; lease expiration
January 2016). There is also one vacant anchor space, formerly
Steve & Barry's, that represents approximately 8% of the NRA). As
of October 2012 the mall was 81% leased compared to 82% at last
review and 22% of the NRA is either month-to-month or expires
within the next 12 months. The special servicer indicated that it
is currently negotiating the terms of a potential loan
modification. The remaining 41 specially serviced loans are
secured by a mix of multifamily, retail, hotel, office and
industrial property types. Most of these loans are either real
estate owned (REO) or in the process of foreclosure. As of the
November 15, 2012 distribution date, the master servicer has
recognized an aggregate $400.5 million appraisal reduction for 27
of the specially serviced loans. Moody's has estimated an
aggregate $577.0 million loss (46% expected loss on average) for
the specially serviced loans.

Moody's has assumed a high default probability for 28 poorly
performing loans representing 14% of the pool and has estimated an
aggregate $123.9 million loss (19% expected loss on average) from
these troubled loans.

As of the most recent remittance date, the pool has experienced
cumulative interest shortfalls totaling $46.2 million and
affecting Classes F through NR. Moody's anticipates that the pool
will continue to experience interest shortfalls caused by
specially serviced loans. Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions (ASERs), loan
modifications, extraordinary trust expenses and non-advancing by
the master servicer based on a determination of non-
recoverability.

Moody's was provided with full year 2011 operating results for 97%
of the pool's non-specially serviced loans. Excluding specially
serviced and troubled loans, Moody's weighted average LTV is 127%
compared to 129% at Moody's prior review. Moody's net cash flow
reflects a weighted average haircut of 10% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 9.7%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.21X and 0.83X, respectively, compared to
1.20X and 0.82X 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 13% of the pool balance.
The largest performing loan is the Maple Drive Portfolio Loan
($220.0 million -- 4.7% of the pool), which is secured by three
suburban office properties, totaling 584,000 SF, located in
Beverly Hills, California. As of May 2012, the portfolio was 84%
leased compare to 74% at last review. The largest tenant is Fox
Interactive Media (28% of the NRA; lease expiration May 2016).
Performance has declined steadily since 2009 due to the decline in
occupancy, however, due to contractual rent bumps and a recent
increase in occupancy, property performance is expected to improve
in 2012. Moody's LTV and stressed DSCR are 142% and 0.67X,
respectively, compared to 145% and 0.65X at last review.

The second largest performing loan is the 5 Penn Plaza Loan
($203.0 million -- 4.3% of the pool), which is secured by a
657,000 SF office building located in New York, New York. The
property was 98% leased as of August 2012, the same as prior
review. Rental revenue has been stable, however, property
performance declined due to an increase in real estate taxes and
repair and maintenance expenses. The loan is interest only for the
entire term and matures in May 2017. Moody's LTV and stressed DSCR
are 126% and 0.75X, respectively, the same as last review.

The third largest performing loan is the Save Mart Portfolio Loan
($185.9 million -- 3.9% of the pool), which is secured by 31
single tenant grocery stores located in various markets in
Northern California. The portfolio totals 1.6 million SF that is
triple net leased to Save Mart through January 2027. One property,
6454 Tupelo Drive, located in Citrus Heights, California, is
currently dark and has several deferred maintenance issues but
Save Mart is still paying the contractual rent amount. The loan is
benefitting from amortization and matures in April 2017. Moody's
LTV and stressed DSCR are 115% and 0.85X, respectively, compared
to 109% and 0.89X at last review.


JP MORGAN 2012-PHH: S&P Rates $8.2MM Class E Certificates 'BB+'
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to J.P. Morgan Chase Commercial Mortgage Securities
Trust's $175.0 million commercial mortgage pass-through
certificates, series 2012-PHH.

The note issuance is a two-year, floating-rate commercial mortgage
loan totaling $175.0 million, secured by the fee interest in the
1,639 guest room Palmer House Hilton hotel in Chicago, Ill.

The preliminary ratings are based on information as of Nov. 29,
2012. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

"The preliminary ratings reflect our view of the collateral's
historical and projected performance, the sponsor's and manager's
experience, the trustee-provided liquidity, the loan's terms, and
the transaction's structure. We determined that the loan has a
beginning and ending loan-to-value (LTV) ratio of 61.1%, based on
our value of the property backing 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.

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

         http://standardandpoorsdisclosure-17g7.com

PRELIMINARY RATINGS ASSIGNED
J.P. Morgan Chase Commercial Mortgage Securities Trust 2012-PHH

Class     Rating                       Amount
                                       (mil. $)(i)
A         AAA (sf)                     $83,000,000
X-CP      BB+ (sf)                     $175,000,000(ii)
X-EXT     BB+ (sf)                     $175,000,000(ii)
B         AA (sf)                      $24,300,000
C         A (sf)                       $24,300,000
D         BBB- (sf)                    $35,300,000
E         BB+ (sf)                     $8,100,000
R         NR                           N/A

(i) The issuer will issue the certificates to qualified
     institutional buyers in line with Rule 144A of the Securities
     Act of 1933.

(ii) Notional balance. The notional amount of the X-CP and X-EXT
     certificates will be reduced by the aggregate amount of
     principal distributions and realized losses allocated to
     the class A, B, C, D, and E certificates.

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


KINGSLAND I: Moody's Hikes Rating on Class D Notes to 'Ba2'
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Kingsland I, Ltd.

US$10,000,000 Class A-2 Floating Rate Notes Due June 13, 2019,
Upgraded to Aaa (sf); previously on June 30, 2011 Upgraded to
Aa1 (sf);

US$17,000,000 Class B-1 Floating Rate Notes Due June 13, 2019,
Upgraded to Aa1 (sf); previously on June 30, 2011 Upgraded to A2
(sf);

US$10,000,000 Class B-2 5.06% Notes Due June 13, 2019, Upgraded
to Aa1 (sf); previously on June 30, 2011 Upgraded to A2 (sf);

US$17,250,000 Class C-1 Floating Rate Notes Due June 13, 2019,
Upgraded to Baa2 (sf); previously on June 30, 2011 Upgraded to
Ba2 (sf);

US$8,750,000 Class C-2 6.13% Notes Due June 13, 2019, Upgraded
to Baa2 (sf); previously on June 30, 2011 Upgraded to Ba2 (sf);

US$7,000,000 Class D Floating Rate Notes Due June 13, 2019,
Upgraded to Ba2 (sf); previously on June 30, 2011 Upgraded to B1
(sf);

US$5,000,000 Type II Composition Notes Due June 13, 2019
(current rated balance of $3,346,378), Upgraded to Aaa (sf);
previously on June 30, 2011 Upgraded to Aa3 (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 June 2011. Moody's notes that the Class A
Notes have been paid down by approximately 22% or $65.2 million
since the last rating action. Based on the latest trustee report
dated October 7, 2012, the Class A, Class B, Class C, and Class D
overcollateralization ratios are reported at 134.9%, 121.0%,
110.0%, and 107.4%, respectively, versus June 2011 levels of
127.1%, 116.5%, 107.8%, and 105.7%, respectively.

Moody's also notes that the deal has benefited from an improvement
in the credit quality of the underlying portfolio since the last
rating action in June 2011. Based on the October 2012 trustee
report, the weighted average rating factor is currently 2029
compared to 2407 in June 2011.

Additionally, Moody's notes that the underlying portfolio no
longer has any exposure to securities that mature after the
maturity date of the notes. Based on Moody's calculations, such
securities comprised approximately 4.28% of the underlying
portfolio as of the last rating action in June 2011. This change
in the underlying portfolio since the last rating action reduces
the exposure of the CLO notes to market value risk.

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 $307.3 million,
defaulted par of $12.4 million, a weighted average default
probability of 7.82% (implying a WARF of 1961), a weighted average
recovery rate upon default of 46.16%, and a diversity score of 38.
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.

Kingsland I, Ltd, issued in July 2005, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Approach to Rating Collateralized Loan Obligations"
rating methodology published in June 2011.

In addition to the base case analysis described above, Moody's
also performed sensitivity analyses to test the impact on 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% (1569)

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

Moody's Adjusted WARF + 20% (2353)

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

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

Sources of additional performance uncertainties are described
below:

1) Deleveraging: The main source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace. Deleveraging may
accelerate due to high prepayment levels in the 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.


LCM XII: S&P Affirms 'BB' Rating on Class E Deferrable Notes
------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on LCM XII
L.P./LCM XII LLC s $465.25 million floating-rate notes following
the transaction's effective date as of Oct. 17, 2012.

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

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

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

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

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

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

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

                STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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
LCM XII L.P./LCM XII LLC

Class                  Rating          Amount
                                     (mil. $)
X                      AAA (sf)          4.00
A                      AAA (sf)        321.25
B                      AA (sf)          62.50
C (deferrable)         A (sf)           35.75
D (deferrable)         BBB (sf)         23.75
E (deferrable)         BB (sf)          18.00


MAGNETITE V: S&P Affirms 'B+' Rating on Class D Notes
-----------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on two
classes of notes from Magnetite V CLO Ltd., a cash flow
collateralized loan obligation (CLO) transaction, and removed the
classes from CreditWatch with positive implications, where S&P had
placed it on Aug. 17, 2012. "At the same time, we affirmed our
ratings on two other classes from the transaction and removed one
of them from CreditWatch with positive implications," S&P said.

"This transaction is currently in its amortization phase since the
reinvestment period ended in October 2008. The upgrades reflect a
$117.33 million paydown of the class A notes since our February
2011 rating actions. Due to this and other factors,
overcollateralization (O/C) ratios increased for the class A, B,
C, and D notes," S&P said.

The affirmations of the ratings on the class C and D notes reflect
credit support commensurate with the current rating levels.

"We note that the transaction has exposure to long-dated assets
(i.e., assets maturing after the stated maturity of the CLO). Our
analysis accounted for the potential market value and/or
settlement related risk arising from the potential liquidation of
the remaining securities on the legal final maturity date of the
transaction," S&P said.

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

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

           http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Magnetite V CLO Ltd.
                Rating
Class        To         From
A            AAA (sf)   AAA (sf)
B            AAA (sf)   AA (sf)/Watch Pos
C            A- (sf)    BBB- (sf)/Watch Pos
D            B+ (sf)    B+ (sf)/Watch Pos


NATIONAL COLLEAGIATE: Moody's Corrects Nov. 20 Rating Release
-------------------------------------------------------------
Moody's Investors Service issued a correction to the rating
release on National Collegiate student loan trusts.

Moody's removed references to the National Collegiate Student Loan
Trust 2007-3 Cl.-A-IO note and the National Collegiate Student
Loan Trust 2007-4 Cl.-A-IO note.

On November 27, 2012, the press release was revised as follows:

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
January 6, 2010 and available at http://www.moodys.comin 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 Moody's website, at http://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)

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)

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)


NEWSTAR COMMERCIAL: Moody's Rates $24.1MM Class F Notes '(P)B2'
---------------------------------------------------------------
Moody's Investors Service has assigned the following provisional
ratings to notes to be issued by NewStar Commercial Loan Funding
2012-2, LLC (the "Issuer" or "NewStar 2012-2"):

U.S. $190,700,000 Class A Senior Secured Floating Rate Notes due
2023 (the "Class A Notes"), Assigned (P)Aaa (sf)

U.S. $26,000,000 Class B Senior Secured Floating Rate Notes due
2023 (the "Class B Notes"), Assigned (P)Aa2 (sf)

U.S. $35,200,000 Class C Secured Deferrable Floating Rate Notes
due 2023 (the "Class C Notes"), Assigned (P)A2 (sf)

U.S. $11,400,000 Class D Secured Deferrable Floating Rate Notes
due 2023 (the "Class D Notes"), Assigned (P)Baa2 (sf)

U.S. $16,300,000 Class E Secured Deferrable Floating Rate Notes
due 2023 (the "Class E Notes"), Assigned (P)Ba1 (sf)

U.S. $24,100,000 Class F Secured Deferrable Floating Rate Notes
due 2023 (the "Class F Notes"), Assigned (P)B2 (sf).

Moody's issues provisional ratings in advance of the final sale of
financial instruments, but these ratings only represent Moody's
preliminary credit opinions. Upon a conclusive review of a
transaction and associated documentation, Moody's will endeavor to
assign definitive ratings. A definitive rating (if any) may differ
from a provisional rating.

Ratings Rationale

Moody's provisional ratings of the Class A Notes, the Class B
Notes, the Class C Notes, the Class D Notes, the Class E Notes and
the Class F Notes (together, the "Notes") address the expected
losses posed to noteholders. The provisional ratings reflect the
risks due to defaults on the underlying portfolio of loans, the
transaction's legal structure, and the characteristics of the
underlying assets.

NewStar 2012-2 is a managed cash flow SME CLO. The issued notes
are collateralized substantially by small to medium enterprise
("SME") first-lien senior secured corporate loans. At least 97.5%
of the portfolio must be invested in first-lien senior secured
loans, cash and eligible investments and up to 2.5% of the
portfolio may consist of second-lien loans. The underlying
portfolio will be approximately 67% ramped up as of the closing
date.

NewStar Financial, Inc. (the "Manager") will direct the selection,
acquisition and disposition of collateral on behalf of the Issuer
and may engage in trading activity during the transaction's three-
year reinvestment period, including discretionary trading.

In addition to the Notes rated by Moody's, the Issuer has
investors in its membership interests, which are the ownership
interests in a limited liability company. The transaction
incorporates interest and par coverage tests which, if triggered,
divert interest and principal proceeds to pay down the notes in
order of seniority.

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

Par of $325,000,000

Diversity of 36

WARF of 3200

Weighted Average Spread of 4.85%

Weighted Average Coupon of 7.0%

Weighted Average Recovery Rate of 45.75%, and

Weighted Average Life of 7.5 years.

Together with the set of modeling assumptions above, Moody's
conducted additional sensitivity analyses which were an important
component in determining the ratings assigned to the Notes. These
sensitivity analyses include increased default probability
relative to the base case.

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

Moody's WARF + 15% (3680)

Class A Notes: 0
Class B Notes: 0
Class C Notes: -2
Class D Notes: -2
Class E Notes: -1
Class F Notes: -1

Moody's WARF +30% (4160)

Class A Notes: -2
Class B Notes: -2
Class C Notes: -4
Class D Notes: -4
Class E Notes: -3
Class F Notes: -3.

The V Score for this transaction is Medium/High. This V Score has
been assigned in a manner similar to the Medium/High V score
assigned for the global cash flow CLO sector, as described in the
special report titled "V Scores and Parameter Sensitivities in the
Global Cash Flow CLO Sector," (the "CLO V Score Report") dated
July 6, 2009, available on www.moodys.com. A significant portion
of the underlying assets for this transaction are SME corporate
loans, which receive Moody's credit estimates, rather than
publicly rated corporate loans. This distinction is an important
factor increasing potential rating sensitivity in the
determination of this transaction's V Score, since only loans
publicly rated by Moody's are the basis for the CLO V Score
Report.

Several scores for sub-categories of the V Score differ from the
CLO sector benchmark scores. The scores for the quality of
historical data for U.S. SME loans and for disclosure of
collateral pool characteristics and collateral performance reflect
higher volatility. This results from lack of a centralized default
database for SME loans, as well as obligor-level information for
SME loans being more limited and less frequently provided to
Moody's than that for publicly rated companies. In addition, the
score for alignment of interests reflects lower volatility since
the transaction is a financing vehicle.

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 rating. V Scores apply to the entire transaction,
rather than individual tranches.

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


NORTHWOODS CAPITAL IV: Moody's Ups Ratings on 2 CLO Notes to Ba1
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Northwoods Capital IV, Limited:

U.S. $32,000,000 Class A-2 Senior Secured Floating Rate Notes Due
2018, Upgraded to Aaa (sf); previously on Jul 25, 2011 Upgraded to
Aa3 (sf);

U.S. $38,000,000 Class B Senior Secured Deferrable Floating Rate
Notes Due 2018, Upgraded to A2 (sf); previously on Jul 25, 2011
Upgraded to Baa1 (sf);

U.S. $16,500,000 Class C-1 Senior Secured Deferrable Floating Rate
Notes Due 2018, Upgraded to Ba1 (sf); previously on Jul 25, 2011
Upgraded to Ba2 (sf);

U.S. $8,500,000 Class C-2 Senior Secured Deferrable Fixed Rate
Notes Due 2018, Upgraded to Ba1 (sf); previously on Jul 25, 2011
Upgraded to Ba2 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the senior notes and an
increase in the transaction's overcollateralization ratios since
the rating action in July 2011. Moody's notes that the Class A-1a
Notes and Class A-1b Notes have been paid down by approximately
30% or $99.2 million since the last rating action. Based on the
latest trustee report dated October 26, 2012, the Class A, Class B
and Class C overcollateralization ratios are reported at 144.35%,
127.12% and 155.18% respectively, versus June 2011 levels of
133.01%, 120.33% 111.14%, respectively. These levels do not take
into account the principal payments made on the November 3, 2012
payment date. Moody's also notes the credit quality of the
underlying portfolio has remained stable.

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 $368.9 million,
defaulted par of $27.9 million, a weighted average default
probability of 19.41% (implying a WARF of 3171), a weighted
average recovery rate upon default of 46.66%, and a diversity
score of 29. 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.

Northwoods Capital IV, Limited, issued in 2004, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Approach to Rating Collateralized Loan Obligations"
rating methodology published in June 2011.

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

Moody's Adjusted WARF -- 20% WARF 2537

Class A-1a: 0
Class A-1b: 0
Class A2: 0
Class B: +1
Class C-1: +2
Class C-2: +2

Moody's Adjusted WARF + 20% WARF 3805

Class A-1a: 0
Class A-1b: 0
Class A2: -1
Class B: -1
Class C-1: -1
Class C-2: -1

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

Sources of additional performance uncertainties are described
below:

1) Deleveraging: The main source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace. Deleveraging may
accelerate due to high prepayment levels in the 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) 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. Moody's tested for a possible extension
of the actual weighted average life in its analysis.


NORTHSTAR 2012-1: Moody's Assigns 'B2' Rating to Class F Certs.
---------------------------------------------------------------
Moody's Investors Service has assigned ratings to seven classes of
CMBS securities, issued by NorthStar 2012-1 Commercial Mortgage
Pass-Through Certificates.

Cl. A, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa2 (sf)

Cl. C, Definitive Rating Assigned A2 (sf)

Cl. D, Definitive Rating Assigned Baa3 (sf)

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

Cl. E, Definitive Rating Assigned Ba2 (sf)

Cl. F, Definitive Rating Assigned B2 (sf)

Ratings Rationale

The Certificates are collateralized by fourteen floating rate
loans secured by nineteen 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 pooled Trust loan balance of $351.4 million represents a
Moody's LTV ratio of 125.3%. The Moody's LTV ratio for the pool is
the highest level observed by Moody's in CMBS 2.0. Moody's also
considers subordinate financing outside of the Trust when
assigning ratings. There are two loans structured with junior
mortgage participations and one loan structured with a mezzanine
loan. Inclusive of these subordinate notes, the total debt amount
increases to $395.0 million and represents a Moody's Total LTV of
138.7%.

The Moody's Actual Trust DSCR is 1.27x. The Moody's Total Trust
stressed DSCR at a 9.25% constant is 0.81X and Moody's total debt
stressed DSCR (inclusive of mezzanine debt) is 0.73X. The Moody's
Actual Trust DSCR is the lowest level Moody's has calculated since
2009.

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 Herfindahl score is
8.5. The score is lower than Herfindahl scores represented by
large loan, multi-borrower transactions previously rated by
Moody's. With respect to property level diversity, the pool's
property level Herfindahl score is 8.8. The transaction's property
diversity profile is consistent with most previously rated large
loan multi-borrower transactions.

Moody's 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 2.6, which is consistent when
compared to other deals rated by Moody's since 2009.

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 8.4. 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 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 Medium, the same
as the V score assigned to the U.S. Large Loan 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 4%, 15%, or 25%, the model-indicated rating for the currently
rated Aaa class would be Aa1; A1; and Baa1. Parameter
Sensitivities are not intended to measure how the rating of the
security might migrate over time; rather they are designed to
provide a quantitative calculation of how the initial rating might
change if key input parameters used in the initial rating process
differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.

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

Moody's has withdrawn the (P)B1 (sf) rating previously assigned to
Cl. X-LF for its own business reasons.


OCTAGON INVESTMENT XIV: S&P Gives 'B' Rating on Class E Def Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Octagon Investment Partners XIV, Ltd./Octagon
Investment Partners XIV, LLC's $474.5 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. 23,
2012. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

The preliminary ratings reflect S&P's view of:

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

    The transaction's credit enhancement, which is sufficient to
    withstand the defaults applicable for the supplemental tests
    (excluding excess spread), and cash flow structure, which can
    withstand the default rate projected by Standard & Poor's CDO
    Evaluator model, as assessed by Standard & Poor's using the
    assumptions and methods outlined in its corporate
    collateralized debt obligation (CDO) criteria.

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

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

    The portfolio manager's experienced management team.

    S&P's projections regarding the timely interest and ultimate
    principal payments on the preliminary rated notes, which it
    assessed using its cash flow analysis and assumptions
    commensurate with the assigned preliminary ratings under
    various interest-rate scenarios, including LIBOR ranging from
    0.31%-13.84%.

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

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

             STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

      http://standardandpoorsdisclosure-17g7.com/1129.pdf

PRELIMINARY RATINGS ASSIGNED

Octagon Investment Partners XIV Ltd./Octagon Investment Partners
XIV LLC

Class                     Rating             Amount
                                           (mil. $)
A-1                       AAA (sf)           314.75
A-2                       AA (sf)             52.50
B (deferrable)            A (sf)              42.75
C (deferrable)            BBB (sf)            25.00
D (deferrable)            BB- (sf)            28.25
E (deferrable)            B (sf)              11.25
Subordinated notes        NR                  47.30

NR--Not rated.


PHOENIX CDO II: Fitch Affirms 'Csf' Rating on Two Class Notes
-------------------------------------------------------------
Fitch Ratings has taken the following rating actions on the notes
issued by Phoenix CDO II, Ltd. (Phoenix II) as follows:

  -- $33,101,272 class B notes upgraded to 'Asf' from 'Dsf',
     assigned Stable Outlook;
  -- $32,224,903 class C-1 notes affirmed at 'Csf';
  -- $27,840,965 class C-2 notes affirmed at 'Csf'.

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

Phoenix II entered an event of default in July 2003 and
accelerated its maturity in November 2003.  The class A notes were
paid in full on the March 1, 2012 payment date.  The class B notes
are now the senior most class in the transaction and are receiving
all proceeds after fees and expenses.  The notes had a substantial
outstanding defaulted interest balance when Fitch last reviewed
Phoenix II in March 2012, which warranted an affirmation at 'Dsf'
despite its increased credit enhancement and improved position in
the capital structure.

The class B notes are upgraded following repayment of its
defaulted interest on the September 2012 distribution date.
Fitch's cash flow modeling results indicate the class B notes can
pass rating stresses higher than 'Asf'.  However, the portfolio is
becoming increasingly concentrated and therefore consideration is
given to Fitch's 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.  The Stable Outlook
reflects Fitch's expectation of stable performance over the next
one to two years.

The class C-1 and C-2 (together, class C) notes continue to
capitalize missed interest and are undercollateralized.  Default
continues to appear inevitable because future payments made to the
class C notes will not be sufficient to cover all principal and
paid in kind interest due at maturity.  Therefore, the class C
notes are affirmed at 'Csf'.

Phoenix II is a cash flow structured finance collateralized debt
obligation (SF CDO) that closed on May 17, 2000 and is monitored
by Newfleet Asset Management, LLC.  The current portfolio is
composed of residential mortgage-backed securities (43.5%),
commercial mortgage-backed securities (27.2%), commercial asset-
backed securities (ABS; 28.2%), and consumer ABS (1.1%) from 1995
through 2002 vintage transactions.


PREFERREDPLUS BLC-2: S&P Raises Rating on $33.5MM Certs. to 'BB'
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on
PreferredPLUS Trust Series BLC-2's $33.530 million 8.00%
certificates to 'BB' from 'BB-'.

"Our rating on the certificates is dependent on our rating on the
underlying security; Belo Corp.'s $250 million 7.25% senior
debentures due Sept. 15, 2027," S&P said.

"The rating action follows the Nov. 19, 2012, raising of our
rating on the underlying security to 'BB' from 'BB-'. We may take
subsequent rating actions on the certificates due to changes in
our rating on 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


SATURNS 2007-1: Moody's Cuts Ratings on 2 Cert. Classes to 'Caa1'
-----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of the
following certificates issued by Structured Asset Trust Unit
Repackagings (SATURNS) Series 2007-1:

Issuer: SATURNS J.C Penney Corporation Inc. Debenture Backed
Series 2007-1

  US$54,500,000 of 7.625% Callable Units due March 1, 2097,
  Downgraded to Caa1; previously on August 13, 2012 Downgraded to
  Ba3

  US$3,690,000 Initial Notional Amortizing Balance of Interest-
  Only Class B Callable Units due March 1, 2097, Downgraded to
  Caa1; previously on August 13, 2012 Downgraded to Ba3

Ratings Rationale

The transaction is a structured note whose ratings change with the
rating of the Underlying Securities. The rating actions are a
result of the change of the rating of J.C. Penney Corporation,
Inc. 7.625% Debentures due March 1, 2097, which was downgraded to
Caa1 from Ba3 on November 20, 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
the underlying security and the legal structure of the
transaction.

Moody's says that the underlying securities are 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 ratings on the underlying
securities, they could also negatively impact the ratings on the
note.


SCHOONER TRUST: Moody's Affirms 'B3' Rating on Class K Certs.
-------------------------------------------------------------
Moody's Investors Service upgraded the ratings of five classes and
affirmed eight classes of Schooner Trust, Commercial Mortgage
Pass-Through Certificates, Series 2004-CCF1 as follows:

Cl. A-2, Affirmed at Aaa (sf); previously on Jan 23, 2004
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Apr 18, 2007 Upgraded
to Aaa (sf)

Cl. C, Upgraded to Aaa (sf); previously on Feb 24, 2011 Upgraded
to Aa1 (sf)

Cl. D-1, Upgraded to A1 (sf); previously on Feb 24, 2011 Upgraded
to A3 (sf)

Cl. D-2, Upgraded to A1 (sf); previously on Feb 24, 2011 Upgraded
to A3 (sf)

Cl. E, Upgraded to A3 (sf); previously on Feb 24, 2011 Upgraded to
Baa2 (sf)

Cl. F, Upgraded to Baa2 (sf); previously on Jan 23, 2004
Definitive Rating Assigned Ba1 (sf)

Cl. G, Affirmed at Ba2 (sf); previously on Jan 23, 2004 Definitive
Rating Assigned Ba2 (sf)

Cl. H, Affirmed at Ba3 (sf); previously on Jan 23, 2004 Definitive
Rating Assigned Ba3 (sf)

Cl. J, Affirmed at B2 (sf); previously on Jan 23, 2004 Definitive
Rating Assigned B2 (sf)

Cl. K, Affirmed at B3 (sf); previously on Jan 23, 2004 Definitive
Rating Assigned B3 (sf)

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

Cl. IO-2, Affirmed at Ba3 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

Ratings Rationale

The upgrades are due to an increase in subordination from payoffs
and amortization. The pool has paid down 47% since securitization
and 15% since last review.

The affirmations are due to key parameters, including Moody's loan
to value (LTV) ratio, Moody's stressed debt service coverage ratio
(DSCR) and the Herfindahl Index (Herf), remaining within
acceptable ranges. Based on Moody's current base expected loss,
the credit enhancement levels for the affirmed classes are
sufficient to maintain their current ratings. The ratings of the
IO Classes, Classes IO-1 and IO-2 are consistent with the
performance of their referenced classes and are thus affirmed.

Moody's rating action reflects a cumulative base expected loss of
$6.3 million or 2.5% of the current balance. At last review,
Moody's cumulative base expected loss was $8.4 million or 2.9%.
Moody's provides a current list of base losses for conduit and
fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

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

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 17 compared to 22 at Moody's prior review.

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

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated February 29, 2012.

Deal Performance

As of the November 13, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 47% to $250.7
million from $474.0 million at securitization. The Certificates
are collateralized by 49 mortgage loans ranging in size from less
than 1% to 12% of the pool, with the top ten loans representing
57% of the pool. Eight loans, representing 9% of the pool, have
defeased and are collateralized with Canadian Government
securities.

Eleven loans, representing 17% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of 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 experienced a $2.1 million loss (24% loss severity)
from the liquidation of one loan. There are currently no loans in
special servicing. Moody's has assumed a high default probability
for two poorly performing loans representing 4% of the pool and
has estimated an aggregate $1.9 million loss (19% expected loss)
from these troubled loans.

Moody's was provided with full year 2011 operating results for 83%
of the pool. Excluding troubled loans, Moody's weighted average
LTV is 62% compared to 64% at last 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 9.9%.

Excluding troubled loans, Moody's actual and stressed DSCRs are
1.60X and 1.83X, respectively, compared to 1.63X and 1.80X 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 30% of the pool balance.
The largest loan is the Merivale/Gateway Mall Portfolio Loan
($30.8 million -- 12.3% of the pool), which is secured by a
242,715 square foot (SF) enclosed mall located in Ottawa and a
333,691 SF enclosed mall located in Prince Albert. The loan is
amortizing on a 300-month schedule maturing in April 2013. The
loan has paid down 19% since securitization. Property performance
has remained stable since the last review. Moody's LTV and
stressed DSCR are 61% and 1.67X, respectively, compared to 69% and
1.49X at last full review.

The second largest loan is the Fortis Portfolio Loan ($22.9
million -- 9.1% of the pool), which is secured by four full
service Holiday Inn hotels located in multiple cities in southern
Ontario. The loan is amortizing on a 300-month schedule maturing
in November 2013. The loan has paid down 23% since securitization.
Moody's LTV and stressed DSCR are 54% and 2.23X, respectively,
compared to 56% and 2.15X at last full review.

The third largest loan is the Cherry Lane Shopping Centre Loan
($21.3 million -- 8.5% of the pool), which is secured by a 269,716
SF anchored retail center located in Penticton, BC. The loan is
amortizing on a 300-month schedule maturing in August 2013. The
loan has paid down 21% since securitization. Property performance
has improved steadily over the prior two reviews. Moody's LTV and
stressed DSCR are 51% and 2.12X, respectively, compared to 54% and
2.02X at last review.


SORIN REAL ESTATE: Moody's Lifts Rating on Cl. A-3 Notes to 'B3'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of three
classes and affirmed the ratings of six classes of Notes issued by
Sorin Real Estate CDO IV Ltd. The upgrades are due to improvement
in underlying collateral performance as evidenced by transition in
Moody's weighted average rating factor (WARF), weighted average
recovery rate (WARR), and a lower balance of defaulted securities
since last review. The affirmations are due to key transaction
parameters performing within levels commensurate with the existing
ratings levels. The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation and collateralized loan obligation (CRE CDO CLO)
transactions.

Moody's rating action is as follows:

Cl. A-1, Upgraded to Baa1 (sf); previously on Dec 15, 2010
Downgraded to Baa2 (sf)

Cl. A-2, Upgraded to B1 (sf); previously on Dec 15, 2010
Downgraded to Caa1 (sf)

Cl. A-3, Upgraded to B3 (sf); previously on Dec 15, 2010
Downgraded to Caa2 (sf)

Cl. B, Affirmed at Caa3 (sf); previously on Dec 15, 2010
Downgraded to Caa3 (sf)

Cl. C, Affirmed at Ca (sf); previously on Dec 15, 2010 Downgraded
to Ca (sf)

Cl. D, Affirmed at C (sf); previously on Dec 15, 2010 Downgraded
to C (sf)

Cl. E, Affirmed at C (sf); previously on Dec 15, 2010 Downgraded
to C (sf)

Cl. F, Affirmed at C (sf); previously on Dec 15, 2010 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Dec 15, 2010 Downgraded
to C (sf)

Ratings Rationale

Sorin Real Estate CDO IV Ltd. is a static (the reinvestment period
ended in October 2011) cash transaction backed by a portfolio of
commercial mortgage backed securities (CMBS) (50.3% of the pool
balance), B-Note debt and rake bonds (30.3%), whole loans (17.6%),
and CRE CDO bonds (1.8%). As of the October 29, 2012 Note
Valuation report, the aggregate Note balance of the transaction,
including Income Notes, has decreased to $286.4 million from
$400.0 million at issuance, as a result of the paydown directed to
the Class A-1 Notes from regular amortization of collateral,
resolution and subsequent sales of defaulted collateral, and
interest proceeds directed to senior classes as principal proceeds
as a result of failing one or more par value and interest coverage
tests. The transaction is currently under-collateralized by $52.9
million, up from $26.6 million as of last review. However, the
transaction's key parameters are compensating for this change in
collateralization.

There are six assets with par balance of $48.6 million (20.8% of
the current pool balance) that are considered defaulted securities
as of the October 29, 2012 Note Valuation report, compared to nine
defaulted securities totaling $77.8 million par amount (25.0%) at
last review. Moody's does expect moderate to high losses to occur
from these defaulted securities once they are realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 3,922 compared to 4,489 at last review. The
current distribution of Moody's rated collateral and assessments
for non-Moody's rated collateral is as follows: Aaa-Aa3 (16.1%
compared to 16.3% at last review), A1-A3 (5.6% compared to 0.0% at
last review),Baa1-Baa3 (9.8% compared to 13.2% at last review),
Ba1-Ba3 (12.1% compared to 3.4% at last review), B1-B3 (6.0%
compared to 9.8% at last review), and Caa1-Ca/C (50.4% compared to
57.3% at last review).

Moody's modeled to a WAL of 3.0 years, compared to 3.2 years at
last review. The current WAL is based on the assumption about
extensions.

Moody's modeled a fixed 27.3% WARR, compared to 24.5% at last
review.

Moody's modeled a MAC of 11.2%, compared to 16.3% 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 27.3% to 17.3% or up to 37.3% would result in modeled
rating movement on the rated Notes of 0 to 2 notches downward and
0 to 3 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.


THORNBURG MORTGAGE 2005-4: Moody's Cuts 2 Tranche Ratings to Caa2
-----------------------------------------------------------------
Moody's Investors Service has downgraded six tranches issued by
Thornburg Mortgage Securities. The collateral backing these deals
primarily consists of first-lien, adjustable-rate Prime Jumbo
residential mortgages. The actions impact approximately $1.1
billion of RMBS issued from 2005 to 2006.

Complete rating actions are as follows:

Issuer: Thornburg Mortgage Securities Trust 2005-4

Cl. A-1, Downgraded to Caa1 (sf); previously on Mar 26, 2010
Downgraded to B3 (sf)

Cl. A-2, Downgraded to Caa1 (sf); previously on Mar 26, 2010
Downgraded to B2 (sf)

Cl. A-3, Downgraded to Caa2 (sf); previously on Mar 26, 2010
Downgraded to B2 (sf)

Cl. A-4, Downgraded to Caa1 (sf); previously on Mar 26, 2010
Downgraded to B2 (sf)

Issuer: Thornburg Mortgage Securities Trust 2006-1

Cl. A-2, Downgraded to Caa2 (sf); previously on Mar 26, 2010
Downgraded to Caa1 (sf)

Cl. A-3, Downgraded to Caa1 (sf); previously on Mar 26, 2010
Confirmed at B3 (sf)

Ratings Rationale

The actions are a result recent performance of the pools backing
the bonds 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 "2005 -- 2008 US RMBS Surveillance Methodology"
published in July 2011. The methodology used in rating Interest-
Only Securities was "Moody's Approach to Rating Structured Finance
Interest-Only Securities" published in February 2012.

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

Loan Modifications

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

Small Pool Volatility

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

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

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_SF308036

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

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


US AIRWAYS: Moody's Assigns 'B1' Rating to Cl. B Certificates
-------------------------------------------------------------
Moody's Investors Service assigned Ba1 and B1 ratings,
respectively, to the Class A and Class B Pass Through
Certificates, Series 2012-2 (the "Certificates") of the 2012-2
Pass Through Trusts that US Airways, Inc. will establish. Moody's
affirmed the B3 Corporate Family and Probability of Default
ratings assigned to US Airways Group, Inc. and all of the other
ratings it assigns to the company's debt or equipment trust
certificates.

Issuer: US Airways, Inc.

  Assignments:

    Series 2012-2 Enhanced Equipment Trust

     Class A Certificates Assigned Ba1

     Class B Certificates Assigned B1

Ratings Rationale

The proceeds of the Series 2012-2 Certificates will fund the
purchase of equipment notes to be issued by US Airways for ten
aircraft: seven newly-manufactured Airbus A321-200s to be
delivered to US Airways in 2013 and three newly-manufactured
Airbus A330-200 aircraft to be delivered in 2013. The payment
obligations of US Airways will be guaranteed by its parent, US
Airways Group, Inc. Amounts due under the respective Certificates
will be subordinated to any amounts due on the separate Class A
and Class B Liquidity Facilities ("Liquidity Facility").
Landesbank Hessen-Thringen Girozentrale will provide the separate
liquidity facility for each of the Class A and Class B
Certificates. The Bank of New York Mellon will serve as the
Depositary.

The ratings of the Certificates consider the credit quality of US
Airways as obligor of the underlying equipment notes, Moody's
opinion of the collateral protection of the Notes, the credit
support provided by the liquidity facilities, the applicability of
Section 1110 of Title 11 of the United States Code (the "Code") to
the equipment notes, as well as the cross-default and cross-
collateralization of the equipment notes. The assigned ratings
reflect Moody's opinion of the ability of the Pass-Through
Trustees to make timely payment of scheduled interest and the
ultimate payment of principal on the final scheduled regular
distribution dates of June 3, 2025 and June 3, 2021 for the A and
B certificates, respectively, either from payments received from
US Airways or from other remedies under the transaction structure.

Moody's estimate of the loan-to-value of the Certificates is in
line with those of US Airways' other recently issued EETCs.
Moody's estimates the initial loan-to-value of the tranches at
above 60% and about 80%, respectively based on its estimates of
market values and after applying its LTV benefit for cross-
collateralization. The inclusion of new A330-200s in this
transaction strengthens the probability of a Section 1110(a)
election under a reorganization scenario relative to that of other
of US Airways' EETCs that do not finance any wide-bodies.
Nevertheless, the ratings assignment for 2012-2 reflects the
relatively high probability of affirmation under a reorganization
scenario. The aircraft in the 2012-2 EETC will be some of the
youngest in the airline's fleet. Additionally, the two aircraft
models are likely to be a stalwart in US Airways' fleet for years
to come. The higher gauge of the A321 and its ability to replace
the B757-200 on many of that aircraft's existing routes are
supportive features for that aircraft. The A330-200 enhances the
company's international fleet.

Any combination of future changes in the underlying credit quality
or ratings of US Airways, unexpected material changes in the
market value of the aircraft and/or changes in the status or terms
of the liquidity facilities or the credit quality of the liquidity
provider could cause Moody's to change its ratings of the
Certificates.

The principal methodology used in rating US Airways was the Global
Passenger Airlines Industry Methodology published in May 2012 and
Enhanced Equipment Trust And Equipment Trust Certificates
published in December 2010. Other methodologies used include Loss
Given Default for Speculative-Grade Non-Financial Companies in the
U.S., Canada and EMEA published in June 2009.
US Airways Group, Inc., based in Tempe, Arizona, through its
subsidiaries, operates one of the largest airlines in the U.S.
with service throughout the U.S. as well as Canada, Mexico,
Europe, the Middle East, the Caribbean, Central and South America.


UTAH HOUSING: Moody's Cuts Rating on Revenue Bonds to 'Caa1'
------------------------------------------------------------
Moody's Investors Service has downgraded to Caa1 from B2 the
rating of Utah Housing Corporation (GNMA Collateralized) Mortgage
Revenue Bonds (Sunset Ridge Apartments Project), Series 2003A and
Series 2003A-T, affecting approximately $14,550,000 of outstanding
debt.

Summary Rationale

This rating action follows the recent downgrade of MBIA Inc. to
Caa1 (developing outlook) from B2 on November 19, 2012. MBIA Inc.
provides a guaranteed investment contract (GIC) for which the
funds of the Series 2003A and 2003A-T are invested with.

Outlook

WHAT COULD CHANGE THE RATING - UP

- An upgrade to the rating of the GIC provider

WHAT COULD CHANGE THE RATING - DOWN

- A downgrade to the rating of the GIC provider

- Deterioration to the asset to debt ratio

- Cash flows projections which demonstrate insufficient revenues
   or asset-to-debt ratios

Rating Methodology

The principal methodology used in this rating was GNMA
Collateralized Multifamily Housing Bonds published in June 2001.


WACHOVIA BANK 2006-C26: Moody's Cuts Rating on G Certs. to 'Ca'
---------------------------------------------------------------
Moody's Investors Service downgraded the ratings of eight classes
and affirmed 14 classes of Wachovia Bank Commercial Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series 2006-
C26:

Cl. A-2, Affirmed at Aaa (sf); previously on Jul 12, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-PB, Affirmed at Aaa (sf); previously on Jul 12, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jul 12, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3FL, Affirmed at Aaa (sf); previously on Jul 12, 2006
Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Jul 12, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Downgraded to Aa2 (sf); previously on Jan 13, 2011
Confirmed at Aaa (sf)

Cl. A-J, Downgraded to Ba1 (sf); previously on Jan 13, 2011
Downgraded to Baa1 (sf)

Cl. B, Downgraded to B1 (sf); previously on Jan 13, 2011
Downgraded to Baa3 (sf)

Cl. C, Downgraded to B2 (sf); previously on Jan 13, 2011
Downgraded to Ba1 (sf)

Cl. D, Downgraded to Caa1 (sf); previously on Jan 13, 2011
Downgraded to B1 (sf)

Cl. E, Downgraded to Caa2 (sf); previously on Jan 13, 2011
Downgraded to B3 (sf)

Cl. F, Downgraded to Caa3 (sf); previously on Jan 13, 2011
Downgraded to Caa2 (sf)

Cl. G, Downgraded to Ca (sf); previously on Jan 13, 2011
Downgraded to Caa3 (sf)

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

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

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

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

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

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

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

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

Cl. X-P, Affirmed at Aaa (sf); previously on Jul 12, 2006
Definitive Rating Assigned Aaa (sf)

Ratings Rationale

The downgrades are due to higher than anticipated realized and
expected losses from specially serviced and troubled loans.

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

Moody's rating action reflects a base expected loss of 10.8% of
the current balance compared to 8.4% at last review. Moody's
provides a current list of base expected losses for conduit and
fusion CMBS transactions on moodys.com at
http://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 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 37 compared to 39 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 30, 2011.

DEAL PERFORMANCE

As of the November 19th, 2012 distribution date, the transaction's
aggregate certificate balance has decreased by 19% to $1.41
billion from $1.73 billion at securitization. The Certificates are
collateralized by 100 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten loans representing 40%
of the pool. There is one fully defeased loan, representing less
than 1% of the pool, that is securitized by U.S. Government
securities.

Twenty-eight loans are on the master servicer's watchlist,
representing approximately 26% 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.

Eight loans have been liquidated since securitization, of which
five have generated a loss of $15.1 million (38% average loss
severity). Currently, there are 13 loans in special servicing,
representing approximately 16% of the pool balance. The largest
specially serviced loan is the Tan-Tar-A Resort Loan ($46.1
million -- 3.3 % of the pool), which is secured by a 497-room
resort hotel located in Osage Beach, Missouri, which is
approximately 200 miles from St. Louis. The hotel consists of five
multi-story guest room buildings, 21 cottage style buildings and
various other buildings. The resort includes approximately 90,000
square feet (SF) of meeting space, 27 holes of golf, a 20,000 SF
water park, 119 slip marina, health club and spa, and other
amenities. The loan was transferred to special servicing in April
2012 for imminent monetary default. Per the special servicer, a
receiver was appointed in September 2012. As of December 2011, the
hotel's occupancy rate and revenue per available room (RevPAR)
were 48.9% and $48.46. Trailing 12 month financials ending in
September 2012 indicate an occupancy rate and RevPAR of 48.8% and
$48.07. The master servicer has recognized an $11.3 million
appraisal reduction amount (ARA) for this loan and as well as
additional $60.1 million ARA for ten other specially serviced
loans. Moody's estimate an aggregate loss of $84.7 million (41%
expected loss) from 12 out of the 13 loans in specially servicing.

Moody's has assumed a high default probability for 11 poorly
performing loans representing 16% of the pool and has estimated a
$45.8 million loss (20% expected loss based on a 50% probability
default) from these troubled loan.

Based on the most recent remittance statement, Classes G through P
have experienced cumulative interest shortfalls totaling $15.1
million. At last review, interest shortfalls totaled $10.7
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), loan
modifications and extraordinary trust expenses

Excluding defeased and specially serviced loans, Moody's was
provided with full year 2011 and partial year 2012 operating
results for 93% and 86% of the pool. Excluding defeased, specially
serviced and troubled loans, Moody's weighted average conduit LTV
is 99% compared to 97% at Moody's prior. Moody's net cash flow
(NCF) reflects a weighted average haircut of 10% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.3%.

Excluding defeased, specially serviced and troubled loans, Moody's
actual and stressed conduit DSCRs are 1.33X and 1.06X,
respectively, compared to 1.35X and 1.07X at last review. Moody's
actual DSCR is based on Moody's net cash flow and the loans 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 19% of the pool balance.
The largest loan is the Prime Outlets Pool II Loan ($140.9 million
-- 10.0% of the pool), which represents a 50% pari passu interest
in a portfolio of three outlet retail properties totaling 1.5
million SF. The loan is also encumbered by a $17.0 million B-
note. The sponsor is Simon Property Group. The three retail
properties are located in Birch Run, Michigan, Williamsburg,
Virginia and Hagerstown, Maryland. As of June 2012, the portfolio
was 93% leased compared to 92% at last review. Performance remains
stable and the loan benefits from amortization. Moody's LTV and
stressed DSCR are 85% and 1.15X, respectively, compared to 89% and
1.10X at last full review.

The second largest loan is the Eastern Shore Centre Loan ($69.5
million -- 4.9% of the pool), which is secured by a 432,689 SF
life-style retail property located near Mobile, Alabama. The loan
was returned from special servicing in February 2011 after an
interest rate modification and has remained since then on the
master servicer's watch list for low debt service coverage. The
property is shadowed anchored by Dillard's. The main in-line
tenants include Belk's, Barnes and Noble and Bed, Bath and Beyond.
As of June 2012, the collateral was 81% leased; since 2008 the
property's historical occupancy rate has ranged from the low to
mid 80%. Per the master servicer, retail sales at the center have
been lower than expected; moreover, 14% of the tenants are paying
percent rent as a rent concession instead of full rent. Moody's
has identified this as a troubled loan. Moody's LTV and stressed
DSCR are 239% and 0.63X, respectively, compared to 248% and 0.38X
at last full review.

The third largest loan is the Chemed Center Leasehold Loan ($59.3
million -- 4.2% of the pool), which is secured by a leasehold
interest in a 551,000 square foot office property located in
Cincinnati, Ohio's Central Business District (CBD). The ground
lease is for 99 years and expires in April 2105. The loan secured
by the fee interest in the Chemed Center is also securitized in
the pool. As of June 2012, the collateral was 97% leased compared
to and 95% in December 2011. The largest tenants are Dinsmore &
Shohl LLP (31% of the NRA; lease expiration in December 2018); PNC
Bank (16% of the NRA; lease expiration in February 2014) and
Chemed Corporation (11% of the NRA; lease expiration in April
2016). The collateral's in-place rents are approximately $26.00
per square foot. Per CBRE Economic Advisors, Class A office rents
in Cincinnati's CBD are approximately $17.00 per square foot. The
loan matures in May 2016. Moody's LTV and stressed DSCR are 79%
and 1.37X, respectively, compared to 76% and 1.43X at last full
review.


WFRBS 2012-C10: Moody's Rates Class F Certificates '(P)B2'
----------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to
twelve classes of CMBS securities, issued by WFRBS Commercial
Mortgage Trust, Commercial Mortgage Pass-Through Certificates,
Series 2012-C10.

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

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

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

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

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

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

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

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

Cl. X-B, Assigned (P)A2 (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 85 fixed rate loans secured
by 122 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 1.74X is greater than the 2007
conduit/fusion transaction average of 1.31X. The Moody's Stressed
DSCR of 1.10X is greater than the 2007 conduit/fusion transaction
average of 0.92X.

Moody's Trust LTV ratio of 98.3% is lower than the 2007
conduit/fusion transaction average of 110.6%. Moody's Total LTV
ratio (inclusive of subordinated debt and debt-like preferred
equity) of 98.4% is also considered when analyzing various stress
scenarios for the rated debt.

Moody's also considers both loan level diversity and property
level diversity when selecting a ratings approach. With respect to
loan level diversity, the pool's loan level (includes cross
collateralized and cross defaulted loans) Herfindahl Index is 29.
The transaction's loan level diversity is at the higher end of the
band of Herfindahl scores found in most multi-borrower
transactions issued since 2009. With respect to property level
diversity, the pool's property level Herfindahl Index is 32. The
transaction's property diversity profile is higher than the
indices calculated in most multi-borrower transactions issued
since 2009.

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

Moody's also grades properties on a scale of 1 to 5 (best to
worst) and considers those grades when assessing the likelihood of
debt payment. The factors considered include property age, quality
of construction, location, market, and tenancy. The pool's
weighted average property quality grade is 2.5, which is higher
than the indices calculated in most multi-borrower transactions
since 2009.

The methodologies used in this rating were "Moody's Approach to
Rating U.S. CMBS Conduit Transactions" published in September
2000, "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 ver_1.1, which
references the following inputs to calculate the proposed IO
rating based on the published methodology: original and current
bond ratings and credit estimates; original and current bond
balances grossed up for losses for all bonds the IO(s)
reference(s) within the transaction; and IO type corresponding to
an IO type as defined in the published methodology.

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

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

Moody's Parameter Sensitivities: If Moody's value of the
collateral used in determining the initial rating were decreased
by 5%, 16%, and 29%, the model-indicated rating for the currently
rated Aaa Super Senior class would be Aaa, Aaa, and Aa1,
respectively; for the most junior Aaa rated class A-S would be
Aa1, Aa1, and A2, respectively. Parameter Sensitivities are not
intended to measure how the rating of the security might migrate
over time; rather they are designed to provide a quantitative
calculation of how the initial rating might change if key input
parameters used in the initial rating process differed. The
analysis assumes that the deal has not aged. Parameter
Sensitivities only reflect the ratings impact of each scenario
from a quantitative/model-indicated standpoint. Qualitative
factors are also taken into consideration in the ratings process,
so the actual ratings that would be assigned in each case could
vary from the information presented in the Parameter Sensitivity
analysis.

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


* Fitch Cuts Rating on 6 Security Classes From 9 CRE CDOs
---------------------------------------------------------
Fitch Ratings has downgraded six classes and affirmed 102 classes
from nine Re-REMICs/commercial real estate collateralized debt
obligations (CRE CDOs) with exposure primarily to commercial
mortgage backed securities (CMBS).

A rating action spreadsheet, titled 'Fitch Takes Various Rating
Actions on 9 CRE CDOs', dated Nov. 29, 2012, details the
individual rating actions for each rated CDO.  It can be found on
Fitch's website at 'www.fitchratings.com' by performing a title
search or by using the link below. For further information and
transaction research, please refer to 'www.fitchratings.com'.

This review was conducted under the framework described in the
reports 'Global Structured Finance Rating Criteria' and 'Global
Rating Criteria for Structured Finance CDOs'.  None of the
reviewed transactions have been analyzed within a cash flow model
framework, as the impact of structural features and excess spread,
or conversely, principal proceeds being used to pay CDO
liabilities and hedge payments, was determined to be minimal in
the context of these CDO ratings.

For the six transactions where the percentage of collateral
experiencing full interest shortfalls in the portfolio already
significantly exceeds the credit enhancement (CE) level of the
most senior class of notes, Fitch believes that the probability of
default for all classes of notes can be evaluated without
factoring in potential further losses from the remaining portion
of the portfolios.  Therefore, these transactions were not modeled
using the Structured Finance Portfolio Credit Model (SF PCM).

For the three transactions where the percentage of interest
shortfalls did not significantly exceed the CE level of the senior
class of notes, Fitch used SF PCM to project future losses from
the transaction's entire portfolio and compared the CE of the
classes to those loss rates.

The two classes affirmed at 'CCCsf' have CE that is comparable to
the 'CCC' rating loss rate (RLR) projected by SF PCM. The classes
are the most senior class and have received paydowns since the
last rating action. Fitch believes that default remains possible
for these classes.

The class downgraded to 'CCsf' has CE that is exceeded by the
'CCC' RLR but is above the percentage of collateral experiencing
interest shortfalls. Fitch believes that default is probable for
this class.

The two classes downgraded to 'Csf' and 63 classes affirmed at
'Csf' are notes whose CE levels are significantly below the
percentage of collateral experiencing interest shortfalls, full or
partial.  The CE levels are also significantly below the
percentage of the collateral with a Fitch derived rating of 'CC'
and below.  Due to the extent of distress in these portfolios,
Fitch believes default continues to appear inevitable for these
classes.

Fourteen classes were affirmed at 'Dsf' because they are non-
deferrable classes that have and are expected to continue to
experience further interest payment shortfalls.  Three classes
were downgraded and 23 classes affirmed at 'Dsf' because the
classes have experienced principal writedowns.

Fitch does not assign Rating Outlooks to classes rated in the
'CCC' and lower categories.

Six of the nine transactions, ACAS CRE CDO 2007-1, ACT 2005-RR
Depositor Corp., Anthracite 2004-HY1, ARCap 2004-RR3, LNR CDO
2006-1 and SASCO 2007-BHC1 Trust are 100% underlying CMBS
transactions.  The remaining composition is as follows:

  -- ARCap 2006-RR7, 77.8% structured finance CDOs (SF CDOs),
     22.2% CMBS;
  -- Ansonia CDO 2006-1, 91.7% CMBS, 8.3% real estate
     investment trust (REIT);
  -- Newcastle CDO VI, Limited, 39.6% CMBS, 26.1% REIT, 22.5%
     residential mortgage backed securities (RMBS), 11.8%
     commercial real estate loans (CREL).


* Fitch Downgrades 54 Bonds on 33 CMBS Transactions to 'D'
----------------------------------------------------------
Fitch Ratings has downgraded 54 bonds in 33 U.S. commercial
mortgage-backed securities (CMBS) transactions to 'D', as the
bonds have incurred a principal write-down.  The bonds were all
previously rated 'C' which indicates that Fitch expected a
default.

The action is limited to just the bonds with write-downs.  The
remaining bonds in these transactions have not been analyzed as
part of this review.  Fitch has downgraded the bonds to 'D' as
part of the ongoing surveillance process and will continue to
monitor these transactions for additional defaults.

In addition, Fitch has withdrawn 11 'D' ratings in four
transactions after the balances have been reduced to zero due to
realized losses.

A spreadsheet detailing Fitch's rating actions on the affected
transactions is available at 'www.fitchratings.com' by performing
a title search for: 'Fitch Downgrades 54 Distressed Bonds in 33
U.S. CMBS Transactions'.


* Moody's Lowers Ratings on $1-Bil. 2005-2007 Prime Jumbo RMBS
--------------------------------------------------------------
Moody's Investors Service has downgraded 56 tranches issued by
four issuers.  The collateral backing these deals primarily
consists of first-lien, fixed-rate Prime Jumbo residential
mortgages.  The actions impact approximately $1 billion of RMBS
issued from 2005 to 2007.

Complete rating actions are as follows:

Issuer: Banc of America Funding 2006-4 Trust

Cl. A-1, Downgraded to Caa2 (sf); previously on Apr 21, 2010
Confirmed at B3 (sf)

Cl. A-2, Downgraded to Caa2 (sf); previously on Apr 21, 2010
Confirmed at B3 (sf)

Cl. A-3, Downgraded to Caa2 (sf); previously on Apr 21, 2010
Confirmed at B3 (sf)

Cl. A-4, Downgraded to Caa2 (sf); previously on Apr 21, 2010
Confirmed at B3 (sf)

Cl. A-8, Downgraded to Caa2 (sf); previously on Apr 21, 2010
Downgraded to Caa1 (sf)

Cl. A-11, Downgraded to Caa2 (sf); previously on Apr 21, 2010
Downgraded to Caa1 (sf)

Cl. 30-IO, Downgraded to Caa2 (sf); previously on Feb 22, 2012
Upgraded to B3 (sf)

Issuer: J.P. Morgan Mortage Trust 2006-S2

Cl. 1-A-1, Downgraded to Caa1 (sf); previously on Apr 12, 2010
Downgraded to B2 (sf)

Cl. 1-A-3, Downgraded to Caa1 (sf); previously on Apr 12, 2010
Confirmed at B3 (sf)

Cl. 1-A-5, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-7, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-8, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-9, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Confirmed at B3 (sf)

Cl. 1-A-11, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-12, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-13, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-14, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-15, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-16, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-17, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 1-A-22, Downgraded to Ca (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 1-A-23, Downgraded to C (sf); previously on Jun 24, 2009
Downgraded to Ca (sf)

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

Cl. 3-A-2, Downgraded to Caa1 (sf); previously on Apr 12, 2010
Confirmed at B3 (sf)

Cl. 3-A-4, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 3-A-5, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 3-A-7, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. 3-A-8, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 3-A-10, Downgraded to Ca (sf); previously on Apr 12, 2010
Downgraded to Caa3 (sf)

Cl. 3-A-11, Downgraded to Ca (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 3-A-12, Downgraded to Ca (sf); previously on Apr 12, 2010
Downgraded to Caa3 (sf)

Cl. 3-A-14, Downgraded to Ca (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Issuer: RFMSI Series 2005-S9 Trust

Cl. A-1, Downgraded to Caa2 (sf); previously on Jul 19, 2011
Confirmed at B2 (sf)

Cl. A-2, Downgraded to Caa2 (sf); previously on Jul 19, 2011
Confirmed at B2 (sf)

Cl. A-3, Downgraded to Caa1 (sf); previously on Jul 19, 2011
Confirmed at B2 (sf)

Cl. A-4, Downgraded to C (sf); previously on Apr 12, 2010
Downgraded to Ca (sf)

Cl. A-5, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-6, Downgraded to Caa1 (sf); previously on Jul 19, 2011
Confirmed at B2 (sf)

Cl. A-8, Downgraded to Caa1 (sf); previously on Jul 19, 2011
Confirmed at B2 (sf)

Cl. A-9, Downgraded to Caa1 (sf); previously on Jul 19, 2011
Confirmed at B3 (sf)

Cl. A-P, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-V, Downgraded to Caa1 (sf); previously on Jul 19, 2011
Confirmed at B2 (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2007-4 Trust

Cl. A-1, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-4, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-5, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Confirmed at B3 (sf)

Cl. A-7, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Confirmed at B3 (sf)

Cl. A-8, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-9, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Confirmed at B3 (sf)

Cl. A-10, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-11, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-12, Downgraded to C (sf); previously on Apr 23, 2009
Downgraded to Ca (sf)

Cl. A-13, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-14, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-15, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-16, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Cl. A-PO, Downgraded to Caa2 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Ratings Rationale

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

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

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

Loan Modifications

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

Small Pool Volatility

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

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

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

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

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_SF308216

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

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


* S&P Puts Ratings on 26 Tranches From 25 Synthetic CDOs on Watch
-----------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 26
tranches from 25 corporate-backed synthetic collateralized debt
obligation (CDO) transactions on CreditWatch positive. "At the
same time, we raised two tranche ratings from two corporate-backed
synthetic CDO transactions. The rating actions followed our
monthly review of synthetic CDO transactions," S&P said.

"The CreditWatch positive placements reflect the seasoning of the
transactions, the rating stability of the obligors in the
underlying reference portfolios over the past few months, and the
synthetic rated overcollateralization (SROC) ratios that had risen
above 100% at the next highest rating level. The upgrades are from
synthetic CDOs with direct links to credit-linked notes of a
separate issuer," 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

Betsen CDO Ltd.
Series 2007-2
                                 Rating
Class                    To                    From
Notes                    CCC- (sf)/Watch Pos   CCC- (sf)

Camber Master Trust Series 10
                                 Rating
Class                    To                  From
Series 10                B- (sf)             CCC (sf)

Camber Master Trust Series 9
                                 Rating
Class                    To                  From
Series 9                 B- (sf)             CCC (sf)

Credit Default Swap
US$1.437 bil J.P. Morgan Chase Bank, N.A. - Credit Protection
Trust 255
(Soleil)
Series J17593 (SOLEIL)
                                 Rating
Class                    To                    From
Tranche                  A+srp (sf)/Watch Pos  A+srp (sf)

Credit Default Swap
US$225 mil Swap Risk Rating - "Paoli" Ref No. 64451
                                 Rating
Class                 To                       From
Tranche               BBB+srp (sf)/Watch Pos   BBB+srp (sf)

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

Credit Linked Notes Ltd. 2006-1
                                 Rating
Class                    To                  From
Notes                    B- (sf)/Watch Pos   B- (sf)

Greylock Synthetic CDO 2006
Series 1
                                 Rating
Class                    To                  From
A1A-$LS                  BBB (sf)/Watch Pos  BBB (sf)

Greylock Synthetic CDO 2006
Series 4
                                 Rating
Class                    To                  From
A1šLS                    BBB (sf)/Watch Pos  BBB (sf)

Infiniti SPC Ltd.
US$20 mil Infiniti SPC Limited Acting on Behalf of and for the
Account of the
Potomac Synthetic CDO 2007-2
Segregated Portfolio, Series 10A-2
                                 Rating
Class                    To                  From
10A-2                    BB+ (sf)/Watch Pos  BB+ (sf)

Lorally CDO Limited Series 2007-3
                                 Rating
Class                    To                  From
2007-3                   A+ (sf)/Watch Pos   A+ (sf)

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

Morgan Stanley ACES SPC
US$75 mil Morgan Stanley ACES SPC 2006-35
                                 Rating
Class                    To                  From
I                        B- (sf)/Watch Pos   B- (sf)

Morgan Stanley Managed ACES SPC
Series 2005-1
                                 Rating
Class                    To                  From
IV A                     B- (sf)/Watch Pos   B- (sf)
IV B                     B- (sf)/Watch Pos   B- (sf)

Morgan Stanley Managed ACES SPC
Series 2006-4
                                 Rating
Class                    To                    From
IIIA                     BBB- (sf)/Watch Pos   BBB- (sf)

PARCS Master Trust
Series 2007-5 CALVADOS
                                 Rating
Class                    To                  From
Trust Unit               B- (sf)/Watch Pos   B- (sf)

PARCS Master Trust
US$300 mil PARCS Master Trust Class 2007-10 CDX7 10Y 10-15
(Floating Recovery)
Units
                                 Rating
Class                    To                  From
Trust Unit               BB+ (sf)/Watch Pos  BB+ (sf)

Repacs Trust Series: Bayshore I
                                 Rating
Class                    To                  From
B                        BB (sf)/Watch Pos   BB (sf)

STARTS (Cayman) Ltd.
Series 2006-3
                                 Rating
Class                    To                  From
B1-D1                    B- (sf)/Watch Pos   B- (sf)

STARTS (Cayman) Ltd.
Series 2006-4
                                 Rating
Class                    To                  From
B2-D2                    B- (sf)/Watch Pos   B- (sf)

STARTS (Cayman) Ltd.
Series 2006-7
                                 Rating
Class                    To                  From
B1-H1                    B- (sf)/Watch Pos   B- (sf)

STARTS (Cayman) Ltd.
Series 2006-6
                                 Rating
Class                    To                  From
B1-A1                    B- (sf)/Watch Pos   B- (sf)

STARTS (Cayman) Ltd.
Series 2006-9
                                 Rating
Class                    To                  From
B3-D3                    B- (sf)/Watch Pos   B- (sf)

STARTS (Cayman) Ltd.
Series 2007-17
                                 Rating
Class                    To                    From
B1-D1                    CCC- (sf)/Watch Pos   CCC- (sf)

STARTS (Ireland) PLC
Series 2006-20
                                 Rating
Class                    To                  From
A1-E1                    B+ (sf)/Watch Pos   B+ (sf)

STARTS (Ireland) PLC
Series 2006-21
                                 Rating
Class                    To                  From
B1-E1                    B- (sf)/Watch Pos   B- (sf)

STRATA Trust Series 2006-10
                                 Rating
Class                    To                  From
Notes                    BB+ (sf)/Watch Pos  BB+ (sf)


* S&P Takes Various Rating Actions on 1,163 RMBS Classes
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 156
classes from 74 U.S. residential mortgage-backed securities (RMBS)
transactions. "We also raised our ratings on wo classes from two
transactions. Additionally, we affirmed our ratings on 1,105
classes from 277 transactions at the 'CCC (sf)' or 'CC (sf)'
rating category," S&P said.

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

        http://bankrupt.com/misc/S&P_RMBS_RA_11_28_12.pdf

The transactions in this review were issued between 1995 and 2008
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.

"We completed our review of the transactions herein using the
revised assumptions from our recently revised criteria for
surveilling pre-2009 U.S. RMBS ratings," S&P said.

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

    An increase in S&P's default and loss multiples at higher
    investment-grade rating levels.

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

    Increased roll-rates for 30- and 60-day delinquent loans;
    Application of a high prepayment/front end stress liquidation
    scenario; and

    A continued elevated level of observed severities.

"In line with the factors, we increased our remaining loss
projections for the majority of the transactions in this review
from our previous projections. The increase in the remaining
projected losses ranged from 0.33% (from 51.36% to 51.53%) for
IXIS Real Estate Capital Trust Series 2006-HE2 to  102.78% (from
10.67% to 21.64%) for RAMP Series 2001-RS1," S&P said.

"We lowered our ratings on 156 classes from 74 transactions. Prior
to the actions, we already rated all of the lowered ratings in the
speculative-grade categories of 'CCC (sf)' or 'CC (sf)'," S&P
said.

Despite the increase in remaining projected losses, S&P upgraded
two classes from two transactions. In general, the upgrades
reflect two general trends S&P has seen in these types of
transactions:

    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 that occurrence.

"All of the upgrades affected classes from transactions issued in
2006 and we originally rated them 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 those classes 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 reperforming loans in the pool;
    Significant growth in observed loss severities; and
    Weak hard-dollar credit support.

"Lastly, we affirmed our ratings on 1,105 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.

"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 generally provide credit support for the reviewed
transactions," 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 Takes Various Rating Actions on 19 Classes From 3 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 three U.S. CMBS transactions and removed nine of them from
CreditWatch with negative implications. Finally, we affirmed our
ratings on two classes from one U.S. CMBS transaction and removed
both ratings from CreditWatch with negative implications. The
CreditWatch resolutions are related to CreditWatch placements that
occurred on Sept. 5, 2012," S&P said.

"The upgrades on the principal and interest certificates reflect
Standard & Poor's expected available credit enhancement for the
affected tranches, which we believe is greater than our most
recent estimate of necessary credit enhancement for the most
recent rating levels. The upgrades also reflect our views
regarding the current and future performance of the collateral
supporting the respective transactions. We raised our rating on
class A-M from Credit Suisse Commercial Mortgage Trust 2006-C1 to
'AAA (sf)' to reflect the results of our cash flow analysis. Our
cash flow analysis indicates that this class should receive its
respective full repayment of principal due to time tranching," S&P
said.

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

"The affirmations primarily reflect our expected available credit
enhancement for the affected tranches, which we believe will
remain consistent with the most recent estimate of necessary
credit enhancement for the current rating levels. The affirmed
ratings also acknowledge our expectations regarding the current
and future performance of the collateral supporting the respective
Transactions," S&P said.

"The rating actions follow a detailed review of the performance of
the collateral supporting the relevant securities and transaction
structures. This review was similar to the review we conducted
before placing 744 U.S. and Canadian CMBS ratings on CreditWatch
following the release of our updated ratings criteria for these
transactions, but was more detailed with respect to collateral and
transaction performance. For more information on the analytic
process we used for those CreditWatch placements," S&P said.

           STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17-g7 Disclosure Reports
included in this credit rating report are available at:

        http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS AND CREDITWATCH ACTIONS

Credit Suisse Commercial Mortgage Trust Series 2006-C1
Commercial mortgage pass-through certificates
           Rating
Class     To        From        Credit enhancement (%)
A-M       AAA (sf)  AA- (sf)/Watch Pos     23.72
F         BB (sf)   BB (sf)/Watch Neg       7.58
G         BB- (sf)  BB- (sf)/Watch Neg      6.32
H         B (sf)    B+ (sf)/Watch Neg       4.89
J         CCC(sf)   B+ (sf)/Watch Neg       3.63

Credit Suisse Commercial Mortgage Trust Series 2006-C3
Commercial mortgage pass-through certificates
           Rating
Class     To        From          Credit enhancement (%)
A-3       AA (sf)   A (sf)/Watch Pos         29.79
A-1-A     AA (sf)   A (sf)/Watch Pos         29.79
A-M       BBB (sf)  BBB- (sf)/Watch Pos      18.72
C         CCC (sf)  B- (sf)                   7.38
D         CCC- (sf)  B- (sf)                  5.58
E         CCC- (sf) CCC+ (sf)                 4.48
F         CCC- (sf) CCC (sf)                  3.09

Morgan Stanley Capital I Trust 2006-HQ9
Commercial mortgage pass-through certificates
           Rating
Class     To        From          Credit enhancement (%)
A-J       BBB+ (sf) A (sf)/Watch Neg         11.01
B         BBB (sf)  A- (sf)/Watch Neg        10.16
C         BBB- (sf) BBB+ (sf)/Watch Neg       8.60
D         BB+ (sf)  BBB (sf)/Watch Neg        7.33
E         BB (sf)   BBB- (sf)/Watch Neg       6.34
F         B+ (sf)   BB+ (sf)/Watch Neg        5.20
G         B (sf)    B+ (sf)/Watch Neg         4.07






                            *********

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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