TCR_Public/130127.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, January 27, 2013, Vol. 17, No. 28

                            Headlines

ABACUS 2005-4: Moody's Cuts Ratings on Five Note Classes to 'B1'
ABACUS 2006-10: Moody's Cuts 'C' Ratings on Four Note Classes
ABACUS 2006-13: Moody's Cuts Rating on Class A Notes to 'C'
ABACUS 2006-17: Moody's Affirms 'C' Ratings on 2 Note Classes
ACAS BUSINESS 2006-1: S&P Raises Rating on Class D Notes to 'B+'

ACAS BUSINESS 2007-1: S&P Raises Rating on Class D Notes to 'BB+'
ADVANTA BUSINESS: S&P Lowers Rating on Class D Notes to 'D'
AIRLIE CLO 2006-I: S&P Raises Rating on Class D Notes to 'BB+'
APIDOS CLO XI: S&P Assigns 'BB' Rating to Class E Notes
ATRIUM IX: S&P Assigns Prelim. 'BB' Rating on Class E Notes

AVOCA CLO V: S&P Affirms 'CCC-' Rating on Class F Notes
BEAR STEARNS 2007-TOP26: Fitch Cuts Rating on Cl. F Certs to 'Csf'
BLACK DIAMOND: S&P Assigns 'BB' Rating to Class D Notes
BRIDGEPORT CLO II: S&P Affirms 'BB' Rating on Class D Notes
C-BASS CBO V: Fitch Hikes Ratings on Two Notes Classes to 'Bsf'

CANADA MORTGAGE: Moody's Cuts Rating on Cl. IO-C Tranche to 'Ba3'
CARLYLE ARNAGE: S&P Raises Rating of Class B-2L Notes to 'BB+'
CD COMMERCIAL 2007-CD5: Fitch Affirms C Ratings in 2 Cert. Classes
CHASE COMMERCIAL 1999-2: Fitch Affirms 'B-' Rating on Cl. E Notes
COMM 2013-LC6: S&P Assigns Prelim. 'B+' Rating on Class F Notes

CONCORD REAL: S&P Retains 'CCC-' Rating on 3 Note Classes
CREST 2003-1: Fitch Affirms 'Csf' Rating on Class D-2 Notes
CREST 2003-1: Moody's Affirms 'Caa2' Ratings on 2 Note Classes
CRYSTAL RIVER: Moody's Affirms 'C' Ratings on Nine Note Classes
DIVERSIFIED ASSET: Moody's Affirms 'C' Rating on Class B Notes

EAGLE CREEK: Moody's Affirms 'Ba3' Rating on Class D Notes
FIRST FRANKLIN: Moody's Affirms 'C' Ratings on Two Note Classes
FMC REAL 2005-1: S&P Lowers Rating on Class E & F Notes to 'CCC-'
FRASER SULLIVAN: S&P Retains 'B+' Rating on 2 Note Classes
GEMSTONE CDO: Moody's Affirms 'C' Ratings on Three Note Classes

GRAMERCY PARK: S&P Affirms 'BB' Rating on Class D Notes
GS MORTGAGE 2013-GC10: Fitch Rates Class F Certificates 'Bsf'
GS MORTGAGE 2013-GC10: S&P Gives Prelim. B+ Rating on Cl. F Notes
HALCYON 2005-2: Moody's Cuts Ratings on 2 Note Classes to 'Ca'
HARCH CLO II: S&P Retains 'CCC-' Rating on Class E Notes

ICE GLOBAL: S&P Affirms 'BB' Rating to Class E Notes
LENOX STREET: Moody's Affirms 'C' Ratings on Nine Note Classes
JP MORGAN 2001-CIBC1: Fitch Cuts Rating on Class G Notes to 'CCC'
JP MORGAN 2003-CIBC6: Fitch Cuts Rating on Class N Notes to 'Csf'
JP MORGAN 2006-CIBC17: Fitch Cuts Rating on Class B Certs. to Csf

JP MORGAN 2006-WMC1: Moody's Hikes Rating on A-4 Certs. to 'Caa3'
KATONAH VII: S&P Lowers Rating on Class D Notes to 'B+'
KATONAH IX: S&P Raises 'B+' Rating on Class B-2L Notes
LEHMAN STRUCTURED: Moody's Withdraws B2 Ratings on Six Tranches
MADISON PARK II: Moody's Upgrades Rating on Class D Notes to 'Ba2'

MADISON PARK VIII: S&P Affirms 'BB' Rating on Class E Notes
MAGNOLIA FINANCE: Moody's Affirms 'C' Rating on Cl. D CMBS Notes
ML-CFC 2007-9: Fitch Lowers Rating on 3 Cert. Classes to 'Csf'
MORGAN STANLEY 2006-HQ9: Fitch Lowers Ratings on 3 Cert. Classes
MRU STUDENT: Moody's Lowers Rating on Class B Tranche to 'C'

N-STAR REAL II: Fitch Affirms Csf Rating on $16.9MM Class D Notes
N-STAR REAL VII: Fitch Cuts Ratings on 8 Cert. Classes to 'Csf'
NATIONSTAR AGENCY: S&P Assigns Prelim 'B' Rating to 2 Note Classes
OCEAN TRAILS: S&P Assigns 'B+' Rating to Class D Notes
OFSI FUND III: S&P Hikes Rating 2 Note Classes to 'CCC+'

OFSI FUND V: S&P Assigns Prelim. 'B' Rating to Class B-3L Notes
OHA LOAN 2012-1: S&P Assigns 'BB' Rating to Class E Notes
OLYMPIC CLO I: S&P Raises Rating on Class B-1L Notes to 'BB+'
OWS CLO I: Moody's Affirms 'Caa3' Rating on Class D Notes
PACIFIC BAY: Fitch Affirms 'Dsf' Rating on Two Note Classes

PACIFICA CDO III: Moody's Hikes Ratings on 2 Note Classes to Ba2
PREMIUM LOAN: S&P Lowers Rating on Class C Notes to 'CCC-'
RASC SERIES 2005-KS2: Moody's Corrects M-1 Certs Rating to Caa3
RASC SERIES 2005-KS2: Moody's Hikes Rating on M-1 Tranche to Ba3
RESOURCE REAL 2006-1: S&P Lowers Rating on Class G Notes to 'B-'

SEQUOIA MORTGAGE 2013-2: Fitch to Rate Class B-4 Certs. 'BB'
SORIN REAL: S&P Lowers Rating on 4 Note Classes to 'D'
SRRSPOKE 2007-IA: Moody's Affirms 'C' Ratings on 2 Note Classes
SRRSPOKE 2007-IB: Moody's Affirms 'C' Rating on Class I Notes
TALMAGE STRUCTURED: Fitch Affirms 'CCsf' Rating on Class F Notes

TERWIN MORTGAGE: Moody's Cuts Rating on Cl. B-2 Tranche to 'C'
TRIMARAN CLO IV: Moody's Raises Rating on Cl. B-2L Notes to 'Ba2'
VENTURE XII: S&P Assigns 'BB' Rating to Class E Notes
VIBRANT CLO: S&P Assigns 'BB' Rating on Class D Notes
VICTORIA FALLS: S&P Retains 'CCC-' Rating on Class D Def Notes

VITALITY RE IV: S&P Assigns 'BB+' Rating to Class B Notes
WACHOVIA CRE 2006-1: S&P Affirms 'CCC-' Rating on 4 Note Classes
WAMU 2007-1: S&P Hikes Rating on Class 2A1 Notes to 'CCC'
WELLS FARGO 2011-C2: Fitch Affirms 'Bsf' Rating on $14.6MM Certs.
WFRBS 2013-C11: S&P Assigns Prelim. 'BB' Rating on Class E Notes

WHITEHORSE VI: S&P Assigns 'B' Rating on Class B-3L Notes
WHITNEY CLO I: S&P Raises Rating on Class B-1LB Notes to BB

* Fitch Lowers Rating on 40 Bonds in 26 CMBS Transaction to 'D'
* Moody's Takes Rating Action on $600-Mil. Subprime RMBS
* Moody's Withdraws Ratings on $122 Million Pre-2005 RMBS
* Moody's Places 31 Tobacco Settlements Under Review
* S&P Withdraws Ratings on 33 Note Classes



                            *********

ABACUS 2005-4: Moody's Cuts Ratings on Five Note Classes to 'B1'
----------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of eight
classes of Notes issued by Abacus 2005-4, Ltd. due to
deterioration in the credit quality of the underlying portfolio of
reference obligations. 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
Synthetic) transactions.

Cl. A-1, Downgraded to Baa2 (sf); previously on Apr 6, 2011
Downgraded to A2 (sf)

Cl. A-2, Downgraded to Ba2 (sf); previously on May 5, 2010
Downgraded to Baa3 (sf)

Cl. B, Downgraded to Ba3 (sf); previously on Apr 6, 2011
Downgraded to Ba2 (sf)

Cl. C, Downgraded to B1 (sf); previously on Apr 6, 2011 Downgraded
to Ba2 (sf)

Cl. D, Downgraded to B1 (sf); previously on May 5, 2010 Downgraded
to Ba2 (sf)

Cl. E-1, Downgraded to B1 (sf); previously on Apr 6, 2011
Downgraded to Ba3 (sf)

Cl. E-3, Downgraded to B1 (sf); previously on Apr 6, 2011
Downgraded to Ba3 (sf)

Cl. E-2, Downgraded to B1 (sf); previously on Apr 6, 2011
Downgraded to Ba3 (sf)

Abacus 2005-4, Ltd. is a static synthetic transaction backed by a
portfolio of credit default swaps on commercial mortgage backed
securities (CMBS) (100% of the reference obligation balance). As
of the December 28, 2012 Trustee report, the aggregate issued Note
balance of the transaction, including preferred shares, was $600.0
million, the same as that at issuance.

RATINGS RATIONALE

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 69
compared to 20 at last review. The current distribution of Moody's
rated collateral and assessments for non-Moody's rated collateral
is as follows: Aaa- Aa3 (73.0% compared to 86.6% at last review),
A1- A3 (16.9% compared to 13.4% at last review) and Baa1-Baa3
(10.1% compared to 0.0% at last review).

Moody's modeled a WAL of 2.6 years, the same as it was at last
review. The current WAL is based on the assumption about
extensions.

Moody's modeled a fixed WARR of 62.0% compared to 65.1% at last
review.

Moody's modeled a MAC of 47.9% compared to 56.4% at last review.

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 current ratings and
credit estimates of the reference obligations by one notch
downward or by one notch upward affects the model results by 1 to
2 notches downward and 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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock; albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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

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

Moody's analysis encompasses the assessment of stress scenarios.


ABACUS 2006-10: Moody's Cuts 'C' Ratings on Four Note Classes
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of five and
affirmed the ratings of four classes of Notes issued by Abacus
2006-10, LTD. The downgrades are due to deterioration in
underlying reference obligation performance as evidenced by
negative transitions in Moody's weighted average rating factor
(WARF) and weighted average recovery rate (WARR). The affirmations
are due to key transaction parameters performing within levels
commensurate with the existing ratings levels. The rating action
is the result of Moody's on-going surveillance of commercial real
estate collateralized debt obligation (CRE CDO Synthetic)
transactions.

Moody's rating action is as follows:

Cl. A, Affirmed Caa3 (sf); previously on Feb 2, 2012 Downgraded to
Caa3 (sf)

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

Cl. C, Downgraded to C (sf); previously on Mar 2, 2011 Downgraded
to Ca (sf)

Cl. D, Downgraded to C (sf); previously on Mar 2, 2011 Downgraded
to Ca (sf)

Cl. E, Downgraded to C (sf); previously on Mar 2, 2011 Downgraded
to Ca (sf)

Cl. F, Downgraded to C (sf); previously on Mar 2, 2011 Downgraded
to Ca (sf)

Cl. J, Affirmed C (sf); previously on Mar 2, 2011 Downgraded to C
(sf)

Cl. K, Affirmed C (sf); previously on Mar 2, 2011 Downgraded to C
(sf)

Cl. L, Affirmed C (sf); previously on Mar 2, 2011 Downgraded to C
(sf)

RATINGS RATIONALE

Abacus 2006-10, LTD. is a static synthetic transaction backed by a
portfolio of credit default swaps referencing 100% commercial
mortgage backed securities (CMBS). All of the CMBS reference
obligations were securitized in 2004 (26.7%) and 2005 (73.3%).
Currently, 74.1% of the reference obligations are rated by
Moody's.

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 reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 2,318 compared to 1,631 at last
review. The current distribution is as follows: Aaa-Aa3 (4.9%
compared to 2.4% at last review), A1-A3 (18.2% compared to 21.9%
at last review), Baa1-Baa3 (21.9% compared to 27.1% at last
review), Ba1-Ba3 (14.2% compared to 21.9% at last review), B1-B3
(17.0% compared to 13.8% at last review), and Caa1-Ca/C (23.8%
compared to 12.9% at last review).

Moody's modeled to a WAL of 2.9 years, compared to 3.6 years at
last review.

Moody's modeled a variable WARR with a mean of 13.7%, compared to
15.6% at last review.

Moody's modeled a MAC of 17.0%, compared to 21.7% 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.

Moody's analysis encompasses the assessment of stress scenarios.

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 credit changes within the reference obligations.
Holding all other key parameters static, stressing the current
ratings and credit assessments of the reference obligations by one
notch downward or one notch upward affects the model results by
approximately 0 to 1 notch negatively and 0 to 1 notch positively,
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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock, albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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


ABACUS 2006-13: Moody's Cuts Rating on Class A Notes to 'C'
-----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of one class
and affirmed five classes of Notes issued by Abacus 2006-13, Ltd.
due to additional writedowns to the notional amount of the
reference obligations. The affirmations are due to the key
transaction parameters performing within levels commensurate with
the existing ratings levels. The rating action is the result of
Moody's on-going surveillance of commercial real estate
collateralized debt obligation and collateralized loan obligation
(CRE CDO Synthetic) transactions.

Cl. A, Downgraded to C (sf); previously on Mar 26, 2010 Downgraded
to Ca (sf)

Cl. B, Affirmed C (sf); previously on Mar 26, 2010 Downgraded to C
(sf)

Cl. C, Affirmed C (sf); previously on Mar 26, 2010 Downgraded to C
(sf)

Cl. D, Affirmed C (sf); previously on Mar 26, 2010 Downgraded to C
(sf)

Cl. E, Affirmed C (sf); previously on Mar 26, 2010 Downgraded to C
(sf)

Cl. F, Affirmed C (sf); previously on Mar 26, 2010 Downgraded to C
(sf)

Abacus 2006-13, Ltd. is a static synthetic transaction backed by a
portfolio of credit default swaps on commercial mortgage backed
securities (CMBS) (100% of the reference obligation balance). As
of the December 28, 2012 Trustee report, the aggregate issued
notional balance of the transaction has decreased to $198.5
million from $323.0 million at issuance, due to writedowns on the
underlying reference obligations and full and partial redemption
of the Class B and the Class D through Class N Notes.

RATINGS RATIONALE

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 6,921
compared to 6,911 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Aaa- Aa3 (1.1% compared to 0.0% at last
review), Baa1-Baa3 (6.7% compared to 10.3% at last review), Ba1-
Ba3 (12.4% compared to 7.7% at last review), B1-B3 (8.8% compared
to 11.9% at last review) and Caa1-C (53.3% compared to 51.6% at
last review).

Moody's modeled a WAL of 3.7 years, compared to 4.7 years at last
review.

Moody's modeled a fixed WARR of 3.4%, the same as at last review.

Moody's modeled a MAC of 100%, the same as at last review.

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 current ratings and
credit assessments of the reference obligations by one notch
downward or by one notch upward does not result in any rating
changes to the rated notes.

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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock; albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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

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

Moody's analysis encompasses the assessment of stress scenarios.


ABACUS 2006-17: Moody's Affirms 'C' Ratings on 2 Note Classes
-------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of all classes
of Notes issued by Abacus 2006-17, 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 (CRE CDO Synthetic)
transactions.

Moody's rating action is as follows:

Cl. A-1, Affirmed C (sf); previously on Mar 2, 2011 Downgraded to
C (sf)

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

RATINGS RATIONALE

Abacus 2006-17, LTD. is a static synthetic transaction backed by a
portfolio of credit default swaps referencing commercial mortgage
backed securities (CMBS) (93.2% of current notional amount), and
CRE CDO bonds (6.8%). All of the reference obligations were
securitized in 2004 (1.1%), 2005 (52.9%), and 2006 (46.0%).
Currently, 80.5% of the reference obligations are rated by
Moody's.

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 reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 8,960 compared to 8,872 at last
review. The current distribution is as follows: Ba1-Ba3 (4.5%
compared to 3.8% at last review), B1-B3 (0.0% compared to 2.8% at
last review), and Caa1-Ca/C (95.5% compared to 93.4% at last
review).


Moody's modeled to a WAL of 4.9 years, compared to 5.6 years at
last review.

Moody's modeled a variable WARR with a mean of 13.7%, the same as
last review.

Moody's modeled a MAC of 0.0%, the same as last review.

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

Moody's analysis encompasses the assessment of stress scenarios.

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 credit changes within the reference obligations.
However, in light of the performance indicators noted above,
Moody's believes that it is unlikely that the ratings announced on
Jan. 24 are sensitive to further change.

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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock, albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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


ACAS BUSINESS 2006-1: S&P Raises Rating on Class D Notes to 'B+'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class C and D notes from ACAS Business Loan Trust 2006-1, a
collateralized loan obligation (CLO) transaction currently
managed by American Capital Ltd.  At the same time, S&P
removed its rating on the class C notes from CreditWatch
positive.

The transaction is in its amortization phase and continues
to use its principal proceeds to pay down the senior notes
in the payment sequence, as specified in the indenture.  The
rating actions follow S&P's performance review of ACAS
Business Loan Trust 2006-1 and reflect $155.2 million in
paydowns to the class A, B, and C notes since S&P affirmed
its ratings on those classes in August 2011.  The class A
and B notes have paid in full and the class C notes have
paid down to 66.9% of their original balance, leading to an
increase in overcollateralization (O/C) available to support
the class C and D notes.  The transaction has also benefited
from the receipt of principal proceeds from prepayments and
sales of defaulted assets, which have led to improving
credit quality of the collateral.

Standard & Poor's took into account the concentration risk
of the transaction resulting from a relatively low number of
loans remaining to support the notes.

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

ACAS Business Loan Trust 2006-1

                              Rating
Class                   To           From

C                       BB+ (sf)     CCC+ (sf)/Watch Pos
D                       B+ (sf)      CCC- (sf)


ACAS BUSINESS 2007-1: S&P Raises Rating on Class D Notes to 'BB+'
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class C and D notes from ACAS Business Loan Trust 2007-1, a
collateralized loan obligation transaction currently managed
by American Capital Ltd., and removed them from CreditWatch
positive.

The transaction is in its amortization phase and continues
to use principal proceeds to pay down the senior notes in
the payment sequence (as specified in the indenture).   The
rating actions follow S&P's performance review of ACAS
Business Loan Trust 2007-1 and reflect $26.9 million in
paydowns to the class B and C notes since S&P raised its
ratings on those classes in June 2012.  The class B notes
have paid in full and the class C notes have paid down to
72.5% of their original balance, leading to an increase in
the class C and D note overcollateralization.  The
transaction has also benefited from the receipt of principal
proceeds from prepayments and sales of defaulted assets,
which have improved the credit quality of the collateral.

Standard & Poor's took into account the concentration risk
of the transaction due to a relatively low number of loans
remaining to support the notes.

S&P will continue to review its ratings on the notes and
assess whether, in its view, the ratings remain consistent
with the credit enhancement available to support them and
take rating actions as it deem 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

ACAS Business Loan Trust 2007-1

                              Rating
Class                   To           From

C                       A (sf)       B- (sf)/Watch Pos
D                       BB+ (sf)     CCC- (sf)/Watch Pos


ADVANTA BUSINESS: S&P Lowers Rating on Class D Notes to 'D'
------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the
class D(2007-D1) notes from Advanta Business Card Master
Trust to 'D (sf)' from 'CC (sf)'.

As of the Jan. 22, 2013 distribution date, the transaction
hasn't repaid the invested amount of the class D(2007-D1)
notes, leaving the full initial principal amount of
$25,000,000 outstanding or unpaid on the legal final
maturity date.

S&P has therefore lowered its rating to 'D (sf)' to reflect
the nonpayment of full principal to the investors of the
class D(2007-D1) notes on the Jan. 22, 2013 final maturity
date.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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


AIRLIE CLO 2006-I: S&P Raises Rating on Class D Notes to 'BB+'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1, A-2, B, C, and D notes from Airlie CLO 2006-I
Ltd., a collateralized loan obligation (CLO) transaction
currently managed by Neuberger Berman Group LLC.  At the
same time, S&P removed its ratings on all five classes from
CreditWatch with positive implications.

The rating actions follow S&P's performance review of Airlie
CLO 2006-I Ltd. and reflect $80 million in paydowns on the
class A-1 notes, to 66.3% of their original balance, since
S&P's March 2011 rating actions, when it raised its ratings
on four classes of notes.  The paydowns have led to an
increase in overcollateralization (O/C) available to support
the notes.  The class A, B, C, and D O/C ratios have
increased by 4.8%, 3.5%, 1.7%, and 1.3%, respectively, since
the February 2011 trustee report which S&P referenced for
its March 2011 rating actions.

For S&P's analysis, it observed $6.5 million in assets from
obligors rated in the 'CCC' category, down from the
$9.0 million it observed for its March 2011 rating actions.
As of the December 2012 trustee report, the transaction held
$0 in defaulted assets.

Another positive factor in S&P's analysis is the increase in
the weighted-average spread to 3.7% from 3.1% since its last
rating action.  The transaction ended its reinvestment
period on June 6, 2012.

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

S&P will continue to review its ratings on the notes and
assess whether, in its view, the ratings remain consistent
with the credit enhancement available to support them and
take rating actions as it deem 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

Airlie CLO 2006-I Ltd.

                              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)    BB+ (sf)/Watch Pos
D                       BB+ (sf)     B+ (sf)/Watch Pos


APIDOS CLO XI: S&P Assigns 'BB' Rating to Class E Notes
--------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
Apidos CLO XI/Apidos CLO XI LLC's $370.25 million floating-
and fixed-rate notes.

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

The ratings reflect S&P's view of:

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

-- The transaction's credit enhancement, which is
    sufficient to withstand the defaults applicable for the
    supplemental tests (not counting excess spread), and
    cash flow structure, which can withstand the default
    rate projected by Standard & Poor's CDO Evaluator model,
    as assessed by Standard & Poor's using the assumptions
    and methods outlined in its corporate collateralized
    debt obligation criteria (see "Update To Global
    Methodologies And Assumptions For Corporate Cash Flow
    And Synthetic CDOs,"published Sept. 17, 2009).

-- 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
    S&P assessed using its cash flow analysis and
    assumptions commensurate with the assigned ratings under
    various interest-rate scenarios, including LIBOR ranging
    from 0.31%-12.81%.

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

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

   http://standardandpoorsdisclosure-17g7.com/1243.pdf

RATINGS ASSIGNED

Apidos CLO XI/Apidos CLO XI LLC

Class                    Rating              Amount
                                            (mil. $)
A                        AAA (sf)            263.25
B-1                      AA (sf)              15.00
B-2                      AA (sf)              25.00
C (deferrable)           A (sf)               29.75
D (deferrable)           BBB (sf)             20.00
E (deferrable)           BB (sf)              17.25
Subordinated notes       NR                   42.60

NR-Not rated.


ATRIUM IX: S&P Assigns Prelim. 'BB' Rating on Class E Notes
------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Atrium IX/Atrium IX LLC's $747.75 million
floating- and fixed-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
Jan. 23, 2013.  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 (see "Update To Global Methodologies And
   Assumptions For Corporate Cash Flow And Synthetic CDOs,"
   published Sept. 17, 2009).

- 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 preliminary rated
   notes, which S&P assessed using its cash flow analysis
   and assumptions commensurate with the assigned
   preliminary ratings under various interest-rate
   scenarios, including LIBOR ranging from 0.3950%-13.8391%.

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

- The transaction's reinvestment overcollateralization
   test, a failure of which will lead to the
   reclassification of excess interest proceeds that are
   available before paying uncapped administrative expenses
   and fees, subordinated hedge termination payments,
   portfolio manager incentive fees, and subordinated note
   payments to principal proceeds for the purchase of
   additional collateral assets during the reinvestment
   period and to reduce the balance of the rated notes
   outstanding, sequentially, after the reinvestment period.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

    http://standardandpoorsdisclosure-17g7.com/1258.pdf

PRELIMINARY RATINGS ASSIGNED

Atrium IX/Atrium IX LLC

Class                      Rating           Amount
                                          (mil. $)

A                          AAA (sf)         522.00
B-1                        AA (sf)           52.00
B-2                        AA (sf)           35.00
C (deferrable)             A (sf)            66.50
D (deferrable)             BBB (sf)          38.25
E (deferrable)             BB (sf)           34.00
Subordinated notes         NR                84.25

NR--Not rated.


AVOCA CLO V: S&P Affirms 'CCC-' Rating on Class F Notes
--------------------------------------------------
Standard & Poor's Ratings Services affirmed its credit
ratings on all of Avoca CLO V PLC's rated classes of
notes in.

The rating actions follow S&P's review of the transaction's
performance by conducting its credit and cash flow analysis
and applying its relevant criteria for transactions of this
type.

"Our analysis shows that the overall credit quality of the
portfolio has improved following our previous review on
Jan. 16, 2012 (see "Ratings Raised On Six Classes Of Notes
In Avoca CLO V; Four Ratings Affirmed").  Since then, the
proportion of assets rated in the 'CCC' category ('CCC+',
'CCC', or 'CCC-') has decreased to 5.35% from 8.61%, and the
level of defaulted assets (assets from obligors rated 'CC',
'C', 'SD' [selective default], or 'D') has decreased to
3.24% from 4.73%.  The level of credit enhancement has
slightly increased for all rated classes of notes.  The
transaction now benefits from a higher weighted-average
spread of 3.74%, compared with 3.04% as of our January
2012 review," S&P said.

S&P has subjected the transaction's capital structure to a
cash flow analysis to determine the break-even default rates
for each rated class at each rating level.  In S&P's
opinion, the credit enhancement available to the class A1a,
A1b, and A2 notes is commensurate with the currently
assigned ratings.  S&P has incorporated a series of cash
flow stress scenarios using various default patterns and
levels for each liability rating category, in conjunction
with different interest stress scenarios.

Avoca CLO V entered into a number of derivative agreements
to mitigate currency risks in the transaction.  S&P do not
consider the documentation for these derivative agreements
to be fully compliant with its 2012 counterparty criteria
(see "Counterparty Risk Framework Methodology And
Assumptions," published on Nov. 29, 2012).  Therefore, S&P
has not assumed any support from these derivative agreements
under its 'AAA', 'AA+', and 'AA' stress scenarios.

S&P has therefore affirmed its 'AAA (sf)' rating on the
class A1a notes and its 'AA+ (sf)' ratings on the class A1b
and A2 notes based on its credit and cash flow analysis.

"Our ratings on the class B, C, D, E, and F notes are
constrained by the application of the largest obligor test,
a supplemental stress test that we introduced in our 2009
cash flow collateralized debt obligation (CDO) criteria
(see "Update To Global Methodologies And Assumptions For
Corporate Cash Flow And Synthetic CDOs," published on
Sept. 17, 2009).  This test addresses event and model risk
that might be present in the transaction.  Although the
break-even default rates generated by our cash flow model
indicated higher ratings, the largest obligor test
effectively constrained the ratings on the class B notes at
'A+ (sf)', on the class C notes at 'BBB+ (sf)', on the class
D notes at 'BB+ (sf)', on the class E notes at 'CCC+ (sf)',
and on the class F notes at 'CCC- (sf)'.  We have therefore
affirmed our ratings on the class B, C, D, E, and F notes at
their current levels," S&P added.

"Following our cash flow analysis, we have observed that the
credit quality of the class R combination notes is still
commensurate with the currently assigned rating.  We have
therefore affirmed our 'BBB+ (sf)' rating on the class R
combination notes," S&P noted.

Deutsche Bank AG (A+/Negative/A-1) acts as bank account
provider and custodian in the transaction.  Under its 2012
counterparty criteria, the counterparty is appropriately
rated to support its ratings on the notes.

Avoca CLO V is a cash flow collateralized loan obligation
(CLO) transaction that closed in June 2006.  The collateral
is managed by Avoca Capital Holdings.

          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 LIST

Avoca CLO V PLC
EUR543.25 Million Floating-Rate Notes

Class           Rating

Ratings Affirmed

A1a             AAA (sf)
A1b             AA+ (sf)
A2              AA+ (sf)
B               A+ (sf)
C1              BBB+ (sf)
C2              BBB+ (sf)
D               BB+ (sf)
E               CCC+ (sf)
F               CCC- (sf)
R Combo         BBB+ (sf)

Combo-Combination.


BEAR STEARNS 2007-TOP26: Fitch Cuts Rating on Cl. F Certs to 'Csf'
------------------------------------------------------------------
Fitch Ratings has downgraded four classes and affirmed 16 classes
of Bear Stearns Commercial Mortgage Securities Trust (BSCMS)
Series 2007-TOP26.

Sensitivity/Rating Drivers

The downgrades reflect an increase in Fitch expected losses across
the pool and greater certainty of losses associated with specially
serviced assets. Fitch modeled losses of 10.9% of the remaining
pool; expected losses on the original pool balance total 11%,
including losses already incurred. The pool has experienced $36.1
million (1.7% of the original pool balance) in realized losses to
date.

Fitch has designated 50 loans (23.9%) as Fitch Loans of Concern,
which includes 11 specially serviced assets (8.3%).

As of the January 2013 distribution date, the pool's aggregate
principal balance has been reduced by 14.9% to $1.79 billion from
$2.11 billion at issuance. Per the servicer reporting, one loan
(0.05% of the pool) has defeased since issuance. Interest
shortfalls are currently affecting classes G through P.

The largest contributor to expected losses is the specially-
serviced 909 A Street loan (2.7% of the pool), which is secured by
a 210,186 square (sf) office property located in Tacoma, WA. The
loan was transferred to the special servicer in February 2012 due
to the lease expiration in November 2013. The sole tenant vacated
the property in 2010 when it moved its headquarters to Seattle.
The tenant (guaranteed by Northwestern Mutual Life, rated 'AAA'
with a Stable Outlook by Fitch) is required to make rental
payments until the lease expires in November 2013. A cash flow
sweep was triggered in December 2011, which is expected to collect
approximately $4.4 million to cover costs associated with re-
leasing the property.

The next largest contributor to expected losses is the Viad
Corporate Center loan (3.1%), which is secured by a 476,424 sf
office property located in Phoenix, AZ. The loan was modified in
May 2011 and the terms included a principal write-down of $9
million to $56 million, and establishing an $8 million capital
expense escrow for tenant improvements, leasing commissions and
repairs. The year-end 2011 DSCR was 1.14x and as of the September
2012 rent roll the property is 62% occupied, an increase from
55.2% in September 2011. Leases representing only 3% of net
rentable area (NRA) expire through year-end 2013.

The third largest contributor to expected losses is a specially-
serviced loan (0.9%), secured by a 149,902 sf office building
located in Ridgefield Park, NJ. The loan transferred to the
special servicer in March 2012 due to monetary default resulting
from a lease expiration that caused occupancy to drop from
approximately 90% to 30%. The special servicer has engaged counsel
and is proceeding with foreclosure.

Fitch downgrades the following classes as indicated and has
assigned or revised Recovery Estimates (REs):

-- $210.6 million class A-M to 'AAsf' from 'AAAsf', Outlook
    Negative;
-- $160.6 million class A-J to 'CCCsf' from 'BBsf', RE 90%;
-- $18.4 million class C to 'CCsf' from 'CCCsf', RE 0%;
-- $18.4 million class F to 'Csf' from 'CCsf', RE 0%.

Fitch affirms the following classes as indicated:

-- $12.4 million class A-2 at 'AAAsf', Outlook Stable;
-- $65.4 million class A-3 at 'AAAsf', Outlook Stable;
-- $68.2 million class A-AB at 'AAAsf', Outlook Stable;
-- $991.9 million class A-4 at 'AAAsf', Outlook Stable;
-- $121.7 million class A-1A at 'AAAsf', Outlook Stable;
-- $42.1 million class B at 'CCCsf', RE 0%;
-- $29 million class D at 'CCsf', RE 0%;
-- $15.8 million class E at 'CCsf', RE 0%;
-- $18.4 million class G at 'Csf', RE 0%;
-- $18.4 million class H at 'Csf', RE 0%;
-- $703,825 class J at 'Dsf', RE 0%;
-- $0 class K at 'Dsf', RE 0%;
-- $0 class L at 'Dsf', RE 0%;
-- $0 class M at 'Dsf', RE 0%;
-- $0 class N at 'Dsf', RE 0%;
-- $0 class O at 'Dsf', RE 0%.

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


BLACK DIAMOND: S&P Assigns 'BB' Rating to Class D Notes
--------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
Black Diamond CLO 2012-1 Ltd./Black Diamond CLO 2012-1 LLC's
$371.04 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 (see "Update To Global Methodologies And
   Assumptions For Corporate Cash Flow And Synthetic CDOs,"
   published Sept. 17, 2009).

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

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

- The asset manager's experienced management team.

- The timely interest and ultimate principal payments on
   the rated notes, which S&P assessed using its cash flow
   analysis and assumptions commensurate with the assigned
   ratings under various interest-rate scenarios, including
   LIBOR ranging from 0.3105%-13.8391%.

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

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

         STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

   http://standardandpoorsdisclosure-17g7.com/1194.pdf

RATINGS ASSIGNED

Black Diamond CLO 2012-1 Ltd./Black Diamond CLO 2012-1 LLC

Class                   Rating     Amount (mil. $)

X                       AAA (sf)              2.25
A-1                     AAA (sf)            260.00
A-2                     AA (sf)              41.14
B (deferrable)          A (sf)              31.425
C (deferrable)          BBB (sf)            19.425
D (deferrable)          BB (sf)              16.80
Subordinated notes      NR                   44.25

NR--Not rated.


BRIDGEPORT CLO II: S&P Affirms 'BB' Rating on Class D Notes
------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-2, B, and C notes from Bridgeport CLO II Ltd., a
collateralized loan obligation (CLO) transaction managed by
Deerfield Capital Management LLC.  At the same time, S&P
removed the ratings from CreditWatch, where it placed them
with positive implications on Oct. 29, 2012.  S&P also
affirmed its ratings on the class A-1 and D notes from the
transaction.

This transaction is currently in its reinvestment phase
until September 2014.

The upgrades reflect improved credit quality since S&P's
January 2012 review.  Due to this and other factors,
overcollateralization (O/C) ratios for all the classes have
increased.  In addition, the transaction's 'CCC' rated
assets decreased to $14.6 million in December 2012 from
$26.4 million in December 2011.  Another positive factor is
the increase in the weighted-average spread to 4.7% from
4.0% since S&P's last rating action.

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

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

Bridgeport CLO II Ltd.

                         Rating
Class                To           From

A-2                  AA (sf)      A+ (sf)/Watch Pos
B                    A (sf)       BBB+ (sf)/Watch Pos
C                    BBB (sf)     BBB- (sf)/Watch Pos

RATINGS AFFIRMED

Bridgeport CLO II Ltd.

Class                Rating
A-1                  AA+ (sf)
D                    BB (sf)


C-BASS CBO V: Fitch Hikes Ratings on Two Notes Classes to 'Bsf'
---------------------------------------------------------------
Fitch Ratings has upgraded and assigned Rating Outlooks to two
classes of notes issued by C-BASS CBO V, Ltd./Corp. (C-BASS V) as
follows:

-- $0 class C notes marked 'PIF';
-- $2,903,961 class D-1 notes upgraded to 'Bsf' from 'CCCsf';
    Outlook Stable;
-- $2,782,963 class D-2 notes upgraded to 'Bsf' from 'CCCsf';
    Outlook Stable.

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

Sensitivity/Rating Drivers

Since the last review in 2012, the negative rating momentum in the
underlying portfolio has somewhat abated, with 25.3% of the pool
upgraded a weighted average of 4.3 notches and 14.2% downgraded a
weighted average of 2.2 notches. Approximately 84.5% of the
portfolio now has a Fitch derived rating below investment grade
and 82.9% has a rating in the 'CCC' rating category or lower,
compared to 57.7% and 48.9%, respectively, at previous review.

However, this additional deterioration has been successfully
offset by the ongoing amortization of the capital structure, with
$4.3 million of the class C notes' remaining balance paid in full
on the June 22, 2012 payment date. Since then, the class D-1 and
D-2 (together, class D) notes have also received all of their
previously deferred interest amounts and approximately $11.8
million in payments towards reduction of their principal.
Consequently, the credit enhancement (CE) levels available to the
class D notes have increased meaningfully, providing cushion to
thse notes to withstand potential further negative migration in
the portfolio.

Although, the cash flow model indicates the class D notes pass
rating levels higher than 'Bsf' in all scenarios, they rely on the
performance of only five non-distressed assets and recoveries
realized on the distressed assets, currently at 82.9% of the
portfolio.

C-BASS V is a static structured finance collateralized debt
obligation (SF CDO) that closed on Dec. 20, 2002. The initial
portfolio was selected by C-BASS Investment Management LLC and as
of Feb. 14, 2011 it is monitored by NIC Management LLC, an
affiliate of Newcastle Investment Corp. As of the Dec. 24, 2012
Trustee report, the portfolio is comprised primarily of
residential mortgage-backed securities (92.3%) from 1997 through
2002 vintage transactions and of one SF CDO (7.7%).


CANADA MORTGAGE: Moody's Cuts Rating on Cl. IO-C Tranche to 'Ba3'
-----------------------------------------------------------------
Moody's Investors Service has withdrawn the rating of one tranche
from one RMBS transactions issued in 2006. The tranche is backed
by a pool of mortgage loans with pool factor less than 5% and
containing fewer than 40 loans.

Complete rating actions are as follows:

Issuer: Canada Mortgage Acceptance Corporation, Series 2006-C5

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

RATINGS RATIONALE

Moody's current RMBS surveillance methodologies apply to pools
with at least 40 loans and a pool factor of greater than 5%. As a
result, Moody's may withdraw its rating when the pool factor drops
below 5% and the number of loans in the pool declines to 40 loans
or lower unless specific structural features allow for a
monitoring of the transaction (such as a credit enhancement
floor).

Moody's has withdrawn the rating pursuant to published rating
methodologies that allow for the withdrawal of the rating if the
size of the underlying collateral pool at the time of the
withdrawal has fallen below a specified level.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF314700


CARLYLE ARNAGE: S&P Raises Rating of Class B-2L Notes to 'BB+'
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1L, A-1LA, A-1LB, A-2L, A-3L, B-1L, and B-2L notes
from Carlyle Arnage CLO Ltd., a U.S. collateralized loan
obligation (CLO) transaction managed by Carlyle Investment
Management LLC.  At the same time, S&P removed its ratings
on the same classes from CreditWatch with positive
implications, where it placed them on Oct. 29, 2012.

The upgrades mainly reflect paydowns to the class A-1L, A-
1LA, and A-1LB notes.  Subsequently, the credit enhancement
available to support the notes has improved since February
2011, when S&P upgraded the class B-2L notes.  Since that
time, the transaction has paid down the class A-1LA, A-1LB,
and A-1L notes by $83.4 million, $12.6 million, and
$33.5 million, respectively, for a total of approximately
$129.6 milion.  These paydowns have reduced the outstanding
note balances of the class A-1LA, A-1LB, and A-1L to 70.68%,
71.77%, and 70.82% of their balances at issuance.

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

   -- The senior class A O/C ratio was 125.66%, compared
      with a reported ratio of 118.93% in January 2011;

   -- The class A O/C ratio was 117.18%, compared with a
      reported ratio of 112.93% in January 2011;

   -- The class B-1L O/C ratio was 111.13%, compared with a
      reported ratio of 108.50% in January 2011; and

   -- The class B-2L O/C ratio was 106.19%, compared with a
      reported ratio of 104.81% in January 2011.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Carlyle Arnage CLO Ltd.

                   Rating
Class         To           From

A-1L          AAA (sf)     AA+ (sf)/Watch Pos
A-1LA         AAA (sf)     AA+ (sf)/Watch Pos
A-1LB         AAA (sf)     AA+ (sf)/Watch Pos
A-2L          AA+ (sf)     A+ (sf)/Watch Pos
A-3L          AA- (sf)     BBB+ (sf)/Watch Pos
B-1L          BBB+ (sf)    BB+ (sf)/Watch Pos
B-2L          BB+ (sf)     B+ (sf)/Watch Pos

TRANSACTION INFORMATION

Issuer:             Carlyle Arnage CLO Ltd.
Coissuer:           Stanfield Arnage CLO (Delaware) Corp.
Collateral manager: Carlyle Investment Management LLC
Underwriter:        Bear Stearns Cos. LLC
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CDO


CD COMMERCIAL 2007-CD5: Fitch Affirms C Ratings in 2 Cert. Classes
------------------------------------------------------------------
Fitch Ratings has affirmed all classes of CD Commercial Mortgage
Trust 2007-CD5, commercial mortgage pass-through certificates, due
to stable performance since Fitch's last review.

KEY RATING DRIVERS

The affirmations reflect a slight increase in cumulative loss
expectations, which were offset by paydown of approximately 9%
since Fitch's previous rating action. Fitch modeled losses of 6.2%
(9% cumulative transaction losses, which includes losses realized
to date) based on expected losses on the specially serviced loans
and loans that are not expected to refinance at maturity.

As of the December 2012 distribution date, the pool's aggregate
principal balance has decreased 18.6% to $1.7 billion from $2.09
billion at issuance. As of December 2012, there are cumulative
interest shortfalls in the amount of $1.6 million, currently
affecting classes N through H. Fitch has designated 50 loans
(22.8%) as Fitch Loans of Concern, which includes 12 specially
serviced loans (4.3%).

The largest contributor to modeled losses is the Lincoln Square
loan (9.4%). The loan is collateralized by a 405,978 square foot
(sf) office property located in Washington, DC. The property
encompasses one-half of the block surrounded by 10th, 11th, E and
F Streets and is located within the East End submarket of
Washington, D.C. The YE 2011 net cash flow DSCR was 1.24x compared
to 1.31x underwritten at issuance. Occupancy dipped slightly, to
96.7%, as of June 2012. The property had previously been 100%
occupied since issuance.

The second largest contributor to modeled losses is a 73,000 sf
retail property(0.9%), located in Culpeper, VA. The loan was
transferred to the Special Servicer in March 2011 for imminent
default. The property became REO in February 2012. The receiver is
working to stabilize the property prior to marketing for sale. A
recent appraisal indicates significant losses.

The third largest contributor to modeled losses is two adjacent
apartment buildings located in the Bronx, NY consisting of 111
units(0.4%). The asset became REO in July 2012. The property was
96% occupied as of October 2012 and the special servicer will be
marketing it for sale in 2013. A recent appraisal indicates
significant losses.

Fitch has affirmed these classes:

-- $954.9 million class A-4 at 'AAAsf'; Outlook Stable;
-- $203.7 million class A-1A at 'AAAsf'; Outlook Stable;
-- $168.7 million class AM at 'AAAsf'; Outlook Stable;
-- $40.7 million class A-MA at 'AAAsf'; Outlook Stable;
-- $111.8 million class AJ at 'BBBsf'; Outlook Stable;
-- $27 million class A-JA at 'BBBsf'; Outlook Stable;
-- $20.9 million class B at 'BBBsf'; Outlook Stable;
-- $20.9 million class C at 'BBsf'; Outlook Stable;
-- $20.9 million class D at 'BBsf'; Outlook Negative;
-- $18.3 million class E at 'Bsf'; Outlook Negative;
-- $18.3 million class F at 'CCCsf'; RE 100%;
-- $20.9 million class G at 'CCsf'; RE 10%;
-- $23.6 million class H at 'CCsf'; RE 0%;
-- $23.6 million class J at 'Csf'; RE 0%;
-- $20.9 million class K at 'Csf'; RE 0%.

Classes A-1, A-2, A-3 and A=AB have been paid in full. Classes L
through Q have realized losses and remain at 'Dsf'; RE 0%. Class S
is not rated by Fitch. Fitch withdrew the ratings of the interest-
only classes X-S and X-P.


CHASE COMMERCIAL 1999-2: Fitch Affirms 'B-' Rating on Cl. E Notes
-----------------------------------------------------------------
Fitch Ratings has upgraded one class and affirmed one class of
Chase Commercial Mortgage Securities Corporation commercial
mortgage pass-through certificates series 1999-2.

Sensitivity/Rating Drivers

The upgrade is a result of principal paydown resulting in
increased credit enhancement to the senior class sufficient to
offset Fitch expected losses, as well as defeasance in the pool.
While class K has high credit enhancement and there are proceeds
from defeased loans to repay a significant portion of the class,
the rating has been capped at 'Asf' due to concentration concerns
with only three non-defeased loans remaining.

As of the January 2013 distribution date, the pool's aggregate
principal balance has been reduced by 97.9% to $16.7 million from
$782.7 million at issuance. There are four of the original 92
loans remaining in the transaction, one of which is fully defeased
(31.9% of the pool balance). Interest shortfalls totaling $4.2
million are affecting the non-rated class M.

Fitch modeled losses of 0.5% of the remaining pool. The pool has
experienced $10.3 million (1.3% of the original pool balance) in
realized losses to date. There are no specially serviced loans as
of the January 2013 distribution date.

Fitch has designated two loans (59.5% of the pool) as Fitch Loans
of Concern, including the largest loan in the pool (43.7%) which
is secured by a 62,042 square foot office property in Los Gatos,
CA. Property cash flow has struggled since 2004 due to reduced
revenue from decreased rental rates and increased concessions. The
loan remains current and the property is currently 100% occupied,
however, debt service coverage ratio (DSCR) remains low reporting
at 0.93x for year to date March 2012.

Fitch upgrades the following class:

-- $6.4 million class K to 'Asf' from 'Bsf'; Outlook Stable.

Fitch affirms the following class:

-- $5.9 million class L at 'B-sf'; Outlook Negative.

The class A-1, A-2, B, C, D, E, F, G, H, I and J certificates have
paid in full. Fitch does not rate the class M certificates. Fitch
previously withdrew the rating on the interest-only class X
certificates.


COMM 2013-LC6: S&P Assigns Prelim. 'B+' Rating on Class F Notes
---------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to COMM 2013-LC6 Mortgage Trust's $1.49 billion
commercial mortgage pass-through certificates series 2013-
LC6.

The note issuance is a commercial mortgage-backed securities
transaction backed by 70 commercial mortgage loans with an
aggregate principal balance of $1,492.3 million, secured by
the fee interest in 99 properties across 27 states.

The preliminary ratings are based on information as of
Jan. 17, 2013.  Subsequent information may result in the
assignment of final ratings that differ from the preliminary
ratings.

The preliminary ratings reflect the credit support provided
by the transaction structure, S&P's view of the underlying
collateral's economics, the trustee-provided liquidity, the
collateral pool's relative diversity, and S&P's overall
qualitative assessment of the transaction.  Standard &
Poor's Ratings Services determined that the collateral pool
has, on a weighted average basis, debt service coverage of
1.71x and beginning and ending loan-to-value ratios of 82.3%
and 69.7%, respectively, based on Standard & Poor's values.

       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/1248.pdf.

PRELIMINARY RATINGS ASSIGNED

COMM 2013-LC6 Mortgage Trust

Class(i)      Rating(i)              Amount
                                        ($)

A-1           AAA (sf)           93,810,000
A-2           AAA (sf)          288,944,000
A-SB          AAA (sf)          116,999,000
A-3           AAA (sf)          140,000,000
A-4           AAA (sf)          404,822,000
X-A           AAA (sf)        1,178,878,000(iii)
A-M           AAA (sf)          134,303,000
B             AA- (sf)           91,400,000
C             A (sf)             55,960,000
X-B(ii)       A (sf)            147,360,000(iii)
X-C(ii)       NR                104,458,024(iii)
D(ii)         BBB- (sf)          61,555,000
E(ii)         BB (sf)            29,845,000
F(ii)         B+ (sf)            27,980,000
G(ii)         NR                 46,633,024

(i) The certificates will be issued to qualified
     institutional buyers according to Rule 144A of
     the Securities Act of 1933.
(ii)Non-offered certificates.
(iii)Notional balance.
NR - Not rated.


CONCORD REAL: S&P Retains 'CCC-' Rating on 3 Note Classes
----------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
seven classes from Concord Real Estate CDO-2006-1 Ltd. a
commercial real estate collateralized debt obligation (CRE
CDO) transaction, and removed them from CreditWatch with
negative implications.

The affirmations reflect S&P's analysis of the transaction's
liability structure and the credit characteristics of the
underlying collateral, using its Global CDOs of Pooled
Structured Finance Assets criteria.  In S&P's analysis, it
also considered the amount of defaulted assets in the
transaction and the recoveries it expects.

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

According to the Dec. 19, 2012, trustee report, the
transaction's collateral totaled $356.8 million, while the
transaction's liabilities totaled $311.0 million and were
down from $465.0 million at issuance.  The transaction's
current asset pool included the following:

   -- Ten subordinate-interest loans ($183.0 million,
      51.3%);

   -- Four whole loans and senior-participation loans ($61.4
      million, 17.2%);

   -- Fifteen commercial mortgage-backed securities (CMBS)
      tranches ($102.3 million, 28.7%); and

   -- One CRE CDO tranche ($10.1 million, 2.8%).

The trustee report noted five defaulted assets
($47.3 million, 13.3%) as follows:

   -- The JW Marriott subordinate-interest loan
      ($27.5 million, 7.7%);

   -- The G-Force CDO 2006-1 Ltd. J tranche CRE CDO
      ($10.1 million, 2.8%);

   -- The COMM 2005-FL11 L tranche CMBS
      ($4.2 million, 1.2%);

   -- The Credit Suisse First Boston Mortgage Securities
      Corp. 2007-TFL1 L tranche CMBS ($3.5 million, 1.0%);
      and

   -- The Credit Suisse First Boston Mortgage Securities
      Corp. 2007-TFL1 K tranche CMBS ($2.0 million, 0.6%).

Standard & Poor's does not expect any recovery on the
defaulted subordinate-interest loan.  S&P based the recovery
rate on information from the collateral manager, special
servicer, and third-party data providers.

S&P applied asset specific recovery rates in its analysis of
the 13 performing loans ($216.9 million, 60.8%) using its
updated "Rating Methodology And Assumptions For U.S. And
Canadian CMBS," published Sept. 5, 2012.  S&P also
considered qualitative factors, such as the near-term
maturities of the loans and refinancing prospects of the
assets in the pool.

According to the trustee report, the deal is passing all of
its overcollateralization coverage tests and all of its
interest coverage tests.

In addition, S&P analysis considers the prior cancellations
of subordinate notes.  According to the June 22, 2011,
trustee report, as well as a notice from the trustee, U.S.
Bank N.A., certain subordinate notes were cancelled before
they were repaid through the transaction's payment
waterfall.  S&P's ratings reflect its assessment of any
risks and credit stability considerations regarding the
subordinate note cancellations.

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 determine necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

          http://standardandpoorsdisclosure-17g7.com

RATINGS AFFIRMED AND REMOVED FROM CREDITWATCH

Concord Real Estate CDO-2006-1 Ltd.

                  Rating
Class     To             From

A-1       BB+ (sf)       BB+ (sf)/Watch Neg
A-2       BB (sf)        BB (sf)/Watch Neg
B         B- (sf)        B- (sf)/Watch Neg
C         CCC+ (sf)      CCC+ (sf)/Watch Neg
D         CCC- (sf)      CCC- (sf)/Watch Neg
E         CCC- (sf)      CCC- (sf)/Watch Neg
F         CCC- (sf)      CCC- (sf)/Watch Neg


CREST 2003-1: Fitch Affirms 'Csf' Rating on Class D-2 Notes
-----------------------------------------------------------
Fitch Ratings has upgraded two and affirmed four classes issued by
Crest 2003-1 Ltd./Corp. as a result of significant paydowns to the
senior notes.

Key Rating Drivers:

Since the last rating action in February 2012, approximately 11.5%
of the collateral has been downgraded and 5.1% has been upgraded.
Currently, 72.9% of the portfolio has a Fitch derived rating below
investment grade and 53.7% has a rating in the 'CCC' category and
below, compared to 54.5% and 42.5%, respectively, at the last
rating action. Over this period, the transaction has received
$127.1 million in pay downs which has resulted in the full
repayment of the class A notes.

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

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

The Stable Outlook on the class B notes reflects Fitch's view that
the transaction will continue to delever.

Crest 2003-1 is a static cash flow collateralized debt obligation
(CDO), which closed March 13, 2003. The collateral is composed of
99% commercial mortgage backed securities (CMBS), and 1% real
estate investment trusts (REIT). The transaction is collateralized
by 36 assets from 16 obligors.

Fitch has taken the following actions as indicated:

--$3,002,232 class B-1 notes upgraded to 'Asf' from 'BBBsf',
  Outlook to Stable from Negative;
--$4,503,348 class B-2 notes upgraded to 'Asf' from 'BBBsf',
  Outlook to Stable from Negative;
--$28,195,450 class C-1 notes affirmed at 'CCCsf';
--$47,909,057 class C-2 notes affirmed at 'CCCsf';
--$11,117,633 class D-1 notes affirmed at 'Csf';
--$64,515,913 class D-2 notes affirmed at 'Csf'.


CREST 2003-1: Moody's Affirms 'Caa2' Ratings on 2 Note Classes
--------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of four classes
of Notes issued by Crest 2003-1, Ltd. The affirmations are due to
the key transaction parameters performing within levels
commensurate with the existing ratings levels. The rating action
is the result of Moody's on-going surveillance of commercial real
estate collateralized debt obligation (CRE CDO and Re-remic)
transactions.

Moody's rating action is as follows:

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

Cl. B-2, Affirmed A1 (sf); previously on Feb 1, 2012 Downgraded to
A1 (sf)

Cl. C-1, Affirmed Caa2 (sf); previously on Feb 1, 2012 Downgraded
to Caa2 (sf)

Cl. C-2, Affirmed Caa2 (sf); previously on Feb 1, 2012 Downgraded
to Caa2 (sf)

RATINGS RATIONALE

Crest 2003-1, Ltd. is a static cash transaction backed by a
portfolio of commercial mortgage backed securities (CMBS) (99.0%
of the pool balance) and real estate investment trust (REIT) debt
(1.0%). As of the December 31, 2012 Trustee report, the aggregate
Note balance of the transaction, including preferred shares, has
decreased to $339.2 million from $600.0 million at issuance, with
the paydown currently directed to the Class B1 and Class B2 Notes,
as a result of both regular amortization of the underlying
collateral and failure of certain par value tests.

There are 13 assets with a par balance of $49.5 million (32.3% of
the current pool balance) that are considered defaulted securities
as of the December 31, 2012 Trustee report. While there have been
moderate losses on the underlying collateral to date, Moody's does
expect moderate losses to occur on the defaulted securities once
they are realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 5,956
compared to 4,603 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Aaa-Aa3 (6.9% compared to 0.9% at last
review), A1-A3 (1.0% compared to 7.4% at last review), Baa1-Baa3
(4.1% compared to 28.0% at last review), Ba1-Ba3 (14.0% compared
to 10.4% at last review), B1-B3 (12.5% compared to 7.1% at last
review), and Caa1-C (61.5% compared to 46.3% at last review).

Moody's modeled a WAL of 2.4 years compared to 2.1 years at last
review.

Moody's modeled a fixed WARR of 6.4% compared to 16.1% at last
review.

Moody's modeled a MAC of 9.1% compared to 2.0% 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.

Moody's analysis encompasses the assessment of stress scenarios.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
6.4% to 0.4% or up to 11.4% would result in a modeled rating
movement on the rated tranches of 0 to 1 notch downward and 0 to 1
notch upward, respectively.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock; albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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.


CRYSTAL RIVER: Moody's Affirms 'C' Ratings on Nine Note Classes
---------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of nine classes
of Notes issued by Crystal River Resecuritization 2006-1, Ltd. The
affirmations are due to the key transaction parameters performing
within levels commensurate with the existing ratings levels. The
rating action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO and
Re-remic) transactions.

Moody's rating action is as follows:

Cl. A, Affirmed C (sf); previously on Apr 12, 2011 Downgraded to C
(sf)

Cl. B, Affirmed C (sf); previously on Apr 28, 2010 Downgraded to C
(sf)

Cl. C, Affirmed C (sf); previously on Apr 28, 2010 Downgraded to C
(sf)

Cl. D, Affirmed C (sf); previously on Apr 28, 2010 Downgraded to C
(sf)

Cl. E, Affirmed C (sf); previously on Apr 28, 2010 Downgraded to C
(sf)

Cl. F, Affirmed C (sf); previously on Apr 28, 2010 Downgraded to C
(sf)

Cl. G, Affirmed C (sf); previously on Apr 28, 2010 Downgraded to C
(sf)

Cl. J, Affirmed C (sf); previously on Apr 28, 2010 Downgraded to C
(sf)

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

RATINGS RATIONALE

Crystal River Resecuritization 2006-1, Ltd. is a static cash
transaction backed by a portfolio of commercial mortgage backed
securities (CMBS) (100.0% of the pool balance). As of the December
24, 2012 Trustee report, the aggregate Note balance of the
transaction, including preferred shares, has decreased to $388.4
million from $390.3 million at issuance, with the paydown directed
to the Class A Notes.

There are 41 assets with a par balance of $229.4 million (91.4% of
the current pool balance) that are considered defaulted securities
as of the December 24, 2012 Trustee report. While there have been
moderate losses on the underlying collateral to date, Moody's does
expect significant losses to occur on the defaulted securities
once they are realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 9,483
compared to 9,479 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: B1-B3 (4.2% compared to 3.4% at last
review), and Caa1-C (95.8% compared to 96.6% at last review).

Moody's modeled a WAL of 7.5 years compared to 7.7 years at last
review.

Moody's modeled a fixed WARR of 0.2%, the same as that at last
review.

Moody's modeled a MAC of 0.0% compared to 100.0% 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.

Moody's analysis encompasses the assessment of stress scenarios.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. However, in the light of the
performance indicators noted above, Moody's believes that it is
unlikely that the ratings announced on
Jan. 24 are sensitive to further change.

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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock; albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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.


DIVERSIFIED ASSET: Moody's Affirms 'C' Rating on Class B Notes
--------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of the
following notes issued by Diversified Asset Securitization
Holdings I, L.P.:

U.S. $218,000,000 Class A-1 Floating Rate Senior Secured Term
Notes Due 2034 (current balance of $35,143,619.03), Affirmed at
Baa3 (sf); previously on Apr 11, 2012 Downgraded to Baa3 (sf);

U.S. $45,000,000 Class A-2 Fixed Rate Senior Secured Term Notes
Due 2034 (current balance of $7,254,416.76), Affirmed at Baa3
(sf); previously on Apr 11, 2012 Downgraded to Baa3 (sf);

U.S. $27,000,000 Class B Senior Subordinated Secured Term Notes
Due 2034 (current balance of $77,645,237.10 including deferred
interest), Affirmed at C (sf); previously on Dec 3, 2004
Downgraded to C (sf).

RATINGS RATIONALE

According to Moody's, the rating affirmations reflect
consideration of the deleveraging of the Class A-1 and A-2 Notes
and an increase in the transaction's overcollateralization ratios
since the last rating action in April 2012, deterioration in the
credit quality of the underlying portfolio and concerns regarding
a material exposure to an unrated security in the portfolio.

Moody's notes that the Class A-1 and Class A-2 Notes have been
paid down by approximately 21.8% or $11.8 million since the last
rating action. Based on the latest trustee report dated December
28, 2012, the Class A and Class B overcollateralization ratios are
reported at 108.6% and 67.5%, respectively, versus March 2012
levels of 94.7% and 64.1% respectively. Notwithstanding the
benefits of the deleveraging, based on the December 2012 trustee
report, the weighted average rating factor is currently 3409
compared to 3144 in March 2012.

In addition, the affirmation also considers the exposure to a
single unrated manufactured housing loans-backed security
comprising 12.6% of the performing par. This security, whose
rating was withdrawn in January 2012, is supported by a corporate
guarantor whose rating Moody's withdrew in November 2011 due to
insufficient or otherwise inadequate information. The guaranty is
the primary source of enhancement to the security and without this
guaranty the rating of the security would be expected to migrate
to Caa1 (sf) or lower, compared to a rating of Baa1 (sf) before
the withdrawal.

Diversified Asset Securitization Holdings I, L.P., issued in
December 1999, is a collateralized debt obligation backed
primarily by a portfolio of RMBS, CMBS, and other types of ABS
securities originated from 1997 to 2000.

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

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

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

Moody's notes that in arriving at its ratings of SF CDOs, there
exist a number of sources of uncertainty, operating both on a
macro level and on a transaction-specific level. Primary sources
of assumption uncertainty are the extent of the slowdown in growth
in the current macroeconomic environment and the commercial and
residential real estate property markets. While commercial real
estate property markets are gaining momentum, a consistent upward
trend will not be evident until the volume of transactions
increases, distressed properties are cleared from the pipeline and
job creation rebounds. Among the uncertainties in the residential
real estate property market are those surrounding future housing
prices, pace of residential mortgage foreclosures, loan
modification and refinancing, unemployment rate and interest
rates.

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

Moody's non-investment grade rated assets notched up by 2 rating
notches:

Class A-1: +5

Class A-2: +4

Class B: 0

Moody's non-investment grade rated assets notched down by 2 rating
notches:

Class A-1: -1

Class A-2: -2

Class B: 0

Sources of additional performance uncertainties are described
below:

1) Amortizations: The main source of uncertainty in this
transaction is whether amortizations will continue and at what
pace. The rate of prepayments in the underlying portfolio 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.

3) Material exposure to unrated security: As stated earlier in
this press release, 12.6% of the transaction performing par is
constituted by manufactured housing loans-backed security whose
rating was withdrawn in January 2012. Although Moody's assessed
the potential for credit deterioration in the security, the
absence of rating on the guarantor introduces additional
uncertainty in the ability to pay of the security, and as a
consequence, in the credit quality and performance of the SF CDO's
rated notes.

4) Lack of portfolio granularity: The performance of the portfolio
depends to a large extent on the credit conditions of a small
number of large obligors.


EAGLE CREEK: Moody's Affirms 'Ba3' Rating on Class D Notes
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Eagle Creek CLO Ltd.:

U.S.$23,200,000 Class B Second Priority Deferrable Floating Rate
Notes Due February 28, 2018, Upgraded to A1 (sf); previously on
July 13, 2011 Upgraded to A2 (sf).

Moody's also affirmed the rating of the following notes:

U.S.$183,600,000 Class A-1 Senior Secured Floating Rate Notes
February 28, 2018, Affirmed Aaa (sf); previously on March 31, 2006
Assigned Aaa (sf);

U.S.$45,900,000 Class A-2 Senior Secured Floating Rate Notes
February 28, 2018, Affirmed Aaa (sf); previously on July 13, 2011
Upgraded to Aaa (sf);

U.S.$12,700,000 Class C Third Priority Deferrable Floating Rate
Notes February 28, 2018, Affirmed Baa3(sf); previously on July 13,
2011 Upgraded to Baa3 (sf);

U.S.$11,800,000 Class D Fourth Priority Deferrable Floating Rate
Notes Due February 28, 2018 (current outstanding balance of
$10,460,103), Affirmed Ba3(sf); previously on July 13, 2011
Upgraded to Ba3 (sf).

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes
reflect the benefit of the short period of time remaining before
the end of the deal's reinvestment period in February 2013. In
consideration of the reinvestment restrictions applicable during
the amortization period, and therefore limited ability to effect
significant changes to the current collateral pool, Moody's
analyzed the deal assuming a higher likelihood that the collateral
pool characteristics will continue to maintain a positive buffer
relative to certain covenant requirements. In particular, the deal
is assumed to benefit from lower WARF compared to the levels
assumed at the last rating action in July 2011. Moody's modeled a
WARF of 2159 compared to 2300 at the time of the last rating
action. Moody's also notes that the transaction's reported
collateral quality and overcollateralization ratio are stable
since the last rating action.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes. Based on Moody's calculations,
securities that mature after the maturity date of the notes
currently make up approximately 7.3% of the underlying portfolio.
These investments potentially expose the notes to market risk in
the event of liquidation at the time of the notes' maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $283.0 million,
no defaulted par, a weighted average default probability of 12.74%
(implying a WARF of 2159), a weighted average recovery rate upon
default of 50.20%, and a diversity score of 42. 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.

Eagle Creek CLO Ltd., issued in February 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

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

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

Moody's Adjusted WARF -- 20% (1727)

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

Moody's Adjusted WARF + 20% (2591)

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of 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) Long-dated assets: The presence of assets that mature beyond
the CLO's legal maturity date exposes the deal to liquidation risk
on those assets. Moody's assumes an asset's terminal value upon
liquidation at maturity to be equal to the lower of an assumed
liquidation value (depending on the extent to which the asset's
maturity lags that of the liabilities) and the asset's current
market value.


FIRST FRANKLIN: Moody's Affirms 'C' Ratings on Two Note Classes
---------------------------------------------------------------
Moody's Investors Service has upgraded the rating on one tranche
and affirmed the ratings on three tranches from First Franklin
Mortgage Loan Trust 2002-FF2, which is backed by Subprime mortgage
loans.

Ratings Rationale

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

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

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

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

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

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

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

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

The primary sources of assumption uncertainty are Moody's central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 8.5% in December 2011 to 7.8% in December 2012.
Moody's forecasts a unemployment central range of 7.5 to 8.0 for
the 2013 year. Moody's expects housing prices to gradually rise
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer activity such as modification-related
principal forgiveness and interest rate reductions. Any change
resulting from servicing transfers or other policy or regulatory
change can also impact the performance of these transactions.

Complete rating actions are as follows:

Issuer: First Franklin Mortgage Loan Trust 2002-FF2

Cl. A-1, Upgraded to B1 (sf); previously on Apr 9, 2012 Downgraded
to Caa2 (sf)

Cl. A-2, Affirmed Caa2 (sf); previously on Apr 9, 2012 Downgraded
to Caa2 (sf)

Cl. M-1, Affirmed C (sf); previously on Apr 9, 2012 Downgraded to
C (sf)

Cl. M-2, Affirmed C (sf); previously on Jun 25, 2009 Downgraded to
C (sf)

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF314522

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

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


FMC REAL 2005-1: S&P Lowers Rating on Class E & F Notes to 'CCC-'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on
Classes D, E, and F from FMC Real Estate CDO 2005-1 Ltd., a
commercial real estate collateralized debt obligation
(CRE CDO) transaction.  At the same time, Standard & Poor's
affirmed its ratings on Classes B and C.  In addition,
Standard & Poor's removed all five of these ratings from
CreditWatch, where they were placed with negative
implications.

The downgrades and affirmations reflect S&P's analysis of
the transaction's liability structure and the credit
characteristics of the underlying collateral using its
criteria for global CDOs of pooled structured finance
assets.  In S&P's analysis, it also considered the amount of
defaulted assets in the transactions and their expected
recoveries.

The criteria for analyzing global CDOs of pooled structured
finance assets, which S&P published on Feb. 21, 2012,
include revisions to its assumptions on correlations,
recovery rates, and default patterns and timings of the
collateral.  Specifically, correlations on commercial real
estate assets increased to 70%.  The criteria also
incorporate supplemental stress tests (a largest obligor
default test and a largest industry default test) into its
analysis.  The downgrades of Classes D, E and F reflect the
results of the largest obligor default test.  The largest
obligor default test assesses the ability of a rated CDO of
pooled structured finance liability tranche to withstand the
default of a minimum number of the largest credit or obligor
exposures within an asset pool, factoring in the underlying
assets' credit quality.

According to the Dec. 27, 2012, trustee report, the
transaction's collateral totaled $216.7 million.  The
transaction's liabilities totaled $173.2 million, which is
down from $439.4 million.  This is due to subordinate note
cancellations and amortizations.  The transaction's current
asset pool consists of four whole loans/senior
participations ($48.3 million, 22.3%) and 16 subordinate
loans/mezzanine loans ($168.5 million, 77.7%).

The trustee report noted 11 defaulted assets
($143.9 million, 66.4%) in the collateral pool, for which
S&P expects a weighted-average recovery of 37.3%.  S&P
based its recovery analysis on information from the
collateral manager, the special servicer, and third-party
data providers.

S&P applied asset-specific recovery rates in its analysis of
the performing loans in both transactions using its updated
methodology and assumptions for rating U.S. and Canadian
CMBS and S&P's global property evaluation methodology, both
published Sept. 5, 2012.  S&P also considered qualitative
factors, such as the near-term maturities of the loans,
refinancing prospects, and loan modifications.

According to the trustee report, the transaction is passing
all principal coverage tests and Class C, D and E interest
coverage tests.  The transaction is failing the Class F and
G interest coverage tests.

"In addition, our analysis considers the prior cancellations
of subordinate notes in both transactions.  Per notice from
the trustee, U.S. Bank N.A., dated Aug. 2, 2011, the Class G
and H subordinate notes were canceled before they were
repaid through the transaction's payment waterfall.  Our
ratings reflect our assessment of any risks and credit
stability considerations regarding the subordinate note
cancellations," S&P said.

S&P will continue to review whether, in its view, the
ratings on the notes remain consistent with the credit
enhancement available to support them, and S&P will take
further rating actions as it deem appropriate.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED AND REMOVED FROM CREDITWATCH

FMC Real Estate CDO 2005-1 Ltd.

                  Rating
Class     To                   From

D         CCC+ (sf)            BB- (sf)/Watch Neg
E         CCC- (sf)            B+ (sf)/Watch Neg
F         CCC- (sf)            CCC+ (sf)/Watch Neg

RATINGS AFFIRMED AND REMOVED FROM CREDITWATCH

FMC Real Estate CDO 2005-1 Ltd.

                  Rating
Class     To                   From

B         BBB (sf)             BBB (sf)/Watch Neg
C         BB+ (sf)             BB+ (sf)/Watch Neg


FRASER SULLIVAN: S&P Retains 'B+' Rating on 2 Note Classes
-----------------------------------------------------
Standard & Poor's Ratings Services raised and removed from
CreditWatch its ratings on three classes of notes from
Fraser Sullivan CLO I Ltd., a collateralized loan obligation
(CLO) transaction that is managed by Fraser Sullivan
Investment Management LLC.  S&P also affirmed its ratings on
five classes and removed three of them from CreditWatch.

"Since our July 2011 rating actions, the transaction has
exited its reinvestment period and paid down the class A
notes to 66% of its initial balance.  The class A/B
overcollateralization (O/C) ratio has increased to 133.45%
as of the December 2012 trustee report from 127.93% as of
the June 2011 trustee report.  Additionally, the level of
defaulted assets has remained low at $3.79 million, down
from $6.18 million in June 2011.  The liability paydowns in
2012 have led to a higher increase in credit support in the
senior part of the capital structure," S&P said.

"We affirmed our ratings on the class C, D, and E notes to
reflect the availability of sufficient credit support at the
current rating levels.  We will continue to review our
ratings on the notes and assess whether, in our view, the
ratings remain consistent with the credit enhancement
available," S&P added.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

        http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Fraser Sullivan CLO I Ltd.

                   Rating
             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-1          B+ (sf)          B+ (sf)/Watch Pos
D-2          B+ (sf)          B+ (sf)/Watch Pos
E-1          CCC- (sf)        CCC- (sf)
E-2          CCC- (sf)        CCC- (sf)


GEMSTONE CDO: Moody's Affirms 'C' Ratings on Three Note Classes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Gemstone CDO Ltd.:

Class A-1 Floating Rate Notes Due December 2034 (current balance
of $6,700,236), Upgraded to Baa1 (sf); previously on April 26,
2011 Upgraded to Ba3 (sf);

Class A-3 Floating Rate Notes Due December 2034 (current balance
of $9,370,959), Upgraded to Baa1 (sf); previously on April 26,
2011 Upgraded to B1 (sf).

Moody's also affirmed the ratings of the following notes:

Class B Floating Rate Notes Due December 2034 (current balance of
$25,000,000), Affirmed at Ca (sf); previously on May 7, 2010
Downgraded to Ca (sf);

Class C Floating Rate Deferrable Interest Notes Due December 2034
(current balance of $20,368,307), Affirmed at Ca (sf); previously
on March 20, 2009 Downgraded to Ca (sf);

Class D-1 Floating Rate Deferrable Interest Notes Due December
2034 (current balance of $21,640,438), Affirmed at C (sf);
previously on March 20, 2009 Downgraded to C (sf);

Class D-2 Fixed Rate Deferrable Interest Notes Due December 2034
(current balance of $12,252,847), Affirmed at C (sf); previously
on March 20, 2009 Downgraded to C (sf);

Class E Floating Rate Deferrable Interest Notes due December 2034
(current balance of $8,748,005), Affirmed at C (sf); previously on
November 19, 2008 Downgraded to C (sf).

RATINGS RATIONALE

According to Moody's, the rating actions taken on Jan. 18 result
primarily from the continuing amortization of the Class A-1 Notes
and Class A-3 Notes, which have been paid down by $8.7 million and
$7.4 million, respectively, since Moody's last rating action on
April 26, 2011. There is currently $33.3 million of performing
assets, roughly 78% of which have investment-grade ratings,
providing sufficient credit support for the ratings on the
approximately $16.1 million of outstanding Class A Notes . The
structure of the transaction initially provided for pro-
rata/sequential payments between the Class A-1 Notes, Class A-2
Notes, and Class A-3 Notes. However, now that the Class A-2 Notes
have been paid in full, the Class A-1 Notes and Class A-3 Notes
receive payments on a pro-rata basis.

Moody's also notes that since March 2012, $3.3 million of
principal distributions have been received from defaulted assets,
which has benefited the Class A Notes.

Gemstone CDO Ltd., issued in December 2004, is a collateralized
debt obligation backed primarily by a portfolio of RMBS and ABS
originated between 2001 and 2004. The performing assets are
primarily ABS backed by student loans and credit cards.

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

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

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

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

Moody's rating action on Jan. 18 factors in a number of
sensitivity analyses and stress scenarios, discussed below.
Results are shown in terms of the number of notches' difference
versus the current model output, where a positive difference
corresponds to lower expected loss, assuming that all other
factors are held equal:

Moody's non-investment grade rated bucket notched up by two rating
notches:

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

Moody's non-investment grade rated bucket notched down by two
rating notches:

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

Sources of additional performance uncertainties are described
below:

1) Amortizations: The main source of uncertainty in this
transaction is whether amortizations will continue and at what
pace. The rate of prepayments in the underlying portfolio may have
significant impact on the ratings, particularly with respect to
the Class A Notes.

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.


GRAMERCY PARK: S&P Affirms 'BB' Rating on Class D Notes
--------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Gramercy Park CLO Ltd./Gramercy Park CLO Corp.'s
$455.45 million floating-rate notes following the
transaction's effective date as of Oct. 31, 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").

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

S&P believes 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.

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

"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 S&P's published effective date report, it discuss its
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,
S&P intends to publish an effective date report each time it
issue an effective date rating affirmation on a publicly
rated U.S. cash flow CLO.

On an ongoing basis after S&P issues an effective date
rating affirmation, it will periodically review whether, in
its 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 it deem necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

       http://standardandpoorsdisclosure-17g7.com

RATINGS AFFIRMED

Gramercy Park CLO Ltd./Gramercy Park CLO Corp.

Class                   Rating              Amount (mil. $)

A-1                     AAA (sf)                   327.50
A-2                     AA (sf)                     33.70
B (deferrable)          A (sf)                      42.50
C (deferrable)          BBB (sf)                    24.25
D (deferrable)          BB (sf)                     27.50
Subordinated notes      NR                          58.15

NR-Not rated


GS MORTGAGE 2013-GC10: Fitch Rates Class F Certificates 'Bsf'
-------------------------------------------------------------
Fitch Ratings has issued a presale report on Goldman Sachs
Mortgage Company's GS Mortgage Securities Trust, series 2013-GC10
commercial mortgage pass-through certificates.

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

-- $53,438,000 class A-1 'AAAsf'; Outlook Stable;
-- $35,275,000 class A-2 'AAAsf'; Outlook Stable;
-- $21,000,000 class A-3 'AAAsf'; Outlook Stable;
-- $110,000,000 class A-4 'AAAsf'; Outlook Stable;
-- $300,475,000 class A-5 'AAAsf'; Outlook Stable;
-- $81,379,000 class A-AB 'AAAsf'; Outlook Stable;
-- $656,352,000(*) class X-A 'AAAsf'; Outlook Stable;
-- $54,785,000 class A-S 'AAAsf'; Outlook Stable;
-- $103,126,000(*) class X-B 'Asf'; Outlook Stable;
-- $63,380,000 class B 'AAsf'; Outlook Stable;
-- $39,746,000 class C 'Asf'; Outlook Stable;
-- $34,376,000 class D 'BBB-sf'; Outlook Stable;
-- $22,558,000 class E 'BB+sf'; Outlook Stable;
-- $16,114,000 class F 'Bsf'; Outlook Stable.

(*) Notional amount and interest only.

The expected ratings are based on information provided by the
issuer as of Jan. 10, 2013. Fitch does not expect to rate the
$26,855,941 class G.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 61 loans secured by 93 commercial
properties having an aggregate principal balance of approximately
$859.4 million as of the cutoff date. The loans were contributed
to the trust by Citigroup Global Market Realty Corp., Goldman
Sachs Commercial Mortgage Capital, L.P., Archetype Mortgage
Capital, and MC-Five Mile Capital.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 68.7% of the properties
by balance, and performed cash flow analysis and asset summary
reviews on 82.3% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.25 times (x), a Fitch stressed loan-to-value (LTV) of
100.2%, and a Fitch debt yield of 9.5%. Fitch's aggregate net cash
flow represents a variance of 6.4% to issuer cash flows.
The Master Servicer and Special Servicer will be Wells Fargo Bank,
N.A. and LNR Partners, Inc., rated 'CMS2' and 'CSS1-',
respectively, by Fitch.


GS MORTGAGE 2013-GC10: S&P Gives Prelim. B+ Rating on Cl. F Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to GS Mortgage Securities Trust 2013-GC10's
$859.4 million commercial mortgage pass-through certificates
series 2013-GC10.

The note issuance is a commercial mortgage-backed securities
transaction backed by 61 commercial mortgage loans with an
aggregate principal balance of $859.4 million, secured by
the fee or leasehold interest in 93 properties across 27
states.

The preliminary ratings are based on information as of
Jan. 18, 2013.  Subsequent information may result in the
assignment of final ratings that differ from the preliminary
ratings.

The preliminary ratings reflect the credit support provided
by the transaction structure, S&P's view of the underlying
collateral's economics, the trustee-provided liquidity, the
collateral pool's relative diversity, and S&P's overall
qualitative assessment of the transaction.  Standard &
Poor's determined that the collateral pool has, on a
weighted average basis, debt service coverage of 1.59x and
beginning and ending loan-to-value ratios of 84.0% and
70.0%, respectively, based on Standard & Poor's values.

          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/1249.pdf

PRELIMINARY RATINGS ASSIGNED

GS Mortgage Securities Trust 2013-GC10

Class       Rating                      Amount
                                           ($)
A-1         AAA (sf)                53,438,000
A-2         AAA (sf)                35,275,000
A-3         AAA (sf)                21,000,000
A-4         AAA (sf)               110,000,000
A-5         AAA (sf)               300,475,000
A-AB        AAA (sf)                81,379,000
X-A         AAA (sf)           656,352,000(ii)
A-S         AAA (sf)                54,785,000
X-B(i)      A- (sf)            103,126,000(ii)
B(i)        AA- (sf)                63,380,000
C(i)        A- (sf)                 39,746,000
D(i)        BBB- (sf)               34,376,000
E(i)        BB (sf)                 22,558,000
F(i)        B+ (sf)                 16,114,000
G(i)        NR                      26,855,941
R(i)        NR                             N/A

(i) Non-offered certificates.
(ii) Notional balance.
NR - Not rated.
N/A - Not applicable.


HALCYON 2005-2: Moody's Cuts Ratings on 2 Note Classes to 'Ca'
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
classes of Notes issued by Halcyon 2005-2, Ltd. The downgrades are
due to deterioration in underlying reference obligations as
evidenced by negative transitions in Moody's weighted average
rating factor (WARF) and weighted average recovery rate (WARR).
The rating action is the result of Moody's on-going surveillance
of commercial real estate collateralized debt obligation (CRE CDO
Synthetic) transactions.

Moody's rating action is as follows:

Cl. A, Downgraded to Caa3 (sf); previously on Feb 8, 2012
Downgraded to B3 (sf)

Cl. B, Downgraded to Ca (sf); previously on Feb 8, 2012 Downgraded
to Caa2 (sf)

Cl. C, Downgraded to Ca (sf); previously on Mar 23, 2011
Downgraded to Caa3 (sf)

RATINGS RATIONALE

Halcyon 2005-2, Ltd. is a static synthetic transaction backed by a
portfolio of commercial mortgage backed securities (CMBS)
reference obligations (100% of the pool balance). The CMBS
reference obligations were securitized in 2005 (80.0%) and 2006
(20.0%).

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 reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 624 compared to 260 at last
review. The current distribution is as follows: Aaa-Aa3 (13.3%
compared to 20.0% at last review), A1-A3 (30.0% compared to 43.3%
at last review), Baa1-Baa3 (30.0% compared to 33.3% at last
review), Ba1-Ba3 (20.0% compared to 0% at last review), and B1-B3
(6.7% compared to 3.3% at last review).

Moody's modeled to a WAL of 2.4 years, compared to 3.3 years at
last review.

Moody's modeled a variable WARR with a mean of 39.7%, compared to
43.7% at last review.

Moody's modeled a MAC of 31.7%, compared to 40.5% 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.

Moody's analysis encompasses the assessment of stress scenarios.

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 credit changes within the reference obligations.
Holding all other key parameters static, stressing the current
ratings and credit assessments of the reference obligations by one
notch downward or one notch upward affects the model results by
approximately 0 to 1 notch negatively and 0 to 1 notch positively,
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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock; albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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


HARCH CLO II: S&P Retains 'CCC-' Rating on Class E Notes
---------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class B and C notes from Harch CLO II Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
Harch Capital Management LLC.  At the same time, S&P
affirmed its ratings on the class A-1A, A-1B, A-2, D, and E
notes.  In addition, S&P removed the ratings on the class B
and C notes from CreditWatch, where it placed them with
positive implications on Oct. 29, 2012.

The upgrades mainly reflect paydowns to the class A-1A and
A-1B notes.  Since the Feb. 10, 2012, trustee report, which
S&P used for its March 2012 rating actions, the A-1A notes
have paid down $25.5 million, while the A-1B notes have paid
down $2.9 million, reducing their outstanding note balances
to 21.92% of the original balances at issuance.

The upgrades also reflect an improvement, primarily due to
the paydowns, in the overcollateralization (O/C) available
to support the notes at the top of the capital structure.
As per the Dec. 10, 2012, monthly trustee report, the class
B O/C ratio (the senior O/C) was 145.87% compared with a
reported 136.63% in February 2012.  However, the class E O/C
ratio (the subordinate O/C) was 100.94%, slightly lower when
compared with a reported 101.36% in February 2012.

S&P affirmed its ratings on the class A-1A, A-1B, A-2, D,
and E notes to reflect the credit support available at the
current rating levels.

S&P will continue to review whether, in its view, the
ratings on the notes remain consistent with the credit
enhancement available to support them, and S&P will take
further rating actions as it deem necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com

RATINGS LIST

Harch CLO II Ltd.

                 Rating
Class         To           From

A-1A          AAA (sf)     AAA (sf)
A-1B          AAA (sf)     AAA (sf)
A-2           AAA (sf)     AAA (sf)
B             AAA (sf)     AA (sf)/Watch Pos
C             AA (sf)      A- (sf)/Watch Pos
D             B- (sf)      B- (sf)
E             CCC- (sf)    CCC- (sf)

TRANSACTION INFORMATION
Issuer:             Harch CLO II Ltd.
Coissuer:           Harch CLO II Inc.
Collateral manager: Harch Capital Management LLC
Underwriter:        Goldman Sachs & Co.
Trustee:            Bank of New York Mellon
Transaction type:   Cash flow CDO


ICE GLOBAL: S&P Affirms 'BB' Rating to Class E Notes
-----------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
ICE Global Credit CLO Ltd./ICE Global Credit CLO Inc.'s
$500 million floating-rate notes following the transaction's
effective date as of Oct. 4, 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").

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

S&P believes 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.

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

"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.  (For more information on our criteria and our
analytical tools, see "Update To Global Methodologies And
Assumptions For Corporate Cash Flow And Synthetic CDOs,"
published Sept. 17, 2009.)," 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 added.

On an ongoing basis after S&P issues an effective date
rating affirmation, it will periodically review whether, in
its 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 it deem necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATINGS AFFIRMED

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

Class                        Rating          Amount
                                           (mil. $)
A                            AAA (sf)        355.00
B                            AA (sf)          43.00
C (deferrable)               A (sf)           39.00
D (deferrable)               BBB (sf)         39.00
E (deferrable)               BB (sf)          24.00


LENOX STREET: Moody's Affirms 'C' Ratings on Nine Note Classes
--------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of nine classes
of Notes issued by Lenox Street 2007-1, Ltd. The affirmations are
due to the key transaction parameters performing within levels
commensurate with the existing ratings levels. The rating action
is the result of Moody's on-going surveillance of commercial real
estate collateralized debt obligation (CRE CDO and Re-remic)
transactions.

Moody's rating action is as follows:

Cl. A, Affirmed C (sf); previously on Feb 23, 2011 Downgraded to C
(sf)

Cl. B, Affirmed C (sf); previously on Mar 5, 2010 Downgraded to C
(sf)

Cl. C, Affirmed C (sf); previously on Mar 5, 2010 Downgraded to C
(sf)

Cl. D, Affirmed C (sf); previously on Mar 5, 2010 Downgraded to C
(sf)

Cl. E, Affirmed C (sf); previously on Mar 5, 2010 Downgraded to C
(sf)

Cl. F, Affirmed C (sf); previously on Mar 5, 2010 Downgraded to C
(sf)

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

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

Cl. J, Affirmed C (sf); previously on Nov 13, 2009 Downgraded to C
(sf)

RATINGS RATIONALE

Lenox Street 2007-1, Ltd. is a currently static (the reinvestment
period ended in May 2012) hybrid transaction backed by a portfolio
of commercial mortgage backed securities (CMBS) (85.7% of the pool
balance) and CRE CDOs (14.3%). The portfolio comprises of both
synthetic reference obligations (78.9% of the pool balance) and
cash assets (21.1%). As of the December 4, 2012 Trustee report,
the aggregate Note balance of the transaction, has decreased to
$349.4 million from $350.0 million at issuance. An event of
default occurred in November 2009 as a result of the failure of
the certain par value tests. As a result, paydown is directed to
the most senior class of Notes until such failure is cured.
Currently all of the rated Notes have outstanding defaulted and
deferred interest.

There are 78 assets with a par balance of $645.6 million (86.5% of
the current pool balance) that are considered defaulted securities
as of the December 4, 2012 Trustee report. Sixty-nine of these
assets (88.6% of the defaulted balance) are CMBS and 9 assets are
CRE CDOs (11.4% of the defaulted balance). Moody's does expect
significant losses to occur on 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 and reference obligations. Moody's modeled a
bottom-dollar WARF of 9,678 compared to 9,539 at last review. The
current distribution of Moody's rated collateral and assessments
for non-Moody's rated collateral is as follows: B1-B3 (1.0%
compared to 0.8% at last review), and Caa1-C (99.0% compared to
99.2% at last review).

Moody's modeled a WAL of 4.5 years compared to 5.9 years at last
review.

Moody's modeled a fixed WARR of 0.1% compared to 0.0% at last
review.

Moody's modeled a MAC of 0.0% compared to 0.0% 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.

Moody's analysis encompasses the assessment of stress scenarios.

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 are
particularly sensitive to rating changes within the collateral and
reference obligation pool. However, in light of the performance
indicators noted above, Moody's believes that it is unlikely that
the ratings announced on Jan. 24 are sensitive to further change.

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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock; albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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.


JP MORGAN 2001-CIBC1: Fitch Cuts Rating on Class G Notes to 'CCC'
-----------------------------------------------------------------
Fitch Ratings has downgraded one and affirmed five classes of J.P.
Morgan Chase Commercial Mortgage Securities Corp. series 2001-
CIBC1 commercial mortgage pass-through certificates.

Rating Sensitivity/Key Rating Drivers

Fitch modeled losses of 7.1% of the remaining pool; expected
losses on the original pool balance total 6%, including losses
already incurred. The pool has experienced $58.3 million (5.8% of
the original pool balance) in realized losses to date. Fitch has
designated 3 loans (35.6%) as Fitch Loans of Concern, which
includes one specially serviced asset (15.9%).

As of the January 2013 distribution date, the pool's aggregate
principal balance has been reduced by 97% to $30.1 million from $1
billion at issuance. Per the servicer reporting, one loan (2% of
the pool) is defeased. Interest shortfalls are currently affecting
classes H through NR.

The downgrade to the class G notes reflects the increased event
risk of a significant loss on a loan as the pool has become more
concentrated with only nine loans remaining.

The largest contributor to expected losses is a 63,059 square foot
(sf) retail strip center (15.9% of the pool) located in Tupelo,
MS. The loan transferred to the special servicer in January 2010
due to imminent maturity default. The borrower filed for
bankruptcy protection in February 2011. The loan is expected to be
corrected and transfer back to the trust.

Fitch downgrades the following class:
-- $27.6 million class G notes to 'CCCsf' from 'Bsf'; RE 100%.

Fitch affirms the following classes:
-- $2.6 million class H notes at 'Dsf'; RE 0%;
-- $0 class J notes at 'Dsf'; RE 0%;
-- $0 class K notes at 'Dsf'; RE 0%;
-- $0 class L notes at 'Dsf'; RE 0%;
-- $0 class M notes at 'Dsf'; RE 0%.

The class A-1, A-2, A-3, B, C, D, E, F, and X2 notes have paid in
full. Fitch previously withdrew the rating on the interest-only
class X1 certificates.


JP MORGAN 2003-CIBC6: Fitch Cuts Rating on Class N Notes to 'Csf'
-----------------------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed 10 classes
of JP Morgan Chase Commercial Mortgage Securities commercial
mortgage pass-through certificates series 2003-CIBC6.

Key Rating Drivers

The downgrades reflect an increase in Fitch expected losses across
the pool. Fitch modeled losses of 2.8% of the remaining pool;
expected losses on the original pool balance total 2.7%, including
losses already incurred. The pool has experienced $7.4 million
(0.7% of the original pool balance) in realized losses to date.
Fitch has designated 19 loans (12.2%) as Fitch Loans of Concern,
which includes three specially serviced assets (1.6%).

As of the December 2012 distribution date, the pool's aggregate
principal balance has been reduced by 25.4% to $793.2 million from
$1.06 billion at issuance. Per the servicer reporting, 28 loans
(42.4% of the pool) are defeased. Interest shortfalls are
currently affecting classes N through NR.

The largest contributor to expected losses is secured by a 43,169
square foot (SF) office property in Sacramento, CA (0.7% of the
pool). The collateral had transferred to special servicing in
April 2012 due to payment default. The property experienced cash
flow issues when the buildings largest tenant, Sacramento County
(48% of the net rentable area [NRA]), had vacated upon its lease
expiration in February 2012. The property became REO in November
2012. The servicer is currently working to stabilize the property
and has hired a third-party management company to assist with
property management and leasing.

The next largest contributor to expected losses is secured by a
portfolio of three Colorado mobile home parks containing a total
of 246 pads (0.5%). The subject loan transferred to special
servicing in January 2011 due to payment default. The entire
portfolio is currently 51% occupied. One of the parks located in
Fort Morgan, CO (80 units; 27% of allocated balance) has been
forced to shut down because of water safety issues with remaining
occupancy currently at 11%. A receiver is in place, and the
servicer is pursuing foreclosure.

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

-- $5.2 million class L to 'CCCsf' from 'B-sf'; RE 100%;
-- $3.9 million class M to 'CCsf' from 'CCCsf'; RE 50%;
-- $1.3 million class N to 'Csf' from 'CCsf'; RE 0%.

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

-- $15.6 million class H at 'BBBsf'; Outlook to Negative
    from Stable;
-- $5.2 million class J at 'BBsf'; Outlook to Negative
    from Stable;
-- $7.8 million class K at 'Bsf'; Outlook to Negative from
    Stable.

Fitch affirms the following classes as indicated:

-- $610.6 million class A-2 at 'AAAsf'; Outlook Stable;
-- $31.2 million class B at 'AAAsf'; Outlook Stable;
-- $32.5 million class C at 'AAAsf'; Outlook Stable;
-- $11.7 million class D at 'AAAsf'; Outlook Stable;
-- $14.3 million class E at 'AAAsf'; Outlook Stable;
-- $10.4 million class F at 'AAsf'; Outlook Stable;
-- $13 million class G at 'Asf'; Outlook Stable.

The class A-1 certificate and the interest only class X-2
certificate have paid in full. Fitch does not rate the class NR,
BM-1, BM-2, BM-3, AC-1, AC-2 and AC-3 certificates. Fitch
previously withdrew the rating on the interest-only class X-1
certificates.


JP MORGAN 2006-CIBC17: Fitch Cuts Rating on Class B Certs. to Csf
-----------------------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed 16 classes
of J.P. Morgan Chase Commercial Mortgage Securities Corp., series
2006-CIBC17 commercial mortgage pass-through certificates due to
increased expected losses on the specially serviced assets. A
detailed list of rating actions follows at the end of this press
release.

RATING SENSITIVITY/KEY RATING DRIVERS

Fitch modeled losses of 17.7% of the remaining pool; expected
losses on the original pool balance total 17.4%, including losses
already incurred. The pool has experienced $16.3 million (0.6% of
the original pool balance) in realized losses to date. Fitch has
designated 40 loans (29.8%) as Fitch Loans of Concern, which
includes 20 specially serviced assets (22.6%).

As of the December 2012 distribution date, the pool's aggregate
principal balance has been reduced by 5.4% to $2.4 billion from
$2.54 billion at issuance. No loans have defeased since issuance.
Interest shortfalls are currently affecting classes A-J through
NR.

The largest contributor to expected losses is the specially-
serviced Bank of America Plaza (11% of the pool), a 1.3 million
square foot (sf), class A office property located in downtown
Atlanta, GA. The loan was transferred to special servicing in
February 2011 for imminent default due to the expected revenue
decline associated with Bank of America downsizing its space.
Since then, the third largest tenant, Paul Hastings (11%) vacated
at lease expiration in October 2012. The property is currently
real estate owned (REO) and is 52% occupied. The special servicer
continues to market the vacant space.

The next largest contributor to expected losses is the specially-
serviced City View Portfolio loan (2.4%), which is secured by
seven multifamily properties consisting of 2,226 units located in
the Greenspoint section of Houston, TX. The loan was transferred
to special servicing in February 2010 due to imminent default. The
property was foreclosed upon in July 2010. As of January 2012, the
portfolio was 89.7% occupied.

The third largest contributor to expected losses is the specially
serviced The Towers loan (1.9%), which is secured by a 184,577 sf
office tower located in Great Neck, NY. Major tenants include
Garfunkel Wild & Travis (20%) NRA),lease expiration Sept. 30,
2020; Sterling Equities Inc. (14% NRA), expiration April 30, 2017;
and Flextrade Systems Inc. (7% NRA), expiration Oct. 31, 2016. The
loan was transferred to special servicing in November 2009 due to
monetary default as a result of the borrower's failure to pay
operating expenses and establish a lockbox. A receiver was
appointed in 2010 and a property management firm was hired. As of
October 2012, the property is 73.1% occupied.

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

--$253.7 million class A-M to 'BBsf' from 'Asf'; Outlook Negative;
--$203 million class A-J to 'CCsf' from 'CCCsf'; RE 35%;
--$44.4 million class B to 'Csf' from 'CCsf'; RE 0%.

Fitch affirms the following classes as indicated:

--$84.1 million class A-3 at 'AAAsf'; Outlook Stable;
--$1.2 billion class A-4 at 'AAAsf'; Outlook Stable;
--$67.9 million class A-SB at 'AAAsf'; Outlook Stable;
--$279.8 million class A-1A at 'AAAsf'; Outlook Stable;
--$19 million class C at 'Csf'; RE 0%;
--$34.9 million class D at 'Csf'; RE 0%;
--$31.7 million class E at 'Csf'; RE 0%;
--$34.9 million class F at 'Csf'; RE 0%;
--$31.7 million class G at 'Csf'; RE 0%;
--$31.7 million class H at 'Csf'; RE 0%;
--$9.5 million class J at 'Csf'; RE 0%;
--$9.5 million class K at 'Csf'; RE 0%;
--$9.5 million class L at 'Csf'; RE 0%;
--$3.2 million class M at 'Csf'; RE 0%;
--$6.3 million class N at 'Csf'; RE 0%;
--$6.3 million class P at 'Csf'; RE 0%.

The class A-1 certificates have paid in full. Fitch does not rate
the class NR certificates. Fitch previously withdrew the rating on
the interest-only class X certificates.


JP MORGAN 2006-WMC1: Moody's Hikes Rating on A-4 Certs. to 'Caa3'
-----------------------------------------------------------------
Moody's Investors Service is correcting the rating for J.P. Morgan
Mortgage Acquisition Corp 2006-WMC1's Cl. A-1 (CUSIP: 46626LJK7)
to Ba2 (sf) from Ba3 (sf) and for Cl. A-4 (CUSIP: 46626LHT0) to
Caa3 (sf) from Ba2 (sf). Due to an internal administrative error,
as part of the rating action announced on January 9, 2013, Cl. A-1
was inadvertently upgraded to Ba3 (sf) and Cl. A-4 was upgraded to
Ba2 (sf). Cl. A-1 should have been upgraded to Ba2 (sf) and no
action was taken on Cl. A-4, so the Caa3 (sf) rating should have
been maintained.

The correct current ratings for these two senior certificates of
J.P. Morgan Mortgage Acquisition Corp 2006-WMC1 are as follows:

Cl. A-1, Ba2 (sf), Upgraded to Ba2 (sf) on January 9, 2013

Cl. A-4, Caa3 (sf), Upgraded to Caa3 (sf) on December 28, 2010.

The list of affected securities from the January 9, 2013 rating
action has been updated and may be found at:

  http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF312865

For the January 9, 2013 press release titled "Moody's takes rating
action on $1.3 billion Subprime RMBS issued by various financial
institutions," in the ratings actions list, under issuer J.P.
Morgan Mortgage Acquisition Corp. 2006-WMC1, the rating for the
Class A-1 tranche was corrected to read: "Cl. A-1, Upgraded to Ba2
(sf); previously on Dec 28, 2010 Upgraded to B3 (sf)" and the
listing for Cl. Cl. A-4 was removed.


KATONAH VII: S&P Lowers Rating on Class D Notes to 'B+'
--------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1, A-2, B, C, and D notes from Katonah VII CLO Ltd.
and removed them from CreditWatch with positive
implications.  At the same time, S&P raised its ratings on
the class A, B, C, and D notes from Katonah VIII CLO Ltd.
and removed its ratings on the class B, C, and D notes from
CreditWatch with positive implications.  S&P placed its
ratings on these classes from both transactions on
CreditWatch in October 2012.  The two deals are U.S.
collateralized loan obligation (CLO) transactions managed
by Katonah Debt Advisors.

The upgrades mainly reflect paydowns to the class A notes in
each transaction.  Since its reinvestment period ended in
November 2011, the class A-1 and A-2 notes from Katanoh VII
CLO Ltd. have combined to pay down over $68.5 million.  The
reinvestment period for Katonah VIII CLO Ltd. ended in
May 2012 and since that time the class A notes have paid
down $16.5 million.  Additionally, both transactions
currently hold more than $40 million in principal cash that
will be used to continue to pay down the class A notes over
the next two payment periods.

Furthermore, the upgrades also reflect the improved
performance of the transactions' underlying asset portfolios
since S&P's rating actions in 2011.  S&P notes that the
underlying asset portfolio since its February 2011 rating
actions.  S&P notes that the amount of defaults and 'CCC'
rated obligations held in the each portfolio have decreased
since their 2011 rating actions.  As a result of the
improved credit quality and the paydowns to the class A
notes, the class A/B, C, and D par value ratios in both
transactions have increased.

The ratings actions on the class D notes from both Katonah
VII CLO Ltd. and Katonah VIII CLO Ltd. were driven by the
application of S&P's largest obligor test for corporate
CDOs.

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

Katonah VII CLO Ltd.

                   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)    BB+ (sf)/Watch Pos
D             B+ (sf)      CCC+ (sf)/Watch Pos

Katonah VIII CLO Ltd.

                   Rating
Class         To           From

A             AAA (sf)     AA+ (sf)
B             AA+ (sf)     AA- (sf)/Watch Pos
C             A+ (sf)      BBB+ (sf)/Watch Pos
D             B+ (sf)      CCC+ (sf)/Watch Pos


KATONAH IX: S&P Raises 'B+' Rating on Class B-2L Notes
-------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-2L, A-3L, B-1L, and B-2L notes from Katonah IX CLO
Ltd., a collateralized loan obligation (CLO) transaction
managed by Katonah Debt Advisors.  At the same time, S&P
removed the ratings on these classes from CreditWatch, where
it place them with positive implications on Oct. 29, 2012.
In addition, S&P affirmed its ratings on the class X, A-1L,
and A-1LV notes.

The transaction's reinvestment period is scheduled to end on
Jan. 24, 2013.  Its legal maturity is in January 2019.

The upgrades of the class A-2L, A-3L, B-1L, and B-2L notes
reflect the improved credit quality of the transaction's
underlying asset portfolio since S&P's November 2011 rating
actions.

"For our analysis, we observed $12.3 million of defaulted
assets in the portfolio as per the December 2012 trustee
report, down from $15.1 million noted in the October 2011
trustee report, which we referenced for our November 2011
rating actions.  Furthermore, assets from obligors rated in
the 'CCC' category were reported at $14.4 million in
December 2012, compared with $19.7 million in October 2011.
Another positive factor in our analysis is the increase in
the weighted-average spread to 3.66% from 3.54% during the
same time period," S&P said.

The rating on the class B-2L notes is driven by the
application of the largest obligor default test, a
supplemental stress test S&P introduced as part of its
2009 corporate criteria update.

S&P affirmed its ratings on the class X, A-1L, and A-1LV
notes to reflect the availability of adequate credit support
at the current rating levels.

S&P 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 deem necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

The Standard & Poor's 17g-7 Disclosure Report included in
this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Katonah IX CLO Ltd.

Class              Rating
             To               From

X            AAA (sf)         AAA
A-1L         AA+ (sf)         AA+ (sf)
A-1LV        AA+ (sf)         AA+ (sf)
A-2L         AA (sf)          A+ (sf) /Watch Pos
A-3L         A- (sf)          BBB+ (sf) /Watch Pos
B-1L         BBB- (sf)        BB+ (sf) /Watch Pos
B-2L         B+ (sf)          CCC+ (sf) /Watch Pos


LEHMAN STRUCTURED: Moody's Withdraws B2 Ratings on Six Tranches
---------------------------------------------------------------
Moody's Investors Service has withdrawn the ratings of six
tranches issued by Lehman Structured Securities Corp. Series 2002-
3. Each tranche is backed by a pool of mortgage loans with a pool
factor less than 5% and containing fewer than 40 loans.

Complete rating actions are as follows:

Issuer: Lehman Structured Securities Corp. Series 2002-3

Cl. A1, Withdrawn (sf); previously on Feb 22, 2012 Downgraded to
B2 (sf)

Cl. A2, Withdrawn (sf); previously on Feb 22, 2012 Downgraded to
B2 (sf)

Cl. A3, Withdrawn (sf); previously on Feb 22, 2012 Downgraded to
B2 (sf)

Cl. A4, Withdrawn (sf); previously on Feb 22, 2012 Downgraded to
B2 (sf)

Cl. A5, Withdrawn (sf); previously on Feb 22, 2012 Downgraded to
B2 (sf)

Cl. A6, Withdrawn (sf); previously on Feb 22, 2012 Downgraded to
B2 (sf)

RATINGS RATIONALE

Moody's current RMBS surveillance methodologies apply to pools
with at least 40 loans and a pool factor of greater than 5%. As a
result, Moody's may withdraw its rating when the pool factor drops
below 5% and the number of loans in the pool declines to 40 loans
or lower unless specific structural features allow for a
monitoring of the transaction (such as a credit enhancement floor
or pool insurance).

Moody's has withdrawn the rating pursuant to published rating
methodologies that allow for the withdrawal of the rating if the
size of the underlying collateral pool at the time of the
withdrawal has fallen below a specified level.

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

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF314701


MADISON PARK II: Moody's Upgrades Rating on Class D Notes to 'Ba2'
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Madison Park Funding II, Ltd.:

U.S. $11,250,000 Class A-2b Floating Rate Notes Due 2020, Upgraded
to Aaa (sf); previously on August 9, 2011 Upgraded to Aa1(sf);

U.S. $38,000,000 Class A-3 Floating Rate Notes Due 2020, Upgraded
to Aa2 (sf); previously on August 9, 2011 Upgraded to Aa3 (sf);

U.S. $25,000,000 Class B-1 Deferrable Floating Rate Notes Due
2020, Upgraded to Baa1 (sf); previously on August 9, 2011 Upgraded
to Baa2 (sf);

U.S. $25,000,000 Class B-2 Deferrable Fixed Rate Notes Due 2020,
Upgraded to Baa1 (sf); previously on August 9, 2011 Upgraded to
Baa2 (sf);

U.S. $25,000,000 Class C-1 Deferrable Floating Rate Notes Due
2020, Upgraded to Baa3 (sf); previously on August 9, 2011 Upgraded
to Ba1 (sf);

U.S. $5,000,000 Class C-2 Deferrable Fixed Rate Notes Due 2020,
Upgraded to Baa3 (sf); previously on August 9, 2011 Upgraded to
Ba1 (sf);

U.S. $22,500,000 Class D Deferrable Floating Rate Notes Due 2020,
Upgraded to Ba2 (sf); previously on August 9, 2011 Upgraded to Ba3
(sf).

Moody's also affirmed the ratings of the following notes:

U.S. $509,750,000 Class A-1 Floating Rate Notes Due 2020 (current
outstanding balance of $502,457,224), Affirmed at Aaa (sf);
previously on August 9, 2011 Upgraded to Aaa (sf);

U.S. $100,000,000 Class A-2a Floating Rate Notes Due 2020 (current
outstanding balance of $98,408,394), Affirmed at Aaa (sf);
previously on Mar 31, 2006 Assigned Aaa (sf).

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes
reflect the benefit of the short period of time remaining before
the end of the deal's reinvestment period in March 2013. In
consideration of the reinvestment restrictions applicable during
the amortization period, and therefore limited ability to effect
significant changes to the current collateral pool, Moody's
analyzed the deal assuming a higher likelihood that the collateral
pool characteristics will continue to maintain a positive buffer
relative to certain covenant requirements. In particular, the deal
is assumed to benefit from higher spread level compared to the
levels assumed at the last rating action in August 2011. Moody's
modeled a WAS of 4.23% compared to 3.11% at the time of the last
rating action. Moody's also notes that the transaction's reported
collateral quality and overcollateralization ratios are stable
since the last rating action.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $824 million,
defaulted par of $8.6 million, a weighted average default
probability of 20.70% (implying a WARF of 2919), a weighted
average recovery rate upon default of 49.28%, and a diversity
score of 82. 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.

Madison Park Funding II, Ltd., issued in February 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

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

Moody's Adjusted WARF + 20% (3503)

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

Moody's Adjusted WARF -- 20% (2335)

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

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

Sources of additional performance uncertainties are described
below:

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

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

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


MADISON PARK VIII: S&P Affirms 'BB' Rating on Class E Notes
------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Madison Park Funding VIII Ltd./Madison Park Funding VIII
LLC's $367.75 million floating-rate notes following the
transaction's effective date as of July 31, 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").

"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 added.

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

"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.  (For more information on our criteria and our
analytical tools, see "Update To Global Methodologies And
Assumptions For Corporate Cash Flow And Synthetic CDOs,"
published Sept. 17, 2009.)," S&P noted

"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 S&P issues an effective date
rating affirmation, it will periodically review whether, in
its 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 it deem necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com

RATINGS AFFIRMED

Madison Park Funding VIII Ltd./Madison Park Funding VIII LLC

Class                        Rating          Amount
                                           (mil. $)

A                            AAA (sf)        252.50
B                            AA (sf)          48.50
C (deferrable)               A (sf)           27.50
D (deferrable)               BBB (sf)         20.25
E (deferrable)               BB (sf)          19.00


MAGNOLIA FINANCE: Moody's Affirms 'C' Rating on Cl. D CMBS Notes
----------------------------------------------------------------
Moody's Investors Service has affirmed the rating of one class of
Notes issued by Magnolia Finance II Series 2007-2. The affirmation
is due to the key transaction parameters performing within levels
commensurate with the existing rating level. The rating action is
the result of Moody's on-going surveillance of commercial real
estate collateralized debt obligation (CRE CDO Synthetic)
transactions.

Cl. D CMBS Portfolio Variable Rate Notes due November 2052,
Affirmed C (sf); previously on Mar 17, 2010 Downgraded to C (sf)

Magnolia Finance II Series 2007-2 is a static synthetic
transaction backed by a portfolio of reference obligations on
commercial mortgage backed securities (CMBS) (100% of the pool
balance). All of the underlying CMBS were securitized in 2005 and
2006.

RATINGS RATIONALE

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 reference obligations. Moody's modeled a bottom-dollar WARF
of 8,808, compared to 8,803 at last review. The current
distribution of Moody's rated collateral and assessments for non-
Moody's rated reference obligations is as follows: Baa1-Baa3 (1.9%
compared to 1.7% at last review), B1-B3 (5.8% compared to 5.0% at
last review), and Caa1-C (92.2% compared to 93.4% at last review).


Moody's modeled a WAL of 4.9 years, compared to 5.3 years at last
review. The current WAL is based on the assumption about
extensions on the underlying reference obligations and associated
loans.

Moody's modeled a fixed WARR of 0.7% compared to 0.6% at last
review.

Moody's modeled a MAC of 100.0%, the same as at last review.

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 rating changes within the reference obligation pool.
However, in light of the performance indicators noted above,
Moody's believes that it is unlikely that the ratings announced on
Jan. 24 are sensitive to further change.

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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock, albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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

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

Moody's analysis encompasses the assessment of stress scenarios.


ML-CFC 2007-9: Fitch Lowers Rating on 3 Cert. Classes to 'Csf'
--------------------------------------------------------------
Fitch Ratings has downgraded seven and affirmed 14 classes of ML-
CFC Commercial Mortgage Trust, series 2007-9 (ML-CFC 2007-9),
commercial mortgage pass-through certificates.

Key Rating Drivers

The downgrades reflect an increase in Fitch modeled losses across
the pool, due to further deterioration of loan performance, most
of which involves significantly higher losses on the specially
serviced loans, as well as several loans in the top 15 with
continued underperformance. Fitch modeled losses of 15.1% of the
remaining pool; expected losses on the original pool balance total
15.5%, including losses already incurred. The Negative Outlook on
classes AM and AM-A reflects the uncertainty surrounding the
workout on many of the specially serviced loans and the
possibility for further underperformance on loans in the top 15.

As of the December 2012 distribution date, the pool's aggregate
principal balance has been reduced by 20% to $2.25 billion from
$2.81 billion at issuance. Approximately $467.48 million (16.6%)
were principal paydowns and approximately $94.45 million (3.4%)
were realized losses. No loans have defeased since issuance.
Interest shortfalls totaling $23.6 million are currently affecting
classes AJ through T.

Fitch has designated 98 loans (51.7%) as Fitch Loans of Concern,
which includes 19 specially serviced assets (13.8%). Seven of the
top 15 loans (26.2%) are or have been in special servicing,
including three loans in the top 15 (16.1%) which have been
modified and returned to the master servicer. These loans are
currently performing under the terms of the modification.

The largest contributors to modeled losses are three (7.7%) of the
top 15 loans in the pool, all of which are specially serviced.

The largest contributor to modeled losses is the DLJ West Coast
Hotel Portfolio loan (3.8%). The loan was transferred to special
servicing in May 2009 due to imminent default. The loan was
initially secured by six cross-collateralized and cross-defaulted
hotel properties totaling 1,159 rooms located in California and
Oregon. The hotels operated under the Residence Inn, Hawthorne
Suites, Courtyard Marriot, and Hilton Garden Inn flags.

All six properties were foreclosed upon between August 2011 and
September 2011. According to the special servicer, five of the six
properties have already been sold to date. The remaining hotel has
not been marketed to allow for an improvement in property
performance and thus an increase in the property's value. Recent
valuations on the remaining hotel property indicate significant
losses to the loan upon liquidation as the outstanding loan
balance already reflects the five properties that were sold being
written down.

The next largest contributor to modeled losses is the St. Louis
Flex Office Portfolio loan (2.3%). The loan was transferred to
special servicing in November 2010 for imminent default due to
cash flow issues. The asset consists of a portfolio of six
industrial/flex properties totaling 864,540 square feet located in
the St. Louis, Missouri MSA. All six properties became real-estate
owned in May 2012. The special servicer is pursuing a lease-up
strategy through the spring of 2013 and will then evaluate the
market and property performance at that time. .

The third largest contributor to modeled losses is the Morgan 7 RV
Park Portfolio loan (1.6%). The loan was transferred to special
servicing in October 2011 for delinquent payments. The loan is
secured by a portfolio of seven RV parks (totaling 1,586 RV sites)
of various vintage ranging from 1960-1990 located on a total of
306 acres in Maine, Michigan, New Jersey and New York. The special
servicer continues pursuing foreclosure and to place the
properties under receivership.

Fitch downgrades and revises Rating Outlooks as indicated:

-- $210 million class AM to 'BBBsf' from 'Asf', Outlook to
    Negative from Stable;
-- $71 million class AM-A to 'BBBsf' from 'Asf', Outlook to
    Negative from Stable;
-- $31.6 million class B to 'CCsf' from 'CCCsf', RE 0%;
-- $21.1 million class C to 'CCsf' from 'CCCsf', RE 0%;
-- $28.1 million class D to 'Csf' from 'CCsf', RE 0%;
-- $24.6 million class E to 'Csf' from 'CCsf', RE 0%;
-- $24.6 million class F to 'Csf' from 'CCsf', RE 0%.

Fitch affirms the following classes as indicated:

-- $255.2 million class A-1A at 'AAAsf', Outlook Stable;
-- $91.1 million class A-2 at 'AAAsf', Outlook Stable;
-- $134.8 million class A-3 at 'AAAsf', Outlook Stable;
-- $87.3 million class A-SB at 'AAAsf', Outlook Stable;
-- $931 million class A-4 at 'AAAsf', Outlook Stable;
-- $168 million class AJ at 'CCCsf', RE 65%;
-- $56.8 million class AJ-A at 'CCCsf', RE 65%;
-- $28.1 million class G at 'Csf', RE 0%;
-- $28.1 million class H at 'Csf', RE 0%;
-- $24.6 million class J at 'Csf', RE 0%;
-- $31.6 million class K at 'Csf', RE 0%;
-- $382,438 class L at 'Dsf', RE 0%;
-- $0 class M at 'Dsf', RE 0%;
-- $0 class N at 'Dsf', RE 0%.

The class A-1 certificates have paid in full. Fitch does not rate
the class P, Q, S and T certificates. Fitch previously withdrew
the ratings on the interest-only class XP and XC certificates.


MORGAN STANLEY 2006-HQ9: Fitch Lowers Ratings on 3 Cert. Classes
----------------------------------------------------------------
Fitch Ratings has downgraded three classes and affirmed 23 classes
of Morgan Stanley Capital I Trust (MSC 2006-HQ9) commercial
mortgage pass-through certificates series 2006-HQ9 due to a slight
increase in expected losses on loans in special servicing, higher
than expected realized losses from liquidation, and further
deterioration in performance of the pool.

Key Rating Drivers

Fitch modeled losses of 5.2% of the remaining pool; expected
losses on the original pool balance total 7.1%, including losses
already incurred. The pool has experienced $66.1 million (2.5% of
the original pool balance) in realized losses to date. Fitch has
designated 50 loans (20.7%) as Fitch Loans of Concern, which
includes nine specially serviced assets (4.2%).

As of the December 2012 distribution date, the pool's aggregate
principal balance has been reduced by 12.1% to $2.29 billion from
$2.6 billion at issuance. No loans have defeased since issuance.
Interest shortfalls are currently affecting classes J through S.

The largest contributor to expected losses is a specially-serviced
loan (1.3% of the pool), which is secured by four specialty trade-
mart properties located in High Point, NC. The aggregate square
footage for the portfolio is 460,681 square feet (sf). All of the
tenants are in the furniture and home improvement sectors. The
loan transferred to special servicing in May 2009 due to monetary
default. The servicer is in the process of preparing the note for
sale.

The next largest contributor to expected losses is is a 452,407 sf
office tower in the financial district of Kansas City, MO (0.9%).
The loan transferred to special servicing in October 2011 and
became REO in November 2012. Occupancy as of December 2012 was
41%, a decline from 82% at issuance.

The third largest contributor to expected losses is a loan secured
by a 110-key hotel property (0.3%) in Tucker, GA, approximately 18
miles southwest of Atlanta. As of December 2012, the loan remained
current and with the master servicer. Cash flow generated by the
property was insufficient to service the debt through June 2012
with a reported NOI DSCR of 0.72x, compared with 0.46x at YE 2011
and 1.66x at issuance. As of the 2nd quarter of 2012, occupancy,
ADR and RevPAR were 54.4%, $69.00 and $38.00, respectively.

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

--$28.9 million class D to 'BBsf' from 'BBB-sf', Outlook to
   Stable from Negative;
--$28.9 million class H to 'CCsf' from 'CCCsf', RE 35%;
--$32.1 million class J to 'Csf' from 'CCsf', RE 0%.

Fitch affirms the following classes as indicated:

--$144.9 million class A-1A at 'AAAsf', Outlook Stable;
--$196.7 million class A-3 at 'AAAsf', Outlook Stable;
--$70.3 million class A-AB at 'AAAsf', Outlook Stable;
--$784.2 million class A-4 at 'AAAsf', Outlook Stable;
--$350 million class A-4FL at 'AAAsf', Outlook Stable;
--$256.5 million class A-M at 'AAAsf', Outlook Stable;
--$202 million class A-J at 'Asf', Outlook Stable;
--$19.2 million class B at 'Asf', Outlook Stable;
--$35.3 million class C at 'BBBsf', Outlook Stable;
--$22.4 million class E at 'BBsf', Outlook Negative;
--$25.7 million class F at 'Bsf', Outlook Negative;
--$25.7 million class G at 'CCCsf', RE 100%;
--$25.7 million class K at 'Csf', RE 0%;
--$2.2 million class L at 'Dsf', RE 0%;
--$0 class M at 'Dsf', RE 0%;
--$0 class N at 'Dsf', RE 0%;
--$0 class O at 'Dsf', RE 0%;
--$0 class P at 'Dsf', RE 0%;
--$0 class Q at 'Dsf', RE 0%;
--$2.7 million class ST-B at 'B-sf', Outlook Stable;
--$1.1 million class ST-C at 'CCCsf', RE 100%;
--$2.3 million class ST-D at 'CCCsf', RE 100%;
--$1.3 million class ST-E at 'CCCsf', RE 100%.

The ST classes are related to a non-pooled B-Note secured by 633
17th Street. The underlying collateral is an office building in
the central business district of Denver, CO. Fitch affirms these
classes as the performance of the property has remained stable
with YE 2011 NOI improving 4% from YE 2010, but still 17% below
levels at issuance.

Fitch does not rate the class S, ST-F and DP certificates. Classes
A-1, A-2, X-RC and ST-A have paid in full. Fitch previously
withdrew the ratings on the interest-only class X and X-MP
certificates.


MRU STUDENT: Moody's Lowers Rating on Class B Tranche to 'C'
------------------------------------------------------------
Moody's Investors Service has downgraded three tranches of notes
issued by MRU Student Loan Trust 2007-A, The underlying collateral
consists of private student loans originated through the direct-
to-consumer channel.

Complete rating actions as follow:

Issuer: MRU Student Loan Trust 2007-A

Cl. A-1, Downgraded to Caa3 (sf); previously on Feb 17, 2010
Downgraded to Caa1 (sf)

Cl. A-2, Downgraded to Caa3 (sf); previously on Feb 17, 2010
Downgraded to Caa1 (sf)

Cl. B, Downgraded to C (sf); previously on Feb 17, 2010 Downgraded
to Ca (sf)

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

RATINGS RATIONALE

The downgrades were a result of the recent restatement of
servicing reports for the period of April 2009 through July 2012,
which indicated higher defaults. The restatements revised the
cumulative default amount from roughly 10% of the original pool
balance to 24% as of the Sept 2012 reporting date. As a result of
this revision, Moody's increased its lifetime expected net losses
from approximately 19% to approximately 38% of the original loan
pool balance. Available credit enhancement is not sufficient to
protect investors against the collateral losses.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely performance over the medium
term. From time to time, Moody's may, if warranted, change these
expectations. Performance that significantly deviates from these
estimates may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated when the related
securities ratings were previously downgraded. Even so, a
deviation from the expected levels 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.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. Private Student Loan-Backed Securities",
published in January 2010.

Primary sources of uncertainty with regard to expected losses are
the weak economic environment and in particular the high
unemployment rate, which adversely impacts the income-generating
ability of the borrowers.


N-STAR REAL II: Fitch Affirms Csf Rating on $16.9MM Class D Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed nine classes issued by N-Star Real
Estate CDO II Ltd. as a result of paydowns to the senior notes
offsetting the deterioration of the underlying collateral. A
complete list of rating actions follows at the end of this
release.

Key Rating Drivers:

Since the last rating action in February 2012, approximately 24.1%
of the collateral has been downgraded and 3.8% has been upgraded.
Currently, 56% of the portfolio has a Fitch derived rating below
investment grade and 32.4% has a rating in the 'CCC' category and
below, compared to 52.6% and 28.1%, respectively, at the last
rating action. Over this period, the class A-1 notes have received
$34.3 million for a total of $229.4 million in pay downs since
issuance.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model (PCM) for projecting future default
levels for the underlying portfolio. The default levels were then
compared to the breakeven levels generated by Fitch's cash flow
model of the CDO under the various default timing and interest
rate stress scenarios, as described in the report 'Global Criteria
for Cash Flow Analysis in CDOs'. Fitch also analyzed the
structure's sensitivity to the assets that are distressed,
experiencing interest shortfalls, and those with near-term
maturities. Based on this analysis, the class A-1 through C-1
notes' breakeven rates are generally consistent with the ratings
assigned below.

For the class C-2 and D notes, Fitch analyzed each class'
sensitivity to the default of the distressed assets ('CCC' and
below). Given the high probability of default of the underlying
assets and the expected limited recovery prospects upon default,
the class C-2 notes have been affirmed at 'CCsf', indicating that
default is probable. Similarly, the class D notes have been
affirmed at 'Csf', indicating that default is inevitable.

The Stable Outlook on the class A-1 and A-2 reflects Fitch's view
that the transaction will continue to delever. The Negative
Outlook on the class B notes reflects the risk of adverse
selection as the portfolio continues to amortize.

N-Star CDO II is a cash flow collateralized debt obligation (CDO),
which closed July 1, 2004. The collateral is composed of 71.2%
commercial mortgage backed securities (CMBS), 15.1% of SF CDOs,
and 13.7% real estate investment trusts (REIT). The transaction is
collateralized by 44 assets from 41 obligors.

Fitch has affirmed the following classes as indicated:

-- $6,555,928 class A-1 notes at 'AAAsf'; Outlook Stable;
-- $42,000,000 class A-2A notes at 'BBBsf'; Outlook to Stable
    from Negative;
-- $15,000,000 class A-2B notes at 'BBBsf'; Outlook to Stable
    from Negative;
-- $12,000,000 class B-1 notes at 'BBBsf'; Outlook Negative;
-- $14,000,000 class B-2 notes at 'Bsf'; Outlook Negative;
-- $24,047,899 class C-1 notes at 'CCCsf';
-- $6,100,215 class C-2A notes at 'CCsf';
-- $16,665,764 class C-2B notes at 'CCsf';
-- $16,962,076 class D notes at 'Csf'.


N-STAR REAL VII: Fitch Cuts Ratings on 8 Cert. Classes to 'Csf'
---------------------------------------------------------------
Fitch Ratings has downgraded eight classes issued by N-Star Real
Estate CDO VII, Ltd. (N-Star CDO VII) as a result of significant
deterioration of the underlying collateral.

SENSITIVITY/RATING DRIVERS:

Since the last rating action in February 2012, approximately 48.4%
of the collateral has been downgraded and 1.8% has been upgraded.
Currently, 95.8% of the portfolio has a Fitch derived rating below
investment grade and 81.9% has a rating in the 'CCC' category and
below, compared to 85.5% and 55.5%, respectively, at the last
rating action. Over this period, the transaction has experienced
$100.1 million in losses from the sale of credit risk securities
by the asset manager.

This transaction was analyzed under the framework described in the
report 'Global Rating Criteria for Structured Finance CDOs' using
the Portfolio Credit Model (PCM) for projecting future default
levels for the underlying portfolio. The default levels were then
compared to the breakeven levels generated by Fitch's cash flow
model of the CDO under the various default timing and interest
rate stress scenarios, as described in the report 'Global Criteria
for Cash Flow Analysis in CDOs'. Fitch also analyzed the
structure's sensitivity to the assets that are distressed,
experiencing interest shortfalls, and those with near-term
maturities. None of the notes' breakeven rates met the 'CCC'
hurdle in the cash flow model.

For all notes in the transaction, Fitch analyzed each class'
sensitivity to the default of the distressed assets ('CCC' and
below). Given the high probability of default of the underlying
assets and the expected limited recovery prospects upon default,
the class A-1 notes have been downgraded to 'CCCsf', indicating
that default is possible. Similarly, the class A-2 notes have been
downgraded to 'CCsf', indicating that default is probable and the
class A-3 through E notes have been downgraded to 'Csf',
indicating that default is inevitable. Further, given the
increased amount of underlying collateral experiencing interest
shortfalls, there is heightened risk that CDO proceeds will be
insufficient to pay the periodic timely interest.

N-Star CDO VII is a collateralized debt obligation (CDO) which
closed June 22, 2006. The transaction is collateralized by 84
assets from 62 obligors. The portfolio is composed of 78.8%
commercial mortgage-backed securities (CMBS); 20.1% of SF CDOs;
and 1.1% residential mortgage-backed securities (RMBS).

Fitch has downgraded the following classes as indicated:

--$93,635,649 class A-1 notes to 'CCCsf' from 'BBsf';
--$54,250,000 class A-2 notes to 'CCsf' from 'Bsf';
--$50,000,000 class A-3 notes to 'Csf' from 'CCCsf';
--$30,300,000 class B notes to 'Csf' from 'CCCsf';
--$22,154,623 class C notes to 'Csf' from 'CCsf';
--$14,215,356 class D-FL notes to 'Csf' from 'CCsf';
--$2,130,453 class D-FX notes to 'Csf' from 'CCsf';
--$17,705,702 class E notes to 'Csf' from 'CCsf'.


NATIONSTAR AGENCY: S&P Assigns Prelim 'B' Rating to 2 Note Classes
------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Nationstar Agency Advance Funding Trust
$900 million servicer advance receivables-backed notes.

The preliminary ratings are based on information as of
Jan. 23, 2013.  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 likelihood
that the recoveries on the servicer advances, together with
the reserve fund and the overcollateralization, will be
sufficient under its rating stresses, as outlined in its
criteria, to meet the scheduled interest and ultimate
principal payments due on the securities according to the
obligations' terms.

          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/1259.pdf.

PRELIMINARY RATINGS ASSIGNED

Nationstar Agency Advance Funding Trust

Class         Rating       Type      Interest rate    Amount
                                                    (mil. $)

A-1-VF1 VFN   AAA (sf)   Floating  1 mo. LIBOR+1.35   30.918
A-1-T1 term   AAA (sf)   Fixed     1.50              177.296
A-2-T2 term   AAA (sf)   Fixed     2.50               88.987
B-1-VF1 VFN    AA (sf)   Floating  1 mo. LIBOR+1.75   32.756
B-1-T1 term    AA (sf)   Fixed     1.75                9.597
B-2-T2 term    AA (sf)   Fixed     3.00                4.853
C-1-VF1 VFN     A (sf)   Floating  1 mo. LIBOR+3.25   17.837
C-1-T1 term     A (sf)   Fixed     2.50                4.850
C-2-T2 term     A (sf)   Fixed     3.75                2.348
D-1-VF1 VFN   BBB (sf)   Floating  1 mo. LIBOR+3.75   18.849
D-1-T1 term   BBB (sf)   Fixed     3.50                4.953
D-2-T2 term   BBB (sf)   Fixed     4.75                 2.40
E-1-T1 term    BB (sf)   Fixed     5.50                1.547
E-2-T2 term    BB (sf)   Fixed     7.50                0.887
F-1-T1 term     B (sf)   Fixed     8.00                1.757
F-2-T2 term     B (sf)   Fixed     9.75                0.525


OCEAN TRAILS: S&P Assigns 'B+' Rating to Class D Notes
-------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-2, A-3, B, and C notes from Ocean Trails CLO II, a
collateralized loan obligation (CLO) transaction managed by
West Gate Horizons Advisors LLC.  In addition, S&P affirmed
its ratings on the class A-1 (voting), A-1 (nonvoting), and
D notes.  S&P also removed its ratings on all of the classes
in this review from CreditWatch, where it place them on
Oct. 29, 2012, with positive implications.

The transaction's reinvestment period is scheduled to end in
July 2014, and it reaches legal maturity in June 2022.

The class A-1 (voting) and A-1 (nonvoting) notes are
identical in terms of payment priority and credit support,
so S&P rates the classes equally.  Previously, the class A-1
notes assigned their voting rights to another party, which
created the second class of notes.

The upgrades of the class A-2, A-3, B, and C notes reflect
the improved credit quality of the transaction's underlying
collateral portfolio since S&P's March 2012 rating actions.

For S&P's analysis, it observed $17.8 million (about 4.7% of
the pool) of assets from obligors rated in the 'CCC'
category as per the January 2013 trustee report, down from
$31.6 million (about 6.8% of the pool) noted in the February
2012 trustee report, which S&P referenced for its March 2012
rating actions.  Furthermore, the transaction continues to
maintain a low level of defaults in the collateral pool.
The January 2013 monthly trustee report indicated
$3.7 million (about 1% of the pool) as defaults.

S&P affirmed its ratings on the class A-1 (voting), A-1
(nonvoting), and D notes to reflect the availability of
adequate credit support at the current rating levels.

The rating on the class D notes is driven by the application
of the largest obligor default test, a supplemental stress
test S&P introduced as part of its 2009 corporate criteria
update.

S&P 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 deem necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

        http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Ocean Trails CLO II
Class                     Rating
                  To               From

A-1 (voting)      AA+ (sf)         AA+ (sf)/Watch Pos
A-1 (nonvoting)   AA+ (sf)         AA+ (sf)/Watch Pos
A-2               AA+ (sf)         AA (sf)/Watch Pos
A-3               AA- (sf)         A+ (sf)/Watch Pos
B                 A- (sf)          BBB+ (sf)/Watch Pos
C                 BBB- (sf)        BB+ (sf)/Watch Pos
D                 B+ (sf)          B+ (sf)/Watch Pos


OFSI FUND III: S&P Hikes Rating 2 Note Classes to 'CCC+'
---------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1, A-2, B, C, D, E-1, and E-2 notes from OFSI Fund
III Ltd., a collateralized loan obligation (CLO) transaction
managed by Orchard First Source Asset Management LLC.  At
the same time, S&P removed its ratings on all of the classes
in this review from CreditWatch, where S&P placed them with
positive implications on Oct. 29, 2012.

The transaction is in its amortization phase following the
end of its reinvestment period in September 2012 and has
commenced paying down the class A-1 and A-2 notes, which are
pari passu.

The upgrades of the class A-1, A-2, B, C, D, E-1, and E-2
notes reflect paydowns to the class A-1 and A-2 notes.  On
Dec. 20, 2012, class A-1 and A-2 notes received
$46.4 million principal pay down in total.  After this most
recent payment, the class A-1 and A-2 notes' outstanding
balance was 86% of the original balance.

The transaction continues to maintain a low level of
defaults in the collateral pool.  The December 2012 monthly
trustee report indicated about 1.4% ($6.2 million par) of
the pool as defaults.

The ratings on the class E-1 and E-2 notes are driven by the
application of the largest obligor default test, a
supplemental stress test S&P introduced as part of its 2009
corporate criteria update.

S&P 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 deem necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

OFSI Fund III Ltd.

Class              Rating
             To               From

A-1          AAA (sf)         AA+ (sf)/Watch Pos
A-2          AAA (sf)         AA+ (sf) /Watch Pos
B            AA+ (sf)         AA (sf) /Watch Pos
C            A+ (sf)          A (sf) /Watch Pos
D            BBB+ (sf)        BB+ (sf) /Watch Pos
E-1          CCC+ (sf)        CCC- (sf)/Watch Pos
E-2          CCC+ (sf)        CCC- (sf)/Watch Pos


OFSI FUND V: S&P Assigns Prelim. 'B' Rating to Class B-3L Notes
----------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to OFSI Fund V Ltd./OFSI Fund V LLC's
$353.00 million floating-rate notes.

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

The preliminary ratings are based on information as of
Jan. 22, 2013.  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
   criteria (see "Update To Global   Methodologies And
   Assumptions For Corporate Cash Flow And Synthetic CDOs,"
   published Sept. 17, 2009).

- 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 preliminary rated
   notes, which S&P assessed using its cash flow analysis
   and assumptions commensurate with the assigned
   preliminary ratings under various interest-rate
   scenarios, including LIBOR ranging from 0.3439%-12.6500%.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

The Standard & Poor's 17g-7 Disclosure Report included in
this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com/1251.pdf.

PRELIMINARY RATINGS ASSIGNED

OFSI Fund V Ltd./OFSI Fund V LLC

Class                    Rating              Amount (mil. $)
A-1LA                    AAA (sf)                     132.00
A-1LB                    AAA (sf)                     108.00
A-2L                     AA (sf)                       34.50
A-2F                     AA (sf)                       10.00
A-3L (deferrable)        A (sf)                        21.00
A-3F (deferrable)        A (sf)                         5.00
B-1L (deferrable)        BBB (sf)                      19.00
B-2L (deferrable)        BB- (sf)                      17.00
B-3L (deferrable)        B (sf)                         6.50
Combination securities   A (sf)                       123.10
Subordinated notes       NR                            41.15

NR-Not rated.


OHA LOAN 2012-1: S&P Assigns 'BB' Rating to Class E Notes
----------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
OHA Loan Funding 2012-1 Ltd./OHA Loan Funding 2012-1 Inc.'s
$332 million floating- and fixed-rate notes.

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

The ratings reflect S&P's view of:

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

- The transaction's credit enhancement, which is sufficient
   to withstand the defaults applicable for the supplemental
   tests (not counting excess spread), and cash flow
   structure, which can withstand the default rate projected
   by Standard & Poor's CDO Evaluator model, as assessed by
   Standard & Poor's using the assumptions and methods
   outlined in its corporate collateralized debt obligation
   (CDO) criteria (see "Update To Global Methodologies And
   Assumptions For Corporate Cash Flow And Synthetic CDOs,"
   published Sept. 17, 2009).

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

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

- The collateral manager's experienced management team.
   S&P's projections regarding the timely interest and
   ultimate principal payments on the rated notes, which S&P
   assessed using its cash flow analysis and assumptions
   commensurate with the assigned ratings under various
   interest-rate scenarios, including LIBOR ranging from
   0.3105%-13.8391%.

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

- The transaction's interest diversion test, a failure of
   which during the reinvestment period will lead to the
   reclassification of up to 50% of excess interest proceeds
   that are available (before paying subordinated and
   incentive collateral management fees, uncapped
   administrative expenses and hedge amounts, subordinated
   note payments, and expenses related to a refinancing) to
   principal proceeds for the purchase of additional
   collateral assets or, after the noncall period, to pay
   the notes sequentially, at the election of the collateral
   manager.

          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/1253.pdf

RATINGS ASSIGNED

OHA Loan Funding 2012-1 Ltd./OHA Loan Funding 2012-1 Inc.

Class                  Rating              Amount
                                         (mil. $)

X                      AAA (sf)               2.0
A                      AAA (sf)             220.0
B-1                    AA (sf)               30.5
B-2                    AA (sf)               19.0
C (deferrable)         A (sf)                25.5
D (deferrable)         BBB (sf)              18.0
E (deferrable)         BB (sf)               17.0
Subordinated notes     NR                    40.5

NR--Not rated.


OLYMPIC CLO I: S&P Raises Rating on Class B-1L Notes to 'BB+'
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-3L and B-1L notes from Olympic CLO I Ltd., a
collateralized loan obligation (CLO) transaction.  At the
same time, S&P affirmed its ratings on the class A-2L, B-2L,
and U notes and removed its ratings on the class A-3L, B-1L,
and B-2L notes from CreditWatch positive, where S&P placed
them on Oct. 29, 2012.

The transaction is in its amortization phase and continues
to pay down the class A notes.  S&P's last rating action on
this transaction was in April 2012, when it raised its
ratings on the class A-2L, A-3L, and B-1L notes and affirmed
the class A-1Lb, A-1L, B-2L, and U ratings.  Since then, the
transaction has paid off its class A-1Lb and A-1L notes in
full.

As of the most recent payment date on Nov. 15, 2012, the
class A-2L note balance was down to $1.461 million (9.13% of
its original balance) and S&P expects it to be paid down in
full on the February 2013 payment date.

"We raised our ratings on the class A-3L and B-1L notes due
to the increase in credit support.  We affirmed our ratings
on the class A-2L and B-2L notes to reflect the availability
of adequate credit support at their current rating levels.
We affirmed our 'AA+ (sf)' rating on the class U notes
because they are backed by a U.S. Treasury strip
certificate," S&P said.

Standard & Poor's is aware that on Jan. 10, 2013, the issuer
sent a notice of optional redemption pursuant to which the
notes may be redeemed on the February 2013 payment date.

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

Olympic CLO I Ltd.

                  Rating
Class         To            From

A-3L          AAA (sf)      AA+ (sf)/Watch Pos
B-1L          BB+ (sf)      BB- (sf)/Watch Pos

RATING AFFIRMED AND REMOVED FROM CREDITWATCH

Olympic CLO I Ltd.

                  Rating
Class         To            From

B-2L          CCC- (sf)     CCC- (sf)/Watch Pos

RATINGS AFFIRMED

Olympic CLO I Ltd.

Class         Rating

A-2L          AAA (sf)
U             AA+ (sf)

TRANSACTION INFORMATION:

Issuer:       Olympic CLO I Ltd.
Coissuer:     Olympic CLO I (Delaware) Corp.
Trustee:      Bank Of New York Mellon (The)


OWS CLO I: Moody's Affirms 'Caa3' Rating on Class D Notes
---------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by OWS CLO I Ltd.:

U.S.$14,000,000 Class B Deferrable Senior Secured Notes Due
January 6, 2016, Upgraded to Aa1 (sf); previously on May 4, 2012
Upgraded to A2 (sf);

U.S.$8,000,000 Class C Secured Notes Due January 6, 2016, Upgraded
to Baa2 (sf); previously on July 28, 2011 Upgraded to Ba3 (sf).

Moody's also affirmed the ratings of the following notes:

U.S.$235,500,000 Class A-1 Senior Secured Notes Due January 6,
2016 (current outstanding balance of $17,760,994), Affirmed at Aaa
(sf); previously on April 20, 2011 Upgraded to Aaa (sf);

U.S.$14,500,000 Class A-2 Senior Secured Notes Due January 6,
2016, Affirmed at Aaa (sf); previously on May 4, 2012 Upgraded to
Aaa (sf);

U.S.$3,000,000 Class X-1 Deferrable Amortizing Senior Secured
Notes Due January 6, 2016 (current outstanding balance of
$1,243,888), Affirmed at Aaa (sf); previously on May 4, 2012
Upgraded to Aaa (sf);

U.S.$11,500,000 Class X-2 Deferrable Amortizing Senior Secured
Notes Due January 6, 2016 (current outstanding balance of
$4,377,462), Affirmed at Aaa (sf); previously on May 4, 2012
Upgraded to Aaa (sf);

U.S.$8,500,000 Class D Subordinated Secured Notes Due January 6,
2016 (current outstanding balance of $8,711,692), Affirmed at Caa3
(sf); previously on July 28, 2011 Confirmed at Caa3 (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 May 2012. Moody's notes that the Class A-1
Notes have been paid down by approximately 66% or $34.6 million
since the last rating action. Based on the latest trustee report
dated December 31, 2012, the Class A, Class B, Class C and Class D
overcollateralization ratios are reported at 182.34%, 138.86%,
122.20% and 108.09%, respectively, versus May 2012 levels of
153.88%, 127.24%, 115.78% and 105.45%, respectively. The current
overcollateralization ratios do not reflect the paydown of
approximately $12.4 million to the Class A-1 Notes on the most
recent payment date in January. The calculation of the Class A, B,
C, and D overcollateralization ratios also does not take into
consideration the outstanding balance on the Class X-1 Notes and
the Class X-2 Notes.

Notwithstanding improvement in the ovecollateralization ratios,
Moody's has affirmed the rating of the Class D Notes due to a
number of investments in securities in the portfolio that mature
after the maturity date of the notes. Based on Moody's
calculation, securities that mature after the maturity date of the
notes currently make up approximately 50.9% of the underlying
portfolio. These investments potentially expose the notes to
market risk in the event of liquidation at the time of the notes'
maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $68.4 million,
defaulted par of $7.3 million, a weighted average default
probability of 12.03% (implying a WARF of 2552), a weighted
average recovery rate upon default of 51.20%, and a diversity
score of 25. 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.

OWS CLO I Ltd., issued in November 2005, 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% (2042)

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

Moody's Adjusted WARF + 20% (3062)

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of 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
collateral sales by the manager, which may have significant impact
on the notes' ratings.

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

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

4) Market value risk: The overcollateralization ratio calculations
include haircuts that can be applied to the par value of a
collateral obligation with a market value below 85% of its
principal balance, regardless of the rating of that collateral
obligation. This haircut continues until such obligation trades at
a market value of at least 90% of its principal balance for 30
consecutive days. The current overcollateralization ratios are
minimally impacted by this haircut. However, if loan market values
were to decline substantially, this haircut could result in
significantly reduced overcollateralization ratio calculations.


PACIFIC BAY: Fitch Affirms 'Dsf' Rating on Two Note Classes
-----------------------------------------------------------
Fitch Ratings has affirmed the ratings on five classes and revised
the Outlook on one class of notes issued by Pacific Bay CDO
Ltd./Inc. as:

-- $24,598,410 class A-1 notes at 'AAsf'; Outlook to Stable
    from Negative;
-- $64,000,000 class A-2 notes at 'Dsf';
-- $36,000,000 class B notes at 'Dsf';
-- $7,691,215 class C notes at 'Csf';
-- $17,000,000 preference shares at 'Csf'.

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

Since the last rating action in January 2012, the credit quality
of the collateral has deteriorated with approximately 39.8%
downgraded a weighted average of 3.5 notches and 4.5% upgraded a
weighted average of 1.0 notch. Approximately 72.5% of the
portfolio has a Fitch derived rating below investment grade and
57.4% has a rating in the 'CCC' rating category or lower, compared
to 71.1% and 46.8%, respectively, at last review.

This deterioration has been effectively offset by the continued
deleveraging of the transaction. The class A-1 notes have received
approximately $16.7 million, or 40.5% of its previous balance, in
paydowns since the last review and are currently the only class
receiving interest and principal payments due to an acceleration
of the transaction. This has increased the class A-1 notes' credit
enhancement, resulting in an affirmation of its rating. Fitch has
revised the Outlook to Stable to reflect the available cushion in
the cash flow modeling results to protect the notes against
further potential deterioration in the credit quality of the
underlying portfolio.

The class A-2 and B notes continue to miss their timely interest
payments as a result of the acceleration. These non-deferrable
classes are considered to be defaulted on the payment of interest
and have been affirmed at 'Dsf'. Fitch expects the class A-2 notes
to recover at least a portion, if not all, of the $2.9 million in
defaulted interest by the stated maturity of the transaction.

The class C notes and the preference shares are no longer
receiving interest distributions and are not expected to receive
any proceeds going forward. Fitch believes that default is
inevitable for these classes at or prior to maturity due to the
concentration of distressed collateral. Therefore, these classes
have been affirmed at 'Csf'.

Pacific Bay is a cash flow structured finance collateralized debt
obligation that closed on Nov. 4, 2003. The portfolio is monitored
by Pacific Investment Management Company LLC. (PIMCO) and is
composed of 79.3% residential mortgage-backed securities, 12%
corporate bonds, 6% asset-backed securities, and 2.7% commercial
mortgage-backed securities, primarily from 1999 through 2005
vintage transactions.


PACIFICA CDO III: Moody's Hikes Ratings on 2 Note Classes to Ba2
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Pacifica CDO III, Ltd.:

U.S. $6,000,000 Class B-1 Deferrable Floating Rate Notes Due 2016,
Upgraded to Aa1 (sf); previously on April 5, 2012 Upgraded to A1
(sf);

U.S. $5,000,000 Class B-2 Deferrable Fixed Rate Notes Due 2016,
Upgraded to Aa1 (sf); previously on April 5, 2012 Upgraded to A1
(sf);

U.S. $10,000,000 Class J Blended Securities Due 2016 (current
outstanding Rated Balance of $1,956,409.72), Upgraded to A1 (sf);
previously on April 5, 2012 Upgraded to A3 (sf).

Moody's also affirmed the ratings of the following notes:

U.S. $278,000,000 Class A-1 Floating Rate Notes Due 2016 (current
outstanding balance of $43,695,313.30), Affirmed Aaa (sf);
previously on May 27, 2011 Upgraded to Aaa (sf);

U.S. $25,000,000 Class A--2a Floating Rate Notes Due 2016,
Affirmed Aaa (sf); previously on April 5, 2012 Upgraded to Aaa
(sf);

U.S. $4,000,000 Class A--2b Fixed Rate Notes Due 2016, Affirmed
Aaa (sf); previously on April 5, 2012 Upgraded to Aaa (sf);

U.S. $15,900,000 Class C--1 Floating Rate Notes Due 2016, Affirmed
Ba2 (sf); previously on July 1, 2011 Upgraded to Ba2 (sf);

U.S. $5,100,000 Class C--2 Fixed Rate Notes Due 2016, Affirmed Ba2
(sf); previously on July 1, 2011 Upgraded to Ba2 (sf);

U.S. $5,000,000 Class L Blended Securities (Current outstanding
Rated Balance of $3,093,764.06), Affirmed Aaa (sf); previously on
July 1, 2011 Upgraded to Aaa (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 April 2012. Moody's notes that the Class A-1
Notes have been paid down by approximately 56% or $55.5 million
since the last rating action. Based on the latest trustee report
dated November 30, 2012, the Class A, Class B and Class C
overcollateralization ratios are reported at 143.28%, 129.12% and
108.62%, respectively, versus March 2012 levels of 129.23%,
120.08% and 105.78%, respectively. The November 30, 2012
overcollateralization ratios do not account for the pay down which
occurred in the December 2012 payment date.

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 $114.2 million,
defaulted par of $3.2 million, a weighted average default
probability of 15.49% (implying a WARF of 2942), a weighted
average recovery rate upon default of 52.92%, and a diversity
score of 28. 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.

Additionally, Moody's notes that the underlying portfolio consists
of a number of investments in securities that mature after the
maturity date of the notes. Based on the November 30, 2012 trustee
report, securities that mature after the maturity of the notes
currently make up approximately 26.8% of the underlying portfolio
These investments potentially expose the notes to market risk in
the event of liquidation at the time of the notes' maturity.

Notwithstanding the increase in overcollateralization of the Class
C Notes, Moody's affirmed the ratings of the Class C Notes due to
the large long-dated asset exposure.

Pacifica CDO III, Ltd., issued in May 2004, 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, due to the
low diversity of the collateral pool, CDOROM 2.8 was used to
simulate a default distribution that was then applied as an input
in the cash flow model.

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

Moody's Adjusted WARF -- 20% (2279)

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

Moody's Adjusted WARF + 20% (3530)

Class A-1: 0
Class A-2a 0
Class A-2b: 0
Class B-1: -2
Class B-2: -2
Class C-1: -1
Class C-2: -1
Class J: -2
Class L: 0

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of 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) Long-dated assets: The presence of assets that mature beyond
the CLO's legal maturity date exposes the deal to liquidation risk
on those assets. Moody's assumes an asset's terminal value upon
liquidation at maturity to be equal to the lower of an assumed
liquidation value (depending on the extent to which the asset's
maturity lags that of the liabilities) and the asset's current
market value.

Further information on Moody's analysis of this transaction is
available on www.moodys.com.


PREMIUM LOAN: S&P Lowers Rating on Class C Notes to 'CCC-'
-----------------------------------------------------
Standard & Poor's Ratings Services raised and removed from
CreditWatch its rating on the class B note from Premium Loan
Trust I Ltd., a collateralized loan obligation (CLO)
transaction.  S&P also lowered its rating on the class C
note and affirmed its rating on the class D note.

Since S&P's last rating action in March 2012, when it
affirmed its rating on class B, the transaction has paid
down the class B notes by $4.9 million, bringing it to 49%
of its initial balance.  During the last review, the class B
notes were still deferring their interest payments on
account of the transaction's event of default and subsequent
declaration of acceleration.  This caused all available
payments to be diverted towards the pay down of the class A
notes.  The class A notes have since been paid and the class
B notes have commenced their pay down.  The pay downs to the
class B notes have resulted in an increase in the class B
overcollateralization (O/C) from 157.98% as of the January
2012 trustee report to 283.14% as of the November 2012
trustee report.

"We lowered our rating on the class C note and affirmed our
rating on the class D note to reflect the low O/C ratios and
the increase in the balance of defaulted assets.  The class
C and D O/C ratios have decreased to 79.00% and 53.35% from
97.93% and 78.65% in January 2012, respectively," S&P said.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

The Standard & Poor's 17g-7 Disclosure Report included in
this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Premium Loan Trust I Ltd.

                   Rating
             To               From

B            A (sf)           B (sf)/Watch Pos
C            CCC- (sf)        CCC (sf)
D            CC (sf)          CC (sf)


RASC SERIES 2005-KS2: Moody's Corrects M-1 Certs Rating to Caa3
---------------------------------------------------------------
Moody's Investors Service is correcting the rating for the Class
RASC Series 2005-KS2 Trust's M-1 tranche (CUSIP: 76110WN69) to
Caa3 (sf) from WR.

The rating for this security was previously withdrawn on December
20, 2011 due to an internal administrative error.


RASC SERIES 2005-KS2: Moody's Hikes Rating on M-1 Tranche to Ba3
----------------------------------------------------------------
Moody's Investors Service upgraded the rating on one tranche and
has affirmed the ratings on four tranches from RASC Series 2005-
KS2 Trust in a Jan. 24, 2013 ratings release. The collateral
backing the transaction are subprime residential mortgage loans.

Complete rating actions are as follows:

Issuer: RASC Series 2005-KS2 Trust

Cl. A-II-1, Affirmed Aaa (sf); previously on Jul 15, 2011
Confirmed at Aaa (sf)

Cl. A-II-2, Affirmed Aaa (sf); previously on Jul 15, 2011
Confirmed at Aaa (sf)

Cl. M-1, Upgraded to Ba3 (sf); previously on Apr 6, 2010
Downgraded to Caa3 (sf)

Cl. M-2, Affirmed C (sf); previously on Apr 6, 2010 Downgraded to
C (sf)

Cl. M-3, Affirmed C (sf); previously on Mar 20, 2009 Downgraded to
C (sf)

RATINGS RATIONALE

The actions are a result of the recent performance of Subprime
pools originated after 2005 and reflect Moody's updated loss
expectations on these pools. The upgrade in the rating action are
a result of improving performance resulting in lower expected
losses for certain bonds than previously anticipated.

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

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

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

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

The primary sources of assumption uncertainty are Moody's central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 8.5% in December 2011 to 7.8% in December 2012.
Moody's forecasts a unemployment central range of 7.5% to 8.0% for
the 2013 year. Moody's expects housing prices to gradually rise
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer activity such as modification-related
principal forgiveness and interest rate reductions. Any change
resulting from servicing transfers or other policy or regulatory
change can also impact the performance of these transactions.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF314681

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

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


RESOURCE REAL 2006-1: S&P Lowers Rating on Class G Notes to 'B-'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on
eight classes from Resource Real Estate Funding CDO 2006-1
Ltd., a commercial real estate collateralized debt
obligation (CRE CDO) transaction, and removed them from
CreditWatch with negative implications.

The downgrades reflect S&P's analysis of the transaction's
liability structure and the underlying collateral's credit
characteristics using S&P's global CDOs of pooled structured
finance assets criteria.  S&P also considered the amount of
defaulted assets in the transactions and their expected
recoveries in S&P's analysis.

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

According to the Dec. 26, 2012, trustee report, the
transaction's collateral totaled $298.3 million.  The
transaction's liabilities totaled $282.9 million, which is
down from $345.0 million at issuance due to amortizations
and subordinate note cancellations.  The transaction's
current asset pool consists of the following:

   -- 15 whole loans/ senior participations ($206.1 million,
      69.1%),

   -- Six subordinate loans / mezzanine loans
      ($58.5 million, 19.6%),

   -- Two CRE CDO securities ($17.3 million, 5.8%), and

   -- Four commercial mortgage-backed securities (CMBS)
      ($16.4 million, 5.5%).

The trustee report noted two defaulted assets
($10.4 million, 3.5%) in the collateral pool, for which S&P
expects minimal recoveries.  S&P based its recovery analysis
on information provided by the collateral manager, special
servicer, and third-party data providers.

S&P applied asset specific recovery rates in our analysis of
the performing loans ($259.7 million, 87.1%) in the
transaction using its updated methodology and assumptions
for rating U.S. and Canadian CMBS and our global property
evaluation methodology, both published Sept. 5, 2012.  S&P
also considered qualitative factors such as the near-term
maturities of the loans, refinancing prospects, and loan
modifications.

According to the trustee report, the transaction is passing
its principal coverage tests and interest coverage tests.

"In addition, our analysis considers the prior cancellations
of subordinate notes in the transaction.  According to the
June 27, 2011, trustee report, as well as notice from the
trustee, U.S. Bank N.A., certain subordinate notes were
cancelled before they were repaid through the transaction's
payment waterfall.  Our ratings reflect our assessment of
any risks and credit stability considerations regarding the
subordinate note cancellations.  For details, please refer
to our Aug. 18, 2011, publication regarding 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 determines necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com


RATINGS LOWERED AND REMOVED FROM CREDITWATCH

Resource Real Estate Funding CDO 2006-1 Ltd.

                  Rating
Class     To                   From

A-1        BBB (sf)               BBB+ (sf)/Watch Neg
A-2-F-X    BBB- (sf)              BBB (sf)/Watch Neg
A-2-FL     BBB- (sf)              BBB (sf)/Watch Neg
C          BB+ (sf)               BBB- (sf)/Watch Neg
D          BB (sf)                BB+ (sf)/Watch Neg
E          B+ (sf)                BB+ (sf)/Watch Neg
F          B (sf)                 BB (sf)/Watch Neg
G          B- (sf)                B+ (sf)/Watch Neg


SEQUOIA MORTGAGE 2013-2: Fitch to Rate Class B-4 Certs. 'BB'
------------------------------------------------------------
Fitch Ratings expects to rate Sequoia Mortgage Trust 2013-2 as
detailed below.

Fitch's stress and rating sensitivity analysis are discussed in
the presale report titled 'Sequoia Mortgage Trust 2013-2', dated
Jan. 22, 2013, which is available on Fitch's web site,
www.fitchratings.com.

Fitch expects to assign these ratings:

--$619,163,000 class A-1 certificate 'AAAsf'; Outlook Stable;
--$619,163,000 class A-IO1 notional certificate 'AAAsf'; Outlook
  Stable;
--$619,163,000 class A-IO2 notional certificate 'AAAsf'; Outlook
  Stable;
--$14,654,000 class B-1 certificate 'AAsf'; Outlook Stable;
--$12,657,000 class B-2 certificate 'Asf'; Outlook Stable;
--$6,661,000 class B-3 certificate 'BBBsf'; Outlook Stable;
--$5,662,000 non-offered class B-4 certificate 'BBsf'; Outlook
  Stable;

The non-offered class B-5 certificate will not be rated.


SORIN REAL: S&P Lowers Rating on 4 Note Classes to 'D'
-------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on
seven classes from Sorin Real Estate CDO IV Ltd., a
commercial real estate collateralized debt obligation (CRE
CDO) transaction, and removed them from CreditWatch with
negative implications. S&P also affirmed its ratings on two
other classes from the same transaction and removed them
from CreditWatch with negative implications.

The rating actions reflect S&P's analysis of the
transaction's liability structure and the credit
characteristics of the underlying collateral using its
criteria for global CDOs of pooled structured finance
assets.  S&P also considered the amount of defaulted assets
in the transaction and their expected recoveries in its
analysis.

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

S&P lowered its ratings on classes D through G to 'D (sf)'
from 'CCC- (sf)' because S&P do not expect these classes to
be repaid in full.

According to the Dec. 31, 2012, trustee report, the
transaction's collateral totaled $233.1 million, while the
transaction's liabilities totaled $286.4 million (including
capitalized interest), down from $400.0 million at issuance.
The transaction's current asset pool included the following:

   -- Fourteen commercial mortgage-backed securities (CMBS)
      tranches ($137.9 million, 59.2%);

   -- Eight whole loan and senior-interest loans
      ($53.3 million, 22.8%);

   -- Three subordinate-interest loans ($37.6 million,
      16.1%); and

   -- One CRE CDO security ($4.3 million, 1.9%).

The trustee report noted six defaulted assets
($48.6 million, 20.8%) as follows:

   -- The Merrill Lynch Mortgage Trust 2005-CKI1 H tranche
      CMBS ($15.0 million, 6.4%);

   -- The Yellowstone - LT senior-interest loan
      ($12.5 million, 5.3%);

   -- The Dyersburg Mall whole loan ($8.5 million, 3.6%);

   -- The Flag Luxury Properties subordinate-interest loan
      ($4.5 million, 1.9%);

   -- The Sorin Real Estate CDO I Ltd. E tranche CRE-CDO
      ($4.3 million, 1.9%);and

   -- The Yellowstone Mountain Club Term Loan senior-
      interest loan ($3.8 million, 1.6%).

Standard & Poor's estimated a 13.4% weighted average asset-
specific recovery rate for the defaulted loan assets.  S&P
based the recovery rates on information from the collateral
manager, special servicer, and third-party data providers.

"We applied asset specific recovery rates in our analysis of
the seven performing loans ($61.6 million, 26.4%) using our
updated rating methodology and assumptions for U.S. and
Canadian CMBS and CMBS global property evaluation
methodology, both published Sept. 5, 2012.  We also
considered qualitative factors such as the near-term
maturities of the loans and refinancing prospects of the
assets in the pool," S&P said.

According to the trustee report, the deal is failing all
three overcollateralization coverage tests and passing all
three interest coverage tests.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED AND REMOVED FROM CREDITWATCH

Sorin Real Estate CDO IV Ltd.

                  Rating
Class     To             From

A2        CCC+ (sf)      B (sf)/Watch Neg
A3        CCC (sf)       B- (sf)/Watch Neg
B         CCC- (sf)      CCC+ (sf)/Watch Neg
D         D (sf)         CCC- (sf)/Watch Neg
E         D (sf)         CCC- (sf)/Watch Neg
F         D (sf)         CCC- (sf)/Watch Neg
G         D (sf)         CCC- (sf)/Watch Neg

RATINGS AFFIRMED AND REMOVED FROM CREDITWATCH

Sorin Real Estate CDO IV Ltd.

                  Rating
Class     To             From

A1        B+ (sf)        B+ (sf)/Watch Neg
C         CCC- (sf)      CCC- (sf)/Watch Neg


SRRSPOKE 2007-IA: Moody's Affirms 'C' Ratings on 2 Note Classes
---------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of two classes
of Notes issued by SRRSpoke 2007-IA. The affirmations are due to
the key transaction parameters performing within levels
commensurate with the existing ratings levels. The rating action
is the result of Moody's on-going surveillance of commercial real
estate collateralized debt obligation (CRE CDO Synthetic)
transactions.

Moody's rating action is as follows:

U.S. $76,050,000 Class I Variable Floating Rate Notes Due 2037,
Affirmed C (sf); previously on May 6, 2010 Downgraded to C (sf)

U.S. $4,095,000 Subordinated Variable Floating Rate Notes Due
2037, Affirmed C (sf); previously on May 6, 2010 Downgraded to C
(sf)

RATINGS RATIONALE

SRRSpoke 2007-IA is a static synthetic transaction backed by a
portfolio of commercial mortgage backed securities (CMBS) (80.7%
of the reference obligation balance) and CRE CDOs (19.3%)
reference obligations. As of the December 5, 2012 Trustee report,
the aggregate issued notional balance of the transaction has
decreased to $557.8 million from $585.0 million at issuance, due
to writedowns of five of the reference obligations.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: 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 reference obligations. The bottom-dollar WARF is a measure
of the default probability within a reference pool. Moody's
modeled a bottom-dollar WARF of 3,959 compared to 3,429 at last
review. The current distribution is as follows: Aaa-Aa3 (1.8%
compared to 1.7%), A1-A3 (3.6% compared to 7.0%),Baa1-Baa3 (14.3%
compared to 29.6% at last review), Ba1-Ba3 (17.9% compared to
15.7% at last review), B1-B3 (23.4% compared to 13.9% at last
review), and Caa1-Ca/C (39.0% compared to 32.2% at last review).

Moody's modeled to a WAL of 4.0 years, compared to 5.1 years at
last review.

Moody's modeled a fixed 15.6% WARR, compared to 20.4% at last
review.

Moody's modeled a MAC of 100.0%, compared to 17.1% at last review.

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

Moody's analysis encompasses the assessment of stress scenarios.

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 rating changes within the reference obligation pool.
However, in light of the performance indicators noted above,
Moody's believes that it is unlikely that the ratings announced on
Jan. 24 are sensitive to further change.

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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock; albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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


SRRSPOKE 2007-IB: Moody's Affirms 'C' Rating on Class I Notes
-------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of one class of
Notes issued by SRRSpoke 2007-IB. The affirmations are due to the
key transaction parameters performing within levels commensurate
with the existing ratings levels. The rating action is the result
of Moody's on-going surveillance of commercial real estate
collateralized debt obligation (CRE CDO Synthetic) transactions.

Moody's rating action is as follows:

U.S. $13,162,500 Class I Variable Floating Rate Notes Due 2037,
Affirmed C (sf); previously on May 6, 2010 Downgraded to C (sf)

RATINGS RATIONALE

SRRSpoke 2007-IB is a static synthetic transaction backed by a
portfolio of commercial mortgage backed securities (CMBS) (80.7%)
and CRE CDOs (19.3%). As of the December 5, 2012 Trustee report,
the aggregate issued notional balance of the transaction has
decreased to $836.7 million from $877.5 million at issuance, due
to writedowns of five of the reference obligations.

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 credit assessments for the non-
Moody's rated reference obligations. The bottom-dollar WARF is a
measure of the default probability within a reference pool.
Moody's modeled a bottom-dollar WARF of 3,959 compared to 3,427 at
last review. The current distribution is as follows: Aaa-Aa3 (1.8%
compared to 1.7% at last review), A1-A3 (3.6% compared to 7.0% at
last review), Baa1-Baa3 (14.3% compared to 29.6% at last review),
Ba1-Ba3 (17.9% compared to 15.7% at last review), B1-B3 (23.3%
compared to 13.9% at last review) and Caa1-C (39.0% compared to
32.2% at last review).

Moody's modeled to a WAL of 4.4 years, compared to 5.5 years at
last review.

Moody's modeled a fixed WARR 15.6% compared to 20.4% at last
review.

Moody's modeled a MAC of 100.0% compared to 17.1% at last review.

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

Moody's analysis encompasses the assessment of stress scenarios.

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 rating changes within the reference obligation pool.
However, in light of the performance indicators noted above,
Moody's believes that it is unlikely that the ratings announced on
Jan. 24 are sensitive to further change.

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 given the weak pace of
recovery and commercial real estate property markets. Commercial
real estate property values are continuing to move in a modestly
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 nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace 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 internet sales
growth. 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 is for continued
below-trend growth in US GDP over the near term, with consumer
spending remaining soft in the US. Hurricane Sandy may skew near-
term economic data but is unlikely to have any long-term
macroeconomic effects. Primary downside risks include: a deeper
than expected recession in the euro area accompanied by deeper
credit contraction; the potential for a hard landing in major
emerging markets, including China, India and Brazil; an oil supply
shock; albeit abated in recent months; and given recent political
gridlock, excessive fiscal tightening in the US in 2013 leading
the US into recession. However, the Federal Reserve has shown
signs of support for activity by continuing with quantitative
easing.

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


TALMAGE STRUCTURED: Fitch Affirms 'CCsf' Rating on Class F Notes
----------------------------------------------------------------
Fitch Ratings has affirmed all classes of Talmage Structured Real
Estate Funding 2005-2 Ltd./LLC reflecting Fitch's base case loss
expectation of 35.9%. Fitch's performance expectation incorporates
prospective views regarding commercial real estate market value
and cash flow declines.

SENSITIVITY/ RATING DRIVERS

While the expected loss expectation has increased since last
review, the affirmations reflect improved credit enhancement to
the rated classes. The increased credit enhancement is the result
of 8.5% paydown of the transaction's liabilities. Since the last
rating action, one asset repaid in full, while others have
amortized.

The portfolio is concentrated with only nine assets remaining and
is comprised of non-senior CMBS tranches and B-notes (67.7%) and
whole loans/A-notes (32.3%). The current percentages of defaulted
assets and Loans of Concern is, 18.7% and 12.2%, respectively,
compared to 49.5% and 11.5%, at the last rating action.

Talmage 2005-2 is a commercial real estate collateralized debt
obligation (CRE CDO) managed by Talmage, LLC. The transaction
exited its reinvestment period on Aug. 18, 2010. As of the
December 2012 trustee report, the class E overcollateralization
test is failing.

Because the collateral pool is concentrated, Fitch assumed
additional cash flow stresses and that 100% of the portfolio will
default in the base case stress scenario, defined as the 'B'
stress. In this scenario, the modeled average cash flow decline is
5% from, generally, trailing 12-month second or third quarter
2012.

The largest component of Fitch's base case loss expectation is
related to a defaulted A-note loan (11.1%) secured by a
development site in Orlando, FL. The property is currently in
foreclosure. Fitch modeled a significant loss in the base case
scenario.

The next largest component of Fitch's base case loss expectation
is related to a subordinate mortgage participation (7.6%) secured
by three gaming properties located in Atlantic City, NJ;
Robinsonville, MS; and Tunica, MS. The loan is 90-plus days
delinquent. The estimated value of the portfolio is less than the
senior debt amount. Fitch modeled a term default and a full loss
on this overleveraged position in the base case scenario.
This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio tests to project future default levels
for the underlying portfolio. Recoveries are based on stressed
cash flows and Fitch's long-term capitalization rates. Cash flow
modeling was not performed as part of the analysis due to the
significant cushion between the base case expected loss of the
transaction and the credit enhancement of each class. The credit
enhancement for the classes B through E is consistent with the
ratings listed below.

The rating on class F is based on a deterministic analysis that
considers Fitch's base case loss expectation for the pool and the
current percentage of defaulted assets and Fitch Loans of Concern,
factoring in anticipated recoveries relative to the class' credit
enhancement.

Fitch has affirmed the following and assigned an RE as indicated:

-- $24.3 million class B at 'BBBsf'; Outlook Stable;
-- $27.3 million class C at 'BBsf'; Outlook Stable;
-- $22.5 million class D at 'CCCsf'; RE 100%.
-- $11.4 million class E at 'CCCsf'; RE 100%.
-- $12.9 million class F at 'CCsf'; RE 15%.

Classes S and A have paid in full.


TERWIN MORTGAGE: Moody's Cuts Rating on Cl. B-2 Tranche to 'C'
--------------------------------------------------------------
Moody's Investors Service has withdrawn the ratings of two
tranches from Terwin Mortgage Trust 2003-3SL. The tranches are
backed by a pool of mortgage loans containing fewer than 40 loans
and with pool factors less than 5%.

Complete rating actions are as follows:

Issuer: Terwin Mortgage Trust 2003-3SL

Cl. B-1, Withdrawn (sf); previously on Oct 20, 2010 Downgraded to
Caa1 (sf)

Cl. B-2, Withdrawn (sf); previously on Oct 20, 2010 Downgraded to
C (sf)

RATINGS RATIONALE

Moody's current RMBS surveillance methodologies apply to pools
with at least 40 loans and a pool factor of greater than 5%. As a
result, Moody's may withdraw its rating when the pool factor drops
below 5% and the number of loans in the pool declines to less than
40 unless specific structural features allow for a monitoring of
the transaction (such as a credit enhancement floor).

Moody's has withdrawn the rating pursuant to published rating
methodologies that allow for the withdrawal of the rating if the
size of the underlying collateral pool at the time of the
withdrawal has fallen below a specified level.

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

A list of these actions including CUSIP identifiers may be found
at:

  http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF314933


TRIMARAN CLO IV: Moody's Raises Rating on Cl. B-2L Notes to 'Ba2'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Trimaran CLO IV:

U.S.$25,000,000 Class A-2L Floating Rate Notes Due December 1,
2017, Upgraded to Aaa (sf); previously on July 29, 2011 Upgraded
to Aa1 (sf)

U.S.$16,000,000 Class A-3L Floating Rate Notes Due December 1,
2017, Upgraded to Aa1 (sf); previously on July 29, 2011 Upgraded
to A1 (sf)

U.S.$15,000,000 Class B-1L Floating Rate Notes Due December 1,
2017, Upgraded to A3 (sf); previously on July 29, 2011 Upgraded to
Baa2 (sf)

U.S.$16,000,000 Class B-2L Floating Rate Notes Due December 1,
2017, Upgraded to Ba2 (sf); previously on July 29, 2011 Upgraded
to Ba3 (sf)

Moody's also affirmed the rating of the following notes:

U.S.$258,000,000 Class A-1L Floating Rate Notes Due December 1,
2017 (current outstanding balance of $175,981,594), Affirmed Aaa
(sf); previously on July 29, 2011 Upgraded to Aaa (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-1L
Notes have been paid down by approximately 31.8%, or $82.0 million
since the last rating action. Based on the latest trustee report
dated December 20, 2012, the Senior Class A, Class A, Class B-1L
and Class B-2L overcollateralization ratios are reported at
133.6%, 123.8%, 115.8% and 108.3%, respectively, versus June 2011
levels of 123.7%, 117.0%, 111.4% and 106.0%, respectively. In
addition, the trustee reported weighted average spread increased
to 4.15% from 3.61% over the same time period.

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 $263.0 million,
defaulted par of $8.4 million, a weighted average default
probability of 15.41% (implying a WARF of 2465), a weighted
average recovery rate upon default of 50.22%, and a diversity
score of 36. 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.

Trimaran CLO IV, issued in September 2005, 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% (1972)

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

Moody's Adjusted WARF + 20% (2958)

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


VENTURE XII: S&P Assigns 'BB' Rating to Class E Notes
------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
Venture XII CLO Ltd./Venture XII CLO Corp.'s $676.0 million
notes.

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

The ratings reflect S&P's view of:

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

- The transaction's credit enhancement, which is sufficient
   to withstand the defaults applicable for the supplemental
   tests (not counting excess spread), and cash flow
   structure, which can withstand the default rate projected
   by Standard & Poor's CDO Evaluator model, as assessed by
   Standard & Poor's using the assumptions and methods
   outlined in its corporate collateralized debt obligation
   criteria (see "Update To Global Methodologies And
   Assumptions For Corporate Cash Flow And Synthetic CDOs,"
   published Sept. 17, 2009).

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

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

- The asset manager's experienced management team.

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

- The transaction's reinvestment overcollateralization
   test, a failure of which will lead to the
   reclassification of a certain amount of excess interest
   proceeds into principal proceeds for the purchase of
   additional collateral.  These interest proceeds are
   available prior to paying uncapped administrative
   expenses and fees; subordinated hedge termination
   payments; collateral manager incentive fees; and
   subordinated note payments.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

    http://standardandpoorsdisclosure-17g7.com/1186.pdf

RATINGS ASSIGNED

Venture XII CLO Ltd./Venture XII CLO Corp.

Class               Rating             Amount
                                     (mil. $)

A-1                 AAA (sf)           475.00
A-X                 AAA (sf)            10.00
B-1                 AA (sf)             55.00
B-2                 AA (sf)             15.00
C-1                 A (sf)              33.00
C-2                 A (sf)              10.00
D                   BBB (sf)            36.00
E                   BB (sf)             42.00
Subordinated notes  NR                  74.00

NR--Not rated.


VIBRANT CLO: S&P Assigns 'BB' Rating on Class D Notes
------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
Vibrant CLO Ltd./Vibrant CLO Corp.'s $281.90 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 (see "Update To Global Methodologies And
   Assumptions For Corporate Cash Flow And Synthetic CDOs,"
   published Sept. 17, 2009).

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

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

- The asset manager's experienced management team.

- The timely interest and ultimate principal payments on
   the rated notes, which S&P assessed using its cash flow
   analysis and assumptions commensurate with the assigned
   ratings under various interest-rate scenarios, including
   LIBOR ranging from 0.31%-12.65%.

- 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 reinvestment test, a failure
   of which during the reinvestment period will lead to the
   reclassification of excess interest proceeds that are
   available prior to paying subordinated management fees,
   uncapped administrative expenses, and subordinated note
   payments into principal proceeds for the purchase of
   collateral assets.

          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/1181.pdf.

RATINGS ASSIGNED

Vibrant CLO Ltd./Vibrant CLO Corp.

Class                      Rating           Amount
                                          (mil. $)

A-1                        AAA (sf)         191.85
A-2                        AA (sf)           39.25
B (deferrable)             A (sf)            21.70
C (deferrable)             BBB (sf)          15.20
D (deferrable)             BB (sf)           13.90
Subordinated notes         NR                35.50

NR-Not rated.


VICTORIA FALLS: S&P Retains 'CCC-' Rating on Class D Def Notes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-1B, A-2, A-3, B-1, and B-2 notes from Victoria Falls
CLO Ltd., a U.S. collateralized loan obligation (CLO)
transaction managed by Babson Capital Management LLC.  At
the same time, S&P affirmed its ratings on the class A-1A, C
def, and D def notes.  Additionally, S&P removed its ratings
on the class A-1B, A-2, A-3, B-1, B-2, C def, and D def
notes from CreditWatch with positive implications, where it
placed them on Oct. 29, 2012 (see list).

The upgrades mainly reflect paydowns to the class A-1A, A-2,
and A-3 notes and a subsequent improvement in the credit
enhancement available to support the notes since March 2012,
when S&P last upgraded some of the notes.  Since that time,
the transaction has paid down the class A-1A, A-2, and A-3
notes by $66.6 million, $34.9 million, and $4.7 million,
respectively.  These paydowns have left the class A-1A, A-2,
and A-3 notes at 10.79%, 28.63%, and 28.63% of their
original balances, respectively.

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

   -- The class A/B O/C ratio was 155.38%, compared with a
      reported ratio of 122.97% in February 2012;

   -- The class C O/C ratio was 125.55%, compared with a
      reported ratio of 111.89% in February 2012; and

   -- The class D O/C ratio was 104.37%, compared with a
      reported ratio of 102.17% in February 2012.

"We affirmed our ratings on the class A-1A, C def, and D def
notes to reflect the availability of credit support at the
current rating levels.  Furthermore, the affirmed ratings on
the class C def and D def notes was driven by our
application of the largest obligor default test, a
supplemental stress test we introduced as part of our 2009
corporate criteria update," S&P said.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Victoria Falls CLO Ltd.

                   Rating
Class         To           From

A-1A          AAA (sf)     AAA (sf)
A-1B          AAA (sf)     AA+ (sf)/Watch Pos
A-2           AAA (sf)     AA+ (sf)/Watch Pos
A-3           AAA (sf)     AA+ (sf)/Watch Pos
B-1           AAA (sf)     AA (sf)/Watch Pos
B-2           AAA (sf)     AA (sf)/Watch Pos
C Def         BBB+ (sf)    BBB+ (sf)/Watch Pos
D Def         CCC- (sf)    CCC- (sf)/Watch Pos

TRANSACTION INFORMATION
Issuer:             Victoria Falls CLO Ltd.
Coissuer:           Victoria Falls CLO Corp.
Collateral manager: Babson Capital Management LLC
Underwriter:        Goldman Sachs & Co.
Trustee:            Wells Fargo Bank N.A.
Transaction type:   Cash flow CDO


VITALITY RE IV: S&P Assigns 'BB+' Rating to Class B Notes
----------------------------------------------------
Standard & Poor's Ratings Services said that it assigned
ratings of 'BBB+(sf)' and 'BB+(sf)' to the Class A and Class
B notes, respectively, issued by Vitality Re IV Ltd.  The
notes will cover claims payments of Health Re Inc. and
ultimately Aetna Life Insurance Co. (ALIC; A+/Stable/--)
relating to the covered insurance business to the extent
the medical benefit ratio (MBR) exceeds 102% for the Class A
notes and 96% for the Class B notes.  The MBR will be
calculated on an annual aggregate basis.

The ratings are based on the lowest of the following:

   -- the implied ratings on the ceded risk ('BBB+' for the
      Class A notes and 'BB+' for the Class B notes);

   -- the rating on ALIC ('A+'), the underlying ceding
      insurer; and

   -- the rating on the permitted investments (initially
      'AAAm', or 'Am' if the short-term U.S. sovereign
      credit rating is less than 'A-1+') that will be held
      in the collateral account (there is a separate account
      for each class of notes).

In S&P's analysis to assign the ratings, S&P relied not only
on the baseline analysis presented to them in the model, but
on the results from various sensitivity tests.  The
sensitivity tests adjusted both the claim and premium
trends, separately and collectively.

RATINGS LIST

New Ratings

Vitality Re IV Ltd.

Class A Notes                               BBB+(sf)
Class B Notes                               BB+(sf)


WACHOVIA CRE 2006-1: S&P Affirms 'CCC-' Rating on 4 Note Classes
----------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
14 classes from Wachovia CRE CDO 2006-1 Ltd., a commercial
real estate collateralized debt obligation (CRE CDO)
transaction, and removed them from CreditWatch with negative
implications.

The affirmations reflect S&P's analysis of the transaction's
liability structure and the underlying collateral's credit
characteristics based on S&P's global CDOs of pooled
structured finance assets criteria, as well as its rating
methodology And assumptions for U.S. and Canadian commercial
mortgage-backed securities (CMBS) and CMBS global property
evaluation methodology.  S&P also considered the amount of
defaulted assets in the transaction and their expected
recoveries in its analysis.

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

According to the Dec. 17, 2012, trustee report, the
transaction's collateral totaled $998.3 million (includes
future funding obligations), while the transaction's
liabilities totaled $944.7 million, down from $1.3 billion
at issuance.  The transaction's current asset pool included
the following:

   -- Fifty-five first-mortgage and senior-participation
      loans ($898.1 million, 90.0%);

   -- Three subordinate-interest loans
      ($13.6 million, 1.4%);

   -- Four CMBS tranches ($65.4 million, 6.6%); and

   -- Three real estate investment trust (REIT) securities
      ($21.3 million, 2.1%).

The trustee report noted eight defaulted loans
($81.9 million, 8.2%) as follows:

   -- The Park La Palma first-mortgage loan
      ($13.9 million, 1.4%);

   -- The Wagon Trails first-mortgage loan
      ($13.0 million, 1.3%);

   -- The Grant Park Plaza first-mortgage loan
      ($12.8 million, 1.3%);

   -- The KWI - Austin (Briarcroft & Continental) first-
      mortgage loan ($9.6 million, 1.0%);

   -- The Carmel Sands Lodge first-mortgage loan
      ($9.0 million, 0.9%);

   -- The Ashford Crossing first-mortgage loan
     ($8.8 million, 0.9%);

   -- The Capitol Plaza first-mortgage loan
     ($8.3 million, 0.8%); and

   -- The College Park Plaza (Appleton) first-mortgage loan
      ($6.4 million, 0.6%).

In addition, S&P designated the Sheraton Providence Airport
Hotel ($14.7 million, 1.5%) as credit-impaired.  According
to the September 2012 Collateral Manager Quarterly Report,
the loan is scheduled to mature in February 2013 and has no
extension options.  Furthermore, the asset is not meeting
operating expectations.

Standard & Poor's estimated a 70.7% weighted average asset-
specific recovery rate for the credit-impaired and defaulted
assets.  S&P based the recovery rates on information from
the collateral manager, special servicer, and third-party
data providers.

S&P applied asset-specific recovery rates in its analysis of
the 49 performing loans ($815.1 million, 81.6%) using
Standard & Poor's updated "Rating Methodology And
Assumptions For U.S. And Canadian CMBS," and "CMBS Global
Property Evaluation Methodology," both published Sept. 5,
2012.  S&P also considered qualitative factors such as the
loans' near-term maturities and the refinancing prospects of
the assets in the pool.

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

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 determine necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATINGS AFFIRMED AND REMOVED FROM CREDITWATCH

Wachovia CRE CDO 2006-1 Ltd.

                  Rating
Class     To             From

A-1A      BBB (sf)       BBB (sf)/Watch Neg
A-1B      BB+ (sf)       BB+ (sf)/Watch Neg
A-2A      A- (sf)        A- (sf)/Watch Neg
A-2B      BB+ (sf)       BB+ (sf)/Watch Neg
B         BB (sf)        BB (sf)/Watch Neg
C         B+ (sf)        B+ (sf)/Watch Neg
D         B (sf)         B (sf)/Watch Neg
E         B (sf)         B (sf)/Watch Neg
F         B- (sf)        B- (sf)/Watch Neg
G         CCC+ (sf)      CCC+ (sf)/Watch Neg
H         CCC- (sf)      CCC- (sf)/Watch Neg
J         CCC- (sf)      CCC- (sf)/Watch Neg
K         CCC- (sf)      CCC- (sf)/Watch Neg
L         CCC- (sf)      CCC- (sf)/Watch Neg


WAMU 2007-1: S&P Hikes Rating on Class 2A1 Notes to 'CCC'
----------------------------------------------------
Standard & Poor's Ratings Services corrected its rating on
the class 2A1 notes from Washington Mutual Mortgage Pass-
Through Certificates WMALT Series 2007-1 Trust by raising it
to 'CCC (sf)' from 'D (sf)'.  S&P also corrected its rating
on the class 2A2 notes from the same transaction by raising
it to 'CC (sf)' from 'D (sf)'.

The underlying collateral for this transaction consists of
Alternative-A (Alt-A) mortgage loans.  On Nov. 19, 2012, S&P
incorrectly lowered its ratings on these classes to 'D (sf)'
based on a loss allocation to these classes reported by
Bloomberg.  However, further research revealed that these
classes had experienced no losses.

The corrected ratings reflect S&P's analysis that the
projected credit support for these classes will remain
insufficient to cover projected losses as of the
December 2012 remittance period.

         STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

         http://standardandpoorsdisclosure-17g7.com

RATINGS CORRECTED

Washington Mutual Mortgage Pass-Through Certificates WMALT
Series 2007-1 Trust
                                 Rating

Class   CUSIP        Current     11/19/12   Pre 11/19/12
2A1     93935PAP4    CCC (sf)    D (sf)     CCC (sf)
2A2     93935PAQ2    CC (sf)     D (sf)     CC (sf)


WELLS FARGO 2011-C2: Fitch Affirms 'Bsf' Rating on $14.6MM Certs.
-----------------------------------------------------------------
Fitch Ratings has affirmed 10 classes of Wells Fargo Bank, N.A.
WF-RBS Commercial Mortgage Trust 2011-C2, commercial mortgage
pass-through certificates.

Key Rating Drivers

Affirmations are due to stable pool performance since issuance.
There have been no delinquent or specially serviced loans since
issuance. Fitch has designated two loans (7.3%) as Fitch Loans of
Concern.

As of the December 2012 distribution date, the pool's aggregate
principal balance has been reduced by 2% to $1.27 billion from
$1.3 billion at issuance. No loans have defeased since issuance.

The largest Fitch loan of concern (6.5% of the pool) is the 1412
Broadway loan, a 415,619 square foot (sf) office building in New
York City. Overall, YE 2011 net operating income (NOI) decreased
by 38.2% from issuer NOI underwritten at issuance. As a result,
the year end 2011 DSCR was 1.03x compared to 1.66x at issuance.
The decline in performance is due to an increase in expenses.
However, according to the rent roll dated Sept. 25, 2012 occupancy
has increased to 95% from 90% as of YE 2011 and the DSCR has
improved slightly to 1.07x as of 3Q'2012.

Fitch affirms the following classes as indicated:

-- $51.8 million class A-1 at 'AAAsf'; Outlook Stable;
-- $383.4 million class A-2 at 'AAAsf'; Outlook Stable;
-- $122.4 million class A-3 at 'AAAsf'; Outlook Stable;
-- $493.2 million class A-4 at 'AAAsf'; Outlook Stable;
-- IO class X-A at 'AAAsf'; Outlook Stable;
-- $39 million class B at 'AAsf'; Outlook Stable;
-- $43.9 million class C at 'Asf'; Outlook Stable;
-- $68.2 million class D at 'BBB-sf'; Outlook Stable;
-- $21.1 million class E at 'BBsf'; Outlook Stable;
-- $14.6 million class F at 'Bsf'; Outlook Stable.

Fitch does not rate classes G and X-B.


WFRBS 2013-C11: S&P Assigns Prelim. 'BB' Rating on Class E Notes
----------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to WFRBS Commercial Mortgage Trust 2013-C11's
$1.44 billion commercial mortgage pass-through certificates
series 2013-C11.

The note issuance is a commercial mortgage-backed securities
transaction backed by 82 commercial mortgage loans with an
aggregate principal balance of $1,436.3 million, secured by
the fee interest in 153 properties across 33 states.

The preliminary ratings are based on information as of
Jan. 22, 2013.  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
support provided by the transaction structure, S&P's view of
the underlying collateral's economics, the trustee-provided
liquidity, the collateral pool's relative diversity, and
S&P's overall qualitative assessment of the transaction.
Standard & Poor's determined that the collateral pool has,
on a weighted average basis, debt service coverage (DSC) of
1.85x and beginning and ending loan-to-value (LTV) ratios of
83.2% and 73.8%, respectively, based on Standard & Poor's
values.

          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/1254.pdf

PRELIMINARY RATINGS ASSIGNED

WFRBS Commercial Mortgage Trust 2013-C11

Class       Rating               Amount
                                    ($)

A-1         AAA (sf)         65,123,000
A-2         AAA (sf)        278,494,000
A-3         AAA (sf)         46,800,000
A-4         AAA (sf)        517,757,000
A-SB        AAA (sf)         97,254,000
A-S         AAA (sf)        134,656,000
X-A(i)      AAA (sf)  1,140,084,000(ii)
X-B(i)      A- (sf)     152,609,000(ii)
B           AA- (sf)         93,361,000
C           A- (sf)          59,248,000
D(i)        BBB- (sf)        46,681,000
E(i)        BB (sf)          32,317,000
F(i)        B+ (sf)          25,136,000
G(i)        NR               39,499,346

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


WHITEHORSE VI: S&P Assigns 'B' Rating on Class B-3L Notes
----------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
WhiteHorse VI Ltd./WhiteHorse VI LLC's $379.5 million
floating-rate notes.

The note issuance is a collateralized loan obligation
securitization (CLO) 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 S&P expects to
   be bankruptcy-remote.

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

- The asset manager's experienced management team.

- The timely interest and ultimate principal payments on
   the rated notes, which S&P assessed using its cash flow
   analysis and assumptions commensurate with the assigned
   ratings under various interest-rate scenarios, including
   LIBOR ranging from 0.3105%-13.8391%.

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

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

    http://standardandpoorsdisclosure-17g7.com/1185.pdf

RATINGS ASSIGNED

WhiteHorse VI Ltd./WhiteHorse VI LLC

Class                      Rating           Amount
                                          (mil. $)
A-1L                       AAA (sf)          262.5
A-2L                       AA (sf)            36.0
A-3L (deferrable)          A (sf)             36.0
B-1L (deferrable)          BBB (sf)           18.5
B-2L (deferrable)          BB- (sf)           17.5
B-3L (deferrable)          B (sf)              9.0
Subordinated notes         NR                 36.0

NR-Not rated.


WHITNEY CLO I: S&P Raises Rating on Class B-1LB Notes to BB
------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the
class A-3L, B-1LA, and B-1LB notes from Whitney CLO I Ltd.,
a collateralized loan obligation (CLO) transaction and
removed their ratings from CreditWatch, where it placed them
with positive implications on Oct. 29, 2012.  At the same
time, S&P affirmed its ratings on the class A-1L, A-1LA, A-
1LB, A-2L, A-2F, P1, and P2 notes.

The transaction is in its amortization phase and continues
to pay down the A-1LA and A-1L notes in the manner the
transaction documents specify.  Class A-1LA receives
principal payments ahead of class A-1LB, and therefore has a
lower balance, which could be paid off ahead of the class A-
1L and A-1LB notes.

After the most recent paydowns in December 2012, the class
A-1LA and class A-1L note balances have declined to 4.51%
and 23.61% of their original amounts, respectively, down
from 44.56% and 56.64% in March 2012, which S&P used for the
analysis when it last upgraded some of the notes in May
2012.

As a result of the notes' lower balance, the transaction's
overcollateralization (O/C) ratios have increased. The
trustee reported the following O/C ratios in its Dec. 20,
2012 monthly report:

   -- The senior class A O/C (measured at the class A-2
      level) ratio was 173.97%, compared with a reported
      ratio of 137.71% in the March 2012;

   -- The class A O/C ratio was 142.05%, compared with a
      reported ratio of 123.36% in March 2012;

   -- The class B-1LA O/C ratio was 121.15%, compared with a
      reported ratio of 112.36% in March 2012; and

   -- The class B-1LB O/C ratio was 111.15%, compared with a
      reported ratio of 106.56% in March 2012.

The upgrades to the A-3L, B-1LA, and B-1LB notes are a
result of an increase in their credit support.  The
affirmation of S&P's ratings on the class A-1L, A-1LA, A-
1LB, A-2F, and A-2L notes reflect the availability of credit
support at the current rating levels.  S&P affirmed the
'AA+' ratings on the class P1 and P2 notes because they are
backed by U.S. Treasury strips.

S&P's analysis also took into account that as per the
Dec. 20, 2012, monthly trustee report, 4.84% of the
underlying assets are scheduled to mature after the
transaction's maturity date.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17g-7 Disclosure Report
included in this credit rating report is available at
http://standardandpoorsdisclosure-17g7.com


RATINGs RAISED; REMOVED FROM CREDITWATCH
Whitney CLO I Ltd.
              Rating
Class     To           From
A-3L      AAA (sf)     AA (sf)/Watch Pos
B-1LA     A+ (sf)      BBB+ (sf)/Watch Pos
B-1LB     BB (sf)      B+ (sf)/Watch Pos

RATINGS AFFIRMED

Whitney CLO I Ltd.
Class                    Rating
A-1LA                    AAA (sf)
A-1L                     AAA (sf)
A-1LB                    AAA (sf)
A-2L                     AAA (sf)
A-2F                     AAA (sf)
P1                       AA+ (sf)
P2                       AA+ (sf)


* Fitch Lowers Rating on 40 Bonds in 26 CMBS Transaction to 'D'
---------------------------------------------------------------
Fitch Ratings has downgraded 40 bonds in 26 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.

Key Rating Drivers

Today's 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 affirms 60 classes currently rated 'D' in 15
transactions where all remaining classes are rated 'D' and losses
have already been incurred. Detail on the affirmations is
available in the spreadsheet described in the paragraph below.

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 40 Bonds in 26 U.S. CMBS
Transactions.'


* Moody's Takes Rating Action on $600-Mil. Subprime RMBS
--------------------------------------------------------
Moody's Investors Service has downgraded the rating on one
tranche, affirmed the ratings on 10 tranches and upgraded the
ratings on three tranches from three subprime RMBS transactions
issued by various financial institutions. The collateral backing
these transactions are subprime residential mortgage loans.

Complete rating actions are as follows:

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2007-CB6

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

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

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

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

Cl. M-1, Affirmed C (sf); previously on Mar 16, 2009 Downgraded to
C (sf)

Issuer: MASTR Asset Backed Securities Trust 2006-AM1

Cl. A-3, Upgraded to Caa2 (sf); previously on Jul 15, 2011
Downgraded to Ca (sf)

Cl. A-4, Upgraded to Caa3 (sf); previously on Jul 15, 2011
Downgraded to Ca (sf)

Cl. M-1, Affirmed C (sf); previously on Jul 15, 2011 Downgraded to
C (sf)

Cl. M-2, Affirmed C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Cl. M-3, Affirmed C (sf); previously on May 5, 2010 Downgraded to
C (sf)

Issuer: Structured Asset Investment Loan Trust 2005-8

Cl. A4, Upgraded to Ba3 (sf); previously on Apr 12, 2010
Downgraded to B3 (sf)

Cl. M1, Affirmed C (sf); previously on Apr 12, 2010 Downgraded to
C (sf)

Cl. M2, Affirmed C (sf); previously on Mar 20, 2009 Downgraded to
C (sf)

Cl. M3, Affirmed C (sf); previously on Mar 20, 2009 Downgraded to
C (sf)

RATINGS RATIONALE

The actions are a result of the recent performance of Subprime
pools originated after 2005 and reflect Moody's updated loss
expectations on these pools. The upgrades/downgrades in the
Jan. 18 rating action are a result of improving/deteriorating
performance and/or structural features resulting in lower/higher
expected losses for certain bonds than previously anticipated.

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

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

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

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

The primary sources of assumption uncertainty are Moody's central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 8.5% in December 2011 to 7.8% in December 2012.
Moody's forecasts a unemployment central range of 7.5 to 8.0 for
the 2013 year. Moody's expects housing prices to gradually rise
towards the end of 2013. Performance of RMBS continues to remain
highly dependent on servicer activity such as modification-related
principal forgiveness and interest rate reductions. Any change
resulting from servicing transfers or other policy or regulatory
change can also impact the performance of these transactions.

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF314532

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

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


* Moody's Withdraws Ratings on $122 Million Pre-2005 RMBS
---------------------------------------------------------
Moody's Investors Service has withdrawn the ratings of 93 tranches
from 18 pre-2005 RMBS transactions issued between 1996 and 2004.
The tranches are backed by pools of mortgage loans containing
fewer than 40 loans and with pool factors less than 5%.

Complete rating actions are as follows:

Issuer: ABN AMRO Mortgage Corporation, Multi-Class Pass-Through
Certificates, Series 2002-9

Cl. A-4, Withdrawn (sf); previously on Dec 19, 2002 Assigned Aaa
(sf)

Cl. A-30, Withdrawn (sf); previously on Dec 19, 2002 Assigned Aaa
(sf)

Cl. A-P, Withdrawn (sf); previously on Dec 19, 2002 Assigned Aaa
(sf)

Cl. A-X, Withdrawn (sf); previously on Apr 19, 2012 Confirmed at
Ba3 (sf)

Cl. B-1, Withdrawn (sf); previously on Apr 19, 2012 Downgraded to
Baa1 (sf)

Cl. B-2, Withdrawn (sf); previously on Apr 19, 2012 Downgraded to
Ba2 (sf)

Cl. B-3, Withdrawn (sf); previously on Apr 19, 2012 Downgraded to
B1 (sf)

Cl. M, Withdrawn (sf); previously on Apr 19, 2012 Downgraded to
Aa3 (sf)

Issuer: ABN AMRO Mortgage Corporation, Multi-Class Pass-Through
Certificates, Series 2003-4

Cl. A-4, Withdrawn (sf); previously on Dec 4, 2012 Downgraded to
Aa2 (sf)

Cl. A-22, Withdrawn (sf); previously on Dec 4, 2012 Downgraded to
A1 (sf)

Cl. A-P, Withdrawn (sf); previously on Dec 4, 2012 Downgraded to
A1 (sf)

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

Cl. M, Withdrawn (sf); previously on Dec 4, 2012 Downgraded to
Baa2 (sf)

Cl. B-1, Withdrawn (sf); previously on Dec 4, 2012 Downgraded to
B1 (sf)

Cl. B-2, Withdrawn (sf); previously on Dec 4, 2012 Downgraded to
Caa2 (sf)

Issuer: Banc of America Mortgage 2002-L Trust

Cl. 1-A-1, Withdrawn (sf); previously on May 11, 2012 Confirmed at
Ba2 (sf)

Cl. 1-A-2, Withdrawn (sf); previously on May 11, 2012 Confirmed at
Ba2 (sf)

Cl. 1-A-3, Withdrawn (sf); previously on May 11, 2012 Confirmed at
Ba2 (sf)

Cl. 2-A-1, Withdrawn (sf); previously on May 11, 2012 Confirmed at
Ba1 (sf)

Cl. 3-A-1, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to Aa3 (sf)

Cl. 2-A-P, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to B1 (sf)

Cl. 3-A-P, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to Baa2 (sf)

Cl. 2-A-2, Withdrawn (sf); previously on May 11, 2012 Confirmed at
Ba1 (sf)

Cl. 2-A-3, Withdrawn (sf); previously on May 11, 2012 Confirmed at
Ba1 (sf)

Cl. 2-A-4, Withdrawn (sf); previously on May 11, 2012 Confirmed at
Ba2 (sf)

Issuer: Banc of America Mortgage 2003-A Trust

Cl. 1-A-1, Withdrawn (sf); previously on Apr 25, 2011 Confirmed at
Aaa (sf)

Cl. 3-A-1, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to A1 (sf)

Cl. 4-A-1, Withdrawn (sf); previously on Apr 25, 2011 Confirmed at
Aaa (sf)

Cl. 2-A-1, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to Ba2 (sf)

Cl. 2-A-2, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to Ba2 (sf)

Cl. 2-A-7, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to Ba2 (sf)

Cl. 2-A-8, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to Ba2 (sf)

Cl. 2-A-9, Withdrawn (sf); previously on Apr 25, 2011 Downgraded
to B1 (sf)

Cl. 4-A-P, Withdrawn (sf); previously on Apr 25, 2011 Confirmed at
Aaa (sf)

Issuer: Banc of America Mortgage 2004-2 Trust

Cl. 5-A-1, Withdrawn (sf); previously on May 11, 2012 Downgraded
to Ba1 (sf)

Cl. 5-A-IO, Withdrawn (sf); previously on May 11, 2012 Confirmed
at Ba3 (sf)

Cl. 5-B-2, Withdrawn (sf); previously on May 11, 2012 Downgraded
to Caa3 (sf)

Cl. 5-B-3, Withdrawn (sf); previously on May 11, 2012 Downgraded
to Ca (sf)

Issuer: Bear Stearns ARM Trust 2002-11

Cl. I-A-2, Withdrawn (sf); previously on Jan 2, 2003 Assigned Aaa
(sf)

Cl. I-A-3, Withdrawn (sf); previously on Jan 2, 2003 Assigned Aaa
(sf)

Cl. I-A-1, Withdrawn (sf); previously on Jan 2, 2003 Assigned Aaa
(sf)

Cl. I-M-1, Withdrawn (sf); previously on May 6, 2011 Downgraded to
Baa1 (sf)

Cl. I-B-1, Withdrawn (sf); previously on May 6, 2011 Downgraded to
B1 (sf)

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

Cl. I-B-3, Withdrawn (sf); previously on May 6, 2011 Downgraded to
Ca (sf)

Cl. I-B-4, Withdrawn (sf); previously on May 6, 2011 Downgraded to
C (sf)

Issuer: CHL Mortgage Pass-Through Trust 2002-18

Cl. A-1, Withdrawn (sf); previously on Oct 21, 2002 Assigned Aaa
(sf)

Cl. A-8, Withdrawn (sf); previously on Oct 21, 2002 Assigned Aaa
(sf)

Cl. PO, Withdrawn (sf); previously on Oct 21, 2002 Assigned Aaa
(sf)

Cl. A-9, Withdrawn (sf); previously on Sep 1, 2004 Upgraded to Aaa
(sf)

Issuer: CHL Mortgage Pass-Through Trust 2002-21

Cl. A-1, Withdrawn (sf); previously on Apr 21, 2011 Downgraded to
A2 (sf)

Cl. A-3, Withdrawn (sf); previously on Apr 21, 2011 Downgraded to
A2 (sf)

Cl. A-PO, Withdrawn (sf); previously on Apr 21, 2011 Downgraded to
A2 (sf)

Issuer: CSFB Mortgage-Backed Pass-Through Certificates, Series
2004-AR2

Cl. VI-M-1, Withdrawn (sf); previously on May 24, 2012 Downgraded
to Baa1 (sf)

Cl. VI-M-2, Withdrawn (sf); previously on Mar 18, 2011 Downgraded
to Ca (sf)

Issuer: CWMBS, Inc. Mortgage Pass-Through Certificates, Series
2003-J12

Cl. A-1, Withdrawn (sf); previously on Jun 13, 2012 Downgraded to
B1 (sf)

Cl. X, Withdrawn (sf); previously on Jun 13, 2012 Downgraded to B3
(sf)

Issuer: Impac CMB Trust Series 2003-4

Cl. 2-A-1, Withdrawn (sf); previously on Nov 17, 2008 Downgraded
to A1 (sf)

Issuer: RFSC Series 2002-RM1 Trust

Cl. A-I-1, Withdrawn (sf); previously on May 2, 2012 Downgraded to
A3 (sf)

Cl. A-I-2, Withdrawn (sf); previously on May 2, 2012 Downgraded to
A3 (sf)

Cl. A-I-3, Withdrawn (sf); previously on May 2, 2012 Downgraded to
A3 (sf)

Cl. AP-1, Withdrawn (sf); previously on May 2, 2012 Downgraded to
A3 (sf)

Cl. AV-1, Withdrawn (sf); previously on May 2, 2012 Confirmed at
Ba3 (sf)

Cl. M-I-1, Withdrawn (sf); previously on May 2, 2012 Downgraded to
Baa1 (sf)

Cl. M-I-2, Withdrawn (sf); previously on May 2, 2012 Downgraded to
Baa3 (sf)

Cl. M-I-3, Withdrawn (sf); previously on May 2, 2012 Downgraded to
B2 (sf)

Cl. B-I-1, Withdrawn (sf); previously on Apr 22, 2011 Downgraded
to Ca (sf)

Cl. B-I-2, Withdrawn (sf); previously on Sep 1, 2010 Downgraded to
C (sf)

Issuer: WaMu Mortgage Pass-Through Certificates Series 2002-AR9

Cl. II-A, Withdrawn (sf); previously on Feb 28, 2011 Downgraded to
Ba3 (sf)

Cl. II-B-1, Withdrawn (sf); previously on Feb 28, 2011 Downgraded
to Caa3 (sf)

Cl. II-B-2, Withdrawn (sf); previously on Feb 28, 2011 Downgraded
to C (sf)

Cl. II-B-3, Withdrawn (sf); previously on Feb 28, 2011 Downgraded
to C (sf)

Cl. II-B-5, Withdrawn (sf); previously on Aug 4, 2009 Downgraded
to C (sf)

Cl. II-B-4, Withdrawn (sf); previously on Feb 28, 2011 Downgraded
to C (sf)

Issuer: Washington Mutual MSC 2003-MS6 Trust

Cl. I-A, Withdrawn (sf); previously on Jun 4, 2012 Confirmed at A2
(sf)

Cl. II-A, Withdrawn (sf); previously on Jun 4, 2012 Confirmed at
A3 (sf)

Cl. C-X, Withdrawn (sf); previously on Jun 4, 2012 Confirmed at
Ba3 (sf)

Cl. C-P, Withdrawn (sf); previously on Apr 25, 2011 Downgraded to
A3 (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2003-E Trust

Cl. A-1, Withdrawn (sf); previously on Apr 10, 2012 Downgraded to
Ba3 (sf)

Cl. A-2, Withdrawn (sf); previously on Apr 10, 2012 Downgraded to
Ba3 (sf)

Cl. A-3, Withdrawn (sf); previously on Apr 10, 2012 Downgraded to
Ba3 (sf)

Cl. A-4, Withdrawn (sf); previously on Apr 10, 2012 Downgraded to
B3 (sf)

Cl. A-WIO, Withdrawn (sf); previously on Apr 10, 2012 Confirmed at
Ba3 (sf)

Issuer: Wells Fargo Mortgage Backed Securities 2003-F Trust

Cl. A-1, Withdrawn (sf); previously on Apr 10, 2012 Confirmed at
Baa3 (sf)

Cl. B-1, Withdrawn (sf); previously on Apr 10, 2012 Confirmed at
Caa1 (sf)

Cl. B-2, Withdrawn (sf); previously on Apr 18, 2011 Downgraded to
Caa3 (sf)

Cl. B-3, Withdrawn (sf); previously on Apr 18, 2011 Downgraded to
Ca (sf)

Issuer: DLJ Mtg Acpt Corp 1996-QB

B-1, Withdrawn (sf); previously on Mar 7, 2011 Downgraded to Caa3
(sf)

Issuer: Structured Asset Sec Corp 1996-4 (Norwest)

A, Withdrawn (sf); previously on May 10, 2012 Confirmed at Aa1
(sf)

B1, Withdrawn (sf); previously on May 10, 2012 Confirmed at A1
(sf)

B2, Withdrawn (sf); previously on Mar 7, 2011 Downgraded to Caa2
(sf)

B4, Withdrawn (sf); previously on Feb 27, 2003 Downgraded to C
(sf)

B3, Withdrawn (sf); previously on Mar 7, 2011 Downgraded to Ca
(sf)

RATINGS RATIONALE

Moody's current RMBS surveillance methodologies apply to pools
with at least 40 loans and a pool factor of greater than 5%. As a
result, Moody's may withdraw its rating when the pool factor drops
below 5% and the number of loans in the pool declines to less than
40 unless specific structural features allow for a monitoring of
the transaction (such as a credit enhancement floor).

Moody's has withdrawn the rating pursuant to published rating
methodologies that allow for the withdrawal of the rating if the
size of the underlying collateral pool at the time of the
withdrawal has fallen below a specified level.

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

A list of these actions including CUSIP identifiers may be found
at http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF314585


* Moody's Places 31 Tobacco Settlements Under Review
----------------------------------------------------
Moody's Investors Service has placed under review with direction
uncertain term bonds in tobacco settlement revenue transactions.
The transactions are securitizations of payments that major
tobacco manufacturers owe to 46 states and certain territories
pursuant to the 1998 Master Settlement Agreement (MSA).

Data on the Tobacco Settlement Bonds Put On Watch Direction
Uncertain is available at:

http://www.moodys.com/viewresearchdoc.aspx?docid=PBS_SF314699

Ratings Rationale

The rating actions are a result of credit implications of the
proposed agreement announced on December 18, 2012, to settle
payment disputes for the years 2003-2012 between major tobacco
manufacturers and 17 states and two territories. The new agreement
remains subject to approval by an arbitration panel. If approved,
several provisions of the agreement will reduce cash flow to most
term bonds in the securitizations sponsored by states joining the
agreement. On a net basis, the joining states will receive only
54% of the approximately $4 billion share under dispute,
significantly less than the 100% that Moody's expected. In
addition, by setting forth a new formula for addressing future
payment disputes, the agreement suggests that similar payment
disputes and concomitant settlements at less than 100% could
continue for a long period of time, potentially for the entire
term of the bonds. These two provisions of the agreement also
indirectly impact the securitizations sponsored by the non-joining
states, because they set a precedent that their recoveries of
future disputed amounts can be less than 100% and that the payment
disputes will continue for a long period of time, both credit
negatives.

In addition, Moody's is in the process of correcting certain
errors in the cash flow models used in rating tobacco settlement
revenue bonds. Moody's expects that in some cases the correction
will have a positive credit impact on the term bonds; in other
cases the correction will likely have a slightly negative credit
impact on the bonds.

Principal Methodology

The principal methodology used in these ratings was "Moody's
Approach to Rating Tobacco Settlement Revenue Securitization"
published on May 25, 2011.

Complete ratings action as follow:

Issuer: Buckeye Tobacco Settlement Financing Authority, Tobacco
Settlement Asset-Backed Bonds, Series 2007 (State of Ohio)

Series 2007A-2-1 Senior Current Interest Turbo Term Bonds, B3 (sf)
Placed Under Review Direction Uncertain; previously on Sep 8, 2011
Downgraded to B3 (sf)

Series 2007A-2-2 Senior Current Interest Turbo Term Bonds, B3 (sf)
Placed Under Review Direction Uncertain; previously on Sep 8, 2011
Downgraded to B3 (sf)

Series 2007A-2-3 Senior Current Interest Turbo Term Bonds, B3 (sf)
Placed Under Review Direction Uncertain; previously on Sep 8, 2011
Downgraded to B3 (sf)

Series 2007A-2-4 Senior Current Interest Turbo Term Bonds, B3 (sf)
Placed Under Review Direction Uncertain; previously on Sep 8, 2011
Downgraded to B3 (sf)

Series 2007A-2-5 Senior Current Interest Turbo Term Bonds, B3 (sf)
Placed Under Review Direction Uncertain; previously on Sep 8, 2011
Downgraded to B3 (sf)

Series 2007A-2-6 Senior Current Interest Turbo Term Bonds, B3 (sf)
Placed Under Review Direction Uncertain; previously on Sep 8, 2011
Downgraded to B3 (sf)

Series 2007A-2-7 Senior Current Interest Turbo Term Bonds, B3 (sf)
Placed Under Review Direction Uncertain; previously on Sep 8, 2011
Downgraded to B3 (sf)

Series 2007-A-3 Senior Convertible Capital Appreciation Turbo Term
Bonds, B3 (sf) Placed Under Review Direction Uncertain; previously
on Sep 8, 2011 Downgraded to B3 (sf)

Issuer: California County Tobacco Securitization Agency (Los
Angeles County Securitization Corporation) Series 2006A
Convertible Turbo Bonds

Cl. 2006A-1, B2 (sf) Placed Under Review Direction Uncertain;
previously on Jun 15, 2012 Downgraded to B2 (sf)

Cl. 2006A-2, B2 (sf) Placed Under Review Direction Uncertain;
previously on Jun 15, 2012 Downgraded to B2 (sf)

Cl. 2006A-3, B2 (sf) Placed Under Review Direction Uncertain;
previously on Jun 15, 2012 Downgraded to B2 (sf)

Cl. 2006A-4, B2 (sf) Placed Under Review Direction Uncertain;
previously on Jun 15, 2012 Downgraded to B2 (sf)

Cl. 2006A-5, B2 (sf) Placed Under Review Direction Uncertain;
previously on Jun 15, 2012 Downgraded to B2 (sf)

Issuer: California County Tobacco Securitization Agency (Merced
County Tobacco Funding Corporation) - Tobacco Settlement Asset-
Backed Refunding Bonds

2005A-1, Ba2 (sf) Placed Under Review Direction Uncertain;
previously on Jun 15, 2012 Upgraded to Ba2 (sf)

2005A-2, B1 (sf) Placed Under Review Direction Uncertain;
previously on Jun 15, 2012 Upgraded to B1 (sf)

2005A-3, B2 (sf) Placed Under Review Direction Uncertain;
previously on Jun 15, 2012 Upgraded to B2 (sf)

Issuer: California Statewide Financing Authority (Pooled Tobacco
Securitization Program) , Series 2002

Ser. 2002A Term Bonds 1, Baa3 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Upgraded to Baa3 (sf)

Ser. 2002A Term Bonds 2, Ba3 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Upgraded to Ba3 (sf)

Ser. 2002A Term Bonds 3, Ba3 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Upgraded to Ba3 (sf)

Ser. 2002B Term Bonds 1, Baa3 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Upgraded to Baa3 (sf)

Ser. 2002B Term Bonds 2, Ba3 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Upgraded to Ba3 (sf)

Ser. 2002B Term Bonds 3, Ba3 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Upgraded to Ba3 (sf)

Issuer: Children's Trust, Series 2002

Term Bond 1, Baa3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Confirmed at Baa3 (sf)

Term Bond 2, Baa3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Confirmed at Baa3 (sf)

Term Bond 3, Baa3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Confirmed at Baa3 (sf)

Issuer: City of San Diego Tobacco Settlement Revenue Funding
Corporation

Term Bonds, Baa1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Issuer: District of Columbia Tobacco Settlement Financing
Corporation, Series 2001

Term Bond 1, A1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to A1 (sf)

Term Bond 2, Baa1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Term Bond 3, Baa1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Issuer: Educational Enhancement Funding Corporation - Tobacco
Settlement Asset-Backed Bonds, Series 2002A and 2002B

Ser. 2002A Taxable Term Bond 1, A1 (sf) Placed Under Review
Direction Uncertain; previously on Sep 8, 2011 Upgraded to A1 (sf)

Ser. 2002 Tax-Exempt Term Bond 2, A3 (sf) Placed Under Review
Direction Uncertain; previously on Sep 8, 2011 Upgraded to A3 (sf)

Issuer: Golden State Tobacco Securitization Corporation (2007
Indenture)

TT Bds A-1-1, B3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B3 (sf)

TT Bds A-1-2, B3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B3 (sf)

TT Bds A-1-3, B3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B3 (sf)

TT Bds A-1-4, B3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B3 (sf)

CVT Bds A-2, B3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B3 (sf)

Issuer: Michigan Tobacco Settlement Finance Authority, Tobacco
Settlement Asset-Backed Bonds, Series 2006 and 2008

Series 2006A Fixed Rate Turbo Term Bonds, B2 (sf) Placed Under
Review Direction Uncertain; previously on Sep 8, 2011 Downgraded
to B2 (sf)

Series 2008A Current Interest Turbo Term Bonds, B2 (sf) Placed
Under Review Direction Uncertain; previously on Sep 8, 2011
Downgraded to B2 (sf)

Issuer: New York Counties Tobacco Trust I, Series 2000

Term Bond 1, A1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to A1 (sf)

Flex. Amort. Term Bond 2, A1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to A1 (sf)

Flex. Amort. Term Bond 3, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Flex. Amort. Term Bond 4, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Issuer: New York Counties Tobacco Trust II, Series 2001

Super Sinker Term Bond 1, A3 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to A3 (sf)

Super Sinker Term Bond 2, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Super Sinker Term Bond 3, Baa2 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa2 (sf)

Issuer: New York Counties Tobacco Trust III, Series 2003

2003 TTB-2, A1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to A1 (sf)

2003 TTB-3, A3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to A3 (sf)

Issuer: Niagara Tobacco Asset Securitization Corporation, Series
2000

Term 3, Baa2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to Baa2 (sf)

Term 4, Baa3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Confirmed at Baa3 (sf)

Term 5, Baa3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Confirmed at Baa3 (sf)

Issuer: Northern Tobacco Securitization Corporation, Series 2006

2006-A-1, Ba1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to Ba1 (sf)

2006-A-2, B2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B2 (sf)

2006-A-3, B2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B2 (sf)

Issuer: Rensselaer Tobacco Asset Securitization Corporation,
Series A

Super Sinker Term Bond, A3 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to A3 (sf)

Super Sinker Term Bond 2, A3 Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to A3

Super Sinker Term Bond 3, A3 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to A3 (sf)

Issuer: Rockland Tobacco Asset Securitization Corporation, Series
2001

Super Sinker Term Bond 1, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Super Sinker Term Bond 2, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Super Sinker Term Bond 3, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Issuer: The California County Tobacco Securitization Agency (
Fresno County Tobacco Funding Corporation), Series 2002

Ser. 2002 Term Bonds 1, A3 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to A3 (sf)

Ser. 2002 Term Bonds 2, A3 (sf) Placed Under Review Direction
Uncertain; previously on May 14, 2012 Upgraded to A3 (sf)

Ser. 2002 Term Bonds 3, Baa2 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa2 (sf)

Ser. 2002 Term Bond 4, Baa3 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Confirmed at Baa3 (sf)

Issuer: The California County Tobacco Securitization Agency
(Alameda County Tobacco Asset Securitization Corporation), Series
2002

Ser. 2002 Turbo Bond 1, A2 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Downgraded to A2 (sf)

Ser. 2002 Turbo Bond 2, Baa2 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Downgraded to Baa2 (sf)

Ser. 2002 Turbo Bond 3, Ba1 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Downgraded to Ba1 (sf)

Ser. 2002 Turbo Bond 4, Ba2 (sf) Placed Under Review Direction
Uncertain; previously on Jun 15, 2012 Downgraded to Ba2 (sf)

Issuer: The California County Tobacco Securitization Agency
(Stanislaus County Tobacco Funding Corporation), Series 2002

Ser. 2002A Term Bond 1, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Ser. 2002A Term Bond 2, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Issuer: Tobacco Securitization Authority of Southern California
(San Diego)

2006A-1-1, B1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B1 (sf)

2006A-1-2, B3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B3 (sf)

2006A-1-3, B2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B2 (sf)

Issuer: Tobacco Settlement Authority (Iowa), Series 2005

2005A TNs, Ba1 (sf) Placed Under Review Direction Uncertain;
previously on Dec 11, 2012 Upgraded to Ba1 (sf)

2005B TNs, B2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B2 (sf)

2005-C1 TNs, B2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B2 (sf)

2005-C2 TNs, B2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B2 (sf)

2005-C3 TNs, B2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B2 (sf)

Issuer: Tobacco Securitization Authority of Northern California
(Sacramento County)

2005A-1-1, B3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B3 (sf)

2005A-1-2, Caa1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to Caa1 (sf)

2005A-1-3, B3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B3 (sf)

2005A-2, Caa1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to Caa1 (sf)

Issuer: Tobacco Settlement Authority (Washington), Series 2002

Ser. 2002 Term Bond 8, A3 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to A3 (sf)

Ser. 2002 Term Bond 9, Baa1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Upgraded to Baa1 (sf)

Issuer: Tobacco Settlement Finance Authority (Taxable Tobacco
Settlement Asset-Backed Bonds, Series 2007) West Virginia

2007A TT CIBS, B2 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B2 (sf)

Issuer: Tobacco Settlement Financing Corporation (New Jersey),
Series 2007-1

2007-1A Term Bond 1, B1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Downgraded to B1 (sf)

2007-1A Term Bond 2, B1 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Downgraded to B1 (sf)

2007-1A Term Bond 3, B2 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Downgraded to B2 (sf)

2007-1A Term Bond 4, B2 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Downgraded to B2 (sf)

2007-1A Term Bond 5, B2 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Downgraded to B2 (sf)

Issuer: Tobacco Settlement Financing Corporation (Virgin Islands),
Series 2001

Term Bond 1, A1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to A1 (sf)

Term Bond 2, A3 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Upgraded to A3 (sf)

Issuer: Tobacco Settlement Financing Corporation, Series 2001A and
2001B

Ser. 2001B-1 Tax-Exempt Term Bond, A1 (sf) Placed Under Review
Direction Uncertain; previously on Sep 8, 2011 Upgraded to A1 (sf)

Ser. 2001B-2 Tax-Exempt Term Bond, A3 (sf) Placed Under Review
Direction Uncertain; previously on Sep 8, 2011 Upgraded to A3 (sf)

Issuer: Tobacco Settlement Financing Corporation, Series 2002A and
2002B

Ser. 2002A Tax-Exempt Term Bond 1, Baa1 (sf) Placed Under Review
Direction Uncertain; previously on Jul 9, 2012 Confirmed at Baa1
(sf)

Ser. 2002A Tax-Exempt Term Bond 2, Baa3 (sf) Placed Under Review
Direction Uncertain; previously on Jan 24, 2012 Upgraded to Baa3
(sf)

Ser. 2002A Tax-Exempt Term Bond 3, Ba1 (sf) Placed Under Review
Direction Uncertain; previously on Jan 24, 2012 Upgraded to Ba1
(sf)

Issuer: Tobacco Settlement Financing Corporation, Series 2007

2007A Turbo Term Bonds, B2 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Downgraded to B2 (sf)

2007B-1 Turbo Term Bonds, B2 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Downgraded to B2 (sf)

2007B-2 Turbo Term Bonds, B2 (sf) Placed Under Review Direction
Uncertain; previously on Sep 8, 2011 Downgraded to B2 (sf)

Issuer: Ulster Tobacco Asset Securitization Corporation, Series
2001

Term CI Bond-1, B1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B1 (sf)

Term CI Bond-2, B1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B1 (sf)

Term CCA Bond-1, B1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B1 (sf)

Term CCA Bond-2, B1 (sf) Placed Under Review Direction Uncertain;
previously on Sep 8, 2011 Downgraded to B1 (sf)


* S&P Withdraws Ratings on 33 Note Classes
--------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on
33 classes of notes from nine collateralized loan obligation
(CLO) transactions, one collateralized bond obligation (CBO)
transaction, four collateralized debt obligation (CDO)
transactions backed in part by residential mortgage-backed
securities, four CDO transactions backed by commercial
mortgage-backed securities, two CDO transactions of mainly
mezzanine tranches of corporate backed CDOs, and one CDO
transaction backed by a pool of trust preferred securities.

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

NYLIM Flatiron CLO 2004-1 Ltd. redeemed its classes in full
after providing notice to S&P that the issuers directed
optional redemptions.

In addition, S&P withdrew its ratings on the Class A-2, B,
and C notes from 280 Funding I following redemption in full
of these classes in connection with an optional redemption
of the notes.  S&P withdrew its rating on the Class A-1
notes from this transaction after receiving notice that the
notes were canceled.

Lastly, S&P withdrew its ratings on the Class C, E, and F
notes from Tricadia CDO 2006-5 Ltd. after they were paid in
full following an optional redemption of the notes, and it
withdrew its rating on the Class B and D notes after
receiving notice that the notes were canceled.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

If applicable, the Standard & Poor's 17g-7 Disclosure
Reports included in this credit rating report are available
at http://standardandpoorsdisclosure-17g7.com

RATINGS WITHDRAWN

280 Funding I

                            Rating
Class               To                  From

A-1                 NR                  AAA (sf)
A-2                 NR                  AAA (sf)
B                   NR                  AA- (sf)
C                   NR                  A+ (sf)

Anthracite CDO I Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)

Anthracite CDO II Ltd.
                            Rating
Class               To                  From
B                   NR                  A+ (sf)
B-FL                NR                  A+ (sf)


Carlyle Modena CLO Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)
B revolve           NR                  AAA (sf)

Carlyle Vantage CLO Ltd.
                            Rating
Class               To                  From
A2                  NR                  AAA (sf)

C-BASS CBO IX Ltd.
                            Rating
Class               To                  From
A-1                 NR                  BB+ (sf)

Crest Dartmouth Street 2003-1 Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)

Denali Capital CLO IV Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)

Diamond Lake CLO Ltd.
                            Rating
Class               To                  From
X                   NR                  AAA (sf)

Dryden XXIII Senior Loan Fund
                            Rating
Class               To                  From
X                   NR                  AAA (sf)

Glacier Funding CDO I Ltd.
                            Rating
Class               To                  From
A-1                 NR                  A+ (sf)

Gulf Stream-Compass CLO 2002-I Ltd.
                            Rating
Class               To                  From
D                   NR                  BB+ (sf)

Gulf Stream-Compass CLO 2004-1 Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)

Helios Series I Multi Asset CBO Ltd.
                            Rating
Class               To                  From
A                   NR                  BB- (sf)

N-Star Real Estate CDO I Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)

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

Peritus I CDO Ltd.
                             Rating
Class               To                  From
C                   NR                  B+ (sf)

Sandstone CDO Ltd.
                            Rating
Class               To                  From
C                   NR                  BB (sf)

Trapeza CDO I LLC
                             Rating
Class               To                  From
A-1                 NR                  AA- (sf)
A-2                 NR                  AA- (sf)

Tricadia CDO 2003-1 Ltd.
                            Rating
Class               To                  From
A-1LA               NR                  A+ (sf)

Tricadia CDO 2006-5 Ltd.
                            Rating
Class               To                  From
B                   NR                  B (sf)
C                   NR                  CC (sf)
D                   NR                  D (sf)
E                   NR                  D (sf)
F                   NR                  D (sf)

NR--Not rated.


                            *********

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., Washington, D.C., 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 2013.  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 $975 for 6 months delivered via
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are $25 each.  For subscription information, contact Peter A.
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                  *** End of Transmission ***