TCR_Public/130217.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, February 17, 2013, Vol. 17, No. 47

                            Headlines

ALESCO PREFERRED: S&P Lowers Rating on Class B Notes to 'D'
ALPINE SECURITIZATION: DBRS Rates $24.63-Mil. Facility 'B(sf)'
BABSON 2007-II: Moody's Keeps 'Ba2' Rating on Class E Notes
BANC OF AMERICA 2006-5: S&P Cuts Rating on 3 Note Classes to 'D'
BEAR STEARNS 2004-PWR6: S&P Lowers Rating on Class N Notes to 'D'

BUSINESS LOAN 2004-A: S&P Lowers Rating on Class C Notes to 'B+'
CARLYLE GLOBAL: S&P Assigns 'BB' Rating to Class D Notes
CENT CLO: S&P Assigns Preliminary BB Rating to Class D Notes
COMM 2000-C1: S&P Raises Rating on Class G Notes to 'B(sf)'
COMM 2003-LNB1: Moody's Affirms 'C' Rating on 3 Cert. Classes

COMMERCIAL MORTGAGE 1998-C1: Moody's Keeps Ratings on 3 Certs
COMMODORE CDO I: Fitch Affirms 'C' Ratings on Two Note Classes
CREDIT SUISSE 2001-CP4: S&P Lowers Ratin on Class E Notes to 'D'
CSAM FUNDING IV: Moody's Affirms 'Ba1' Rating on 2 Note Classes
FRASER SULLIVAN I: Moody's Affirms Ba3 Ratings on 2 Note Classes

FREMF 2012-K705: Moody's Lowers Rating on X2 Certs to 'Ba3'
GE CAPITAL 2007-C1: DBRS Assigns 'BB(sf)' Rating to A-MLF Certs
GMAC COMMERCIAL 2002-C3: Moody's Lowers Class X-1 Certs to 'Caa2'
GREENWICH CAPITAL: Fitch Affirms 'D' Rating on Class M Certs
GS MORTGAGE 2012-GC6: Moody's Affirms 'B2' Rating on Class F Certs

GS MORTGAGE 2013-GC10: S&P Assigns 'BB' Rating to Class E Notes
INDEPENDENCE I CDO: Fitch Affirms 'D' Rating on Class B Notes
INSTITUTIONAL MORTGAGE 2013-3: DBRS Rates Cl. F Securities 'BB'
JP MORGAN 2006-FL1: S&P Cuts Rating on Class K Notes to 'D'
JP MORGAN 2007-CIBC20: Fitch Lowers Rating on Class N Notes to 'D'

KINGSLAND III: S&P Affirms 'BB' Rating on 2 Note Classes
LB MULTIFAMILY 1991-4: Moody's Keeps Caa1 Rating on Cl. A-2 Certs
LB-UBS 2002-C4: S&P Lowers Rating on Class M Notes to 'D'
LB-UBS 2002-C7: S&P Lowers Rating on Class Q Notes to 'D'
LONGFELLOW PLACE: S&P Assigns 'BB' Rating to Class E Notes

MERRILL LYNCH 2002-CA: DBRS Hikes Rating on K Debt From BB(high)
MERRILL LYNCH 2002-MW1: Expected Losses Cue Moody's Downgrades
MIDOCEAN CREDIT: S&P Assigns 'BB' Rating on Class D Notes
ML-CFC 2006-3: Fitch Cuts Ratings on Five Note Classes
MORGAN STANLEY 2006-9: S&P Cuts Rating on Subordinate Notes to 'D'

NATIONSLINK FUNDING: Moody's Keeps 'Ba3' Rating on Class X Certs
OFSI FUND V: S&P Assigns 'B' Rating to Class B-3L Notes
PACIFIC COAST: Moody's Hikes Rating on $450-Mil. Notes to 'B2'
PNC MORTGAGE 2000-C2: Moody's Cuts Rating on Cl. X Cert to Caa2
PNC MORTGAGE 2001-C1: S&P Lowers Rating on Class J Notes to 'D'

PNC MORTGAGE 2011-C1: Moody's Cuts Rating on Cl. J Certs to 'Caa3'
REALT 2006-1: Moody's Affirms Ratings on 18 CMBS Classes
RFC CDO I: Fitch Lowers Rating on Class C Notes to 'C'
SAGAMORE CLO: Moody's Lifts Rating on $16-Mil. Notes to 'Ba2'
SEAWALL 2006-4: Moody's Retains C Rating on 3 Certificate Classes

SLM STUDENT 2004-1: Fitch Affirms 'BB' Student Loan Note Rating
SLM STUDENT 2004-3: Fitch Affirms 'BB' Student Loan Note Rating
SUTTER CBO: S&P Lowers Rating on Class B-2 Notes to 'D(sf)'
TRAVIS COUNTY: Moody's Affirms Ratings on 2002A & 2002C Bonds
UBS-BARCLAYS 2013-C5: Fitch Assigns 'B' Rating to Class F Notes

UNITED ARTISTS: Moody's Keeps 'B3' Rating on Series 1995-A Certs
VERITAS CLO I: Moody's Affirms 'B3' Rating on $8MM Class E Notes
WFRBS 2013-C11: Fitch Assigns 'B' to Class F Certificates
WFRBS 2013-C11: S&P Assigns 'B+' Rating on Class F Notes

* Fitch Says U.S. Subprime Auto ABS Could See Poorer Underwriting
* Moody's Takes Action on 3 RMBS Deals Backed by Assured Guaranty
* S&P Lowers Rating on 4 Tranches from 3 CDO Transactions
* S&P Lowers Rating on 16 Classes From 43 US CDO Transactions
* S&P Lowers Ratings on 6 Classes From 3 U.S. CMBS Transactions

* S&P Lowers Ratings on 43 Classes From 24 US RMBS Transactions
* S&P Lowers Ratings on 33 Classes From 7 US RMBS Transactions
* S&P Lowers Ratings on 217 Classes From 66 U.S. RMBS Deals
* S&P Lowers Rating on 614 Classes From 120 US RMBS Transactions
* S&P Cuts Ratings on 95 Classes From 15 US RMBS Transactions

* U.S. CMBS Delinquencies Begin Lower in 2013, Fitch Says

                            *********


ALESCO PREFERRED: S&P Lowers Rating on Class B Notes to 'D'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
from 'CCC- (sf)' on the class B notes from Alesco Preferred
Funding VII Ltd., a trust preferred collateralized debt obligation
transaction backed predominantly by bank trust preferred
securities.

According to the trustee note valuation report dated Dec. 24,
2012, the transaction missed the interest payment on the
nondeferrable class B notes.  Therefore, S&P lowered its rating on
the class B notes to 'D (sf)' according to its criteria.

          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

RATING LOWERED

Alesco Preferred Funding VII Ltd.
                            Rating
Class               To                  From
B                   D (sf)               CCC- (sf)


ALPINE SECURITIZATION: DBRS Rates $24.63-Mil. Facility 'B(sf)'
--------------------------------------------------------------
DBRS, Inc. has confirmed the rating of R-1 (high) (sf) for the
Commercial Paper ("CP") issued by Alpine Securitization Corp.
("Alpine"), an asset-backed commercial paper ("ABCP") vehicle
administered by Credit Suisse, New York branch.  In addition, DBRS
has confirmed the ratings and revised the tranche sizes of the
aggregate liquidity facilities ("the Liquidity") based on the June
30, 2012, reported portfolio provided by Credit Suisse, the
administrator of Alpine.

The $10,341,739,169 aggregate liquidity facilities as of June 30,
2012, are tranched as follows:

- $ 10,039,708,980 rated AAA (sf)
- $ 64,757,890 rated AA (sf)
- $ 73,859,695 rated A (sf)
- $ 54,858,311 rated BBB (sf)
- $ 24,627,804 rated BB (sf)
- $ 73,626,844 rated B (sf)
- $ 10,299,645 unrated (sf)

The CP rating reflects the AAA credit quality of Alpine's asset
portfolio.  The updated credit quality aspect of the CP rating is
based on both the portfolio of assets and the available program-
wide credit enhancement ("PWCE").  The rationale for the CP rating
is based on the updated AAA credit quality assessment as well as
DBRS's prior and ongoing review of legal, operational and
liquidity risks associated with Alpine's overall risk profile.

The ratings assigned to the Liquidity reflect the credit quality
of Alpine's asset portfolio based on an analysis that assesses
each transaction to a term standard.  The tranche sizes are
expected to vary each month based on reported changes in portfolio
composition.

For Alpine, both the CP and the Liquidity ratings use DBRS's
simulation methodology, which was developed to analyze diverse
ABCP conduit portfolios.  This analysis uses the DBRS Diversity
Model, with adjustments to reflect the unique structure of an ABCP
conduit and its underlying assets.  DBRS determines attachment
points for risk based on an analysis of the portfolio and models
the portfolio based on key inputs such as asset ratings, asset
tenors and recovery rates.  The attachment points determine the
portion of the exposure rated AAA, AA, A through B, as well as
unrated.


BABSON 2007-II: Moody's Keeps 'Ba2' Rating on Class E Notes
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Babson Mid-Market CLO Ltd. 2007-II:

USD23,000,000 Class B Senior Notes Due April 15, 2021, Upgraded
to Aaa (sf); previously on October 25, 2011 Upgraded to Aa2
(sf);

USD27,000,000 Class C Deferrable Mezzanine Notes Due April 15,
2021, Upgraded to A1 (sf); previously on October 25, 2011
Upgraded to A2 (sf);

USD5,000,000 Combination Notes Due April 15, 2021 (current rated
balance of $2,192,451), Upgraded to A2 (sf); previously on
October 25, 2011 Upgraded to A3 (sf).

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

USD249,600,000 Class A-1 Senior Notes Due April 15, 2021
(current outstanding balance of $241,436,339), Affirmed Aaa
(sf); previously on October 25, 2011 Upgraded to Aaa (sf);

USD40,000,000 Class A-2R Senior Revolving Notes Due April 15,
2021 (current outstanding balance of $38,547,810), Affirmed Aaa
(sf); previously on May 12, 2011 Upgraded to Aaa (sf);

USD4,400,000 Class A-2B Senior Notes Due April 15, 2021,
Affirmed Aaa (sf); previously on October 25, 2011 Upgraded to
Aaa (sf);

USD18,750,000 Class D Deferrable Mezzanine Notes Due April 15,
2021, Affirmed Baa2 (sf); previously on October 25, 2011
Upgraded to Baa2 (sf);

USD15,500,000 Class E Deferrable Mezzanine Notes Due April 15,
2021, Affirmed Ba2 (sf); previously on October 25, 2011 Upgraded
to Ba2 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes
reflect the benefit of the short period of time remaining before
the end of the deal's reinvestment period in April 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 a lower WARF level compared to the
level assumed at the last rating action in October 2011. Moody's
modeled a WARF of 2590 compared to 3311 at the time of the last
rating action. Notwithstanding the improvement in the WARF
calculation, Moody's notes that the amount of defaulted par has
increased from $4.8 million to $8.8 million 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 $399.5 million,
defaulted par of $8.8 million, a weighted average default
probability of 18.16% (implying a WARF of 2590), a weighted
average recovery rate upon default of 50.21%, and a diversity
score of 74. 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.

Babson Mid-Market CLO Ltd. 2007-II, issued in April 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

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

Moody's Adjusted WARF -- 20% (2072)

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

Combination Notes: +2

Moody's Adjusted WARF + 20% (3107)

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

Combination Notes: -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) Exposure to credit estimates: The deal is exposed to a number
of securities whose default probabilities are assessed through
credit estimates. In the event that Moody's is not provided the
necessary information to update the credit estimates in a timely
fashion, the transaction may be impacted by any default
probability adjustments Moody's may assume in lieu of updated
credit estimates.


BANC OF AMERICA 2006-5: S&P Cuts Rating on 3 Note Classes to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes of commercial mortgage pass-through certificates from Banc
of America Commercial Mortgage Trust 2006-5, a U.S. commercial
mortgage-backed securities (CMBS) transaction.  In addition, S&P
affirmed its 'AAA (sf)' ratings on seven other classes from the
same transaction, including the ratings on the interest-only (IO)
classes.

S&P's rating actions follow its analysis of the transaction
primarily using its criteria for rating U.S and Canadian CMBS.
S&P's analysis included a review of the credit characteristics of
all of the assets in the pool, the transaction structure, and the
liquidity available to the trust.

The downgrades reflect credit support erosion that S&P anticipates
will occur upon the resolution of the 14 assets ($359.1 million,
18.4%) currently with the special servicer (LNR Partners Inc.).
Based solely on S&P's valuation of the specially serviced assets,
S&P expects the trust to incur losses approximating 7.6% of the
original outstanding trust balance upon the resolution or
liquidation of these assets.  To date, the trust has incurred
losses totaling $74.7 million, or 3.3% of the original outstanding
trust balance.

S&P's rating actions also considered the monthly interest
shortfalls that are affecting the trust.  S&P lowered its ratings
to 'D (sf)' on the class B, C, and D certificates because S&P
expects interest shortfalls to continue and it believes the
accumulated interest shortfalls will remain outstanding for the
foreseeable future.

As of the Jan. 10, 2013, trustee remittance report, the trust
experienced monthly interest shortfalls totaling $928,406
primarily related to appraisal subordinate entitlement reduction
amounts of $843,084 and special servicing fees of $78,687.  Total
interest shortfalls were offset by yield maintenance penalties of
$6,537 in this period.  The interest shortfalls affected all
classes subordinate to and including class A-J. Classes B through
H have experienced cumulative interest shortfalls between three
and 33 months.

The affirmations of the principal and interest certificates
reflect S&P's expectation that the available credit enhancement
for these classes will be within S&P's estimate of the necessary
credit enhancement required for the current outstanding ratings.
The affirmed ratings on these classes also reflect the credit
characteristics and performance of the remaining loans, as well as
the transaction-level changes.

The affirmations of the interest-only (IO) certificates reflect
S&P's current criteria for rating IO securities.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Banc of America Commercial Mortgage Trust 2006-5
              Rating                        Credit
Class      To          From        enhancement (%)
A-M        BBB- (sf)   BBB+ (sf)             19.15
A-J        CCC- (sf)   BB- (sf)               9.96
B          D (sf)      B- (sf)                7.52
C          D (sf)      CCC (sf)               6.22
D          D (sf)      CCC- (sf)              4.79

RATINGS AFFIRMED

Banc of America Commercial Mortgage Trust 2006-5
Class      Rating           Credit enhancement (%)
A-2        AAA (sf)                          30.63
A-3        AAA (sf)                          30.63
A-AB       AAA (sf)                          30.63
A-4        AAA (sf)                          30.63
A-1A       AAA (sf)                          30.63
XP         AAA (sf)                            N/A
XC         AAA (sf)                            N/A

N/A-Not applicable.


BEAR STEARNS 2004-PWR6: S&P Lowers Rating on Class N Notes to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
classes of commercial mortgage pass-through certificates from Bear
Stearns Commercial Mortgage Securities Trust 2004-PWR6, a
commercial mortgage-backed securities (CMBS) transaction, due to
interest shortfalls.

"The downgrades reflect current and potential interest shortfalls.
We lowered our rating on class N to 'D (sf)' because of
accumulated interest shortfalls that have been outstanding for 14
months.  We expect these interest shortfalls to remain outstanding
for the foreseeable future.  We lowered our rating on class M to
'CCC- (sf)' to reflect reduced liquidity support resulting from
the interest shortfalls that are affecting the trust.  The
interest shortfalls resulted primarily from ASER amounts ($38,763)
related to the three ($15.0 million, 2.0%) assets that are
currently with the special servicer, C-III Asset Management LLC.
As of the Jan. 11, 2013, trustee remittance report, appraisal
reduction amounts (ARAs) totaling $8.3 million were in effect for
the three specially serviced assets.  The current reported
interest shortfalls totaled $36,491 and have affected all of the
classes subordinate to and including class N," S&P said.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED

Bear Stearns Commercial Mortgage Securities Trust 2004-PWR6
Commercial mortgage pass-through certificates
                                           Reported
         Rating           Credit       Interest shortfalls
Class  To        From  enhancement(%)  Current  Accumulated
M      CCC- (sf) B (sf)     1.70
N      D (sf)    CCC+ (sf)  1.17         2,164   94,656


BUSINESS LOAN 2004-A: S&P Lowers Rating on Class C Notes to 'B+'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A, B, and C notes from Business Loan Express Business Loan
Backed Notes Series 2005-A.  At the same time S&P affirmed its
ratings on the class A, B, and C notes from Business Loan Express
Business Loan Backed Notes Series 2004-A.  The two transactions
are ABS transactions collateralized primarily by a pool of small
business development loans not insured or guaranteed by any
governmental agency.

The downgrades of the series 2005-A class A, B, and C notes
reflect S&P's opinion of diminished credit enhancement to the
notes.  The current spread account balance available to the notes
is now zero, failing to meet the specified spread account
requirement of $6.74 million.  The lack of a current spread
account balance has had a direct impact on the class B and C notes
as they both now have shortfalls on their carry-forward principal
amount.  Since S&P's rating action in June 2011, the cumulative
net loss for the portfolio has increased from $19.8 million to
$30.2 million.

The affirmations of the series 2004-A class A, B, and C notes
reflect S&P's opinion of the sufficient credit support available
to the notes at the current rating levels.  Since S&P's rating
action in June 2011, the spread account balance has increased to
$5.54 million, but it still remains short of the current specified
account requirement of $7.95 million.  The series 2004-A
transaction has also benefited from paydowns to the notes, as the
class A, B, and C notes have combined to receive over $9.4 million
since S&P's June 2011 rating action.

Standard & Poor's will continue to review whether, in its view,
the rating currently assigned to the notes remains consistent with
the credit enhancement available to support them and take rating
actions 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 Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com

RATING ACTIONS

Business Loan Express Business Loan Backed Notes
Series 2005-A
                   Rating
Class         To           From
A             BBB+ (sf)    A+ (sf)
B             BB+ (sf)     BBB+ (sf)
C             B+ (sf)      BB+ (sf)

RATINGS AFFIRMED

Business Loan Express Business Loan Backed Notes
Series 2004-A

Class                  Rating
A                      AA+ (sf)
B                      A- (sf)
C                      BBB- (sf)



CARLYLE GLOBAL: S&P Assigns 'BB' Rating to Class D Notes
--------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Carlyle
Global Market Strategies CLO 2013-1 Ltd./Carlyle Global Market
Strategies CLO 2013-1 LLC's $542.4 million floating- and fixed-
rate notes.

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

The ratings reflect S&P's view of:

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

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

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

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

   -- The collateral manager's experienced management team.

   -- S&P's projections regarding the timely interest and ultimate
      principal payments on the rated notes, which 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%-11.57%.

   -- The transaction's overcollateralization and interest
      coverage tests, a failure of which would 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/1301.pdf

RATINGS ASSIGNED

Carlyle Global Market Strategies CLO 2013-1 Ltd./Carlyle Global
Market
Strategies CLO 2013-1 LLC
Class            Rating          Amount
                                 (mil. $)
A-1              AAA (sf)        380.0
A-2A             AA (sf)          25.0
A-2B             AA (sf)          29.0
B (deferrable)   A (sf)           49.5
C (deferrable)   BBB (sf)         28.3
D (deferrable)   BB (sf)          30.6
Subordinated     NR               62.5


CENT CLO: S&P Assigns Preliminary BB Rating to Class D Notes
------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Cent CLO 17 Ltd./Cent CLO 17 Corp.'s $370.50 million
floating-rate notes.

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

The preliminary ratings are based on information as of Feb. 12,
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.

   -- 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 0.30%-11.36%.

   -- 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/1295.pdf

PRELIMINARY RATINGS ASSIGNED

Cent CLO 17 Ltd./Cent CLO 17 Corp.

Class                     Rating               Amount (mil. $)
A-1                       AAA (sf)                      262.00
A-2A                      AA (sf)                        22.50
A-2B                      AA (sf)                        20.00
B (deferrable)            A (sf)                         29.00
C (deferrable)            BBB (sf)                       19.50
D (deferrable)            BB (sf)                        17.50
Subordinated notes        NR                             44.30

NR-Not rated.


COMM 2000-C1: S&P Raises Rating on Class G Notes to 'B(sf)'
-----------------------------------------------------------
Standard & Poor's Ratings Services raises its rating on the class
G commercial mortgage pass-through certificates from COMM 2000-C1
Mortgage Trust, a U.S. commercial mortgage-backed securities
(CMBS) transaction, to 'B (sf)' from 'CCC+ (sf)'.

The upgrade follows S&P's analysis of the transaction using its
criteria for rating U.S and Canadian CMBS and also reflects the
stability of this class as well as its decreased risk of near-term
default and S&P's review of the three remaining loans in the
trust, details for which are as follows:

The largest loan in the pool is the Saks - Stratford Square loan,
a $10.3 million loan (88.9% of the pooled trust balance) secured
by a 147,000 sq. ft. Saks Fifth Avenue retail store (lease expires
February 2024) in Bloomingdale, Ill.  The loan matures in
January 2024.  The servicer reported that debt service coverage
(DSC) and occupancy were 1.00x and 100%, respectively, as of year-
end 2011.

The second-largest loan is the Murray Square loan, a $718,523 loan
(6.2%) secured by 113,768-sq.-ft. retail center in Colorado
Springs, Colo.  The loan was transferred to the special servicer,
CWCapital Asset Management LLC, in May 2010 due to imminent
maturity default.  The loan was modified, extended, and returned
to the master servicer in August 2012.  The loan was added to the
master servicer's watchlist in October 2012, shortly after its
return from special servicing, because the occupancy was still
depressed mainly due to the largest tenant, King Soopers
(52,601 sq. ft.), vacating at lease expiration in October 2011.
According to the borrower, the property was replatted and the
building parcel was sold to Walmart for a neighborhood market.
The market opened for business in August or September of 2012.
The master servicer, Key Bank Real Estate Capital, contacted the
borrower requesting market conditions, occupancy, and strategy
updates.  The modified loan maturity date is in April 2014.  The
servicer reported DSC at 0.48x as of year-to-date Sept. 30, 2012,
while reported occupancy was 66% as of Dec. 18, 2012.

The smallest loan in the pool is the Pines & Scholars Apartment
Portfolio loan, a $569,197 loan (4.9%) secured by two multifamily
properties totaling 198 units in Tahlequah and Stillwater, Okla.
The loan matures in June 2015.  The servicer reported that DSC and
occupancy were 1.52x and 99%, respectively, as of year-end 2011.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

SEC Rule 17g-7 requires an NRSRO, for any report accompanying a
credit rating relating to an asset-backed security as defined in
the Rule, to include a description of the representations,
warranties and enforcement mechanisms available to investors and a
description of how they differ from the representations,
warranties and enforcement mechanisms in issuances of similar
securities.  The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.
If applicable, the Standard & Poor's 17-g7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com


COMM 2003-LNB1: Moody's Affirms 'C' Rating on 3 Cert. Classes
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 14 classes of
COMM 2003-LNB1, Commercial Mortgage Pass-Through Certificates as
follows:

Cl. A-1A, Affirmed Aaa (sf); previously on Jul 3, 2003 Definitive
Rating Assigned Aaa (sf)

Cl. A-2, Affirmed Aaa (sf); previously on Jul 3, 2003 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aaa (sf); previously on Feb 2, 2007 Upgraded to
Aaa (sf)

Cl. C, Affirmed Aaa (sf); previously on Feb 2, 2007 Upgraded to
Aaa (sf)

Cl. D, Affirmed Aa3 (sf); previously on Mar 2, 2011 Confirmed at
Aa3 (sf)

Cl. E, Affirmed Baa1 (sf); previously on Mar 2, 2011 Downgraded to
Baa1 (sf)

Cl. F, Affirmed Ba1 (sf); previously on Mar 2, 2011 Downgraded to
Ba1 (sf)

Cl. G, Affirmed B2 (sf); previously on Mar 2, 2011 Downgraded to
B2 (sf)

Cl. H, Affirmed Caa1 (sf); previously on Mar 2, 2011 Downgraded to
Caa1 (sf)

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

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

Cl. L, Affirmed C (sf); previously on Oct 7, 2010 Downgraded to C
(sf)

Cl. M, Affirmed C (sf); previously on Oct 7, 2010 Downgraded to C
(sf)

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

Ratings Rationale

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

Moody's rating action reflects a cumulative base expected loss of
5.0% of the current balance. At last review, Moody's cumulative
base expected loss was 2.8%. Moody's cumulative base expected loss
plus realized loss is now 5.6% of the original pooled balance
compared to 4.8% at last review.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000. The methodology used in
rating Interest-Only Securities was "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2012. The Interest-Only Methodology was used for the rating of
Class X-1.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit assessment
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the credit assessment level, is incorporated
for loans with similar credit assessments in the same transaction.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 13 compared to 19 at Moody's prior review.

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

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated February 24, 2013.

Deal Performance

As of the January 10, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 32% to $432.6
million from $635.7 million at securitization. The Certificates
are collateralized by 55 mortgage loans ranging in size from less
than 1% to 15% of the pool, with the top ten non-defeased loans
representing 56% of the pool. The pool contains one loan with an
investment grade credit assessment, representing 15% of the pool.
Eleven loans, representing 20% of the pool, have defeased and are
secured by U.S. Government securities. Loans representing
approximately 87% of the pool mature within the next 6 months.

Eighteen loans, representing 28% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Nine loans have been liquidated from the pool, resulting in an
aggregate realized loss of $25.9 million (71.6% loss severity on
average). Approximately 51% of this deal's aggregate realized loss
is attributed to the liquidation of the Hampton Inn and Holiday
Inn Loan. This loan realized a loss of over 115% when it was
disposed of in May 2011. Currently one loan, representing 0.9% of
the pool, is in special servicing. Moody's has estimated
approximately a $960,000 loss (26% expected loss) for the
specially serviced loan. Moody's has assumed a high default
probability for 6 poorly performing loans representing 16% of the
pool and has estimated an aggregate $16.9 million loss (24%
expected loss based on a 50% probability default) from these
troubled loans.

Moody's was provided with full year 2011 operating results for 95%
of the pool's non-specially serviced and non-defeased loans.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 78% compared to 84% at Moody's prior review.
Moody's net cash flow reflects a weighted average haircut of 11%
to the most recently available net operating income. Moody's value
reflects a weighted average capitalization rate of 8.6%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.44X and 1.33X, respectively, compared to
1.35X and 1.23X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit assessment is the 75 Rockefeller
Plaza Loan ($65.0 million -- 15.0% of the pool), which is secured
by a 578,000 square foot (SF) office building that is part of the
Rockefeller Center complex in New York City. The property is 100%
leased to Time Warner Companies Inc. (Moody's Senior Unsecured
Rating Baa2, Stable Outlook) under a 21-year triple net lease that
is coterminous with the loan's maturity in August 2014. Time
Warner has subleased all the space within the building, 99% is
currently occupied, and does not plan to renew its lease. As per
the lease agreement, the borrower now has the right to negotiate
directly with the sub-tenants. Moody's valuation reflects an
anticipated increase in the property's new cash flow resulting
from re-leasing the building at market rents at the expiration of
Time Warner's lease. Moody's credit assessment and stressed DSCR
are Aa1 and 2.18X, respectively, compared to Aa1 and 2.22X at last
review.

The top three conduit loans represent 18% of the pool. The largest
conduit loan is the Gateway Center BJ's Loan ($38.2 million --
8.8% of the pool), which is secured by a 153,000 SF portion of a
640K SF community center located in Brooklyn, New York. The
collateral is 100% leased to BJ's Wholesale Club (85% of the gross
leasable area (GLA); lease expiration 2027) and several restaurant
tenants. The property is shadow anchored by Home Depot, Target,
Bed Bath & Beyond and Marshall's. Moody's LTV and stressed DSCR
are 73% and 1.37X, respectively, compared to 75% and 1.33X at last
review.

The second largest conduit loan is The Reserve at Sugarloaf Loan
($23.8 million -- 5.5% of the pool), which is secured by a 333
unit multifamily complex located in Duluth, Georgia. The property
was 94% occupied as of September 2012 compared to 96% at YE 2011.
Moody's LTV and stressed DSCR are 96% and 0.99X, respectively,
compared to 97% and 0.98X at last review.

The third largest conduit loan is the IAC JFK Building B Loan
($16.7 million -- 3.9% of the pool), which is secured by a 108,000
SF industrial building located in Jamaica, New York. The property
is 100% leased to Kintetsu World Express USA Inc. and UTI United
States Inc. through 2016 and 2017, respectively. The properties
serve as cargo and warehouse space to the Kennedy Airport
corridor. Moody's LTV and stressed DSCR are 76% and 1.32X,
respectively, compared to 77% and 1.30X at last review.


COMMERCIAL MORTGAGE 1998-C1: Moody's Keeps Ratings on 3 Certs
-------------------------------------------------------------
Moody's Investors Service affirmed the ratings of three classes of
Commercial Mortgage Acceptance Corp., Commercial Mortgage Pass-
Through Certificates, Series 1998-C1 as follows:

  Cl. L, Affirmed Caa3 (sf); previously on Mar 24, 2011 Upgraded
  to Caa3 (sf)

  Cl. M, Affirmed C (sf); previously on May 25, 2006 Downgraded
  to C (sf)

  Cl. X, Affirmed Caa1 (sf); previously on Feb 22, 2012
  Downgraded to Caa1 (sf)

Ratings Rationale

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

Moody's rating action reflects a cumulative base expected loss of
2.5% of the current balance, the same as at last review.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating CMBS Large Loan/Single
Borrower Transactions" published in July 2000. The methodology
used in rating Interest-Only Securities was "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012. The Interest-Only Methodology was used for the
rating of Class X.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit assessment
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the credit assessment level, is incorporated
for loans with similar credit assessments in the same transaction.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 19 compared to 23 at Moody's prior review.

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

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated February 29, 2012.

Deal Performance

As of the January 15, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 95% to $61.4
million from $1.2 billion at securitization. The Certificates are
collateralized by 37 mortgage loans ranging in size from less than
1% to 16% of the pool, with the top loans representing 56% of the
pool.

Fifteen loans, representing 37% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Eighteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $14.6 million (30% loss severity on
average). There are no loans that are currently in special
servicing.

Moody's was provided with full year 2011 operating results for 89%
of the pool's loans. Moody's weighted average LTV is 49% compared
to 52% at last review. Moody's net cash flow reflects a weighted
average haircut of 12% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 10.1%.

Moody's actual and stressed DSCRs are 1.41X and 2.66X,
respectively, compared to 1.46X and 2.43X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three loans represent 28% of the pool balance. The largest
loan is Shrewsbury Plaza Loan ($9.7 million -- 15.8% of the pool),
which is secured by a 225,000 square foot (SF) retail center
located in Shrewsbury, New Jersey. The property was 99% leased as
of October 2012 compared to 97% at last review. The loan is fully
amortizing and matures in March 2023. Moody's LTV and stressed
DSCR are 44% and 2.46X, respectively, compared to 48% and 2.27X at
last review.

The second largest loan is Best Buy Store Loan ($3.8 million --
6.3% of the pool), which is secured by a 45,500 SF single-tenant
retail property located in Madison Heights, Michigan. The property
is 100% leased to Best Buy through February 2018. Due to the
single tenant exposure, Moody's stressed the value of this
property utilizing a lit/dark analysis. Moody's LTV and stressed
DSCR are 97% and 1.23X, respectively, compared to 90% and 1.32X at
last review.

The third largest loan is Pinewood Apartments Loan ($3.7 million -
- 6.0% of the pool), which is secured by a 246-unit multifamily
complex located in Brunswick, Ohio. The property was 96% leased as
of November 2012 compared to 91% at last review. Rental revenue at
the property has continued to increase but overall property
performance decreased in 2012 due primarily to an increase in the
payroll and repair and maintenance expenses. The loan is
benefitting from amortization and matures in May 2013. Moody's LTV
and stressed DSCR are 74% and 1.39X, respectively, compared to 73%
and 1.41X at last review.


COMMODORE CDO I: Fitch Affirms 'C' Ratings on Two Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed two classes of notes issued by
Commodore CDO I, Ltd./Corp., as follows:

-- $33,087,797 class B notes affirmed at 'Csf';
-- $17,550,000 class C notes affirmed at 'Csf'.

This review was conducted under the framework described in the
reports 'Global Structured Finance Rating Criteria' and 'Global
Rating Criteria for Structured Finance CDOs'. The transaction has
not been analyzed within the Structured Finance Portfolio Credit
Model and the cash flow model framework, as the impact of
structural features and excess spread, or conversely, principal
proceeds being used to pay CDO liabilities and hedge payments, was
determined to be minimal in the context of these CDO ratings.
Instead, to determine appropriate rating levels for the rated
notes, Fitch compared their respective credit enhancement (CE)
levels to the amount of expected losses (EL) from the distressed
and defaulted assets in the portfolio (rated 'CCsf' or lower).
This comparison indicates that default continues to appear
inevitable for the class B and the class C, at or prior to
maturity.

Key Rating Drivers

Since Fitch's last rating action in February 2012, the credit
quality of the underlying collateral has remained relatively
stable; however, the pool has become more concentrated in the
lower credit quality assets with only 23 obligors remaining. Over
the last 12 months, approximately 11.3% of the underlying
collateral has been downgraded a weighted average of 3.0 notches
and 6.4% has been upgraded a weighted average of 6.7 notches.
Currently, approximately 84.7% of the portfolio has a Fitch
derived rating below investment grade and 76.4% has a rating in
the 'CCCsf' rating category or lower. This compares to 91.1% and
56.8%, respectively, at the time of the last rating action.

However, this additional deterioration has been offset by the
ongoing amortization of the capital structure, with $19.3 million
of excess interest and principal received from the underlying
securities over this period. This resulted in the full repayment
of $9.6 million of the remaining balance of the class A notes on
the August 28, 2012 payment date and $9.6 million in paydowns to
the class B notes. Although, the CE levels available to the class
B notes have increased since the last review, due to the ongoing
delevering of the capital structure, they remain below the amount
of expected losses. As such, Fitch believes an affirmation of the
notes at 'Csf' reflects the transaction's performance given the
concentration risks of the remaining portfolio.

The class C notes continue to defer their interest payments with
approximately $3.4 million of deferred interest balance after
November 2012 payment date. Since the last rating action, this
class has become even more undercollateralized and is not expected
to receive any proceeds going forward. Fitch believes that default
continues to appear inevitable for the class C notes at CDO's
maturity. Therefore, this class has been affirmed at 'Csf'.

Commodore I is a cash flow structured finance collateralized debt
obligation (SF CDO) that closed on Feb. 26, 2002 and is monitored
by Fischer Francis Trees & Watts, Inc. As of the Jan. 2, 2013
Trustee report, the portfolio is comprised of 46.7% commercial
asset-backed securities (ABS), 40.0% of residential mortgage-
backed securities (RMBS), 10.9% of consumer ABS, and 2.4% of
commercial mortgage-backed securities (CMBS), from 1999 through
2005 vintage transactions.


CREDIT SUISSE 2001-CP4: S&P Lowers Ratin on Class E Notes to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
classes of commercial mortgage pass-through certificates from
Credit Suisse First Boston Mortgage Securities Corp.'s series
2001-CP4, a U.S. commercial mortgage-backed securities (CMBS)
transaction, and removed them from CreditWatch with negative
implications, where S&P placed them on Nov. 21, 2012.

S&P's downgrades primarily reflect its analysis of the interest
shortfalls to classes D and E, liquidity available to the trust,
and its review of the 12 remaining assets ($71.3 million) in the
pool, six ($51.9 million, 72.8%) of which are with the special
servicer, LNR Partners LLC (LNR).  As of the Jan. 17, 2013,
trustee remittance report, total interest shortfalls allocated to
the trust was $611,749, of which $448,392 were reported as
interest shortfalls on all of the outstanding certificate classes,
including the A-X interest-only class, and the remainder was
reported as a principal loss.  The interest shortfalls were
primarily due to:

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

   -- Appraisal subordinate entitlement reduction (ASER) amounts
      of $14,589;

   -- Special servicing fees of $11,180; and

   -- Reimbursement of advances to the servicer of $301,760.

According to the January 2013 trustee remittance report, $104,547
of outstanding advances related to the Somerset Center & Somerset
Place ($13.3 million, 18.7%) specially serviced loan remains
outstanding.  Midland has informed S&P that it intends to recover
the remaining outstanding advances in the February payment period.
Standard & Poor's had previously placed its ratings on the class D
and E certificates on CreditWatch with negative implications due
to ongoing interest shortfalls.  S&P's analysis indicates that
even after Midland recovers its remaining outstanding advances in
February, the trust is likely to continue experiencing a
significant amount of interest shortfalls going forward due to the
specially serviced assets.  Also, Midland has indicated that due
to the high amount of advances for the other specially serviced
assets, it is not ruling out the possibility of recovering further
amounts at a later time if deemed necessary.

S&P lowered its rating on class D to 'CCC- (sf)' because the bond
experienced interest shortfalls for the past three reporting
periods and S&P expects this bond to remain susceptible to future
interest shortfalls.  S&P lowered its rating on class E to 'D
(sf)' because it believes accumulated interest shortfalls for this
class will remain outstanding for the foreseeable future.

As of the Jan. 17, 2013, remittance report, the transaction
collateral comprised 12 commercial real estate assets
($71.3 million), including six ($51.9 million, 72.8%) that are
with the special servicer.  The reported payment status of the
specially serviced assets is as follows: three assets
($25.4 million, 35.6%) are real estate owned (REO); one loan
($13.3 million, 18.7%) is in foreclosure; and two loans
($13.2 million, 18.5%) are nonperforming matured balloon loans.
Details for the two largest assets in the pool, both of which are
specially serviced, are as follows:

The Reservoir Corporate Center asset ($15.4 million trust balance,
21.6%) is the largest asset in the pool and the largest specially
serviced asset.  The asset has a total reported exposure of
$22.2 million.  The property comprises 156,776 sq. ft. of office
space in Shelton, Conn.  The loan was transferred to the special
servicer on June 11, 2008, and the property became REO on June 6,
2012.  Midland has declared this asset nonrecoverable.  The
special servicer indicated that it is currently attempting a lease
up strategy for six months.  S&P expects a significant loss upon
the eventual resolution of this asset.

The Somerset Center & Somerset Place loan ($13.3 million, 18.7%)
is secured by a 166,594-sq.-ft. office property in Raleigh, N.C.
The loan, which is reported as a nonperforming matured balloon
loan, has a total reported exposure of $17.0 million.  The loan
was transferred to the special servicer on Dec. 8, 2009, and
foreclosure was filed on Sept. 16, 2010, and the borrower filed
for bankruptcy on Nov. 8, 2010.  Midland has declared this loan
nonrecoverable.  Midland indicated that it is working with the
borrower on a bankruptcy plan.  S&P expects a moderate loss upon
the resolution of this loan.

The remaining four assets with the special servicer individually
represent less than 17.9% of the total pool balance.  Two of the
four assets were deemed nonrecoverable by the master servicer
while one of the assets has an ARA of $2.4 million in effect.  S&P
estimated losses for the four assets and S&P expects moderate to
significant losses upon the eventual resolutions of these 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 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

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

                                                  Reported
                                                  Interest
          Rating                   Credit       Shortfalls ($)
Class  To         From             Enhncmt (%) Current  Accum.
D      CCC- (sf)  A+ (sf)/Watch Neg   78.58    84,100  252,301
E      D (sf)     BBB (sf)/Watch Neg  55.86    94,247  282,7422


CSAM FUNDING IV: Moody's Affirms 'Ba1' Rating on 2 Note Classes
---------------------------------------------------------------
Moody's Investors Service upgraded the ratings of the following
notes issued by CSAM Funding IV:

USD19,000,000 B-1 Due June 9, 2016, Upgraded to Aaa (sf);
previously on April 27, 2012 Upgraded to Aa1 (sf);

USD14,000,000 B-2 Due June 9, 2016, Upgraded to Aaa (sf);
previously on April 27, 2012 Upgraded to Aa1 (sf);

USD16,500,000 C-1 Due June 9, 2016, Upgraded to Baa1 (sf);
previously on July 14, 2011 Upgraded to Baa2 (sf);

USD7,500,000 C-2 Due June 9, 2016, Upgraded to Baa1 (sf);
previously on July 14, 2011 Upgraded to Baa2 (sf).

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

USD319,000,000 A-1 Due June 9, 2016 (current outstanding
balance of $54,177,746), Affirmed Aaa (sf); previously on March
29, 2011 Upgraded to Aaa (sf);

USD100,000 A-1 V Due June 9, 2016 (current outstanding balance
of $16,984), Affirmed Aaa (sf); previously on March 29, 2011
Upgraded to Aaa (sf);

USD129,900,000 A-1NV Due June 9, 2016 (current outstanding
balance of $22,061,722), Affirmed Aaa (sf); previously on March
29, 2011 Upgraded to Aaa (sf);

USD32,500,000 A-2 Due June 9, 2016, Affirmed Aaa (sf);
previously on July 14, 2011 Upgraded to Aaa (sf);

USD6,750,000 D-1 Due June 9, 2016, Affirmed Ba1 (sf);
previously on July 14, 2011 Upgraded to Ba1 (sf);

USD4,250,000 D-2 Due June 9, 2016 Affirmed Ba1 (sf); previously
on July 14, 2011 Upgraded to Ba1 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the senior notes and an
increase in the transaction's overcollateralization ratios since
the rating action in April 2012. Moody's notes that the Class A-1
Notes have been paid down by approximately 48.4% or $71.6 million
since the last rating action. Based on the latest trustee report
in January 2013, the Class A, Class B, Class C and Class D
overcollateralization ratios are reported at 175.3%, 141.8%,
124.5% and 117.9%, respectively, versus April 2012 levels of
147.8%, 128.4%, 117.1% and 112.6%, respectively.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes. Based on the January 2013 trustee
report, securities that mature after the maturity date of the
notes currently make up approximately 51.9% 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. Notwithstanding the increases in the
overcollateralization ratios of the Class D-1 Notes and Class D-2
Notes, Moody's affirmed the ratings of the Class D-1 Notes and
Class D-2 Notes due to the market risk posed by the exposure to
these long-dated assets.

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 $211.2 million,
defaulted par of $7.1 million, a weighted average default
probability of 15.7% (implying a WARF of 2803), a weighted average
recovery rate upon default of 49.3%, and a diversity score of 40.
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 ach 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.

CSAM Funding IV, issued in June 2004, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

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

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

In addition to the base case analysis described, Moody's also
performed sensitivity analyses to test the impact on all rated
notes of various default probabilities.

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% (3363)

A1: 0
A1V: 0
A1NV: 0
A2: 0
B1: -1
B2: -1
C1: -2
C2: -2
D1: 0
D2: -1

Moody's Adjusted WARF -20% (2242)

A1: 0
A1V: 0
A1NV: 0
A2: 0
B1: 0
B2: 0
C1: +2
C2: +2
D1: +2
D2: +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:

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

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

3) Long-dated assets: The presence of assets that mature beyond
the CLO's legal maturity date exposes the deal to liquidation risk
on those assets. Moody's assumes an asset's terminal value upon
liquidation at maturity to be equal to the lower of an assumed
liquidation value (depending on the extent to which the asset's
maturity lags that of the liabilities) and the asset's current
market value. In consideration of the large size of the deal's
exposure to long-dated assets, which increase its sensitivity to
the liquidation assumptions used in the rating analysis, Moody's
ran different scenarios considering a range of liquidation value
assumptions. However, actual long-dated asset exposure and
prevailing market prices and conditions at the CLO's maturity will
drive the extent of the deal's realized losses, if any, from long-
dated assets.

4) Post-Reinvestment Period Trading: Subject to certain
requirements, the deal is allowed to reinvest certain proceeds
after the end of the reinvestment period, and as such the manager
has the flexibility to deteriorate some collateral quality metrics
to the covenant levels. In particular, the post-reinvestment
period reinvesting criteria do not require reinvestments to have a
Moody's rating equal to or better than the rating of the security
sold or prepaid. Additionally, the post-reinvestment period
reinvesting criteria is less restrictive with respect to the
weighted average life of the portfolio compared to other CLOs
currently in their post-reinvestment period.


FRASER SULLIVAN I: Moody's Affirms Ba3 Ratings on 2 Note Classes
----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of the following
notes issued by Fraser Sullivan CLO I Ltd.:

USD32,000,000 Class B Senior Secured Floating Rate Notes Due
March 15, 2020, Upgraded to Aaa (sf); previously on August 19,
2011 Upgraded to Aa1 (sf);

USD31,000,000 Class C Senior Secured Deferrable Floating Rate
Notes Due March 15, 2020, Upgraded to Aa3 (sf); previously on
August 19, 2011 Upgraded to A2 (sf);

USD22,800,000 Class D-1 Senior Secured Deferrable Floating Rate
Notes Due March 15, 2020, Upgraded to Baa3 (sf); previously on
August 19, 2011 Upgraded to Ba1 (sf);

USD10,200,000 Class D-2 Senior Secured Deferrable Fixed Rate
Notes Due March 15, 2020, Upgraded to Baa3 (sf); previously on
August 19, 2011 Upgraded to Ba1 (sf);

USD15,000,000 Composite Obligations Due March 15, 2020 (current
outstanding balance of $8,154,775), Upgraded to A2 (sf);
previously on August 19, 2011 Upgraded to Baa1 (sf).

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

USD50,000,000 Class A-1 Senior Secured Floating Rate Revolving
Notes Due March 15, 2020 (current outstanding balance of
$32,944,762), Affirmed Aaa (sf); previously on August 19, 2011
Upgraded to Aaa (sf);

USD298,000,000 Class A-2 Senior Secured Floating Rate Term Notes
Due March 15, 2020 (current outstanding balance of
$196,350,779), Affirmed Aaa (sf); previously on August 19, 2011
Upgraded to Aaa (sf);

USD10,200,000 Class E-1 Senior Secured Deferrable Floating Rate
Notes Due March 15, 2020, Affirmed Ba3 (sf); previously on
August 19, 2011 Upgraded to Ba3 (sf);

USD4,800,000 Class E-2 Senior Secured Deferrable Fixed Rate
Notes Due March 15, 2020, Affirmed Ba3 (sf); previously on
August 19, 2011 Upgraded to Ba3 (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 August 2011. Moody's notes that the Class A
Notes have been paid down by approximately 34.1% or $118.7 million
since the last rating action. Based on the latest trustee report
dated from January 2013, the Class A/B, Class C, Class D and Class
E overcollateralization ratios are reported at 140.6%, 125.7%,
112.9% and 107.9%, respectively, versus July 2011 levels of
127.9%, 118.3%, 109.5% and 105.9%, respectively.

Notwithstanding benefits of the deleveraging, Moody's notes that
the credit quality of the underlying portfolio has deteriorated
since the last rating action. Based on the January 2013 trustee
report, the weighted average rating factor is currently 2557
compared to 2480 in July 2011.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $360.8 million,
defaulted par of $6.5 million, a weighted average default
probability of 19.6% (implying a WARF of 2895), a weighted average
recovery rate upon default of 48.5%, and a diversity score of 47.
The default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Fraser Sullivan CLO I Ltd., issued in March 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

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

Moody's Adjusted WARF +20% (3474)

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

Moody's Adjusted WARF -20% (2316)

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

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

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

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


FREMF 2012-K705: Moody's Lowers Rating on X2 Certs to 'Ba3'
-----------------------------------------------------------
Moody's Investors Service downgraded one interest-only class and
affirmed the ratings of five classes of FREMF 2012-K705 Mortgage
Trust, Multifamily Mortgage Pass-Through Certificates, Series
2012-K705 as follows:

  Cl. A-1, Affirmed Aaa (sf); previously on Feb 8, 2012 Definitive
  Rating Assigned Aaa (sf)

  Cl. A-2, Affirmed Aaa (sf); previously on Feb 8, 2012 Definitive
  Rating Assigned Aaa (sf)

  Cl. B, Affirmed A2 (sf); previously on Feb 8, 2012 Definitive
  Rating Assigned A2 (sf)

  Cl. C, Affirmed Baa2 (sf); previously on Feb 8, 2012 Definitive
  Rating Assigned Baa2 (sf)

  Cl. X1, Affirmed Aaa (sf); previously on Feb 8, 2012 Definitive
  Rating Assigned Aaa (sf)

  Cl. X2, Downgraded to Ba3 (sf); previously on Feb 8, 2012
  Definitive Rating Assigned Aaa (sf)

Ratings Rationale

The downgrade of the IO Class, Class X2 is due to the
implementation of the methodology for rating structured finance
interest-only securities.

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

Moody's rating action reflects a cumulative base expected loss of
3.6% of the current balance. Depending on the timing of loan
payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
the commercial 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. The hotel and multifamily sectors are in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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 U.S. CMBS Conduit Transactions" published in
September 2000. The methodology used in rating Interest-Only
Securities was "Moody's Approach to Rating Structured Finance
Interest-Only Securities" published in February 2012. The
Interest-Only Securities Methodology was used for the rating of
Classes X1 and X2.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit assessments is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit assessments
in the same transaction.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 38, the same as at securitization.

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors. Therefore,
the rating outcome may differ from the model output. The rating
action is a result of Moody's on-going surveillance of commercial
mortgage backed securities (CMBS) transactions. Moody's monitors
transactions on a monthly basis through two sets of quantitative
tools -- MOST (Moody's Surveillance Trends) and CMM (Commercial
Mortgage Metrics) on Trepp -- and on a periodic basis through a
comprehensive review. Moody's prior full review is summarized in a
pre-sale report dated January 18, 2012.

Deal Performance

As of the January 25, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$1.21 billion from $1.22 billion at securitization. The
Certificates are collateralized by 70 mortgage loans ranging in
size from less than 1% to 10% of the pool, with the top ten loans
representing 37% of the pool.

Currently, there are no loans on the master servicer's watchlist
or in special servicing.

Moody's was provided with full year 2011 and partial 2012
operating results for 100% and 81%, respectively, of the pool's
loans. Moody's weighted average LTV is 110%, essentially the same
as at securitization. Moody's net cash flow reflects a weighted
average haircut of 9% to the most recently available full year net
operating income. Moody's value reflects a weighted average
capitalization rate of 8.7%.

Moody's actual and stressed DSCRs are 1.38X and 0.86X,
respectively, compared to 1.38X and 0.86X at securitization.
Moody's actual DSCR is based on Moody's net cash flow (NCF) and
the loan's actual debt service. Moody's stressed DSCR is based on
Moody's NCF and a 9.25% stressed rate applied to the loan balance.

The top three conduit loans represent approximately 18% of the
pool. The largest conduit loan is the Enclave Loan ($119.8 million
-- 9.8% of the pool), which is secured by a 1,119-unit multi-
family property in Silver Spring, Maryland. The collateral
consists of three, 19-story apartment buildings and one club
house. At securitization, the property was 90% leased. The loan is
full term interest-only and the sponsor is Berkshire Property
Advisors. Moody's LTV and stressed DSCR are 112% and 0.77X, the
same as at securitization.

The second largest conduit loan is the Crosswind at Rolling Road
Loan ($56.6 million -- 4.6% of the pool), which is secured by a
803-unit multi-family property in Baltimore, Maryland. The
collateral consists of 80 two-story and three-story townhouse-
style buildings. As of September 2012, the property was 93% leased
compared to 89% at securitization. The loan is partial term
interest-only and the sponsor is the Harbor Group. Moody's LTV and
stressed DSCR are 95% and 1.0X, the same as at securitization.

The third largest conduit loan is the University Village
Apartments ($40.6 million -- 3.3% of the pool ), which is secured
by a 1,008 unit multi-family property located near the Ohio State
University campus in Columbus, Ohio. The collateral consists of
54, three-story apartment buildings, a club house and six
maintenance buildings. As of September 2012, the property was 99%
leased compared to 100% at securitization. Moody's LTV and
stressed DSCR are 104% and 0.88X, essentially the same as at
securitization.


GE CAPITAL 2007-C1: DBRS Assigns 'BB(sf)' Rating to A-MLF Certs
---------------------------------------------------------------
DBRS has assigned a rating of BB (sf) to Class A-MFL of GE Capital
Commercial Mortgage Corporation, Commercial Mortgage Pass-Through
Certificates, Series 2007-C1.  The trend is Stable.  The rating
was issued at the request of an investor and coincides with the
issuance of the rating of BB (sf) by DBRS to the Class A-M on
December 31, 2012, as the classes share the same loss profile
within the transaction's waterfall.

The rating assigned to the certificate by DBRS is based
exclusively on the credit provided by the transaction structure
and underlying trust assets.  This class will be subject to
ongoing surveillance, which could result in upgrades or downgrades
by DBRS.


GMAC COMMERCIAL 2002-C3: Moody's Lowers Class X-1 Certs to 'Caa2'
-----------------------------------------------------------------
Moody's Investors Service affirms the ratings of ten classes and
downgrades the rating of one class of GMAC Commercial Mortgage
Securities, Inc., Series 2002-C3 Mortgage Pass-Through Certificate
as follows:

  Cl. F, Affirmed Aa3 (sf); previously on Sep 25, 2008 Upgraded
  to Aa3 (sf)

  Cl. G, Affirmed Baa3 (sf); previously on Feb 16, 2012
  Downgraded to Baa3 (sf)

  Cl. H, Affirmed Ba1 (sf); previously on Feb 16, 2012 Downgraded
  to Ba1 (sf)

  Cl. J, Affirmed B3 (sf); previously on Feb 16, 2012 Downgraded
  to B3 (sf)

  Cl. K, Affirmed Caa2 (sf); previously on Feb 16, 2012
  Downgraded to Caa2 (sf)

  Cl. L, Affirmed Caa3 (sf); previously on Feb 16, 2012
  Downgraded to Caa3 (sf)

  Cl. M, Affirmed Ca (sf); previously on Feb 16, 2012 Downgraded
  to Ca (sf)

  Cl. N, Affirmed C (sf); previously on Feb 16, 2012 Downgraded
  to C (sf)

  Cl. O-1, Affirmed C (sf); previously on Dec 2, 2010 Downgraded
  to C (sf)

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

  Cl. X-1, Downgraded to Caa2 (sf); previously on Feb 22, 2012
  Downgraded to Ba3 (sf)

Ratings Rationale

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

The downgrade of the IO Class, Class X-1, is due to significant
payoffs since last review and is based on the ratings of its
remaining referenced classes.

Moody's rating action reflects a cumulative base expected loss of
39.7% of the current balance. At last review, Moody's cumulative
base expected loss was 4.6%. Moody's base expected loss plus
realized loss is 5.4%, compared to 4.7% at last review, of
original balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating CMBS Large Loan/Single
Borrower Transactions" published in July 2000. The methodology
used in rating Interest-Only Securities was "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012. The Interest-Only Methodology was used for the
rating of X-1.

On November 22, 2011 Moody's released a Request for Comment, in
which the rating agency has requested market feedback on potential
changes to its rating methodology for Interest-Only Securities. If
the revised methodology is implemented as proposed, the ratings on
GMAC Commercial Mortgage Securities, Inc., Series 2002-C3 Mortgage
Pass-Through Certificates, Class X-1 may be negatively affected.
Refer to Moody's request for Comment, titled "Proposal Changing
the Global Rating Methodology for Structured Finance Interest-Only
Securities," for further details regarding the implications of the
proposed methodology change on Moody's rating.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit assessment
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the credit assessment level, is incorporated
for loans with similar credit assessments in the same transaction.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 8 compared to 37 at Moody's prior review.

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

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST (Moody's Surveillance Trends) and CMM
(Commercial Mortgage Metrics) on Trepp -- and on a periodic basis
through a comprehensive review. Moody's prior full review is
summarized in a press release dated February 16, 2012.

Deal Performance

As of the January 10, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 91% to $70.3
million from $777.4 million at securitization. The Certificates
are collateralized by 12 mortgage loans ranging in size from less
than 1.5% to 16.8% of the pool, with the top ten non-defeased
loans representing 95.3% of the pool. One loan, representing 3.2%
of the pool, has defeased and is secured by U.S. Government
securities.

Two loans, representing 29.5% of the pool, are on the master
servicer's Watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Six loans have been liquidated from the pool, resulting in a
realized loss of $14.3 million (42.8% loss severity). Currently
six loans, representing 62.2% of the pool, are in special
servicing. Moody's estimates an aggregate $25.9 million loss for
the specially serviced loans (37% expected loss on average).

As of the most recent remittance date, the pool has experienced
cumulative interest shortfalls totaling $3.5 million and affecting
Classes P through J. Moody's anticipates that the pool will
continue to experience interest shortfalls caused by specially
serviced loans. Interest shortfalls are caused by special
servicing fees, including workout and liquidation fees, appraisal
subordinate entitlement reductions (ASERs), extraordinary trust
expenses and nonadvancing by the master servicer based on a
determination of non-recoverability. The master servicer has made
a determination of non-recoverability for the Nashville Business
Center Loan ($9.3 million), Cherryland Center Loan ($7.6 million)
and the Wakefield Forest Apartments Loan ($3.9 million) and is no
longer advancing on these loans.

Moody's was provided with partial year 2012 operating results for
67% of the pool and full year 2011 for 75% of the pool. Excluding
specially serviced and troubled loans, Moody's weighted average
LTV is 94% compared to 82% at Moody's prior review. Moody's net
cash flow reflects a weighted average haircut of 12% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.6%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.26X and 1.25X, respectively, compared to
1.41X and 1.35X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing loans represent 31.4% of the pool. The
largest loan is the Parkway Manor Apartments Loan ($11.8 million -
- 16.8% of the pool), which is secured by a 176 unit garden-style
multifamily complex located in Carson City, NV. Moody's LTV and
stressed DSCR are 112.1% and 0.89X, respectively, compared to
114.7% and 0.87X at last review. This loan is currently on the
Watchlist due to low DSCR and loan maturity. The loan matured on
12/1/2012 and borrower is currently requesting an extension.

The second largest loan is the Hyatt Place, formerly known as
Holiday Inn Select, ($8.9 million -- 12.7% of the pool), and is
secured by a 170 room hotel located in New Orleans, LA. As of
December 2012, the property had an occupancy rate, ADR and RevPar
of 65.8%, 128.85 and 84.81 respectively, compared to 39.6%, 110.62
and 43.76 in 2011. Moody's LTV and stressed DSCR are 84.4% and
1.47X respectively, compared to 92.7% and 1.34X at last review.
This loan was recently returned from the Special Servicer and is
currently on the Watchlist due to upcoming loan maturity on
4/1/2013. The borrower has indicated that they are working to
secure financing in order to pay off the loan at maturity.

The third largest loan is Walgreens Hattiesburg ($1.3 million --
1.9% of the pool), which is secured by a 15,120 SF Walgreens
anchored retail property in Haittesburg, MS. This property has
been 100% leased to Walgreens since securitization and has a lease
expiration in April 2059. Moody's LTV and stressed DSCR are 67.3%
and 1.62X, respectively, compared to 74.1% and 1.47X, at last
review. Walgreens is currently rated Baa1.


GREENWICH CAPITAL: Fitch Affirms 'D' Rating on Class M Certs
------------------------------------------------------------
Fitch Ratings has affirmed 22 classes of Greenwich Capital
Commercial Funding Corporation commercial mortgage pass-through
certificates series 2007-GG11 due to stable performance.

Key Rating Drivers

Fitch modeled losses of 12.6% of the remaining pool; expected
losses on the original pool balance total 14.2%, including losses
already incurred. The pool has experienced $79.3 million (3% of
the original pool balance) in realized losses to date. Fitch has
designated 37 loans (42.6%) as Fitch Loans of Concern, which
includes 12 specially serviced assets (16.4%). While loss
expectations have decreased slightly since Fitch's last review,
there remains significant uncertainty about the ultimate
resolution of several large loans in special servicing.

As of the January 2013 distribution date, the pool's aggregate
principal balance has been reduced by 13.4% to $2.33 billion from
$2.69 billion at issuance. No loans have defeased since issuance.
Interest shortfalls are currently affecting classes E through S.

The largest contributor to expected losses is the specially-
serviced Bush Terminal loan (10.7% of the pool), which is secured
by a portfolio of 16 buildings totaling 6,152,896 sf of
industrial/flex/office space located in Brooklyn, NY. At
origination the loan was underwritten by the lender on pro-forma
basis with the expectation that the re-development of the property
and conversion of a portion of the space from industrial to office
(690,000 sf) and loft/showroom space (2.5 million sf) would
achieve higher rents. Occupancy at the property has been gradually
declining to 65% as of April 2012 from 87.2% at issuance, which
partly reflects space being kept vacant for conversion. The
borrowers received approximately $100 million in equity cash-out
at issuance, net of reserves.

The loan transferred to the special servicer in January 2011 due
to payment default. The loan was subsequently modified in April
2012 and split into an A-Note of $190 million and a B-Note of $110
million. The collateral sustained significant damage from
Superstorm Sandy. The basements of all of the buildings had
substantial water intrusion, as well as wind damage to some of the
properties. The borrower is in the process of filing an insurance
claim, but the claim is being delayed due to the large backlog
that insurers are experiencing because of the storm.

The next largest contributor to expected losses is the specially-
serviced Diamond Run Mall loan (1.6%), which is secured by a
383,987 sf regional mall in Rutland, VT. The loan transferred to
special servicing in May 2010 for payment default. The property is
one of only three malls in Vermont and the only mall in Rutland
County, and is anchored by JC Penney, Sears and Kmart. Property
performance has deteriorated as a result of higher vacancy and
higher expenses relative to issuance. Occupancy dropped to 81% as
of August 2012 from 91.5% at YE 2008 and 92.8% at issuance. The
servicer-reported DSCR for August 2012 was 0.37 times (x) down
from 1.20x at issuance.

The third largest contributor to expected losses is the Scottsdale
Fashion Square loan. The interest-only loan is secured by a 1.7
million-sf (1.3 million sf of collateral) regional mall located in
Scottsdale, AZ. The property was originally built in the 1960s,
expanded in 1998, and renovated between 2003 and 2006. Annualized
NOI as of third-quarter 2012 was down approximately 13% from
issuance due primarily to a 12% decrease in revenues; however, it
marked an increase in NOI from previous years (2007 - 2011).
Overall occupancy as of third-quarter 2012 was 96.8%, which breaks
down to 97.9% for the mall component and 83.1% for the office
component. Overall occupancy has been steady since issuance.

Fitch affirms these classes and revises the Rating Outlook as
indicated:

-- $268.7 million class A-M at 'BBBsf'; Outlook to Stable from
    Negative.

Fitch affirms these classes as indicated:

--$319.3 million class A-2 at 'AAAsf';
--$37.4 million class A-3 at 'AAAsf';
--$47 million class A-AB at 'AAAsf';
--$995.6 million class A-4 at 'AAAsf';
--$202 million class A-1-A at 'AAAsf';
--$211.6 million class A-J at 'CCCsf'; RE 100%;
--$20.2 million class B at 'CCCsf'; RE 45%;
--$26.9 million class C at 'CCsf'; RE 0%;
--$20.2 million class D at 'CCsf'; RE 0%;
--$33.6 million class E at 'CCsf'; RE 0%;
--$13.4 million class F at 'Csf'; RE 0%;
--$33.6 million class G at 'Csf'; RE 0%;
--$23.5 million class H at 'Csf'; RE 0%;
--$26.9 million class J at 'Csf'; RE 0%;
--$37 million class K at 'Csf'; RE 0%;
--$6.7 million class L at 'Csf'; RE 0%;
--$4.7 million 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%.

Fitch does not rate the class S certificates.


GS MORTGAGE 2012-GC6: Moody's Affirms 'B2' Rating on Class F Certs
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 11 classes of GS
Mortgage Securities Corporation II, Commercial Mortgage Pass-
Through Certificates, Series 2012-GC6 as follows:

  Cl. A-1, Affirmed Aaa (sf); previously on Feb 9, 2012
  Definitive Rating Assigned Aaa (sf)

  Cl. A-2, Affirmed Aaa (sf); previously on Feb 9, 2012
  Definitive Rating Assigned Aaa (sf)

  Cl. A-3, Affirmed Aaa (sf); previously on Feb 9, 2012
  Definitive Rating Assigned Aaa (sf)

  Cl. A-AB, Affirmed Aaa (sf); previously on Feb 9, 2012
  Definitive Rating Assigned Aaa (sf)

  Cl. A-S, Affirmed Aaa (sf); previously on Feb 9, 2012
  Definitive Rating Assigned Aaa (sf)

  Cl. B, Affirmed Aa3 (sf); previously on Feb 9, 2012 Definitive
  Rating Assigned Aa3 (sf)

  Cl. C, Affirmed A3 (sf); previously on Feb 9, 2012 Definitive
  Rating Assigned A3 (sf)

  Cl. D, Affirmed Baa3 (sf); previously on Feb 9, 2012 Definitive
  Rating Assigned Baa3 (sf)

  Cl. E, Affirmed Ba2 (sf); previously on Feb 9, 2012 Definitive
  Rating Assigned Ba2 (sf)

  Cl. F, Affirmed B2 (sf); previously on Feb 9, 2012 Definitive
  Rating Assigned B2 (sf)

  Cl. X-A, Affirmed Aaa (sf); previously on Feb 9, 2012
  Definitive Rating Assigned Aaa (sf)

Ratings Rationale

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

The rating of the IO Class, Class X-A, is consistent with the
expected credit performance of its referenced classes and thus is
affirmed.

Moody's rating action reflects a cumulative base expected loss of
2.1% of the current balance. Depending on the timing of loan
payoffs and the severity and timing of losses from specially
serviced loans, the credit enhancement level for investment grade
classes could decline below the current levels. If future
performance materially declines, the expected level of credit
enhancement and the priority in the cash flow waterfall may be
insufficient for the current ratings of these classes.

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

Primary sources of assumption uncertainty are the extent of the
slowdown in growth in the current macroeconomic environment and
the commercial 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. The hotel and multifamily sectors are in
recovery and improvements in the office sector continue, with
fundamentals in Gateway cities outperforming their suburban
counterparts. However, office demand is closely tied to
employment, where fundamentals remain weak, so significant
improvement may be delayed. Performance in the retail sector has
been mixed with on-going rent deflation and leasing challenges.
Across all property sectors, the availability of debt capital
continues to improve with monetary policy expected to remain
supportive and interest rate hikes postponed. Moody's central
global macroeconomic scenario reflects an overall downward
revision of forecasts since last quarter, amidst ongoing fiscal
consolidation efforts, household and banking sector deleveraging,
persistently high unemployment levels, and weak housing markets
that will continue to constrain growth.

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 Fusion U.S. CMBS Transactions" published in
April 2005. The methodology used in rating Interest-Only
Securities was "Moody's Approach to Rating Structured Finance
Interest-Only Securities" published in February 2012. The
Interest-Only Methodology was used for the rating of Class X-A.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the underlying rating
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the underlying rating level, is incorporated
for loans with similar credit assessments in the same transaction.

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

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

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors. Therefore,
the rating outcome may differ from the model output. The rating
action is a result of Moody's ongoing surveillance of commercial
mortgage backed securities (CMBS) transactions. Moody's monitors
transactions on a monthly basis through two sets of quantitative
tools -- MOST (Moody's Surveillance Trends) and CMM (Commercial
Mortgage Metrics) on Trepp -- and on a periodic basis through a
comprehensive review. Moody's prior full review is summarized in a
pre-sale report dated January 18, 2012.

Deal Performance

As of the January 11, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by approximately 1% to
$1.14 billion from $1.15 billion at securitization. The
Certificates are collateralized by 80 mortgage loans ranging in
size from less than 1% to 11% of the pool, with the top ten loans
representing 53% of the pool. There is one loan with an
investment-grade credit assessment, representing approximately 9%
of the pool.

Seven loans, representing 8% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance. There are currently no loans in special
servicing.

Moody's was provided with full year 2011 and partial 2012
operating results for 100% and 75%, respectively, of the pool's
loans. Moody's weighted average LTV is 93%, essentially the same
as at securitization. Moody's net cash flow reflects a weighted
average haircut of 11% to the most recently available full year
net operating income. Moody's value reflects a weighted average
capitalization rate of 9.7%.

Moody's actual and stressed DSCRs are 1.46X and 1.13X, essentially
the same as at securitization. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The one loan with an investment-grade credit assessment is the ELS
Portfolio Loan ($100.0 million -- 8.7% of the pool), which is
secured by 12 cross-collateralized/cross-defaulted loans for
manufactured housing communities and recreational vehicle (RV)
parks. Located across six states, the portfolio consists of 5,225
pads. As of September 2012, the weighted average occupancy was 93%
compared to 99% at securitization, excluding the RV parks. The
loan is partial term interest-only. The sponsor is MHC Operating
Ltd. Partnership. Moody's credit assessment and hurdle DSCR are
Baa3 and 1.43X, the same as at securitization.

The top three conduit loans represent approximately 18% of the
pool. The largest conduit loan is the Meadowood Mall Loan ($123.3
million -- 10.8% of the pool), which is secured by 404,865 square
feet (SF) of mall space that is part of a larger 878,000 SF,
single-story, enclosed regional mall in Reno, Nevada. Mall anchors
include J.C. Penney, Sears and two Macy's and Macy's Men's and
Home store. As of September 2012, the collateral was 88% leased
compared to 86% at securitization, excluding Sports Authority,
which vacated in December 2011. The tenant is obligated to
continue paying rent through 2015. Moody's did not account for
this tenant's rent in the cash flow analysis. The sponsors are the
Mills Ltd. Partnership, Simon Property Group and GM Pension
Trusts. Moody's LTV and stressed DSCR are 96% and 1.05X,
essentially the same as at securitization.

The second largest conduit loan is the SunTrust International
Center Loan ($61.9 million -- 5.4% of the pool), which is secured
by a 420,000 SF, 31-story office building in downtown Miami,
Florida. As of September 2012, the property was approximately 83%
leased, the same as at securitization. The largest tenant is
Akerman, Senterfitt and Edison (28% of the net rentable area
(NRA); lease expiration in 10/2018). The loan is partial term
interest-only. The sponsor is Crocker Partners. Moody's LTV and
stressed DSCR are 113% and 0.93X, the same as at securitization.

The third largest conduit loan is the LHG Hotel Portfolio ($58.9
million -- 5.2% of the pool ), which is secured by a portfolio of
12 limited service hotels, comprised of 852 rooms across six
states. The hotel flags are Fairfield Inn, Fairfield Inn & Suites,
Courtyard by Marriot and Country Inn & Suites. As of September
2012, the weighted average occupancy rate and revenue per
available room (RevPAR) were 75.9% and $77.02. For the trailing
12-month period ending in September 2011, the occupancy rate and
RevPAR were 76.8% and $72.07. Moody's LTV and stressed DSCR are
91% and 1.36X, essentially the same as at securitization.


GS MORTGAGE 2013-GC10: S&P Assigns 'BB' Rating to Class E Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its 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 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

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.


INDEPENDENCE I CDO: Fitch Affirms 'D' Rating on Class B Notes
-------------------------------------------------------------
Fitch Ratings has upgraded one and affirmed one class of notes
issued by Independence I CDO, Ltd./Inc. as follows:

-- $14,711,059 class A notes upgraded to 'Asf' from 'BBBsf',
    Outlook Stable;

-- $50,000,000 class B notes affirmed at 'Dsf'.

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 February 2012, the credit quality
of the collateral has deteriorated with approximately 25.6% of the
portfolio downgraded a weighted average of 4.8 notches. 83.7% of
the portfolio has a Fitch derived rating below investment grade
and 30.8% is considered to be defaulted by the trustee, compared
to 77.2% and 20.9%, respectively, at last review.

Key Rating Drivers:

The upgrade to the class A notes is due to the significant
amortization offsetting the deterioration of the underlying
collateral. Interest and principal collections have been diverted
to redeem the class A notes due to the acceleration following an
event of default. Since the last review, the notes have received
approximately $20.5 million, or 58.2% of its previous balance, in
principal repayment. The amount of interest collections diverted
to pay down the notes has increased after the expiration of the
transaction's interest rate swap in March 2012. Fitch maintains a
Stable Outlook on the class to reflect the available cushion in
the cash flow modeling results to mitigate potential further
negative migration in the portfolio.

Due to the acceleration, the class B notes have not been receiving
their interest on each quarterly distribution date. The class B
notes are non-deferrable and are affirmed at 'Dsf'.

Independence I is a cash flow structured finance collateralized
debt obligation (SF CDO) that closed on Dec. 18, 2000. The
portfolio is monitored by Declaration Management & Research LLC
and is composed of residential mortgage-backed securities (29.8%),
commercial asset-backed securities (25.2%), commercial mortgage-
backed securities (24.5%), SF CDOs (15.7%) and corporate CDOs
(4.9%) from 1996 through 2003 vintage transactions.


INSTITUTIONAL MORTGAGE 2013-3: DBRS Rates Cl. F Securities 'BB'
---------------------------------------------------------------
DBRS has assigned final ratings to the following classes of
Institutional Mortgage Securities Canada Inc., Series 2013-3.

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class B at AA (sf)
-- Class C at A (sf)
-- Class D at BBB (sf)
-- Class E at BBB (low) (sf)
-- Class F at BB (sf)
-- Class G at B (sf)
-- Class X at AAA (sf)

The collateral for the transaction consists of 38 fixed-rate loans
secured by 43 properties.  The 38 loans in the transaction have
terms of approximately five to ten years and are subject to
remaining amortization schedules ranging from 16 to 30 years.  In
addition, 90.7% of the pool (by dollar balance) has partial or
full recourse to the respective sponsor.

A cash flow underwriting review of 35 of the 38 loans in the
transaction was completed by DBRS, resulting in a DBRS weighted-
average term debt service coverage ratio (DSCR) and debt yield of
1.36x and 9.1%, respectively.


JP MORGAN 2006-FL1: S&P Cuts Rating on Class K Notes to 'D'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of commercial mortgage pass-through certificates from
JPMorgan Chase Commercial Mortgage Securities Corp.'s Series
2006-FL1, a U.S. commercial mortgage-backed securities (CMBS)
transaction.  At the same time, Standard & Poor's removed these
ratings from CreditWatch with negative implications, where they
were placed on Dec. 18, 2012.  In addition, Standard & Poor's
withdrew its 'AAA (sf)' rating on the Class X-2 certificates
from the same transaction.

The downgrades of Classes G, H, and J follow S&P's analysis of the
transaction, which included its revaluation of the remaining
floating-rate loan, the transaction structure, liquidity available
to the trust, and losses that S&P anticipates will occur upon the
eventual resolution of the sole remaining loan in the trust.  S&P
also considered its expectation--based on its discussions with the
special servicer, C-III Asset Management LLC (C-III)--of
additional interest shortfalls on the classes due to an appraisal
reduction amount (ARA) that S&P anticipates to be effected on the
sole remaining collateral in the trust as early as in the March
2013 reporting cycle.

S&P lowered its rating on Class K to 'D (sf)' due to accumulated
interest shortfalls that it believes will remain outstanding in
the near term.  Class K has accumulated interest shortfalls
outstanding for four months.

S&P withdrew its 'AAA (sf)' rating on the Class X-2 interest-only
(IO) certificates because the ratings on the rated principal and
interest paying classes are now below 'AA- (sf)' in accordance
with S&P's IO criteria.

"We placed our ratings on Classes G, H, J, and K on CreditWatch
negative on Dec. 18, 2012, because we expected additional interest
shortfalls on these classes due to an ARA that we anticipate to be
effected on the sole remaining specially serviced collateral, the
Independence Mall loan, in the trust as soon as the next reporting
cycle.  According to the special servicer, C-III, two updated
appraisal values were recently finalized and accepted. C-III
informed us that it is currently working on the ARA calculation
based on the recent appraisal values.  We believe that there
likely will be a significant decline in the value of the property,
in view of the continued decline in occupancy and expected
decrease in net cash flow," S&P said.

As of the Jan. 15, 2013, trustee remittance report, the trust
consisted of one remaining floating-rate amortizing loan indexed
to one-month LIBOR--the Independence Mall loan.  The one-month
LIBOR rate was 0.209% according to the January 2013 trustee
remittance report.

The Independence Mall loan has a trust and whole-loan balance of
$70.9 million and a reported total trust exposure of
$71.8 million.  The loan was transferred to the special servicer
on Aug. 27, 2012, due to imminent payment default.  The loan
matured on Feb. 9, 2013.  The payment status of the loan is
currently reported as 90-plus days delinquent.  C-III indicated
that it is currently waiting on the borrower's proposal for a
discounted payoff as well as note sale option.  The loan is
secured by 679,705 sq. ft. of an 830,158-sq.-ft. regional mall in
Kingston, Mass.  The master servicer, Wells Fargo Bank N.A.,
reported a 0.96x debt service coverage for the three months ended
March 31, 2012, and occupancy for the collateral dropped to 61.4%,
according to the Sept. 30, 2012, rent roll, following H&M Group's
vacancy (34,000 sq. ft.) in 2012.  This compares with 67.5%
occupancy as of the Dec. 31, 2011, rent roll. Anchor tenants in
the collateral include Target Corp. (126,000 sq. ft.), Sears
Holding Corp. (79,441 sq. ft.), and Regal Cinema (58,115 sq. ft.),
according to the September 2012 rent roll.  The loan amortizes on
a 20-year schedule.

S&P based its analysis, in part, on a review of the borrower's
operating statements for the year-end 2012, 2011, and 2010 and the
Sept. 30, 2012, rent rolls.  The property reported declining
revenue due to decreased occupancy over the past four years, which
the special servicer primarily attributed to the borrower's
inability to retain or attract new tenants.  S&P's adjusted
valuation, using an 8.0% capitalization rate, yielded an in-trust
stressed loan-to-value ratio that was significantly above 100%.
S&P expects a significant loss upon the eventual resolution of
this loan.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED AND REMOVED FROM CREDITWATCH NEGATIVE

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates Series 2006-FL1
                    Rating
Class     To                    From
G         BB+ (sf)              AA- (sf)/Watch Neg
H         B- (sf)               A-(sf)/Watch Neg
J         CCC- (sf)             BB (sf)/Watch Neg
K         D (sf)                CCC (sf)/Watch Neg

RATING WITHDRAWN

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates Series 2006-FL1
                    Rating
Class     To                    From
X-2       NR                    AAA (sf)

NR-Not rated.


JP MORGAN 2007-CIBC20: Fitch Lowers Rating on Class N Notes to 'D'
------------------------------------------------------------------
Fitch Ratings has downgraded 13 classes, removed two from Rating
Watch Negative, and affirmed seven classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust, (JPMCC) commercial mortgage
pass-through certificates series 2007-CIBC20 due to increased loss
expectations associated with the specially serviced assets and on
performing loans with declines in performance indicative of a
higher probability of default.

Rating Sensitivities

Fitch modeled losses of 13.1% of the remaining pool; expected
losses on the original pool balance total 13.5%, including $45.8
million or 1.8% of the original pool balance in realized losses to
date. This is an increase from the previous modeled 11.6% of
original pool balance, and is primarily attributed to declining
valuations on the specially serviced assets. Fitch has designated
52 loans (32.9%) as Fitch Loans of Concern, which includes 15
specially serviced assets (15.8%).

As of the January 2013 distribution date, the pool's aggregate
principal balance has been reduced by 10.7% to $2.27 billion from
$2.54 billion at issuance. No loans have defeased since issuance.
Interest shortfalls are currently affecting classes L through NR.

The largest contributor to expected losses is the North Hills Mall
loan (6.2% of the pool), which is secured by a 576,431 square foot
(sf) regional lifestyle center located in Raleigh, NC within the
Raleigh-Durham-Chapel Hill MSA, referred to as 'The Research
Triangle'. The property is anchored by J.C. Penney, Regal
Entertainment, REI, and Target (not part of the collateral). There
is also a 101,354 sf office component. The 200 room Renaissance
Hotel is not part of the collateral. The property has struggled
with low cash flow and declining debt service since issuance.
Although as of June 2012, the debt-service coverage ratio (DSCR)
has shown improvement to 1.17x from 1.06x at year-end (YE) 2011
and 1.20x at issuance. The property is 98.3% occupied as of
October 2012. There is approximately 10% of the net rentable
scheduled to roll in 2014. Per REIS, as of the third quarter (3Q)
2012, the Raleigh retail market had a vacancy rate of 9.5% with
asking rents at $18.57. The average in-line base rents at the
property are slightly above market.

The next largest contributor to expected losses is the specially-
serviced STF Portfolio (1.9%), originally secured at issuance by a
portfolio of 19 properties totaling 1.2 million sf located in
McAllen, TX, El Paso, TX and Santa Theresa, NM. The loan
transferred to special servicing in August 2010 for payment
default. In July 2012, the special servicer foreclosed on 17
properties, the remaining two NM properties are expected to be
foreclosed in February 2013. The special servicer is in
discussions with 9 existing tenants for a renewal of approximately
96,891 sf and three new leases have been signed. There are eight
properties currently remaining in the portfolio.

The third largest contributor to expected losses is the specially-
serviced Baldwin Park Retail asset (1.8%), which is secured by an
182,464 sf retail property located in Orlando, FL. The property is
anchored by a Publix, CVS, and other small retail units. The asset
transferred into special servicing in June 2010 for payment
default. Foreclosure occurred in November 2012. As of December
2012, the property was 73.6% occupied with a DSCR of 0.34x. Per
REIS as of the fourth quarter (4Q) 2012, the Orlando retail market
had a vacancy rate of 13.7%. The Northeast submarket had vacancy
rates of 11.5% and 12.3% for anchored and non-anchored retail.

Fitch downgrades and removes from Rating Watch Negative these two
classes:

--$219.3 million class A-M to 'Asf' from 'AAAsf'; Outlook Stable;
--$35 million class A-MFX to 'Asf' from 'AAAsf'; Outlook Stable.

In addition Fitch downgrades and assigns Rating Outlooks or
Recovery Estimates (REs) to these classes as indicated:

-- $152.6 million class A-J to 'Bsf' from 'BBB-sf'; Outlook
   Negative;
-- $31.8 million class B to 'CCCsf' from 'BBsf'; RE 100%;
-- $25.4 million class C to 'CCCsf' from 'Bsf'; RE 100%;
-- $28.6 million class D to 'CCsf' from 'CCCsf'; RE 10%;
-- $22.3 million class E to 'CCsf' from 'CCCsf'; RE 0%;
-- $22.3 million class F to 'CCsf' from 'CCCsf'; RE 0%;
-- $25.4 million class G to 'CCsf' from 'CCCsf'; RE 0%;
-- $35 million class H to 'Csf' from 'CCsf'; RE 0%;
-- $31.8 million class J to 'Csf' from 'CCsf'; RE 0%;
-- $28.6 million class K to 'Csf' from 'CCsf'; RE 0%.
-- $1.6 million class N to 'D' from 'Csf'; RE 0%.

Fitch affirms these classes:

-- $14 million class A-2 at 'AAAsf'; Outlook Stable;
-- $208.6 million class A-3 at 'AAAsf'; Outlook Stable;
-- $991.7 million class A-4 at 'AAAsf'; Outlook Stable;
-- $73.1 million class A-SB at 'AAAsf'; Outlook Stable;
-- $281.6 million class A-1A at 'AAAsf'; Outlook Stable;
-- $31.8 million class L at 'Csf'; RE 0%;
-- $9.5 million class M at 'Csf'; RE 0%;

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


KINGSLAND III: S&P Affirms 'BB' Rating on 2 Note Classes
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-3 and B notes from Kingsland III Ltd., a U.S. collateralized
loan obligation (CLO) transaction managed by Kingsland Capital
Management LLC.  At the same time, S&P affirmed its ratings on the
class A-1, A-2, C-1, C-2, D-1, and D-2 notes.

The upgrades mainly reflect an improvement in the
overcollateralization (O/C) available to support the notes since
the time of S&P's last actions in March 2011, when it last
upgraded most of the notes.  The trustee reported the following
O/C ratios in the January 2013 monthly report:

   -- The class A O/C ratio was 128.52%, compared with a reported
      ratio of 126.02% in February 2011;

   -- The class B O/C ratio was 117.85%, compared with a reported
      ratio of 115.55% in February 2011;

   -- The class C O/C ratio was 110.63%, compared with a reported
      ratio of 108.47% in February 2011; and

   -- The class D O/C ratio was 108.51%, compared with a reported
      ratio of 106.39% in February 2011.

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

Kingsland III Ltd is in its reinvestment period until August 2013.
After that time, S&P expects the paydown of the senior notes to
begin.  All of the rated notes are currently at 100% of their
original issuance amount.

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

Kingsland III Ltd.
                   Rating
Class         To           From
A-1           AAA (sf)     AAA (sf)
A-2           AA+ (sf)     AA+ (sf)
A-3           AA (sf)      AA- (sf)
B             A (sf)       BBB+ (sf)
C-1           BB+ (sf)     BB+ (sf)
C-2           BB+ (sf)     BB+ (sf)
D-1           BB (sf)      BB (sf)
D-2           BB (sf)      BB (sf)


TRANSACTION INFORMATION
Issuer:             Kingsland III Ltd.
Coissuer:           Kingsland III Corp.
Collateral manager: Kingsland Capital Management LLC
Underwriter:        JPMorgan Chase Bank N.A.
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CDO


LB MULTIFAMILY 1991-4: Moody's Keeps Caa1 Rating on Cl. A-2 Certs
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of two classes of
LB Multifamily Mortgage Trust, Series 1991-4 as follows:

Cl. A-1 Senior Secured Pass-Through Apr 25, 2021, Affirmed at Caa1
(sf); previously on Sept 11, 2008 Affirmed at Caa1 (sf)

Cl. A-2 Senior Secured Pass-Through Apr 25, 2021, Affirmed at B1
(sf); previously on Sept 11, 2008 Upgraded to B1 (sf)

Ratings Rationale

The Class A-1 affirmation is due to the current rating being
consistent with the losses the class has experienced. The Class A-
2 affirmation is due to sufficient credit support provided by the
reserve fund.

This transaction is classified as a small balance CMBS
transaction. Small balance transactions, which represent
approximately 1% of the Moody's rated conduit/fusion universe,
have generally experienced higher defaults and losses than
traditional conduit and fusion transaction.

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 methodology used in this rating was "Moody's Approach to
Rating Structured Finance Securities in Default" published in
November 2009.

Other Factors used in this rating are described in "CMBS: Moody's
Approach to Small Loan Transactions" published in December 2004.

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors. There was no
model used in the review of this transaction.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated February 16, 2012.

Deal Performance

As of the January 25, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 99% to $306,682
from $105.8 million at securitization. The Certificates are
collateralized by one mortgage loan, which is secured by a multi-
family property located in Huntington Beach, California. The loan
is fully amortizing and matures in 2019. It has amortized by 68%
since securitization. The loan is current.

The pool has experienced aggregate realized losses totaling $33.5
million, which have eliminated non-rated Classes B, C and D and
resulted in a $9.2 million loss for Class A-1. Class A-2 has not
experienced any losses to date. Realized losses allocated to the
Class A-2 certificates are offset by a reserve fund held by the
Trustee. It is anticipated that there are sufficient funds
available in the reserve fund to offset any potential losses to
Class A-2. However, due to exposure to only one remaining small
balance loan Moody's is concerned about the possibility of
interest shortfalls.


LB-UBS 2002-C4: S&P Lowers Rating on Class M Notes to 'D'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
H commercial mortgage pass-through certificates from LB-UBS
Commercial Mortgage Trust 2002-C4, a U.S. commercial mortgage-
backed securities (CMBS) transaction.  In addition, S&P lowered
its rating on class M and affirmed its ratings on three other
classes from the same transaction.

S&P's rating actions follow its analysis of the transaction
primarily using its criteria for rating U.S. and Canadian CMBS
transactions.  S&P's analysis included a review of the credit
characteristics of all of the remaining assets in the pool, the
transaction structure, and the liquidity available to the trust.

The upgrade of the class H certificates reflects S&P's expected
available credit enhancement for the class, which S&P believes is
greater than its most recent estimate of necessary credit
enhancement for the most recent rating level, as well as S&P's
reviews regarding the current and future performance of the
collateral supporting the transaction.

S&P lowered its rating on the class M certificates to 'D (sf)'
because it expects the accumulated interest shortfalls to remain
outstanding for the foreseeable future.  As of the Jan. 17, 2013,
trustee remittance report, the trust experienced net monthly
interest shortfalls totaling $44,836, primarily related to
appraisal subordinate entitlement reduction (ASER) amounts of
$47,238 and special servicing fees of $4,421, offset by a one-time
ASER recovery of $6,823.  The net interest shortfalls affected all
classes subordinate to and including class M.  The class M
certificates have accumulated interest shortfalls outstanding for
six consecutive months.

The affirmations of S&P's ratings on the principal and interest
certificates reflects its expectation that the available credit
enhancement for these classes will be within S&P's estimate of the
necessary credit enhancement required for the current outstanding
ratings.  S&P affirmed its ratings on these classes to also
reflect the credit characteristics and performance of the
remaining assets, as well as the transaction-level changes.

S&P tempered its rating actions on classes H, J, K, and L because
it also considered that six ($21.2 million, 30.8%) of the
remaining 12 assets ($68.7 million) are with the special servicer,
which could lead to additional interest shortfalls and decreased
liquidity support available to the trust.

Using servicer-provided financial information, S&P calculated a
Standard & Poor's adjusted debt service coverage (DSC) of 1.30x
and a Standard & Poor's loan-to-value (LTV) ratio of 27.7% for
five of the 12 remaining assets in the pool.  The DSC and LTV
calculations exclude the six assets ($21.2 million, 30.8%) that
are with the special servicer (details below) and one nonreporting
loan ($1.1 million, 1.5%).

As of the Jan. 17, 2013, trustee remittance report, the collateral
pool had an aggregate trust balance of $68.7 million, down from
$1.5 billion at issuance.  The pool comprises 10 loans and two
real estate owned (REO) assets, down from 114 loans at issuance.
To date, the transaction has experienced losses totaling
$31.7 million or 2.2% of the transaction's original certificate
balance.  Six ($21.2 million, 30.8%) of the remaining 12 assets
are with the special servicer, which S&P discusses below.  There
were no assets reported on the master servicer's watchlist.
Excluding the six specially serviced assets and one nonreporting
loan, no loans had a reported DSC of below 1.00x.  Details on
the largest asset in the pool are as follows:

The 1166 Avenue of the Americas loan ($39.0 million, 56.7%), the
largest asset in the pool, is one of two loans secured by a
commercial office condominium unit, which consists of floors seven
to 21 (excluding floor 13) totaling 560,925 sq. ft. of a 44-story,
1.56 million-sq.-ft. class A office building in midtown Manhattan.
The other fixed-rate amortizing mortgage loan totaling
$147.4 million is in the 1166 Avenue of the Americas Commercial
Mortgage Trust 2002-C5 (1166 AofA) transaction.  The trust balance
is pari passu with a $72.4 million portion of the 1166 AofA loan.
The remaining $75.0 million of the 1166 AofA loan is subordinate
to the pari passu components.  According to the transaction's
documents, prior to an event of default, principal payments are
applied first to fully amortize the trust balance.  The master
servicer, Wells Fargo Bank N.A., reported a DSC of 1.39x on the
whole-loan balance for the nine months ended Sept. 30, 2012.

                    SPECIALLY SERVICED ASSETS

As of the Jan. 17, 2013, trustee remittance report, six assets
($21.2 million, 30.8%) are with the special servicer, LNR Partners
LLC (LNR).  As of the January 2013 trustee remittance report, the
reported payment status of the specially serviced assets is as
follows: two are REO ($7.6 million, 11.0%) and four are
nonperforming matured balloon loans ($13.6 million, 19.8%).
Appraisal reduction amounts (ARAs) totaling $6.1 million are in
effect for five of the six assets. Details on the six assets are
below:

The University Cabana asset, a 496-unit, multifamily apartment
complex in Memphis, Tenn., is the second-largest asset in the pool
and the largest asset with the special servicer.  The asset has a
trust balance of $6.1 million (8.8%) and a reported total exposure
of $7.4 million.  The loan was transferred to the special servicer
on April 25, 2011, and the property became REO on March 9, 2012.
LNR reported that the property was 47.0% occupied as of
September 2012.  LNR stated that it plans to list the property for
sale by the end of the first quarter of 2013.  An ARA of
$2.3 million is in effect for this asset.  S&P expects a moderate
loss upon the eventual resolution of this asset.

The One St. Louis Centre loan, the third-largest asset in the
pool, is secured by a 104,659-sq.-ft. office property in Mobile,
Ala.  The loan has a trust balance of $6.0 million (8.7%) and a
reported total exposure of $6.3 million.  The loan was transferred
to LNR on Sept. 11, 2012, due to the borrower's inability to pay
off the loan by its Aug. 11, 2012, maturity date.  LNR stated that
it is evaluating various liquidation strategies, including
foreclosure.  An ARA of $1.5 million is in effect for this loan.
S&P expects a minimal loss upon the eventual resolution of this
loan.

The Waterbury Multifamily Portfolio loan, the fifth-largest asset
in the pool, is secured by nine multifamily apartment complexes
totaling 163 units in Waterbury, Conn.  The loan has a trust
balance of $2.8 million (4.1%) and a reported total exposure of
$4.5 million.  The loan was transferred to the special servicer on
March 18, 2010, because it was 60-plus-days delinquent.  LNR
informed S&P that a receiver is in place and it is proceeding with
foreclosure.  S&P expects a minimal loss upon the eventual
resolution of this loan.

The Money World Retail Plaza loan, the sixth-largest asset in the
pool, is secured by a 12,937-sq.-ft. retail property in Las Vegas.
The loan has a trust balance of $2.6 million (3.7%) and a reported
total exposure of $2.7 million.  The loan was transferred to LNR
on Jan. 19, 2012, because it was 60-plus-days delinquent.  LNR
indicated that updated property performance data is not available
and it is currently pursuing foreclosure.  An ARA of $897,978 is
in effect for this loan.  S&P expects a moderate loss upon the
eventual resolution of this loan.

The Parvenu Plaza loan, the eighth-largest asset in the pool, is
secured by a 28,092-sq.-ft. retail property in Orem, Utah.  The
loan has a trust balance of $2.2 million (3.3%) and a reported
total exposure of $2.5 million.  The loan was transferred to LNR
on May 2, 2012, because it was 60-plus-days delinquent.  LNR
stated that it is currently pursuing foreclosure.  An ARA of
$897,967 is in effect for this loan.  S&P expects a moderate loss
upon the eventual resolution of the loan.

The Clarcona Crossing asset, consisting of three retail buildings
totaling 42,251 sq. ft. in Orlando, Fla., is the ninth-largest
asset in the pool and the smallest asset with LNR.  The asset has
a trust balance of $1.5 million (2.2%) and a reported total
exposure of $1.7 million.  The loan was transferred to LNR on
Aug. 5, 2011, due to imminent default and the property became REO
on Oct. 1, 2012.  LNR stated that it plans to list the property
for sale after leasing up the property.  An ARA of $511,638 is in
effect for this asset.  S&P expects a moderate loss upon the
eventual resolution of the asset.

As it relates to the above asset resolutions, minimal loss is
considered to be less than 25%, moderate loss is between 26% and
59%, and significant loss is 60% or greater.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING RAISED

LB-UBS Commercial Mortgage Trust 2002-C4
Commercial mortgage pass-through certificates
               Rating
Class       To            From     Credit enhancement (%)
H           AA+ (sf)      A (sf)                    88.97

RATING LOWERED

LB-UBS Commercial Mortgage Trust 2002-C4
Commercial mortgage pass-through certificates
               Rating
Class       To            From     Credit enhancement (%)
M           D (sf)        CCC- (sf)                 12.16

RATINGS AFFIRMED

LB-UBS Commercial Mortgage Trust 2002-C4
Commercial mortgage pass-through certificates

Class      Rating      Credit enhancement (%)
J          BBB+ (sf)                    70.43
K          BBB- (sf)                    51.89
L          CCC (sf)                     22.75


LB-UBS 2002-C7: S&P Lowers Rating on Class Q Notes to 'D'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its rating to 'A+ (sf)'
on the class L commercial mortgage pass-through certificates from
LB-UBS Commercial Mortgage Trust 2002-C7, a U.S. commercial
mortgage-backed securities (CMBS) transaction.  S&P also lowered
its ratings on the class P and Q certificates.  In addition, S&P
affirmed its ratings on two other classes from the same
transaction.

S&P's rating actions follow its analysis of the transaction
primarily using its criteria for rating U.S and Canadian CMBS.
S&P's analysis included a review of the credit characteristics of
all of the assets in the pool, the transaction structure, and the
trust's available liquidity.  The upgrade reflects Standard &
Poor's expected available credit enhancement for the affected
tranche, which S&P believes is greater than its most recent
estimate of necessary credit enhancement for the rating level.
The upgrade also reflects S&P's views regarding the current and
future performance of the transaction's collateral.

"We lowered our rating to 'D (sf)' on class Q to reflect 12 months
of outstanding accumulated interest shortfalls.  We expect these
accumulated interest shortfalls to remain outstanding for the
foreseeable future.  We lowered our rating on class P to 'CCC-
(sf)' to reflect three months of outstanding accumulated interest
shortfalls as well as reduced liquidity resulting from the
interest shortfalls that are affecting the trust.  The interest
shortfalls resulted primarily from appraisal subordination
entitlement reduction (ASER) amounts ($25,803) related to four
($12.2 million, 30.8%) of the six assets ($16.8 million, 42.6%)
that are currently with the special servicer, LNR Partners LLC
(LNR), and special servicing fees ($3,522).  As of the Jan. 17,
2013, remittance report, appraisal reduction amounts (ARAs)
totaling $3.6 million were in effect for four assets, generating
ASER amounts totaling $25,803.  The current reported interest
shortfalls totaled $29,637 and have affected all of the classes
subordinate to and including class P," S&P said.

As of the Jan. 17, 2013, trustee remittance report, the collateral
pool consisted of one real estate-owned (REO) asset and 12 loans
with an aggregate principal balance of $39.5 million, down from
101 loans with an aggregate balance of $1.19 billion at issuance.
One loan, the Matthews Crossing Shopping Center ($6.6 million,
16.7%), is defeased.  Based on the most recent data from the
master servicer (Wells Fargo Bank N.A.), using Standard & Poor's
adjusted net cash flow (NCF) and cap rates, S&P has calculated a
weighted average debt service coverage(DSC) for those remaining
loans (which are not in special servicing and are not defeased) of
1.10x and a weighted average loan-to-value (LTV) of 52.2%.

As of the Jan. 17, 2013, trustee remittance report, six assets
($16.8 million, 42.6%) in the pool were in special servicing.  The
reported payment status of the specially serviced assets is as
follows: one is REO ($8.4 million, 21.2%); four are in foreclosure
($6.9 million, 17.4%); and, one is a nonperforming matured balloon
loan ($1.6 million, 4.0%).  There were two loans ($4.9 million,
12.3%) on the servicer's watchlist.  Subsequent to the January
reporting period, one of the two watchlist loans, the Hawthorn
Place Townhomes loan ($1.7 million, 4.3%), was transferred to
special servicing.  On Feb. 4, 2013, the Doral Distribution loan
($3.1 million, 7.9%), which was in special servicing, paid off in
full. ARAs totaling $3.6 million were in effect against four of
the six specially serviced assets.

The University Plaza REO asset ($8.4 million, 21.2%) is the
largest specially serviced asset and the largest asset in the
pool.  The property (a 96,475-sq.-ft. retail shopping center in
Houston, Texas) became REO on June 7, 2011.  According to LNR, the
property is now 70% leased, and the management company is seeking
an anchor for the remaining space.  An ARA of $2.3 million is in
effect for this asset.  A moderate loss is expected upon
disposition of this asset.  S&P defines a moderate loss as ranging
between 26% and 60%.

The remaining five specially serviced assets have individual
balances that represent less than 8.0% of the total pool balance.
ARAs totaling $1.3 million were in effect against three of the
five remaining specially serviced assets.

Based solely on S&P's valuation of the specially serviced assets,
it expects the trust to incur losses approximating 0.4% of the
original outstanding trust balance upon the resolution or
liquidation of these assets.  To date, the trust has incurred
losses totaling $11.1 million, or 0.9% of the original outstanding
trust balance.

While adjusted credit enhancement levels were sufficient to
support upgrades of classes M and N, S&P's rating actions were
tempered by the reduced liquidity available to these classes due
to interest shortfalls.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

SEC Rule 17g-7 requires an NRSRO, for any report accompanying a
credit rating relating to an asset-backed security as defined in
the Rule, to include a description of the representations,
warranties and enforcement mechanisms available to investors and a
description of how they differ from the representations,
warranties and enforcement mechanisms in issuances of similar
securities.  The Rule applies to in-scope securities initially
rated (including preliminary ratings) on or after Sept. 26, 2011.
If applicable, the Standard & Poor's 17-g7 Disclosure Reports
included in this credit rating report are available at:

            http://standardandpoorsdisclosure-17g7.com

RATING RAISED

LB-UBS Commercial Mortgage Trust 2002-C7
Commercial mortgage pass-through certificates

              Rating                     Credit
Class    To         From        enhancement (%)
L        A+ (sf)    BBB+ (sf)             91.83


RATINGS LOWERED

LB-UBS Commercial Mortgage Trust 2002-C7
Commercial mortgage pass-through certificates

              Rating                     Credit
Class    To         From        enhancement (%)
P        CCC- (sf)  CCC+ (sf)             35.54
Q        D (sf)     CCC- (sf)             24.28

RATINGS AFFIRMED

LB-UBS Commercial Mortgage Trust 2002-C7
Commercial mortgage pass-through certificates

Class    Rating           Credit enhancement (%)
M        BB (sf)                           73.07
N        B+ (sf)                           58.06


LONGFELLOW PLACE: S&P Assigns 'BB' Rating to Class E Notes
----------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
Longfellow Place CLO Ltd./Longfellow Place CLO LLC's $463.0
million floating-rate notes.

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

The ratings reflect S&P's view of:

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

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

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

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

   -- The collateral manager's experienced management team.

   -- S&P's projections regarding the timely interest and ultimate
      principal payments on the rated notes, which S&P assessed
      using its cash flow analysis and assumptions commensurate
      with the assigned ratings under various interest-rate
      scenarios, including LIBOR ranging from 0.3523%-13.8391%.

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

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

      http://standardandpoorsdisclosure-17g7.com/1288.pdf

RATINGS ASSIGNED

Longfellow Place CLO Ltd./Longfellow Place CLO LLC

Class                   Rating           Amount
                                       (mil. $)
A                       AAA (sf)         325.00
B                       AA (sf)           52.00
C (deferrable)          A (sf)            41.00
D (deferrable)          BBB (sf)          23.00
E (deferrable)          BB (sf)           22.00
F (deferrable)          NR                15.50
Subordinated notes      NR                36.50

NR-Not rated.


MERRILL LYNCH 2002-CA: DBRS Hikes Rating on K Debt From BB(high)
----------------------------------------------------------------
DBRS has upgraded four classes of Merrill Lynch Financial Assets
Inc., Series 2002-Canada 8 as follows:

-- Class G to AAA (sf) from AA (sf)
-- Class H to AA (sf) from A (high) (sf)
-- Class J to A (sf) from BBB (high) (sf)
-- Class K to BBB (low) (sf) from BB (high) (sf)

In addition, DBRS has confirmed five classes as follows:

-- Class D at AAA (sf)
-- Class E at AAA (sf)
-- Class F at AAA (sf)
--Class X-1 at AAA (sf)
-- Class X-2 at AAA (sf)

DBRS does not rate the $8.2 million first loss piece, Class L. All
trends are Stable

The rating upgrades reflect the strong performance the pool
continues to exhibit, with 45 loans having been successfully
repaid since issuance out of the original loan count of 70.  Since
the last DBRS rating action of the transaction in June 2012, 24
loans have repaid in full.  As of the February 2013 remittance
report, approximately 91.7% of the collateral has been reduced,
with 42.7% of collateral reduction having occurred since June
2012.  Additionally, two loans, representing 4.1% of the pool
balance, are defeased.

There are no loans in special servicing and four loans on the
servicer's watchlist, representing approximately 19.4% of the
current pool balance.  All four loans remain current and are being
monitored for a low debt service coverage ratio (DSCR).

As part of its review, DBRS analyzed the top 15 loans and the
loans on the servicer's watchlist, which comprise approximately
82.0% of the current pool balance.

DBRS has applied a net cash flow (NCF) stress scenario across all
the loans in the pool and the resulting DBRS required credit
enhancement levels, when compared with the current credit
enhancement levels to the bonds, warrant the rating upgrades.


MERRILL LYNCH 2002-MW1: Expected Losses Cue Moody's Downgrades
--------------------------------------------------------------
Moody's Investors Service downgraded the ratings of six classes
and affirmed the ratings of two classes of Merrill Lynch Mortgage
Trust, Commercial Mortgage Pass-Through Certificates, Series 2002-
MW1 as follows:

Cl. G, Affirmed A2 (sf); previously on Feb 23, 2012 Upgraded to A2
(sf)

Cl. H, Downgraded to Baa3 (sf); previously on Feb 23, 2012
Upgraded to Baa1 (sf)

Cl. J, Downgraded to B3 (sf); previously on Apr 3, 2006 Confirmed
at Ba2 (sf)

Cl. K, Downgraded to Caa3 (sf); previously on May 21, 2009
Downgraded to B3 (sf)

Cl. L, Downgraded to C (sf); previously on May 21, 2009 Downgraded
to Caa2 (sf)

Cl. M, Downgraded to C (sf); previously on May 21, 2009 Downgraded
to Ca (sf)

Cl. N, Affirmed C (sf); previously on Feb 23, 2012 Downgraded to C
(sf)

Cl. XC, Downgraded to Caa2 (sf); previously on Feb 22, 2012
Downgraded to Ba3 (sf)

Ratings Rationale

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

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

Moody's rating action reflects a cumulative base expected loss of
42.1% of the current balance. At last review, Moody's cumulative
base expected loss was 5.1%. Moody's cumulative base expected loss
plus realized loss is now 4.4% of the original pooled balance
compared to 3.5% at last review.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating CMBS Large Loan/Single
Borrower Transactions" published in July 2000. The methodology
used in rating Interest-Only Securities was "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012. The Interest-Only Methodology was used for the
rating of Class XC.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit assessment
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the credit assessment level, is incorporated
for loans with similar credit assessments in the same transaction.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 4 compared to 11 at Moody's prior review.

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

Since over half of the pool is in special servicing, Moody's also
utilized a loss and recovery approach in rating this deal. In this
approach, Moody's determines a probability of default for each
specially serviced loan and determines a most probable loss given
default based on a review of recent third-party appraisals and/or
broker's opinions of value (if available), other information from
the special servicer and available market data. The loss given
default for each loan also takes into consideration servicer
advances to date and estimated future advances and closing costs.
Translating the probability of default and loss given default into
an expected loss estimate, Moody's then applies the aggregate loss
from specially serviced loans to the most junior class(es) and the
recovery as a pay down of principal to the most senior class(es).

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(Moody's Surveillance Trends) and CMM
(Commercial Mortgage Metrics) on Trepp -- and on a periodic basis
through a comprehensive review. Moody's prior full review is
summarized in a press release dated February 23, 2012.

Deal Performance

As of the January 14, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 93% to $73.8
million from $1.1 billion at securitization. The Certificates are
collateralized by 7 mortgage loans ranging in size from 3% to 42%
of the pool. One loan, representing 3% of the pool, has defeased
and is secured by U.S. Government securities.

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

Nine loans have been liquidated from the pool, resulting in a
realized loss of $17.1 million (22% loss severity overall).
Currently four loans, representing 81% of the pool, are in special
servicing.

The largest specially-serviced loan is Seven Mile Crossing Loan
($31.3 million -- 42% of the pool) which is secured by three class
B office buildings with 346,265 SF located in Livonia, Michigan.
Since 2008, the property has been less than 70% leased and has not
generated enough cash flow to cover debt service. As of August
2012, the property was 64% leased as compared to 67% at last
review. The foreclosure was completed in November 2012 however
there is a six month redemption period therefore title of the
property will not transfer until May 2013.

The second-largest specially-serviced loan is the Lake Meridian
Marketplace Loan ($15.6 million -- 21% of the pool), which is
secured by a retail center located in Kent, Washington. As of
September 2012, the property was 59% leased as compared to 66% at
last review. The property was transferred to special servicing in
July 2012 due to maturity default. The largest tenant at the
property is 24 Hour Fitness which occupies 45,000 square feet. The
largest tenant's lease expires in July 2023.

The third-largest specially-serviced loan is the Lakes at College
Pointe Phase I Loan ($7.8 million -- 11% share of the pool), which
is secured by a 148 unit multifamily property located in Fort
Myers, Florida. The loan was transferred to special servicing in
May 2011 due to payment default. As of July 2012, the property was
79% leased as compared to 76% at last review.

The remaining specially serviced loan is the Foxfire/Cloister
Apartments Loan which is secured by a 226 unit multifamily
property located in High Point, North Carolina.

Moody's estimated an aggregate $30.8 million loss for the
specially serviced loans (52% expected loss on average).

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

The conduit is comprised of two loans totaling $11.9 million (16%
of the pool). The largest loan is the 4400 Matthew Drive Loan
($6.7 million -- 9% of the pool), which is secured by a 407,500
square-foot industrial property located in Flint, Michigan. The
property is fully leased to Android Industries. Moody's performed
a "Lit/Dark" analysis in valuing this property. The loan is on the
watchlist due to missing the ARD date of August 1, 2007. Moody's
LTV and stressed DSCR are 79% and 1.31X, respectively, compared
30% and 3.41X at last review.

The second largest loan is the King Center Square Loan ($5.2
million -- 7% of the pool), which is secured by a 94,428 square-
foot grocery anchored retail property located in Mount Vernon,
Illinois. As of September 2012, the property was 84% leased
compared to 87% at last review. The loan is on the watchlist due
to missing the ARD date of January 1, 2012. Moody's LTV and
stressed DSCR are 91% and 1.10X, respectively, compared 90% and
1.12X at last review.


MIDOCEAN CREDIT: S&P Assigns 'BB' Rating on Class D Notes
---------------------------------------------------------
Standard & Poor's Ratings Services made public its ratings on five
classes of notes issued by MidOcean Credit CLO I/MidOcean Credit
CLO I LLC, a collateralized loan obligation (CLO) transaction that
comprises primarily broadly syndicated senior-secured corporate
loans.  S&P made its ratings public at the issuer's request.

S&P's ratings reflect its assessment of:

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

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

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

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

   -- The collateral manager's and designated successor collateral
      manager's experienced management teams.

   -- 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 0.3050% to 13.8391%.

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

   -- The transaction's interest diversion test, a failure of
      which will lead to the reclassification of up to 75% of the
      excess interest proceeds that are available prior to paying
      uncapped administrative expenses, incentive management fees,
      and subordinated note payments into principal proceeds for
      the purchase of additional collateral assets during the
      reinvestment period.

The MidOcean Credit CLO I/MidOcean Credit CLO I LLC transaction's
characteristics include the following:

   -- Closing date: Jan. 24, 2013.

   -- Effective date: April 24, 2013.

   -- Reinvestment period end date: Jan. 15, 2016.

   -- Noncall period end date: Jan. 15, 2015.

   -- Stated maturity date: Jan. 15, 2024.

   -- Total preliminary rated amount: $370.75 million.

   -- Total note balance (including the subordinated notes):
      $425.27 million.

   -- Note proceeds (including unrated and subordinated notes) net
      of fees: $400.00 million.

   -- Collateral: A revolving pool consisting primarily of broadly
      syndicated senior-secured loans.

   -- Structure type: A cash flow CLO consisting of broadly
      syndicated loans.

   -- Structure purpose: Arbitrage.

   -- Management: An actively managed portfolio.

   -- Note payment frequency: Quarterly, commencing July 15, 2013.

   -- Issuer: MidOcean Credit CLO I (incorporated in the Cayman
      Islands).

   -- Co-issuer: MidOcean Credit CLO I LLC (incorporated in
      Delaware).

   -- Initial purchaser and placement agent: Citigroup Global
      Markets Inc.

   -- Trustee, collateral administrator, registrar, authenticating
      agent, securities intermediary, custodian, calculation agent
      and paying agent: Wells Fargo Bank N.A.

          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/1290.pdf

RATINGS MADE PUBLIC

MidOcean Credit CLO I/MidOcean Credit CLO I LLC

Class                 Rating      Amount (mil. $)
A-1                   AAA (sf)             252.00
A-2                   AA (sf)               49.70
B (deferrable)        A (sf)                32.50
C (deferrable)        BBB (sf)              20.55
D (deferrable)        BB (sf)               16.00


ML-CFC 2006-3: Fitch Cuts Ratings on Five Note Classes
------------------------------------------------------
Fitch Ratings has downgraded five classes and affirmed 15 classes
of ML-CFC Commercial Mortgage Trust, series 2006-3, 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 higher losses on the specially serviced loans
resulting from updated valuations, as well as continued
underperformance for several loans in the top 15, many of which
are in secondary or tertiary markets. Fitch modeled losses of 8.9%
of the remaining pool; expected losses on the original pool
balance total 10.8%, including losses already incurred. The pool
has experienced $71.1 million (2.9% of the original pool balance)
in realized losses to date. Fitch has designated 67 loans (39.1%)
as Fitch Loans of Concern, which includes 15 specially serviced
assets (7.6%). The negative Rating Outlook on Class AJ is due to
the relatively thin size of the tranches subordinate to it.

As of the January 2013 distribution date, the pool's aggregate
principal balance has been reduced by 10.8% to $2.16 billion from
$2.43 billion at issuance. Per the servicer reporting, one loan
(0.4% of the pool) has defeased since issuance. Interest
shortfalls are currently affecting classes F through Q.

The largest contributor to expected losses is the Atrium Hotel
Portfolio loan (11.3% of the pool), the largest loan in the pool.
The loan is secured by a portfolio of six full-service hotels
located in six metropolitan areas across six different states. The
properties are well located in their respective markets with close
proximate to downtown areas, airports, universities, and
convention centers. Five of the six hotels are flagged by Hilton
Hotels as Embassy Suites. The year-end (YE) December 2012 net
operating income (NOI) reported an 8% improvement over YE December
2011, primarily attributed to increased revenues at five out of
the six hotels. Due to loan amortization which began in October
2011, the YE 2012 NOI debt service coverage ratio (DSCR) reported
lower at 1.13 times (x), compared to the interest-only DSCR's of
1.21x and 1.24x for YE 2011 and YE 2010, respectively. The
portfolios combined occupancy reported at 74% for trailing 12
month (TTM) December 2012.

The second largest contributor to Fitch-modeled losses is secured
by a 156,846sf retail center located in Gibert, AZ (1.1%). The
movie theater anchored (28% of net rentable area (NRA)) property
had experienced cash flow issues from occupancy declines due to a
slow leasing market as well as newer competition in the subject
area. The loan transferred to special servicing in February 2011
due to payment default. The receiver, which was appointed in
November 2011, has been successful in negotiating leases with new
and existing tenants. The servicer reports property occupancy at
82% as of December 2012.

The third largest contributor to Fitch-modeled losses is secured
by a 142-unit multifamily property located in Tucson, AZ (0.9%).
The servicer reported current occupancy at 92%. The loan
transferred to the special servicer in December 2008 due to
payment default. The Borrower subsequently filed for Chapter 11
Bankruptcy in September 2009. In October 2010 the Bankruptcy Court
had ruled for the lender to modify the loan at specific terms,
which included a significant principal reduction. The special
servicer had appealed the ruling, which was denied by the US
District Court of AZ in July 2011. The servicer has re-appealed
the decision to the US Court of Appeals. According to the
servicer, briefings have been filed and are pending assignment to
judge.

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

-- $191 million class AJ to 'BBsf' from 'BBB-sf'; Outlook to
    Negative from Stable;
-- $48.5 million class B to 'CCCsf' from 'Bsf'; RE 75%;
-- $18.2 million class C to 'CCCsf' from 'B-sf'; RE 0%;
-- $48.5 million class D to 'CCsf' from 'CCCsf'; RE 0%;
-- $21.2 million class E to 'Csf' from 'CCsf'; RE 0%.

Fitch affirms these classes as indicated:

-- $116.1 million class A-2 at 'AAAsf'; Outlook Stable;
-- $34 million class A-3 at 'AAAsf'; Outlook Stable;
-- $83.8 million class A-SB at 'AAAsf'; Outlook Stable;
-- $971.8 million class A-4 at 'AAAsf'; Outlook Stable;
-- $301.5 million class A-1A at 'AAAsf'; Outlook Stable;
-- $242.5 million class AM at 'AAAsf'; Outlook Stable;
-- $36.4 million class F at 'Csf'; RE 0%.
-- $24.3 million class G at 'Csf'; RE 0%;
-- $21.2 million class H at 'Csf'; RE 0%;
-- $4.8 million class J at 'Dsf'; RE 0%;
-- Class K at 'Dsf'; RE 0%;
-- Class L at 'Dsf'; RE 0%;
-- Class M at 'Dsf'; RE 0%;
-- Class N at 'Dsf'; RE 0%;
-- Class P at 'Dsf'; RE 0%.

The balances for classes K through P have been reduced to zero due
to realized losses. The class A-1 certificate has paid in full.
Fitch does not rate the class Q certificate. Fitch previously
withdrew the ratings on the interest-only class XP and XC
certificates.


MORGAN STANLEY 2006-9: S&P Cuts Rating on Subordinate Notes to 'D'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the
subordinate junior super senior notes issued by Morgan Stanley
Managed ACES SPC's series 2006-9, a synthetic corporate
investment-grade collateralized debt obligation transaction.

The lowered ratings follow a number of write-downs of underlying
reference entities, which have caused the notes to breach their
attachment point.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING LOWERED

Morgan Stanley Managed ACES SPC
Series 2006-9
                  Rating
Class          To         From
SbJrSuprSr     D (sf)      CCC- (sf)


NATIONSLINK FUNDING: Moody's Keeps 'Ba3' Rating on Class X Certs
----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of four classes of
NationsLink Funding Corporation, Commercial Loan Pass-Through
Certificates, Series 1999-LTL-1 as follows:

  Cl. A-3 Certificate, Affirmed Aaa (sf); previously on Mar 11,
  1999 Assigned Aaa (sf)

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

  Cl. C Certificate, Affirmed at A1 (sf); previously on Jan 18,
  2007 Upgraded to A1 (sf)

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

Ratings Rationale

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

The rating of the IO Class, Class X, is consistent with the
expected credit performance of its referenced classes and thus is
affirmed.

Moody's rating action reflects a cumulative base expected loss of
8.3% of the current pooled balance compared to 9.1% at last
review.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000. The methodology used in
rating Interest-Only Securities was "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2012. The Interest-Only Methodology was used for the rating of
Class X.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit assessment
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the credit assessment level, is incorporated
for loans with similar credit assessments in the same transaction.

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

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 26, compared to 29 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST (Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated February 9, 2012.

Deal Performance

As of the January 22, 2013 distribution date, the transaction's
aggregate pooled certificate balance has decreased by 71% to $141
million from $492 million at securitization. The Certificates are
collateralized by 85 mortgage loans ranging in size from less than
1% to 12% of the pool, with the top ten loans representing 47% of
the pool. One loan, representing 2% of the pool, has been defeased
and is collateralized with U.S. Government Securities. One loan,
representing 12% of the pool, has an investment grade credit
assessment.

Nine loans, representing 8% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Two loans have been liquidated from the pool, resulting in an
aggregate realized loss of $1.2 million (22% average loss
severity). No loans are currently in special servicing.

The CTL component consists of 74 loans ($110 million -- 77.6%)
secured by properties leased to 21 tenants under bondable leases.
The largest exposures are Rite Aid Corporation (senior unsecured
Caa2, on review for possible upgrade; 21.7% of the CTL component)
and Home Depot Inc. (senior unsecured rating A3, positive outlook;
17.0% of the CTL component).

Credits representing approximately 92% of the CTL exposure are
publicly rated by Moody's. The bottom-dollar weighted average
rating factor (WARF) for the CTL component is 2,348 compared to
2,302 at last review. WARF is a measure of the overall quality of
a pool of diverse credits. The bottom-dollar WARF is a measure of
the default probability within the pool.

The conduit component consists of nine fixed rate mortgage loans
representing 8% of the deal. Moody's was provided with full year
2011 and partial or full year 2012 operating results for 100% and
76% of the conduit, respectively. Moody's weighted average LTV is
48% compared to 57% at Moody's prior review. Moody's net cash flow
reflects a weighted average haircut of 11% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 10.4%.

Moody's actual and stressed DSCRs are 1.70X and 3.73X,
respectively, compared to 1.33X and 2.41X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The loan with a credit assessment is the Broadway at the Beach
Loan ($17 million -- 12.1%), which is secured by a 343,000 square
foot entertainment retail complex located in Myrtle Beach, South
Carolina. The property includes specialty shops, restaurants and
tourist attractions. The complex was fully leased as of June 2012
compared to 97% at last review. Property performance has been
stable since last review. The loan is fully amortizing on a 240-
month schedule and has paid down by approximately 61% since
securitization. Moody's credit estimate and stressed DSCR are Aaa
and 4.7X, respectively, compared to Aaa and 3.8X at last review.

The conduit portion of the transaction only represents 8% of the
deal. All conduit loans are less than $2.5 million. Each conduit
loan has a hurdle DSCR in excess of 1.5X. Moody's expects all
conduit loans to be able to repay or refinance by loan maturity.
Loans representing 34% of the conduit mature in the first half of
2013, while the remaining 66% mature in 2018.


OFSI FUND V: S&P Assigns 'B' Rating to Class B-3L Notes
-------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to OFSI
Fund V Ltd./OFSI Fund V LLC's $523.77 million floating-rate notes.

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

The ratings reflect S&P's view of:

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

   -- The transaction's credit enhancement, which is sufficient to
      withstand the defaults applicable for the supplemental tests
      (not counting excess spread), and cash flow structure, which
      can withstand the default rate projected by Standard &
      Poor's CDO Evaluator model, as assessed by Standard & Poor's
      using the assumptions and methods outlined in its corporate
      collateralized debt obligation criteria (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 0.3439%-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

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)                       170.77
Subordinated notes       NR                            41.15

NR-Not rated.


PACIFIC COAST: Moody's Hikes Rating on $450-Mil. Notes to 'B2'
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Pacific Coast CDO, Ltd.:

  USD450,000,000 Class A First Priority Senior Secured Floating
  Rate Notes due October 25, 2036 (current outstanding balance of
  $36,941,613), Upgraded to B2 (sf); previously on March 23, 2012
  Upgraded to Caa1 (sf).

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

  USD96,000,000 Class B Second Priority Senior Secured Floating
  Rate Notes due October 25, 2036, Affirmed Ca (sf); previously
  on June 4, 2008 Downgraded to Ca (sf)

  USD21,000,000 Class C-1 Mezzanine Secured Floating Rate Notes
  due October 25, 2036 (current outstanding balance of
  $29,128,683), Affirmed C (sf); previously on May 17, 2006
  Downgraded to C (sf)

  USD9,000,000 Class C-2 Mezzanine Secured Floating Rate Notes
  due October 25, 2036 (current outstanding balance of
  $12,117,119), Affirmed C (sf); previously on May 17, 2006
  Downgraded to C (sf)

  USD26,000,000 Class Preferred Shares due October 25, 2036,
  Affirmed C (sf); previously on June 18, 2004 Downgraded to C
  (sf)

Ratings Rationale:

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the senior notes and an
increase in the transaction's overcollateralization ratios since
the rating action in March 2012. Moody's notes that the Class A
Notes have been paid down by approximately 29.8% or $15.7 million
since the last rating action. Based on Moody's calculations, the
class A overcollateralization ratio is 211.3% versus March 2012
level of 172.1%.

Pacific Coast CDO Ltd., issued in September 2001, is a
collateralized debt obligation backed primarily by a diversified
portfolio of RMBS, CMBS and SF CDOs originated from 2002 to 2004.

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. Results are shown in terms of the number of
notches' difference versus the current model output, where a
positive difference corresponds to lower expected loss, assuming
that all other factors are held equal:

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

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

Preferred Shares: 0

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

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

Preferred Shares: 0


PNC MORTGAGE 2000-C2: Moody's Cuts Rating on Cl. X Cert to Caa2
---------------------------------------------------------------
Moody's Investors Service affirmed the ratings of five classes and
downgraded three classes of PNC Mortgage Acceptance Corp.,
Commercial Mortgage Pass-Through Certificates, Series 2000-C2 as
follows:

  Cl. G, Affirmed Aa2 (sf); previously on Feb 9, 2012 Upgraded to
  Aa2 (sf)

  Cl. H, Downgraded to Ba1 (sf); previously on Feb 9, 2012
  Downgraded to Baa2 (sf)

  Cl. J, Downgraded to B3 (sf); previously on Feb 9, 2012
  Downgraded to B2 (sf)

  Cl. K, Affirmed Caa1 (sf); previously on Feb 9, 2012 Downgraded
  to Caa1 (sf)

  Cl. L, Affirmed Ca (sf); previously on Sep 9, 2010 Downgraded
  to Ca (sf)

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

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

  Cl. X, Downgraded to Caa2 (sf); previously on Feb 22, 2012
  Downgraded to Caa1 (sf)

Ratings Rationale

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

The downgrades of the principal classes are primarily due to
concerns about increased interest shortfalls and potential future
interest shortfalls.

The rating of the IO Class, Class X-1 is downgraded based on the
ratings of its referenced classes.

Moody's rating action reflects a base expected loss of 20.9% of
the current balance compared to 21.2% at last review. Moody's base
expected loss plus realized losses is 3.4%, compared to 3.5% at
last review, of securitized balance.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating CMBS Large Loan/Single
Borrower Transactions" published in July 2000. The methodology
used for rating Interest-Only Securities was "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012. The Interest-Only Methodology was used for the
rating of Class X.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit assessment
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the credit assessment level, is incorporated
for loans with similar credit assessments in the same transaction.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 9, compared to 10 at last review.

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

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated February 9, 2012.

Deal Performance

As of the January 14, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 90% to $102.8
million from $1.08 billion at securitization. The Certificates are
collateralized by 19 mortgage loans ranging in size from less than
1% to 20% of the pool. There are no defeased loans or loans with
investment grade credit assessments.

Six loans, representing 31% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council monthly reporting package. As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Seventeen loans have been liquidated from the pool since
securitization, resulting in an aggregate $15.5 million loss (18%
loss severity on average). There are currently five loans,
representing 26% of the pool, in special servicing. The largest
specially serviced loan is the Taconic Corporate Park Loan ($12.6
million - 12.3% of the pool), which is secured by a 210,000 square
foot (SF) office property located Yorktown Heights, New York. The
loan transferred to special servicing in January 2010 as the
result of imminent default. The loan became Real Estate Owned
(REO) in May 2011. As of December 2012, the property was 42%
leased.

The second largest specially serviced loan is the 1450 Marina Way
South Office Building Loan ($6.8 million - 6.6% of the pool),
which is secured by a 93,900 (SF) office property located
Richmond, California. The loan transferred to special servicing in
March 2012 as the result of imminent default. The property's sole
tenant Chevron downsized their space resulting in total occupancy
of 53%. Subsequently, the borrower submitted a modification
proposal and the modification was executed and closed on December
4, 2012. Terms of the modification include new equity
contribution, hard lock box, interest rate reduction from 8.26% to
6.0% in 2012 through 2013, 7.00% in 2013 through 2014 and 8.26% in
2014 through 2015. The maturity date remains February 2015.

The third largest specially serviced loan is the Shops at Eagle
Point Loan and Shops at Haw Creek Loan ($4.2 million - 4.0% of the
pool). These loans are cross collateralized and cross defaulted
loans, secured by properties located in Forsyth, Georgia and
Woodstock, Georgia, respectively. The loans transferred to special
servicing in July 2012 as the result of maturity default. As of
September 2012, combined occupancy was 76%. The properties are
currently in the process of foreclosure.

The remaining specially serviced loan is secured by a retail
property.

Moody's estimates an aggregate $11.2 million loss for all of the
specially serviced loans (42% expected loss on average).

Based on the most recent remittance statement, Classes J through O
have experienced cumulative interest shortfalls totaling $5.8
million compared to $4.5 million at last review. Moody's
anticipates that the pool will continue to experience interest
shortfalls because of the exposure to specially serviced loans.
Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, appraisal entitlement
reductions, advanced interest claw backs on loans determined to be
non-recoverable and extraordinary trust expenses.

Moody's has assumed a high default probability for three poorly
performing loans representing 31% of the pool and has estimated a
$9.4 million aggregate loss (30% expected loss based on a 68%
probability default) from these troubled loans.

Moody's was provided with full year 2011 and partial year 2012
operating results for 100% and 70% of the loans respectively.
Excluding specially serviced loans, Moody's weighted average LTV
is 68% compared to 71% at Moody's prior review. Moody's net cash
flow reflects a weighted average haircut of 11% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 10.2%.

Excluding specially serviced loans, Moody's actual and stressed
DSCRs are 1.35X and 1.91X, respectively, compared to 1.25X and
1.97X at last review. Moody's actual DSCR is based on Moody's net
cash flow (NCF) and the loan's actual debt service. Moody's
stressed DSCR is based on Moody's NCF and a 9.25% stressed rate
applied to the loan balance.

The top three performing conduit loans represent 42% of the pool
balance. The largest loan is the Sweetheart Cup Distribution
Center Loan ($20.4 million -- 19.8% of the pool), which is secured
by a 1.03 million SF industrial building located in Hampstead,
Maryland. The property is fully occupied by a single tenant, Solo
Cup Company, through July 2020. The loan had an anticipated
repayment date (ARD) of October 1, 2010 but remains current.
Although property performance has been stable since
securitization, Moody's utilized a Lit/Dark analysis to reflect
potential cash flow volatility due to the single tenant exposure.
Moody's LTV and stressed DSCR are 68% and 1.72X, respectively,
compared to 79% and 1.48X at last review.

The second largest loan is the Northside Marketplace Loan ($13.8
million -- 13.5% of the pool) which is secured by an 189,299 SF
retail property located in Nashville, Tennessee. At Moody's last
review, the loan was in special servicing due to imminent default
and it passed its ARD of September 1, 2010. The loan was
subsequently modified and returned to the master servicer in
December 2012. Terms of the modification include a maturity date
extension until January 2017, an interest rate reduction from
8.31% to 4.5%. The loan remains on the watchlist. The largest
tenants are Dicks Sporting Good, Best Buy and Old Navy. As of
September 2012 the property was 75% leased. Moody's identifies
this loan as a troubled loan.

The third largest loan is the Waterford at Portage Apartments
Phase 1 Loan ($8.8 million -- 8.5% of the pool), which is secured
by two cross collateralized and cross defaulted multifamily
properties totaling 304 units located in Akron, Ohio. The loan is
on the watchlist due to a decline in occupancy and low DSCR. As of
September 2012, weighted average occupancy was 78% compared to 88%
at last review. Moody's identifies this loan as a troubled loan.


PNC MORTGAGE 2001-C1: S&P Lowers Rating on Class J Notes to 'D'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
F commercial mortgage pass-through certificate from PNC Mortgage
Acceptance Corp.'s series 2001-C1, a U.S. commercial mortgage-
backed securities (CMBS) transaction.  In addition, S&P lowered
its rating on one class from the same transaction and affirmed its
ratings on two other classes.

S&P's rating actions follow its analysis of the transaction
primarily using its criteria for rating U.S. and Canadian CMBS
transactions.  S&P's analysis included a review of the credit
characteristics of all of the assets in the pool, the transaction
structure, and the liquidity available to the trust.

The upgrade of the class F certificate reflects S&P's expected
available credit enhancement for the class, which S&P believes is
greater than its most recent estimate of necessary credit
enhancement for the most recent rating level, as well as S&P's
reviews regarding the current and future performance of the
collateral supporting the transaction.  S&P tempered its rating on
class F because it also considered that three ($36.1 million,
58.1%) of the remaining 10 assets ($62.2 million) are with the
special servicer, which could potentially lead to additional
interest shortfalls and liquidity available to the trust.

S&P lowered its rating on the class J certificate to 'D (sf)'
because S&P expects the accumulated interest shortfalls to remain
outstanding for the foreseeable future.  As of the Jan. 14, 2013,
trustee remittance report, the trust experienced net monthly
interest shortfalls totaling $86,525, primarily related to
appraisal subordinate entitlement reduction (ASER) amounts of
$74,240 and special servicing fees of $7,787.  The net interest
shortfalls affected all classes subordinate to and including class
J.  The class J certificate has had interest shortfalls for two
consecutive months and 19 months in total since issuance.

The affirmations of the principal and interest certificates
reflect S&P's expectation that the available credit enhancement
for these classes will be within S&P's estimate of the necessary
credit enhancement required for the current outstanding ratings.
The affirmed ratings on these classes also reflect the credit
characteristics and performance of the remaining assets, as
well as the transaction-level changes.

Using servicer-provided financial information, S&P calculated an
adjusted Standard & Poor's debt service coverage (DSC) ratio of
1.11x and a loan-to-value (LTV) ratio of 60.2% for five of the 10
remaining assets in the pool.  The DSC and LTV calculations
exclude the three assets ($36.1 million, 58.1%) that are with the
special servicer (details below), one defeased loan ($4.4 million,
7.1%), and one nonreporting loan ($0.5 million, 0.7%).

As of the Jan. 14, 2013, trustee remittance report, the collateral
pool had an aggregate trust balance of $62.2 million, down from
$881.6 million at issuance.  The pool comprises seven loans and
three real estate owned (REO) assets, down from 124 loans at
issuance.  To date, the transaction has experienced losses
totaling $25.5 million or 2.9% of the transaction original
certificate balance.  The three largest assets in the pool
($36.1 million, 58.1%) are with the special servicer, which S&P
discusses below.  In addition, the sixth-largest asset, the Best
Buy Store loan ($4.4 million, 7.1%) is defeased and two loans
($7.3 million, 11.7%) in the pool are on the master servicer's
watchlist.  Excluding the three specially serviced assets and one
nonreporting loan, the Barry Towne Center - Phase II loan
($5.9 million, 9.5%) is the only loan with a reported DSC of less
than 1.00x.  The loan is secured by a 137,766-sq.-ft. retail
shopping center in Kansas City, Missouri.  The reported DSC as of
year-end 2011 was 0.53x.  The property was 57.4% leased and 22.4%
occupied according to the Dec. 31, 2012, rent roll.

                    SPECIALLY SERVICED ASSETS

As of the Jan. 14, 2013, trustee remittance report, three REO
assets ($36.1 million, 58.1%) are with the special servicer, C-III
Asset Management LLC (C-III).  Details on the three assets are
below:

The Deer Grove Shopping Center asset ($17.7 million, 28.5%), the
largest asset in the pool, is a 214,168 sq. ft., grocery-anchored
retail center in Palatine, Illinois.  The asset has a reported
total exposure of $19.7 million.  Due to the borrower's inability
to repay the loan in full at maturity, the loan transferred to the
special servicer on Jan. 6, 2011, and the property became REO on
Sept. 21, 2011.  According to C-III, it is actively working on
leasing up the property, which reported 70.0% occupancy as of
Oct. 5, 2012.  S&P expects a moderate loss upon the eventual
resolution of this asset.

The Radisson Plaza Hotel asset ($11.4 million, 18.4%), the second-
largest asset in the pool, is a five-story, 185-room hotel in San
Jose, Calif.  The asset has a total reported exposure of
$13.8 million.  Due to pending loan and franchise defaults, the
loan transferred to the special servicer on Sept. 11, 2007, and
the property became REO on April 27, 2012.  The reported occupancy
was 62.6% for the trailing-12-months ending Aug. 31, 2012, and
C-III indicated it is currently working on improving the
property's performance.  S&P expects a moderate loss upon the
eventual resolution of this asset.

The Memorex Drive Business Park asset ($7.0 million, 11.2%), the
third-largest asset in the pool, consists of industrial buildings
totaling 215,902 sq. ft. in Santa Clara, Calif.  The asset has a
total reported exposure of $7.3 million.  Due to the borrower's
inability to repay the loan in full at maturity, the loan
transferred to the special servicer on May 10, 2011, and the
property became REO on Oct. 5, 2012. C-III stated that the
property is being marketed for sale.  S&P expects a minimal loss
upon the eventual resolution of this asset.

As it relates to the above asset resolutions, minimal loss is
considered to be less than 25%, moderate loss is between 26% and
59%, and significant loss is 60% or greater.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING RAISED

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2001-C1
            Rating
Class   To          From          Credit enhancement (%)
F       BBB+ (sf)   BBB- (sf)                    83.10

RATING LOWERED

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2001-C1
            Rating
Class   To          From          Credit enhancement (%)
J       D (sf)      CCC (sf)                     21.05

RATINGS AFFIRMED

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2001-C1
            Rating
Class   To          From          Credit enhancement (%)
G       BB+ (sf)    BB+ (sf)                     70.69
H       BB- (sf)    BB- (sf)                     44.10


PNC MORTGAGE 2011-C1: Moody's Cuts Rating on Cl. J Certs to 'Caa3'
------------------------------------------------------------------
Moody's Investors Service upgraded the rating of one class,
downgraded one class and affirmed six classes of PNC Mortgage
Acceptance Corp. Commercial Mortgage Pass-Through Certificates,
Series 2001-C1 as follows:

Cl. F, Upgraded to Aa3 (sf); previously on Mar 22, 2012 Upgraded
to A2 (sf)

Cl. G, Affirmed Baa1 (sf); previously on Oct 23, 2006 Upgraded
to Baa1 (sf)

Cl. H, Affirmed B1 (sf); previously on May 25, 2011 Downgraded
to B1 (sf)

Cl. J, Downgraded to Caa3 (sf); previously on May 25, 2011
Downgraded to Caa2 (sf)

Cl. K, Affirmed C (sf); previously on Sep 16, 2010 Downgraded to
C (sf)

Cl. L, Affirmed C (sf); previously on Sep 16, 2010 Downgraded to
C (sf)

Cl. X, Affirmed Caa2 (sf); previously on Feb 22, 2012 Downgraded
to Caa2 (sf)

Cl. X-1, Affirmed Caa2 (sf); previously on Feb 22, 2012
Downgraded to Caa2 (sf)

Ratings Rationale

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

The downgrade for the one principal and interest bond class is due
to an increase in realized losses and the potential for additional
interest shortfalls.

The ratings of the IO Classes, Classes X-1 and X, are consistent
with the expected credit performance their referenced classes and
thus are affirmed.

Moody's rating action reflects a base expected loss of 27.5% of
the current pooled balance compared to 24.0% at last review.
Moody's based expected loss plus realized losses is now 4.8% of
the original pooled balance compared to 4.7% at last review.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 U.S. CMBS Conduit Transactions" published in September
2000, and "Moody's Approach to Rating CMBS Large Loan/Single
Borrower Transactions" published in July 2000. The methodology
used in rating Interest-Only Securities was "Moody's Approach to
Rating Structured Finance Interest-Only Securities" published in
February 2012. The Interest-Only Methodology was used for the
rating of Classes X and X-1.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit assessment
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the credit assessment level, is incorporated
for loans with similar credit assessments in the same transaction.

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

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 6 compared to 7 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated March 22, 2012.

Deal Performance

As of the January 14, 2013 distribution date, the transaction's
aggregate pooled certificate balance has decreased by 93% to $62.2
million from $881.6 million at securitization. The Certificates
are collateralized by 10 mortgage loans ranging in size from less
than 1% to 29% of the pool, with the top ten loans representing
93% of the pool. One loan, representing 7% of the pool, has
defeased and is collateralized with U.S. Government Securities.

Two loans, representing 12% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Fourteen loans have been liquidated from the pool, resulting in an
aggregate realized loss of $25.5 million (34% average loss
severity). The top three loans, representing 58% of the pool, are
currently in special servicing. The largest specially serviced
loan is the Deer Grove Shopping Center Loan ($17.7 million --
28.5% of the pool), which is secured by a 214,168 square foot (SF)
community shopping center located approximately 30 miles northwest
of Chicago in suburb of Palatine, Illinois. The property became
real estate owned (REO) in September 2011. The shopping center is
presently 70% leased with strong leasing prospects that will
bolster occupancy. Target is a shadow anchor at this center. The
servicer recognized a $5.8 million appraisal reduction in December
2012 for this property and is currently marketing this shopping
center for sale.

The second largest specially serviced loan is the Radisson Plaza
Hotel Loan ($11.4 million -- 18.4% of the pool) which is secured
by a 185-key full service hotel located in San Jose, California.
The loan transferred to special servicing September 2007, a
receiver was appointed February 2011 and the loan was foreclosed
May 2012. The property is currently being marketed for sale.

The third largest specially serviced loan is the Memorex Drive
Business Park Loan ($7.0 million -- 11.2% of the pool) which is
secured by a 215,902 SF industrial/flex property located in Santa
Clara, California. The property was 54% leased compared to 60% at
last review. The loan was transferred to special servicing May
2011 due to maturity default and was foreclosed October 2012. A
one-year loan modification was granted.

The servicer has recognized an aggregate $12.1 million appraisal
reduction for two of the specially serviced loans and Moody's has
estimated an aggregate $13.9 million loss (39% average expected
loss) for all specially serviced loans.

Moody's has assumed a high default probability for one poorly
performing loan representing 10% of the pool and has estimated an
$2.4 million aggregate loss (41% expected loss based on a 75%
probability default) from this troubled loan.

Moody's was provided with full year 2011 and partial year 2012
operating results for 97% and 23% of the pool's non-defeased
loans, respectively. Moody's weighted average conduit LTV is 76%
compared to 77% at Moody's prior review. The conduit portion of
the pool excludes specially serviced, troubled and defeased loans.
Moody's net cash flow reflects a weighted average haircut of 11%
to the most recently available net operating income. Moody's value
reflects a weighted average capitalization rate of 9.5%.

Moody's actual and stressed conduit DSCRs are 1.16X and 1.54X,
respectively, compared to 1.13X and 1.44X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three conduit loans represent 26% of the pool. The largest
loan is the Tuscany at Goldmark Apartments Loan ($6.4 million --
10.4% of the pool), which is secured by a 152-unit apartment
complex located in Dallas, Texas. The property was 100% leased as
of November 2012, the same as at last review. Property performance
has been stable. Moody's LTV and stressed DSCR are 76% and 1.36X,
respectively, compared to 80% and 1.28X at last review.

The second largest loan is the Barry Town Center Loan ($5.9
million -- 9.5% of the pool), which is secured by a 137,766 SF
retail center located in Kansas City, Missouri. The complex is 50%
leased to Dick's Sporting Goods and Babies R Us yet only 22%
occupied by Babies R Us. This loan is on the servicer's watchlist
due to low occupancy and low DSCR. Moody's stressed the property
cash flow due these issues. Moody's LTV and stressed DSCR are 171%
and 0.33X, respectively, compared to 110% and 0.92X at last
review.

The third largest loan is the Best Buy Loan ($3.8 million -- 6.0%
of the pool), which is secured by a freestanding Best Buy store
totaling 44,988 SF located in Roanoke, Virginia. The Best Buy
lease expires five years after the loan matures. Moody's LTV and
stressed DSCR are 111% and 0.92X, respectively, compared to 98%
and 0.93X at last review.


REALT 2006-1: Moody's Affirms Ratings on 18 CMBS Classes
--------------------------------------------------------
Moody's Investors Service affirmed the ratings of 18 classes of
Real Estate Asset Liquidity Trust Commercial Mortgage Pass-Through
Certificates, Series 2006-1 as follows:

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

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

Cl. B, Affirmed Aa2 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed A2 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned A2 (sf)

Cl. D-1, Affirmed Baa2 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Baa2 (sf)

Cl. D-2, Affirmed Baa2 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Baa2 (sf)

Cl. E-1, Affirmed Baa3 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Baa3 (sf)

Cl. E-2, Affirmed Baa3 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Baa3 (sf)

Cl. F, Affirmed Ba1 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Ba1 (sf)

Cl. G, Affirmed Ba2 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Ba2 (sf)

Cl. H, Affirmed Ba3 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Ba3 (sf)

Cl. J, Affirmed B1 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned B1 (sf)

Cl. K, Affirmed B2 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned B2 (sf)

Cl. L, Affirmed B3 (sf); previously on Apr 12, 2006 Definitive
Rating Assigned B3 (sf)

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

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

Cl. XP-1, Affirmed Aaa (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Aaa (sf)

Cl. XP-2, Affirmed Aaa (sf); previously on Apr 12, 2006 Definitive
Rating Assigned Aaa (sf)

Ratings Rationale

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

Moody's rating action reflects a cumulative base expected loss of
1.4% of the current balance, the same as at Moody's prior review.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 Fusion U.S. CMBS Transactions" published in April 2005,
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000, and "Moody's Approach to
Rating Canadian CMBS" published in May 2000. The methodology used
in rating Interest-Only Securities was "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2012. The Interest-Only Methodology was used for the rating of
Classes XP-1, XP-2, XC-1 and XC-2.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.62 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score, a measure of loan level diversity, is a primary
determinant of pool level diversity and has a greater impact on
senior certificates. Other concentrations and correlations may be
considered in Moody's analysis. Based on the model pooled credit
enhancement levels at Aa2 (sf) and B2 (sf), the remaining conduit
classes are either interpolated between these two data points or
determined based on a multiple or ratio of either of these two
data points. For fusion deals, the credit enhancement for loans
with investment-grade credit assessments is melded with the
conduit model credit enhancement into an overall model result.
Fusion loan credit enhancement is based on the credit assessment
of the loan which corresponds to a range of credit enhancement
levels. Actual fusion credit enhancement levels are selected based
on loan level diversity, pool leverage and other concentrations
and correlations within the pool. Negative pooling, or adding
credit enhancement at the credit assessment level, is incorporated
for loans with similar credit assessments in the same transaction.

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

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 13, the same as at Moody's prior review.

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

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST(Moody's Surveillance Trends) Reports and a
proprietary program that highlights significant credit changes
that have occurred in the last month as well as cumulative changes
since the last full transaction review. On a periodic basis,
Moody's also performs a full transaction review that involves a
rating committee and a press release. Moody's prior transaction
review is summarized in a press release dated February 29, 2012.

Deal Performance

As of the January 14, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 3.7% to $243.7
million from $253.0 million at securitization. The Certificates
are collateralized by 52 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten non-defeased loans
representing 55% of the pool. Four loans, representing 6% of the
pool, have defeased and are secured by U.S. Government securities.
The pool contains two loans with investment grade credit
assessments, representing 21% of the pool.

Eight loans, representing 18% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

No loans have liquidated from the pool and there are no loans
currently in special servicing.

Moody's was provided with full year 2011 operating results for 88%
of the performing pool. Moody's weighted average LTV is 74%, the
same at Moody's prior review. Moody's net cash flow reflects a
weighted average haircut of 14.2% to the most recently available
net operating income. Moody's value reflects a weighted average
capitalization rate of 9.8%.

Moody's actual and stressed DSCRs are 1.46X and 1.55X,
respectively, compared to 1.49X and 1.52X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The largest loan with a credit assessment is the Crombie Portfolio
Loan ($42.2 million -- 17.3% of the pool), which is secured by a
portfolio of seven retail and mixed-use properties across three
Canadian provinces (Newfoundland, Nova Scotia & New Brunswick)
totaling 936,000 square feet (SF). Year-end 2011 occupancy was 82%
-- a slight decrease from the 86% occupancy reported the prior
year. Performance remains stable. Moody's credit assessment and
stressed DSCR are Baa2 and 1.46X, respectively, compared to Baa2
and 1.41X at last review.

The second largest loan with a credit assessment is the Royal
Centre Loan ($8.6 million -- 3.5% of the pool), which is secured
by a 163,000 SF office building located in Vaughan, Ontario, a
northern suburb of Toronto. The largest tenant is the Royal Bank
of Canada (Moody's Senior Unsecured Rating, Aa3, Stable Outlook),
which renewed its lease through May 2021. Occupancy was 87% as of
July 2012, compared to 86% at last Moody's review. The loan has
amortized 4% since last review. Moody's current credit assessment
and stressed DSCR are Aaa and 2.2X, respectively, compared to Aaa
and 2.17X at last review.

The top three conduit loans represent 27.6% of the pool. The
largest conduit loan is The Landing Loan ($27.0 million -- 11.1%
of the pool), which is secured by a 183,000 SF, seven-story office
building in the Gastown district of downtown Vancouver, British
Columbia. The property was 95% leased as of YE 2011 compared to
99% as of YE 2010. The loan has amortized 2.6% since Moody's last
review. The largest tenant is Intrawest Corporation (20% NRA), the
owner and operator of several North American destination resorts.
Moody's current LTV and stressed DSCR are 78.8% and 1.24X,
respectively, compared to 80.3% and 1.21X at last review.

The second largest conduit loan is the Dominion Square Loan ($26.3
million -- 10.8% of the pool). The loan is Pari Passu (50%) with
REALT 2006-2 and is secured by a 12-story 374,000 SF, mixed-use
building located in downtown Montreal, Quebec. Local and state
government agencies represent 26% of the tenancy in the building.
As of December 2012, the property was 87% leased, down from 98%
leased as of April 2011. Moody's current LTV and stressed DSCR are
99.6% and 0.98X, respectively, compared to 81.6% and 1.19X at last
review.

The third largest conduit loan is the InnVest Portfolio Loan
($13.9 million -- 5.7% of the pool), which is secured by a
portfolio of two full service hotels located in London and
Toronto, Ontario. Performance has continued to improve since
Moody's last review. Moody's current LTV and stressed DSCR are
102.9% and 1.1X, respectively, compared to 109.3% and 1.04X at
last review.


RFC CDO I: Fitch Lowers Rating on Class C Notes to 'C'
------------------------------------------------------
Fitch Ratings has downgraded one and affirmed four classes of
notes issued by RFC CDO I, Ltd. as follows:

-- $7,360,687 class A notes affirmed at 'BBBsf'; Outlook Stable;
-- $22,500,000 class B1 notes affirmed at 'Bsf'; Outlook
     Negative;
-- $2,000,000 class B2 notes affirmed at 'Bsf'; Outlook Negative;
-- $16,200,000 class C notes downgraded to 'Csf' from 'CCsf';
-- $7,288,634 class D notes affirmed at 'Csf'.

Key Rating Drivers

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 actions for the notes.

Since the last rating action in February 2012, the credit quality
of the collateral has further deteriorated with approximately
25.3% of the portfolio downgraded a weighted average of 3.5
notches. Approximately 89.1% of the portfolio has a Fitch derived
rating below investment grade and 61.0% has a rating in the 'CCC'
rating category or lower, compared to 82.7% and 57.9%,
respectively, at last review.

The class A notes have been affirmed at their current rating of
'BBBsf' to reflect the continued deleveraging of the capital
structure offsetting portfolio deterioration. Since the last
review, the notes have received approximately $12.2 million, or
62.4% of its previous balance. Although the notes have benefited
from excess spread as a result of a failing class C
Overcollateralization (OC) test, the amount was relatively small,
at $0.5 million over the last four payment dates. The Outlook
Stable reflects the cushion available in the cash flow modeling
results to mitigate potential further negative migration in the
portfolio.

The amortization of the capital structure has also increased the
class B-1 and B-2 (together, class B) notes' credit enhancement
levels. This increase offset the deterioration in the underlying
assets, resulting in an affirmation of the class's rating.
Although the current passing levels are slightly lower than those
corresponding to a 'Bsf' rating, Fitch expects that the notes'
credit enhancement levels will continue to increase with the
ongoing deleveraging of the transaction. Based on the most recent
pace of paydowns and maturity profile of the remaining portfolio,
the class B notes are likely to become the most senior class and
start receiving principal payments within the next one to two
years. Given these expectations, the 'Bsf' rating remains
appropriate for this class. However, Fitch maintains an Outlook
Negative on this class due to a high susceptibility to potential
further deterioration in the credit quality of the portfolio.

The credit enhancement levels for the class C and D notes are
below the expected losses from the distressed and defaulted assets
in the portfolio (assets rated 'CCsf' of lower). The class C notes
are downgraded to 'Csf' and the class D notes are affirmed at
'Csf', indicating that default is inevitable for both classes at
the transaction's maturity.

RFC CDO I is a structured finance collateralized debt obligation
(SF CDO) that closed on June 30, 2004. The portfolio of collateral
was originally selected by Residential Funding Corporation and is
now monitored by Castle Peak Capital Advisors. The portfolio is
composed of primarily residential mortgage-backed securities
(96.7%) from the 2004 and prior vintages.


SAGAMORE CLO: Moody's Lifts Rating on $16-Mil. Notes to 'Ba2'
-------------------------------------------------------------
Moody's upgrades the ratings of USD 39.8 million notes issued by
Sagamore CLO Ltd. Global Credit Research - 12 Feb 2013 Moody's
also affirms the ratings of USD 30.1 million of notes New York,
February 12, 2013)

Moody's Investors Service upgraded the ratings of the following
notes issued by Sagamore CLO, Ltd.:

  USD18,000,000 Class B Deferrable Note Rights Due 2015, Upgraded
  to Aaa (sf); previously on May 2, 2012 Upgraded to Aa1 (sf);

  USD16,000,000 Class C-1 Floating Rate Deferrable Note Rights
  Due 2015, Upgraded to Ba2 (sf); previously on May 2, 2012
  Upgraded to B1 (sf);

  USD500,000 Class C-2 Fixed Rate Deferrable Note Rights Due
  2015, Upgraded to Ba2 (sf); previously on May 2, 2012 Upgraded
  to B1 (sf);

  USD3,000,000 Class D Junior Mezzanine Deferrable Note Rights
  Due 2015, Upgraded to Ca (sf); previously on September 14, 2011
  Confirmed at C (sf);

  USD5,000,000 Class 2 Participation Notes Due 2015 (current
  rated balance of $2,121,851), Upgraded to Aaa (sf); previously
  on May 2, 2012 Upgraded to Aa1 (sf).

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

  USD70,000,000 Class A-1 Delayed Drawdown Note Rights Due 2015
  (current balance $8,974,268), Affirmed Aaa (sf); previously on
  September 14, 2011 Upgraded to Aaa (sf);

  USD161,000,000 Class A-2 Note Rights Due 2015 (current balance
  $20,640,816), Affirmed Aaa (sf); previously on September 14,
  2011 Upgraded to Aaa (sf);

  USD5,000,000 Class A-3 Zero Coupon Accreting Note Rights Due
  2015 (current balance $477,558), Affirmed Aaa (sf); previously
  on September 14, 2011 Upgraded to Aaa (sf).

Ratings Rationale:

According to Moody's, the rating actions taken on the notes are
primarily a result of delevering of the senior notes and an
increase in the transaction's overcollateralization ratios since
the rating action in May 2012. The Class A Notes have been paid
down by approximately 45% or $25 million since the last rating
action. Based on the latest trustee report dated January 3, 2013,
the Class A, Class B, and Class C overcollateralization ratios are
reported at 254.3%, 159.1%, and 118.5%, respectively, versus April
2012 levels of 167.3%, 132.7%, and 111.5%, respectively. The
reported overcollateralization ratios do not reflect the recent
principal distribution of $13.4 million to the Class A Notes on
January 2013.

The Class D Notes receive interest and principal payments in an
amount up to 38% of available proceeds after the payment of any
trustee, collateral administrator, and administrative expenses
remaining unpaid after the application of an expense cap.
According to the latest trustee report, the Class D Notes are
current on all interest payments.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes, many of which are in CLO tranches with
speculative-grade ratings. Based on Moody's calculation, reference
securities that mature after the maturity date of the notes
currently make up approximately $21.1 million or 32.8% of the
underlying reference portfolio, including $12.5 million or 19.5%
of CLO tranches. 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 examined the underlying portfolio using a double-
binomial analysis that assumes two pools: one pool consisting of
"long-dated" CLO securities, with a performing par balance of
$12.5 million, and another pool consisting of corporate loans with
a performing par balance of $50.3 million. Moody's also assumed a
principal proceeds balance of $13.4 million, defaulted par of $7.4
million (including Ca-rated securities that are treated as if they
are defaulted securities). The corporate loan pool is assumed to
have an overall weighted average default probability of 16.17%
(implying a WARF of 3457), an overall weighted average recovery
rate upon default of 52.91%%, and a diversity score of 23. The CLO
securities pool is assumed to be liquidated at the maturity of the
deal. The default and recovery properties of the loan 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.

Sagamore CLO Ltd., issued in October 2003, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans, with material exposure to investments in CLO securities.

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 the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in June 2011.

In addition to the base case analysis described, Moody's also
performed sensitivity analyses to test the impact on all rated
notes of various default probabilities.

Listed 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% (2766)

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

Moody's Adjusted WARF + 20% (4148)

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2014 and
2016 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties:

1) Delevering: The main source of uncertainty in this transaction
is whether delevering from unscheduled principal proceeds will
continue and at what pace. Delevering 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.


SEAWALL 2006-4: Moody's Retains C Rating on 3 Certificate Classes
-----------------------------------------------------------------
Moody's has affirmed the ratings of three classes of Notes issued
by Seawall 2006-4, 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 Synthetic) transactions.

Moody's rating action is as follows:

Cl. A, Affirmed C (sf); previously on Feb 8, 2012 Downgraded to C
(sf)

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

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

Ratings Rationale

Seawall 2006-4, Ltd. is a static synthetic CRE CDO transaction
backed by a portfolio of credit default swaps on commercial
mortgage backed securities (CMBS) (100.0% of the reference
obligation balance). The notional balance of the reference
obligations has decreased to $267.8 million from $300.0 million at
issuance, due to realized write-downs on the underlying
collateral.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated reference obligations. Moody's modeled a bottom-dollar WARF
of 8,500 compared to 7,959 at last review. The current
distribution of Moody's rated referenced collateral and
assessments for non-Moody's rated referenced collateral is as
follows: B1-B3 (7.5% compared to 14.3% at last review), and Caa1-C
(92.5% compared to 85.7% at last review).

Moody's modeled a WAL of 4.7 years compared to 5.0 years at last
review.

Moody's modeled a fixed WARR of 0.4% compared to 0.7% at last
review.

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

Moody's review incorporated CDOROM 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 obligations.
However, in light of the performance indicators noted above,
Moody's believes that it is unlikely that the ratings announced
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.


SLM STUDENT 2004-1: Fitch Affirms 'BB' Student Loan Note Rating
---------------------------------------------------------------
Fitch Ratings affirms both the senior notes at 'AAAsf' and the
subordinate student loan note at 'BBsf' issued by SLM Student Loan
Trust series 2004-1. The Rating Outlook on the senior notes, which
is tied to the sovereign rating of the U.S. government, will
remain Negative. The rating on the subordinate notes will remain
Stable.

The ratings on the senior and subordinate notes are affirmed based
on the sufficient level of credit to cover the applicable risk
factor stresses. Credit enhancement for the senior and subordinate
notes consists of overcollateralization and projected minimum
excess spread, while the senior notes also benefit from
subordination provided by the class B note.

Fitch affirms these ratings:

SLM Student Loan Trust, Series 2004-1:

-- Class A-3 at 'AAAsf'; Outlook Negative;
-- Class A-4 at 'AAAsf'; Outlook Negative;
-- Class A-5 at 'AAAsf'; Outlook Negative;
-- Class A-6 at 'AAAsf'; Outlook Negative;
-- Class B at 'BBsf'; Outlook Stable;


SLM STUDENT 2004-3: Fitch Affirms 'BB' Student Loan Note Rating
---------------------------------------------------------------
Fitch Ratings affirms both the senior notes at 'AAAsf' and the
subordinate student loan note at 'BBsf' issued by SLM Student Loan
Trust series 2004-3. The Rating Outlook on the senior notes, which
is tied to the sovereign rating of the U.S. government, will
remain Negative. The rating on the subordinate notes will remain
Stable.

The ratings on the senior and subordinate notes are affirmed based
on the sufficient level of credit to cover the applicable risk
factor stresses. Credit enhancement for the senior and subordinate
notes consists of overcollateralization and projected minimum
excess spread, while the senior notes also benefit from
subordination provided by the class B note.

Fitch affirms these ratings:

SLM Student Loan Trust, Series 2004-3:

-- Class A-4 at 'AAAsf'; Outlook Negative;
-- Class A-5 at 'AAAsf'; Outlook Negative;
-- Class A-6A at 'AAAsf'; Outlook Negative;
-- Class A-6B at 'AAAsf'; Outlook Negative;
-- Class B at 'BBsf'; Outlook Stable;


SUTTER CBO: S&P Lowers Rating on Class B-2 Notes to 'D(sf)'
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the Class
B-2 notes from Sutter CBO 2000-2 Ltd., a U.S. collateralized bond
obligation (CBO) transaction, to 'D (sf)' from 'CC (sf)'.

According to the notice of event of default dated Feb. 4, 2013,
the Class B-2 notes did not receive aggregate principal amount in
full, which was due on its final maturity date Jan. 30, 2013.
Therefore, S&P lowered its rating on the Class B-2 notes to 'D
(sf)' pursuant to its criteria.

RATING LOWERED

Sutter CBO 2000-2 Ltd.
                            Rating
Class               To                  From
B-2                 D(sf)               CC(sf)


TRAVIS COUNTY: Moody's Affirms Ratings on 2002A & 2002C Bonds
-------------------------------------------------------------
Moody's affirmed the B2 and C ratings of Travis County (TX)
Housing Finance Corporation Multifamily Housing Revenue Bonds
(Park at Wells Branch Apartments Project) Series 2002A (the
"Senior Bonds") and Series 2002C (the "Subordinate Bonds"). The
outlook of the Series 2002A bonds remains Negative.

The Senior bonds continue to be insured by National Public Finance
Guarantee (formerly MBIA) and carry National's financial strength
rating (Baa2, Negative). The Subordinate Series 2002C bonds are
not insured.

Rating Rationale

The rating affirmation of the Senior bonds is based on the
increase in occupancy, audited FY2011 debt service coverage of
1.08x on the senior bonds (with the Capital Reserve Fee and MBIA
fee's below the line), and the untapped Series 2002A Debt Service
Reserve fund.

The C rating of the Subordinate Bonds is based on continued
defaults, as evidenced by a Notice of Non-Payment dated December
3, 2012.

Park at Wells Branch (the "Property") is a 304-unit apartment
complex composed of 18 apartment buildings, and is located in the
northern section of the Austin metropolitan area in Travis County,
Texas.

Strengths:

- Debt service coverage of 1.08x on the Senior Bonds as of the
   audited FY2011 audit, up from 0.98x in audited FY2010.

- Community Housing Corporation of America, Inc. (CHC), the
   owner of the Property, has contributed substantial amounts to
   the Property to fund working capital and debt service
   requirements since 2003.

- Management indicates that the Property is 97% occupied as of
   November 2012.

Challenges:

- The Senior Bond's Debt Service Reserve fund is currently
   funded at 95% of maximum annual debt service (MADS), however,
   in the event that cash becomes available through the flow of
   funds, it will be replenished to its requirement.

- Fund balances provided by the Trustee show that the
   Subordinate Bond's Debt Service Reserve Fund has been
   depleted.

- The Property still struggles with generating greater revenue
   due to low rental rates.

Outlook

The outlook on the bonds remains negative due to the weak
financial performance of the project and the underfunded Senior
Bond's Debt Service Reserve Fund.

What Could Change The Rating -- Up

  - An increase in revenues and debt service coverage, and a
    fully funded reserve

What Could Change The Rating -- Down

  - Deterioration of the debt service coverage level to less than
    1.0x

  - A tap to the Senior Bond's Debt Service Reserve fund

The principal methodology used in this rating was Global Housing
Projects published in July 2010.


UBS-BARCLAYS 2013-C5: Fitch Assigns 'B' Rating to Class F Notes
---------------------------------------------------------------
Fitch Ratings has issued a presale report on UBS-Barclays
Commercial Mortgage Trust 2013-C5.

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

-- $82,500,000 class A-1 'AAAsf'; Outlook Stable;
-- $17,000,000 class A-2 'AAAsf'; Outlook Stable;
-- $200,000,000 class A-3 'AAAsf'; Outlook Stable;
-- $629,529,000 class A-4 'AAAsf'; Outlook Stable;
-- $110,500,000 class A-AB 'AAAsf'; Outlook Stable;
-- $120,660,000(a) class A-S 'AAAsf'; Outlook Stable;
-- $1,160,189,000(a)(b)class XA 'AAAsf'; Outlook Stable;
-- $154,073,000(a)(b)class XB 'A-sf'; Outlook Stable;
-- $96,528,000(a) class B 'AA-sf'; Outlook Stable;
-- $274,733,000(a) class EC 'A-sf'; Outlook Stable;
-- $57,545,000(a) class C 'A-sf'; Outlook Stable;
-- $70,540,000(a) class D 'BBB-sf'; Outlook Stable;
-- $27,844,000(a) class E 'BBsf'; Outlook Stable;
-- $27,845,000(a) class F 'Bsf'; Outlook Stable.

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

The expected ratings are based on information provided by the
issuer as of Feb. 8, 2013. Fitch does not expect to rate the
$44,551,823 class G.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 81 loans secured by 122 commercial
properties having an aggregate principal balance of approximately
$1.5 billion as of the cutoff date. The loans were contributed to
the trust by UBS Real Estate Securities, Inc., Barclays Bank PLC,
General Electric Capital Corp., KeyBank N.A., Archetype Mortgage
Funding I LLC, RAIT Partnership, LP, and The Bancorp Bank.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 77.9% of the properties
and cash flow analysis on 85.2% of the collateral pool by balance.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.45x, a Fitch stressed loan-to-value (LTV) of 95.8%,
and a Fitch debt yield of 9.75%. Fitch's aggregate net cash flow
represents a variance of 7.6% to issuer cash flows.

The Master Servicer and Special Servicer will be Midland Loan
Services, Inc., rated 'CMS1' and 'CSS1', respectively, by Fitch.


UNITED ARTISTS: Moody's Keeps 'B3' Rating on Series 1995-A Certs
----------------------------------------------------------------
Moody's Investors Service affirmed the rating of United Artists
Theatre Circuit, Inc. 1995-A Pass Through Trust 9.3% Pass Through
Certificates, Series 1995-A as follows:

1995-A, Affirmed at B3; previously on Mar 23, 2011 Upgraded to B3

Ratings Rationale

The rating of the Certificates is affirmed at B3 based on the
current rating of Regal Entertainment Group (senior unsecured
rating B3; stable outlook).

The principal methodology used in this rating was "Commercial Real
Estate Finance: Moody's Approach to Rating Credit Tenant Lease
Financings" published in November 2011.

There was no model used in the review of this transaction.

Other methodologies and factors that may have been considered in
the process of rating this issuer can also be found on Moody's
website.

Moody's ratings are determined by a committee process that
considers both quantitative and qualitative factors.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
prior full review is summarized in a press release dated February
16, 2012.

Deal Performance

As of the January 2013 distribution date, the Certificate balance
has paid down by approximately 85% to USD18 million from USD117
million at securitization. The transaction is supported by a
portfolio of movie theatres that are subject to fully bondable,
triple net leases to Regal. The lease payments are sufficient to
pay all principal and interest for the Certificates.


VERITAS CLO I: Moody's Affirms 'B3' Rating on $8MM Class E Notes
----------------------------------------------------------------
Moody's Investors Service upgraded the ratings of the following
notes issued by Veritas CLO I, Ltd.:

  USD16,000,000 Class C Third Priority Mezzanine Secured Floating
  Rate Deferrable Interest Notes Due 2016, Upgraded to Aaa (sf);
  previously on May 9, 2012 Upgraded to Aa1 (sf);

  USD10,500,000 Class D Fourth Priority Mezzanine Secured
  Floating Rate Deferrable Interest Notes Due 2016, Upgraded to
  Baa2 (sf); previously on August 11, 2011 Upgraded to Ba1 (sf).

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

  USD229,000,000 Class A First Priority Senior Secured Floating
  Rate Notes Due 2016 (current outstanding balance of
  $13,989,147), Affirmed Aaa (sf); previously on February 4, 2011
  Upgraded to Aaa (sf);

  USD19,000,000 Class B Second Priority Senior Secured Floating
  Rate Notes Due 2016, Affirmed Aaa (sf); previously on August
  11, 2011 Upgraded to Aaa (sf);

  USD8,000,000 Class E Fifth Priority Mezzanine Secured Floating
  Rate Deferrable Interest Notes Due 2016, Affirmed B3 (sf);
  previously on August 11, 2011 Upgraded to B3 (sf).

Ratings Rationale

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the senior notes and an
increase in the transaction's overcollateralization ratios since
the rating action in May 2012. Moody's notes that the Class A
Notes have been paid down by approximately 68% or $29.6 million
since the last rating action. Based on the latest trustee report
dated December 31, 2012, the Class A/B, Class C, Class D, and
Class E overcollateralization ratios are reported at 224.2%,
151.0%, 124.3% and 109.6%, respectively, versus March 2012 levels
of 159.2%, 130.1%, 116.2%, and 107.4%, respectively.

Additionally, the deal has benefited from an improvement in the
credit quality of the underlying portfolio since the last rating
action in May 2012. Based on the December 2012 trustee report, the
weighted average rating factor is currently 2355 compared to 2510
in March 2012.

Moody's notes that the underlying portfolio includes a number of
investments in securities that mature after the maturity date of
the notes. Based on the December 2012 trustee report, securities
that mature after the maturity date of the notes currently make up
approximately 40.1% 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 the overcollateralization ratio of
the Class E notes, Moody's affirmed the rating of the Class E
notes due to the market risk posed by the exposure to these long-
dated assets.

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 $66.9 million,
defaulted par of $5.6 million, a weighted average default
probability of 12.1% (implying a WARF of 2240), a weighted average
recovery rate upon default of 47.8%, and a diversity score of 24.
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.

Veritas CLO I, Ltd., issued in August 2004, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

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

In addition to the base case analysis described, Moody's also
performed sensitivity analyses to test the impact on all rated
notes of various default probabilities.

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% (1792)

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

Moody's Adjusted WARF + 20% (2688)

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

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

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

3) Long-dated assets: The presence of assets that mature beyond
the CLO's legal maturity date exposes the deal to liquidation risk
on those assets. Moody's assumes an asset's terminal value upon
liquidation at maturity to be equal to the lower of an assumed
liquidation value (depending on the extent to which the asset's
maturity lags that of the liabilities) and the asset's current
market value. The deal continues to experience an increased
exposure resulting from Amend- and- Extend activities relating to
loan agreements. In consideration of the size of the deal's
exposure to long-dated assets, which increases its sensitivity to
the liquidation assumptions used in the rating analysis, Moody's
ran different scenarios considering a range of liquidation value
assumptions. However, actual long-dated asset exposure and
prevailing market prices and conditions at the CLO's maturity will
drive the extent of the deal's realized losses, if any, from long-
dated assets.


WFRBS 2013-C11: Fitch Assigns 'B' to Class F Certificates
---------------------------------------------------------
Fitch Ratings has assigned these ratings to WFRBS Commercial
Mortgage Trust 2013-C11 commercial mortgage pass-through
certificates:

-- $65,123,000 class A-1 'AAAsf'; Outlook Stable;
-- $278,494,000 class A-2 'AAAsf'; Outlook Stable;
-- $46,800,000 class A-3 'AAAsf'; Outlook Stable;
-- $100,000,000 class A-4 'AAAsf'; Outlook Stable;
-- $417,757,000 class A-5 'AAAsf'; Outlook Stable;
-- $97,254,000 class A-SB 'AAAsf'; Outlook Stable;
-- $134,656,000 class A-S 'AAAsf'; Outlook Stable;
-- $1,140,084,000(*a) class X-A 'AAAsf'; Outlook Stable;
-- $152,609,000(*a) class X-B 'A-sf'; Outlook Stable;
-- $93,361,000 class B 'AA-sf'; Outlook Stable;
-- $59,248,000 class C 'A-sf'; Outlook Stable;
-- $46,681,000(a) class D 'BBB-sf'; Outlook Stable;
-- $32,317,000(a) class E 'BBsf'; Outlook Stable;
-- $25,136,000(a) class F 'Bsf'; Outlook Stable.

Fitch does not rate the $39,499,346(a) class G.

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

The certificates represent the beneficial ownership in the trust,
the primary assets of which are 82 loans secured by 153 commercial
properties having an aggregate principal balance of approximately
$1.436 billion as of the cutoff date. The loans were contributed
to the trust by Wells Fargo Bank, National Association, The Royal
Bank of Scotland, C-III Commercial Mortgage LLC, Liberty Island
Group I LLC, and Basis Real Estate Capital II, LLC.

A detailed description of Fitch's rating analysis including key
rating drivers, stresses, rating sensitivity, analysis, model,
criteria application and data adequacy is available in Fitch's
Presale Report.


WFRBS 2013-C11: S&P Assigns 'B+' Rating on Class F Notes
--------------------------------------------------------
Standard & Poor's Ratings Services assigned its 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 $1.44 billion, secured by the fee
interest in 153 properties across 33 states.

The 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
Ratings Services determined that the collateral pool has, on a
weighted average basis, debt service coverage of 1.85x
and beginning and ending loan-to-value 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

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)        100,000,000
A-5         AAA (sf)        417,757,000
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.


* Fitch Says U.S. Subprime Auto ABS Could See Poorer Underwriting
-----------------------------------------------------------------
Fitch believes the recent success in the U.S. subprime auto ABS
market is leading to increased competition among lenders, which
could result in looser underwriting practices. "We also believe
the recent improvement in the stability of asset performance may
suggest future loss performance is more closely tied to new
jobless claims than overall unemployment," Fitch says.

"The recent positive U.S. subprime auto ABS market has, overall,
been driven by strong 2009, 2010, and 2011 vintages, which have
benefitted from comparatively strong credit quality and loan terms
during a solid market for used vehicles. During this time, the
financial condition of the borrowers in the pool has improved as
the less credit worthy ones defaulted. We believe these changes
have contributed to a continued decoupling of subprime auto ABS
from the overall employment rate beginning in 2010. In our view,
trends in new jobless claims may provide a better leading
indicator going forward because it more closely tracks the
financial condition of borrowers remaining in the pools.

"Performance in subprime auto ABS will likely to tail off for 2012
and 2013 vintages. We expect 2013 securitizations to include
weaker collateral quality than prior years, including extended
loan terms and weaker credit tier distributions. Over the longer
term, this factor is viewed as a potential risk to the market.
Should the positive performance in the market continue and attract
more participants to it, the subsequent increase in competition
could result in looser underwriting standards and exaggerate
expectations. And if another recession or downdraft in the market
coincides with this expansion, we would expect a significant
challenge to many vintages."


* Moody's Takes Action on 3 RMBS Deals Backed by Assured Guaranty
-----------------------------------------------------------------
Moody's Investors Service downgraded the ratings of four tranches,
confirmed the ratings of two tranches, and affirmed the ratings of
41 tranches from three RMBS resecuritization deals. The
resecuritizations are backed by underlying bonds from different
prime jumbo, Alt-A , subprime, and HELOC RMBS transactions.

Ratings Rationale

The rating actions reflect the January 18, 2013 rating action on
some of the underlying bonds wrapped by Assured Guaranty Municipal
Corp. (AGM) and Assured Guaranty Corp. (AGC). The actions also
reflect the recent performance of the pools of mortgages backing
the underlying bonds and the updated loss expectations on the
resecuritization bonds.

The principal methodology used in these ratings was "Moody's
Approach to Rating US Resecuritized Residential Mortgage-Backed
Securities" published in February 2011. The methodology used in
rating Interest-Only Securities was "Moody's Approach to Rating
Structured Finance Interest-Only Securities" published in February
2012.

The principal methodology used in determining the ratings of the
underlying bonds is described in the Monitoring and Performance
Review section in "Moody's Approach to Rating US Residential
Mortgage-Backed Securities" published in December 2008.

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

The primary sources of assumption uncertainty are our 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 7.9% in January 2013.
Moody's forecasts a unemployment central range of 7.5% to 8.5% 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 the transaction.

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

Complete rating actions are as follows:

Issuer: AAA Trust 2007-2

Cl. A-1, Affirmed A3 (sf); previously on Jan 18, 2013 Downgraded
to A3 (sf)

Financial Guarantor: Assured Guaranty Corp (Downgraded to A3,
Outlook Stable on Jan 17, 2013)

Cl. A-2, Affirmed A3 (sf); previously on Jan 18, 2013 Downgraded
to A3 (sf)

Financial Guarantor: Assured Guaranty Corp (Downgraded to A3,
Outlook Stable on Jan 17, 2013)

Cl. A-3, Affirmed C (sf); previously on May 24, 2011 Downgraded to
C (sf)

Cl. X, Affirmed Caa2 (sf); previously on Feb 22, 2012 Downgraded
to Caa2 (sf)

Issuer: CWHEQ Revolving Home Equity Loan Resecuritization Trust
2006-RES

Cl. 04D-1a, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04D-1b, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04E-1a, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04E-1b, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04F-1a, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04F-1b, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04K-1a, Affirmed Caa3 (sf); previously on Jun 29, 2011
Downgraded to Caa3 (sf)

Cl. 04K-1b, Affirmed Caa3 (sf); previously on Jun 29, 2011
Downgraded to Caa3 (sf)

Cl. 04L-1a, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04L-1b, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04M-1a, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04M-1b, Affirmed Caa2 (sf); previously on Jun 29, 2011
Downgraded to Caa2 (sf)

Cl. 04N-1a, Affirmed Caa3 (sf); previously on Jun 29, 2011
Downgraded to Caa3 (sf)

Cl. 04N-1b, Affirmed Caa3 (sf); previously on Jun 29, 2011
Downgraded to Caa3 (sf)

Cl. 04P-1a, Affirmed Caa2 (sf); previously on Dec 5, 2012
Downgraded to Caa2 (sf)

Financial Guarantor: MBIA Insurance Corporation (Downgraded to
Caa2, Outlook Developing on Nov 19, 2012)

Cl. 04P-1b, Affirmed Caa2 (sf); previously on Dec 5, 2012
Downgraded to Caa2 (sf)

Financial Guarantor: MBIA Insurance Corporation (Downgraded to
Caa2, Outlook Developing on Nov 19, 2012)

Cl. 04Q-1a, Affirmed Caa3 (sf); previously on Jun 2, 2009
Downgraded to Caa3 (sf)

Cl. 04Q-1b, Affirmed Caa3 (sf); previously on Jun 2, 2009
Downgraded to Caa3 (sf)

Cl. 04R-1a, Affirmed Ca (sf); previously on Jun 2, 2009 Downgraded
to Ca (sf)

Cl. 04R-1b, Affirmed Ca (sf); previously on Jun 2, 2009 Downgraded
to Ca (sf)

Cl. 04T-1a, Affirmed Ca (sf); previously on Jun 29, 2011
Downgraded to Ca (sf)

Cl. 04T-1b, Affirmed Ca (sf); previously on Jun 29, 2011
Downgraded to Ca (sf)

Cl. 04U-1a, Affirmed Ca (sf); previously on Jun 2, 2009 Downgraded
to Ca (sf)

Cl. 04U-1b, Affirmed Ca (sf); previously on Jun 2, 2009 Downgraded
to Ca (sf)

Cl. 05A-1a, Affirmed Caa2 (sf); previously on Dec 5, 2012
Downgraded to Caa2 (sf)

Financial Guarantor: MBIA Insurance Corporation (Downgraded to
Caa2, Outlook Developing on Nov 19, 2012)

Cl. 05A-1b, Affirmed Caa2 (sf); previously on Dec 5, 2012
Downgraded to Caa2 (sf)

Financial Guarantor: MBIA Insurance Corporation (Downgraded to
Caa2, Outlook Developing on Nov 19, 2012)

Cl. 05B-1a, Affirmed Caa3 (sf); previously on Jun 2, 2009
Downgraded to Caa3 (sf)

Cl. 05B-1b, Affirmed Caa3 (sf); previously on Jun 2, 2009
Downgraded to Caa3 (sf)

Cl. 05C-1a, Downgraded to A2 (sf); previously on Dec 5, 2012 Aa3
(sf) Placed Under Review for Possible Downgrade

Financial Guarantor: Assured Guaranty Municipal Corp (Downgraded
to A2, Outlook Stable on Jan 17, 2013)

Cl. 05C-1b, Downgraded to A2 (sf); previously on Dec 5, 2012 Aa3
(sf) Placed Under Review for Possible Downgrade

Financial Guarantor: Assured Guaranty Municipal Corp (Downgraded
to A2, Outlook Stable on Jan 17, 2013)

Cl. 05D-1a, Downgraded to A2 (sf); previously on Dec 5, 2012 Aa3
(sf) Placed Under Review for Possible Downgrade

Financial Guarantor: Assured Guaranty Municipal Corp (Downgraded
to A2, Outlook Stable on Jan 17, 2013)

Cl. 05D-1b, Downgraded to A2 (sf); previously on Dec 5, 2012 Aa3
(sf) Placed Under Review for Possible Downgrade

Financial Guarantor: Assured Guaranty Municipal Corp (Downgraded
to A2, Outlook Stable on Jan 17, 2013)

Cl. 05E-1a, Affirmed Caa2 (sf); previously on Dec 5, 2012
Downgraded to Caa2 (sf)

Financial Guarantor: MBIA Insurance Corporation (Downgraded to
Caa2, Outlook Developing on Nov 19, 2012)

Cl. 05E-1b, Affirmed Caa2 (sf); previously on Dec 5, 2012
Downgraded to Caa2 (sf)

Financial Guarantor: MBIA Insurance Corporation (Downgraded to
Caa2, Outlook Developing on Nov 19, 2012)

Cl. 05F-1a, Affirmed Ca (sf); previously on Jun 29, 2011
Downgraded to Ca (sf)

Cl. 05F-1b, Affirmed Ca (sf); previously on Jun 29, 2011
Downgraded to Ca (sf)

Cl. 05G-1a, Affirmed Caa3 (sf); previously on Jun 29, 2011
Downgraded to Caa3 (sf)

Cl. 05G-1b, Affirmed Caa3 (sf); previously on Jun 29, 2011
Downgraded to Caa3 (sf)

Cl. 05H-1a, Affirmed Caa3 (sf); previously on Jun 29, 2011
Downgraded to Caa3 (sf)

Cl. 05H-1b, Affirmed Caa3 (sf); previously on Jun 29, 2011
Downgraded to Caa3 (sf)

Issuer: Financial Asset Securities Corp. AAA Trust 2003-1

Cl. A-5, Confirmed at Ba2 (sf); previously on Feb 13, 2012 Ba2
(sf) Placed Under Review for Possible Downgrade

Cl. A-6, Confirmed at Baa3 (sf); previously on Feb 13, 2012 Baa3
(sf) Placed Under Review for Possible Downgrade

Cl. X, Affirmed Ba1 (sf); previously on Feb 22, 2012 Downgraded to
Ba1 (sf)


* S&P Lowers Rating on 4 Tranches from 3 CDO Transactions
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
tranches from two corporate-backed synthetic collateralized debt
obligation (CDO) transactions and one synthetic CDO transaction
referencing commercial-mortgage backed-securities.  At the same
time, S&P withdrew its ratings on four tranches from three
corporate-backed synthetic CDO transactions and affirmed its
rating on one tranche from one corporate-backed synthetic CDO
transaction.

The downgrades are from tranches that either experienced principal
losses due to credit events in the underlying portfolios or have
had interest shortfall observed on tranches.

The withdrawals follow notices of cancellation of the notes.  S&P
notes that it withdrew its rating on the CreditLink notes from
Iridal Public Ltd. Co. following the withdrawal of its rating on
the underlying linked security.

The affirmed rating reflects S&P's belief that the credit support
available is commensurate with the current rating level.

          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

ARLO VII Ltd.
Series 2007-CSTOB-7A-2
                     Rating
Class              To        From
CSTON-7A-2         D (sf)    CCC- (sf)

ARLO VII Ltd.
Series 2007-CSTON-10A-2
                  Rating
Class            To        From
CSTON-10A-2      CCC- (sf) CCC- (sf)

Tiers Wolcott Synthetic CDO Floating Rate Credit Linked Trust
Series 2007-27
                  Rating
Class            To        From
Certificate      D (sf)    CC (sf)

Aphex Capital NSCR 2007-7SR Ltd.
                  Rating
Class            To         From
A-1A             D (sf)     CC (sf)
A-1B             D (sf)     CC (sf)

RATINGS WITHDRAWN

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

Iridal Public Ltd. Co.
Series 4
                  Rating
Class            To        From
CreditLink       NR        AAA (sf)

Morgan Stanley ACES SPC
AUD20 mil class III floating rate secured combination notes series
2007-9
Class                   To        From
Class III interest      NR        CCC- (sf)
Class III principle     NR        BB-p (sf)

NR - Not rated.


* S&P Lowers Rating on 16 Classes From 43 US CDO Transactions
-------------------------------------------------------------
Standard & Poor's Ratings Services said that it affirmed its
ratings on 24 tranches from 24 corporate-backed synthetic
collateralized debt obligations (CDOs).  S&P lowered its ratings
on 16 tranches from 16 corporate-backed CDOs.  At the same time,
S&P withdrew its ratings on two tranches from two corporate-backed
synthetic CDO transactions and one from one of CDO transaction.

The affirmed ratings reflect S&P's belief that the credit support
available is commensurate with the current rating level.

The downgrades are from tranches with attachment points that were
breached.

The withdrawals result from lack of timely information on the
tranches.

          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:

Cloverie PLC
Series 2007-24
                            Rating
Class               To                  From
2007-24             CCC- (sf)           CCC- (sf)

Credit Default Swap
                            Rating
Class               To                  From
Tranche             CCC-srb (sf)        CCC-srb (sf)

Deutsche Bank AG
                            Rating
Class               To                  From
Tranche             CCC-srp (sf)        CCC-srp (sf)

Infiniti SPC Limited
Series 2007-4
                            Rating
Class               To                  From
B                   CCC- (sf)           CCC- (sf)
Landgrove Synthetic CDO SPC
Series 2007-2
                            Rating
Class               To                  From
C2                  CCC- (sf)           CCC- (sf)

PARCS Master Trust
Series 2006-8 TRIPOLI
                            Rating
Class               To                  From
Trust Unit          CCC- (sf)           CCC- (sf)

PARCS Master Trust
Series 2007-4 CALVADOS
                            Rating
Class               To                  From
Trust Unit          CCC- (sf)           CCC- (sf)

PARCS Master Trust
Series 2007-8
                            Rating
Class               To                  From
Trust Unit          CCC- (sf)           CCC- (sf)

PARCS Master Trust
                            Rating
Class               To                  From
Unit                CCC- (sf)           CCC- (sf)

PARCS Master Trust
Series 2007-19
                            Rating
Class               To                  From
TrustUnits          CCC- (sf)           CCC- (sf)

Rutland Rated Investments
Series 2007-1 (48)
                            Rating
Class               To                  From
A3A-F               CCC- (sf)           CCC- (sf)

Rutland Rated Investments
Series 48
                            Rating
Class               To                  From
A3A-L               CCC- (sf)           CCC- (sf)

STARTS (Cayman) Ltd.
Series 2006-8
                            Rating
Class               To                  From
C1-D1               CCC- (sf)           CCC- (sf)

STARTS (Cayman) Ltd.
Series 2007-14
                            Rating
Class               To                  From
A2-A                CCC- (sf)           CCC- (sf)

STARTS (Cayman) Ltd.
2007-18
                            Rating
Class               To                  From
B1-A1               CCC- (sf)           CCC- (sf)

STARTS (Cayman) Ltd.
2007-29
                            Rating
Class               To                  From
B3-D3               CCC- (sf)           CCC- (sf)

STARTS (Ireland) PLC
2007-15
                            Rating
Class               To                  From
Notes               CCC- (sf)           CCC- (sf)

STEERS Randolph Gate CDO Trust
2006-1
                            Rating
Class               To                  From
Trust Unit          CCC- (sf)           CCC- (sf)

STEERS Thayer Gate CDO Trust
Series 2006-6
                            Rating
Class               To                  From
Trust Unit          CCC- (sf)           CCC- (sf)

Strata Trust
Series 2007-4
                            Rating
Class               To                  From
Notes               CCC- (sf)           CCC- (sf)

Tribune Ltd.
Series 28
                            Rating
Class               To                  From
Aspen061A3          CCC- (sf)           CCC- (sf)

Tribune Ltd.
39
                            Rating
Class               To                  From
Tranche             CCC- (sf)           CCC- (sf)

UBS AG (Jersey Branch)
3832
                            Rating
Class               To                  From
Notes               CCC- (sf)           CCC- (sf)

UBS AG (Jersey Branch)
4012
                            Rating
Class               To                  From
Notes               CCC- (sf)           CCC- (sf)


RATINGS LOWERED:
US$10 mil Swap Risk Rating Portfolio - CDS Reference # C1304925M
                            Rating
Class               To                  From
Swap                D (sf)              CCsrp (sf)

US$10 mil Swap Risk Rating Portfolio - CDS Reference # C1315268M
                            Rating
Class               To                  From
Swap                D (sf)              CCsrp (sf)

US$50 mil Swap Risk Rating Portfolio - CDS Reference # C1355189M
                            Rating
Class               To                  From
Swap                D (sf)              CCsrp (sf)

Primoris SPC Ltd
Series A1-7
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series A1-7-2
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series A2-7
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series A5-7
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series A6-7
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series B1-7
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series B2-10-2
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series C3-7
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series D1-7-2
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series D3-10
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series E3-7
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Primoris SPC Ltd
Series F1-10
                            Rating
Class               To                  From
Nts                 D (sf)              CC (sf)

Signum Platinum II Ltd. Series 2006-01
2006-01
                            Rating
Class               To                  From
2006-01             D (sf)              CC (sf)


RATINGS WITHDRAWN:

Aphex Pacific Capital Ltd.
5 DESIGN 2006
                            Rating
Class               To                  From
                    NR                  CCC- (sf)

Morgan Stanley ACES SPC
Series 2006-16
                            Rating
Class               To                  From
III                 NR                  CCC- (sf)

Sceptre Capital B.V.
2007-2
                            Rating
Class               To                  From
                    NR                  CC (sf)

NR-Not Rated


* S&P Lowers Ratings on 6 Classes From 3 U.S. CMBS Transactions
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of commercial mortgage pass-through certificates from
three U.S. commercial mortgage-backed securities (CMBS)
transactions due to current and potential interest shortfalls and
reduced liquidity support.

S&P lowered its ratings on four of these classes to 'D (sf)'
because it expects the accumulated interest shortfalls to remain
outstanding for the foreseeable future.  The four classes that S&P
downgraded to 'D (sf)' have had accumulated interest shortfalls
outstanding for nine to 12 months.  The recurring interest
shortfalls for the respective certificates are primarily due to
one or more of the following factors:

   -- Appraisal subordinate entitlement reduction (ASER) amounts
      in effect for specially serviced assets.

   -- Special servicing fees.

   -- Shortfalls due to rate modifications.

Standard & Poor's analysis primarily considered the ASER amounts
based on appraisal reduction amounts (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals.  S&P
also considered special servicing fees that it believes are likely
to cause recurring interest shortfalls.

The servicer implements ARAs and resulting ASER amounts in
accordance with each respective transaction's terms.  Typically,
these terms call for the automatic implementation of an ARA equal
to 25% of the stated principal balance of a loan when a loan is 60
days past due and an appraisal or other valuation is not available
within a specified timeframe.  S&P primarily considered ASER
amounts based on ARAs calculated from MAI appraisals when deciding
which classes from the affected transactions to downgrade to 'D
(sf)'.  This is because ARAs based on a principal balance haircut
are highly subject to change, or even reversal, once the special
servicer obtains the MAI appraisals.

Credit Suisse First Boston Mortgage Securities Corp., Series 2002-
                               CP5

S&P lowered its ratings on the Class H, J, and K certificates from
Credit Suisse First Boston Mortgage Securities Corp., Series 2002-
CP5.  S&P lowered its ratings on the Class J and K certificates to
'D (sf)' to reflect accumulated interest shortfalls outstanding
nine months, primarily due to ASER amounts related to 13
($81.8 million; 67.6%) of the 21 assets ($119.4 million; 98.6%)
that are currently with the special servicer, LNR Partners Inc.,
and special servicing fees of $24,998.  S&P expects these
accumulated interest shortfalls to remain outstanding for the
foreseeable future.  S&P lowered its rating on Class H due to
reduced liquidity support available to the class resulting from
the continued interest shortfall.  Class H has outstanding
accumulated interest shortfalls for six months. As of the Jan. 17,
2013, trustee remittance report, ARAs totaling $38.5 million were
in effect for 15 of the 21 specially serviced assets, and the
total reported ASER amount was $12,437.  The net reported monthly
interest shortfalls totaled $41,758 and affected Class J and all
bonds subordinate to it.

Credit Suisse First Boston Mortgage Securities Corp., Series 2003-
                                C5

S&P lowered its ratings on the Class J and K certificates from
Credit Suisse First Boston Mortgage Securities Corp., Series 2003-
C5, due to interest shortfalls.  S&P lowered its rating on the
Class K certificate to 'D (sf)' to reflect accumulated interest
shortfalls outstanding for nine months, primarily due to ASER
amounts related to four ($22.8 million; 3.3%) of the five
($34.1 million; 4.9%) assets that are currently with the special
servicer, Torchlight Investors LLC, and special servicing fees of
$18,999.  S&P lowered its rating on the Class J certificate due to
reduced liquidity support available to the class and the potential
for the class to experience interest shortfalls related to the
specially serviced assets.  As of the Jan. 17, 2013, trustee
remittance report, ARAs totaling $7.1 million were in effect for
five specially serviced assets.  The total reported monthly ASER
amount was $36,067.  Of the monthly shortfalls, $232,503 is
workout fees.  Given the liquidation of one asset, it is expected
that $231,221 of the shortfall will not be ongoing.  The reported
monthly interest shortfalls totaled $358,454 and affected Class F
and all of the classes subordinate to it.

Credit Suisse First Boston Mortgage Securities Corp., Series 2005-
                                C3

S&P lowered its rating on the Class E certificate from Credit
Suisse First Boston Mortgage Securities Corp., Series 2005-C3, to
'D (sf)' due to accumulated interest shortfalls outstanding for 12
months.  The accumulated interest shortfalls were primarily as a
result of ASER amounts related to five ($33.3 million; 3.0%) of
the seven ($35.1 million; 3.1%) assets that are currently with the
special servicer, LNR Partners Inc., and special servicing fees of
24,179.  As of the Jan. 17, 2013, trustee remittance report, ARAs
totaling $11.7 million were in effect for five of the specially
serviced loans.  The reported ASER amount was $53,775.  The
reported monthly interest shortfalls totaled $ 80,086 and affected
all bonds subordinate to and including Class E.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS LOWERED

Credit Suisse First Boston Mortgage Securities Corp., Series 2002-
CP5
                                             Reported
          Rating           Credit      Interest shortfalls
Class     To     From     enhcmt(%)  Current  Accumulated
H      CCC(sf)    BB+(sf)     36.45    0           97,250
J      D(sf)      CCC(sf)     18.09    97,234     753,776
K      D(sf)      CCC-(sf)    13.19    25,931     230,896

Credit Suisse First Boston Mortgage Securities Corp., Series 2003-
C5
                                             Reported
          Rating           Credit      Interest shortfalls
Class     To     From     enhcmt(%)  Current  Accumulated
J      CCC-(sf)   CCC(sf)      3.63    41,194      41,194
K      D(sf)      CCC-(sf)     2.72    27,464     141,428

Credit Suisse First Boston Mortgage Securities Corp., Series 2005-
C3
                                             Reported
          Rating           Credit      Interest shortfalls
Class     To     From     enhcmt(%)  Current  Accumulated
E      D(sf)      CCC-(sf)      1.1    31,485      57,205


* S&P Lowers Ratings on 43 Classes From 24 US RMBS Transactions
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 43
classes from 15 U.S. residential mortgage-backed securities (RMBS)
transactions and removed 22 of them from CreditWatch with negative
implications, four from CreditWatch with positive implications,
and 16 from CreditWatch with developing implications.  S&P also
raised its rating on one class from one transaction and removed it
from CreditWatch developing.  S&P also affirmed its ratings on 72
classes from 21 transactions and removed five from CreditWatch
negative, one from CreditWatch positive, and 10 from CreditWatch
developing.  Furthermore, S&P withdrew its ratings on five classes
because they were supported by mortgage pools containing less than
20 loans, paid in full, or in accordance with S&P's interest-only
(IO) criteria.

The transactions in this review were issued between 1995 and 2008
and are backed by a mix of adjustable- and fixed-rate subprime and
"scratch-and-dent" loans secured primarily by first liens on one-
to four-family residential properties.

On Aug. 15, 2012, S&P placed its ratings on 63 classes from 19 of
the transactions within this review on CreditWatch negative or
developing, along with ratings from a group of other RMBS
securities due to the implementation of S&P's recently revised
criteria for surveilling pre-2009 U.S. RMBS ratings.  S&P
completed its review of the transactions herein using the revised
assumptions and these rating actions resolve some of the
CreditWatch placements.  The directional movements of the
CreditWatch resolutions within this review are as follows:

                           Three or fewer       More than three
From Watch   Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos          1          0        3        0        0
Watch Neg          5          0        3        0       19
Watch Dev         10          0       11        1        5

* S&P withdrew its ratings on an additional four classes, which
  were also on CreditWatch.

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

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

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

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

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

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

   -- A continued elevated level of observed severities.

In line with the factors described above, S&P increased its
remaining loss projections for the majority of the transactions in
this review from its previous projections.  The remaining
projected losses ranged from an increase of 1.61% (to 39.58% from
38.96%) for Accredited Mortgage Loan Trust 2007-1 to an increase
of 140.44% (to 30.56% from 12.71%) for OwnIt Mortgage Loan Trust,
Series 2005-1.

"We lowered our ratings on 43 classes from 15 transactions.  Of
the lowered ratings, we lowered our ratings on 21 classes out of
investment-grade, including 16 that we lowered to 'CCC (sf)' or
lower.  Of the classes we downgraded out of investment-grade, 13
classes from three transactions had ratings in the 'AAA (sf)'
categories before today's actions.  Some of the downgrades to
speculative-grade from 'AAA (sf)' reflect significant increases
to our updated loss severities for the related transactions.
Another nine ratings remain at investment-grade after being
lowered.  We rated the remaining classes with lowered ratings in
the speculative-grade category before today's rating actions. Of
the ratings lowered,  class B-2 from Structured Asset Securities
Corp. 2005-RF2 reflected the application of our interest shortfall
criteria," S&P said.

Despite the increase in remaining projected losses, S&P raisedthe
rating on class A-2B from Merrill Lynch Mortgage Investors Trust
Series 2005-HE3, which S&P originally rated in an investment-grade
category.  In general, the upgrade reflects two general trends S&P
have seen in this type of transaction:

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

   -- The class has a first priority in interest and principal
      payments driven by the occurrence of the above.

The raised rating has sufficient projected credit support to
absorb the projected remaining losses associated with those rating
stresses.

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

   -- Historical interest shortfalls;

   -- Low priority in principal payments;

   -- Significant growth in the delinquency pipeline;

   -- High proportion of reperforming loans in the pool;

   -- Significant growth in observed loss severities; and

   -- Weak hard-dollar credit support.

The five 'AAA (sf)' ratings from four transactions that S&P
affirmed affect bonds that:

   -- Have more than sufficient credit support to absorb the
      projected remaining losses associated with this rating
      stress; and

   -- Benefit from permanently failing cumulative loss triggers.

The five affirmations from three transactions in the 'AA (sf)' and
'A (sf)' categories affect classes that:

   -- Are currently in first, second, or third payment priority;
      and

   -- Benefit from permanently failing cumulative loss triggers.

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

S&P affirmed its ratings on 56 additional classes in the 'CCC
(sf)' or 'CC (sf)' rating categories.  S&P believes that the
projected credit support for these classes will remain
insufficient to cover the revised projected losses to these
classes.

"We withdrew our ratings on three classes in accordance with our
IO criteria because the referenced classes no longer sustain
ratings above 'A+ (sf)'.  We withdrew one other rating because the
class is within a structure or transaction that is backed by less
than 20 loans outstanding.  We withdrew one other rating because
the class paid in full," S&P noted.

Standard & Poor's believes that the liquidation of one or more of
the loans in transactions with a small number of remaining loans
may have an adverse effect on the stability of its outstanding
ratings.  Therefore, in cases where a structure contained fewer
than 100 loans or was approaching 100 loans remaining, S&P
addressed tail risk by conducting additional loan-level analysis
that stressed the loan concentration risk within the specific
pool.  In accordance with S&P's counterparty criteria, it
considered any applicable hedges related to these securities when
performing these rating actions.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com


* S&P Lowers Ratings on 33 Classes From 7 US RMBS Transactions
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 33
classes from seven U.S. residential mortgage-backed securities
(RMBS) transactions.  Of these, S&P removed 31 from CreditWatch
with negative implications.

In addition, S&P raised its ratings on nine classes from two
transactions and removed eight of these ratings from CreditWatch
developing.

S&P also affirmed its ratings on 26 classes from seven
transactions, removed three from CreditWatch negative, and took
three off CreditWatch developing.

S&P also withdrew its ratings on four classes from two
transactions due to its current interest-only criteria which
prompts withdrawal on these classes that would be rated below 'AA-
(sf)'.

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

On Aug. 15, 2012, S&P placed its ratings on 49 classes from six of
these transactions on CreditWatch negative or developing, along
with ratings from a group of other RMBS securities due to the
implementation of S&P's recently revised criteria for surveilling
U.S. RMBS ratings assigned before 2009.  Ratings on CreditWatch
negative accounted for about 78% of the resolved CreditWatch
actions in this review, with the remainder ratings on CreditWatch
developing.  S&P completed its review of these transactions using
its revised assumptions, and these rating actions resolve these
CreditWatch placements.

                              3 or fewer       More than 3
From         Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos          0          0        0        0        0
Watch Neg          3          0       24        0        7
Watch Dev          3          0        0        8        0

The high percentage of CreditWatch negative placements reflected
S&P's projection that remaining losses for a majority of the prime
jumbo transactions will increase.  The ratings on certain
structures were on CreditWatch negative because of decreased
forecasted losses because of a higher multiple of loss coverage
for certain investment-grade rated tranches, as set forth in S&P's
revised criteria.

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

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

   -- An increased portion (generally 1%-8%) of nondelinquent
      loans are now categorized as reperforming (many of these
      loans have been modified) and

   -- have a default frequency of 25%-30%.

   -- S&P's extended liquidation curves that eroded projected
      credit support prior to when it would be needed.

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

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

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

   -- The lack of credit enhancement floors that could add
      additional protection to the classes within a structure.
      Securities currently rated 'AAA (sf)' in transactions that
      have shifting-interest pay mechanisms and do not benefit
      from a credit enhancement floor or an equivalent functional
      mechanism will be rated no higher than 'AA+ (sf)'.

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

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

Of the 33 downgraded classes, S&P lowered its ratings on six to
speculative-grade from investment-grade.  Each of these classes
were lowered to ratings between 'BB+ (sf)' and 'B- (sf)'.  In
addition, 16 of the lowered ratings remain at investment-grade.
The remaining 11 downgraded classes already had speculative-grade
ratings prior to the downgrades.

S&P affirmed its ratings on 20 classes in the 'CCC (sf)' or 'CC
(sf)' categories.  S&P believes that the projected credit support
for these classes will remain insufficient to cover the revised
base-case projected losses to these classes.

In accordance with S&P's counterparty criteria, it considered any
applicable hedges related to these securities when performing
these rating actions and resolving the CreditWatch placements.

For prime jumbo transactions subordination generally provides the
credit support, while overcollateralization (prior to its
depletion) and excess spread, when applicable, provide support for
additional structures.

          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

BellaVista Mortgage Trust 2004-1
Series 2004-1
                       Rating               Rating
Class      CUSIP       To                   From
II-A-1     07820QAC9   A+ (sf)              AA+ (sf)/Watch Neg
II-A-2     07820QAD7   A+ (sf)              AA+ (sf)/Watch Neg
II-A-3     07820QAF2   A+ (sf)              AA+ (sf)/Watch Neg
II-A-4     07820QAG0   A+ (sf)              AA+ (sf)/Watch Neg
II-A-5     07820QAH8   A+ (sf)              AA+ (sf)/Watch Neg
II-M       07820QAQ8   B- (sf)              BB (sf)/Watch Neg

Citigroup Mortgage Loan Trust 2007-10
Series  2007-10
                       Rating               Rating
Class      CUSIP       To                   From
3A3A       17313QBP2   CC (sf)              CCC (sf)

GSR Mortgage Loan Trust 2003-9
Series 2003-9
                       Rating               Rating
Class      CUSIP       To                   From
A-1        36228FWR3   B+ (sf)              AAA (sf)/Watch Neg
A-2        36228FWS1   B+ (sf)              AAA (sf)/Watch Neg
A3         36228FWT9   B+ (sf)              AAA (sf)/Watch Neg
X1         36228FWX0   NR                   AAA (sf)/Watch Neg
X2         36228FWY8   NR                   AAA (sf)/Watch Neg
X3         36228FWZ5   NR                   AAA (sf)/Watch Neg
B1         36228FWU6   B+ (sf)              AA- (sf)/Watch Neg
B2         36228FWV4   CCC (sf)             B- (sf)/Watch Neg

Prime Mortgage Trust 2005-4
Series 2005-4
                       Rating               Rating
Class      CUSIP       To                   From
I-A-1      74160MJX1   BBB+ (sf)            A- (sf)/Watch Neg
I-A-2      74160MJY9   BB+ (sf)             BBB- (sf)/Watch Neg
I-A-3      74160MJZ6   BB+ (sf)             AA+ (sf)/Watch Neg
I-A-4      74160MKA9   B (sf)               BB+ (sf)/Watch Neg
I-A-5      74160MKB7   BB (sf)              BB (sf)/Watch Dev
I-A-6      74160MKC5   BBB- (sf)            BBB (sf)/Watch Neg
I-A-7      74160MLM2   B (sf)               BB (sf)/Watch Neg
I-PO       74160MKD3   B (sf)               BB (sf)/Watch Neg
I-X        74160MKE1   NR                   AA+ (sf)/Watch Neg
II-A-8     74160MKT8   B- (sf)              CC (sf)
II-A-10    74160MKV3   CC (sf)              CCC (sf)

Structured Asset Securities Corp.
Series      2002-6
                       Rating               Rating
Class      CUSIP       To                   From
1-A5       86358RZK6   AA+ (sf)             AAA (sf)/Watch Neg
2-A2       86358RZM2   AA+ (sf)             AAA (sf)/Watch Neg
AP         86358RZY6   AA+ (sf)             AAA (sf)/Watch Neg
AX         86358RZZ3   AA+ (sf)             AAA (sf)/Watch Neg
PAX        86358RZX8   AA+ (sf)             AAA (sf)/Watch Neg
IAX        86358RZW0   AA+ (sf)             AAA (sf)/Watch Neg
B1         86358RA23   AA (sf)              AA (sf)/Watch Dev
B2         86358RA31   B (sf)               B (sf)/Watch Dev

Structured Asset Securities Corp.
Series      2002-5A
                       Rating               Rating
Class      CUSIP       To                   From
1-A1       86358RYP6   A (sf)               BB (sf)/Watch Dev
1-A2       86358RYQ4   A (sf)               BB (sf)/Watch Dev
1-A3       86358RYR2   A (sf)               BB (sf)/Watch Dev
1-A4       86358RYS0   A (sf)               BB (sf)/Watch Dev
2-A1       86358RYU5   A (sf)               BB (sf)/Watch Dev
2-A2       86358RYV3   A (sf)               BB (sf)/Watch Dev
3-A        86358RYX9   B+ (sf)              BB (sf)/Watch Neg
4-A        86358RYY7   A (sf)               BB (sf)/Watch Dev
5-A        86358RYZ4   A (sf)               BB (sf)/Watch Dev
6-A        86358RZA8   B (sf)               BB (sf)/Watch Neg
B1         86358RZB6   B (sf)               B (sf)/Watch Neg
B2         86358RZC4   CCC (sf)             B (sf)/Watch Neg
B3         86358RZD2   CCC (sf)             B (sf)/Watch Neg

Thornburg Mortgage Securities Trust 2004-1
Series      2004-1
                       Rating               Rating
Class      CUSIP       To                   From
II-1A      885220EV1   AAA (sf)             AAA (sf)/Watch Neg
II-2A      885220EW9   AA+ (sf)             AAA (sf)/Watch Neg
II-3A      885220EX7   AA+ (sf)             AAA (sf)/Watch Neg
II-4A      885220EY5   AAA (sf)             AAA (sf)/Watch Neg
II-M       885220FA6   BBB (sf)             A (sf)/Watch Neg

RATINGS AFFIRMED

BellaVista Mortgage Trust 2004-1
Series          2004-1
Class      CUSIP       Rating
II-B-1     07820QAR6   CC (sf)

Citigroup Mortgage Loan Trust 2007-10
Series        2007-10
Class      CUSIP       Rating
2A5A       17313QAW8   CCC (sf)
2A5B       17313QAX6   CC (sf)
3A1A       17313QBG2   CCC (sf)
3A2A       17313QBM9   CC (sf)

GSR Mortgage Loan Trust 2003-9
Series          2003-9
Class      CUSIP       Rating
B3         36228FWW2   CC (sf)

Prime Mortgage Trust 2005-4
Series       2005-4
Class      CUSIP       Rating
II-A-2     74160MKM3   CC (sf)
II-A-3     74160MKN1   CC (sf)
II-A-4     74160MKP6   CC (sf)
II-A-7     74160MKS0   CC (sf)
II-A-9     74160MKU5   CC (sf)
II-A-11    74160MKW1   CC (sf)
II-A-12    74160MKX9   CC (sf)
II-PO      74160MKY7   CC (sf)
I-B-1      74160MKH4   CCC (sf)
I-B-2      74160MKJ0   CC (sf)
I-B-3      74160MKK7   CC (sf)
I-B-4      74160MLF7   CC (sf)
I-B-5      74160MLG5   CC (sf)

Structured Asset Securities Corp.
Series           2002-6
Class      CUSIP       Rating
B3         86358RA49   CCC (sf)


* S&P Lowers Ratings on 217 Classes From 66 U.S. RMBS Deals
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 217
classes from 66 U.S. residential mortgage-backed securities (RMBS)
resecuritized real estate mortgage investment conduit (re-REMIC)
transactions and removed 210 of them from CreditWatch with
negative implications and one from CreditWatch with developing
implications.  S&P also affirmed its ratings on 1,109 classes from
116 transactions and removed 751 of them from CreditWatch negative
and 29 of them from CreditWatch developing.  In addition, S&P is
keeping 1,663 classes from 88 transactions on CreditWatch,
negative or developing.  Furthermore, S&P withdrew its ratings on
90 classes because they were paid in full or in accordance with
its interest-only (IO) criteria.

The transactions in this review were issued between 2003 and 2010
and are supported by underlying RMBS backed by an assortment of
different collateral types including, but not limited to, prime,
Alt-A, and subprime mortgage loans.  Subordination,
overcollateralization (when available), and excess interest as
applicable generally provide credit support for underlying
securities of the re-REMIC transactions.  In addition,
subordination within the capital structures of the re-REMICs
themselves is generally existent in most transactions.

On Oct. 26, 2012, S&P placed its ratings on 2,847 classes from 205
re-REMIC transactions on CreditWatch negative or developing due to
the implementation of S&P's revised criteria, "U.S. RMBS
Surveillance Credit and Cash Flow Analysis for Pre-2009
Originations," published Aug. 9, 2012.  S&P completed its review
for a portion of the transactions herein using the revised
assumptions, and therefore these rating actions resolve some of
the CreditWatch placements.  The directional movements for the
CreditWatch resolutions within this review are as follows:

                              Three or fewer    More than three
From Watch   Affirmations      notches           notches
                                   Down            Down
Watch Neg        751               130               80
Watch Dev        29                  1                0

Overall, the CreditWatch resolutions indicated in the table above
represent that most re-REMIC classes may have possessed adequate
credit enhancement, which was indicative of a rating affirmation.
The revised criteria did, however, result in a number of downward
rating movements.  S&P attributed roughly 10% of the downgrades to
projected interest shortfalls applied to the re-REMIC classes
based on the analysis.  In particular, the revised criteria
resulted in additional stress to certain underlying securities,
thus affecting some re-REMIC classes.  Such additional stresses
include, but are not limited to, one or more of the following
factors:

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

   -- A substantial portion of nondelinquent loans now
      categorized as reperforming (many of these underlying loans
      have been modified) and have a default frequency from 25%-
      to-50%;

   -- Overall increases in roll rates (expected default) for
      30- and 60-day delinquent loans;

   -- Application of a high prepayment/front end stress
      liquidation scenario under investment-grade rating
      scenarios; and

   -- An overall continued elevated level of observed loss
      severities.

For certain transactions, S&P's lowest rating in the re-REMIC may
be different than the lowest rating on an underlying class.  S&P
attribute this to the mechanics of the re-REMIC (such as
additional credit enhancement or rapid pay-down at the re-REMIC
level) or the application of additional stress at the re-REMIC
level in concert with tempered upward rating movement compared
with that of the underlying security.

S&P resolved the CreditWatch placements for roughly half of the
transactions within this review.  When doing so, S&P applied its
loss projections to the underlying collateral in order to identify
the magnitude of losses that S&P believes could be passed through
from the underlying securities to the applicable re-REMIC classes.
In addition, S&P stressed its loss projections at various rating
categories to assess whether the re-REMIC classes could withstand
the stressed losses associated with their ratings, while receiving
the appropriate level of interest and principal due.

The remaining half, approximately, of re-REMIC transactions in
this review have ratings that are remaining on CreditWatch.  For
roughly half of these, the CreditWatch resolutions are pending
S&P's analysis of projected, if any, interest shortfalls that may
affect the re-REMIC classes under the applicable rating scenario.
For the other half, or so, the resolutions are pending S&P's
evaluation of certain structural features of the re-REMIC and/or
the mechanics of the underlying securities which may require
additional analysis.

As such, the CreditWatch placements for the associated classes
will remain until S&P has concluded the extent of any applicable
rating actions.  S&P intends on completing these in subsequent
weeks ahead.

S&P lowered its ratings on three classes to 'D (sf)' due to
defaults.  Additionally, S&P affirmed a number of 'CCC' and 'CC'
re-REMIC ratings based on its evaluation of the change in overall
losses and associated downward rating movements of underlying
securities, combined with S&P's overall view that the securities
lack sufficient credit enhancement when compared with S&P's base-
case outlook.  S&P also withdrew its ratings on 90 classes either
because the classes have been paid in full or in accordance with
S&P's interest-only (IO) criteria in which the referenced classes
no longer sustain ratings above 'A+ (sf)'.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com


* S&P Lowers Rating on 614 Classes From 120 US RMBS Transactions
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 614
classes from 120 U.S. residential mortgage-backed securities
(RMBS) transactions and removed 390 of them from CreditWatch with
negative implications and 110 of them from CreditWatch with
developing implications.  S&P also raised its ratings on 83
classes from 30 transactions and removed 13 of them from
CreditWatch with positive implications, 37 of them from
CreditWatch developing, and 12 of them from CreditWatch negative.
S&P also affirmed its ratings on 464 classes from 136 transactions
and removed 16 of them from CreditWatch negative, 18 from
CreditWatch developing, and three of them from CreditWatch
positive.  Six classes from six transactions will remain on
CreditWatch negative, and two classes from two transactions will
remain on CreditWatch developing.  S&P also withdrew its ratings
on 65 classes from 30 transactions.  Of the withdrawn ratings, 43
were on CreditWatch negative and four were on CreditWatch
developing.  Three of the withdrawn ratings were lowered prior to
withdrawal.

The transactions in this review were issued between 1999 and 2008
and are backed primarily by adjustable- and fixed-rate Alt-A and
Neg-am mortgage loans secured primarily by first liens on one- to
four-family residential properties.  The IndyMac Loan Trust and
IndyMac Residential Mortgage-Backed Trust transactions in this
review are backed by residential lot loans.

On Aug. 15, 2012, S&P placed its ratings on 654 classes from 105
transactions within this review on CreditWatch negative, positive,
or developing, along with ratings from a group of other RMBS
securities after implementing S&P's recently revised criteria for
surveillance on pre-2009 U.S. RMBS ratings.

CreditWatch negative placements were approximately 57% of the
actions, CreditWatch developing placements were approximately 36%,
and CreditWatch positive placements were approximately 7%.  S&P
completed its review using the new methodology and assumptions,
and the rating actions resolve some of the CreditWatch placements;
an overview of the directional change of the CreditWatch
resolutions is as follows:

                            Three or fewer       More than three
From         Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos          3          2        0       11        0
Watch Neg         16          8      162        4      228
Watch Dev         18         12       89       25       21

The high number of CreditWatch negative placements reflected S&P's
projection that remaining losses for most of the transactions in
this review will increase.  S&P may have also placed its ratings
on CreditWatch negative for certain structures that had reduced
forecasted losses due to an increased multiple of loss coverage
for certain investment-grade rated tranches as set forth in S&P's
revised criteria.

Increases in projected losses resulted from one or more of the
following factors:

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

   -- A substantial portion of non-delinquent loans now
      categorized as reperforming (many of these loans have been
      modified) and having a default frequency of between 30% and
      45%;

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

   -- An overall continued elevated level of observed loss
      severities.  S&P used deal- or shelf-specific loss
      severities for the majority of the transactions within this
      review: 38% of the Alt-A and 45% of the Neg-am structures
      had loss severities that were greater than the default loss
      severity for its respective cohort.

Shelf                                               No.deals/
                                                    structures
Name                                                reviewed
American General Mortgage Loan Trust  (AGT0)        1/1
American Home Mortgage Assets Trust  (AHA0)         1/1
American Home Mortgage Investment Trust  (AHM0)     8/25
Banc of America Alternative Loan Trust  (BAA0)      3/5
Banc of America Funding Trust (BAF0)                2/5
BCAP LLC Trust  (BCP0)                              2/2
Bear Stearns Mortgage Funding (BSF0)                6/9
Chevy Chase Funding LLC (CCF0)                      2/2
Citicorp Mortgage Securities Inc. (CMA0)            2/2
Citigroup Mortgage Loan Trust  (CML0/SB70)          4/8
Credit Suisse First Boston Mtg. Sec. Corp. (CSF0)   8/13
CSMC Mortgage-Backed Trust  (CSM0)                  2/4
Alternative Loan Trust  (CWA0/CWF0)                 15/18
Deutsche Alt-A Securities Mortgage Loan Tr (DAA0)   4/4
Deutsche Alt-B Securities Mortgage Loan Tr (DAB0)   1/1
Deutsche Mortgage Securities (DMS0)                 3/4
DSLA Mortgage Loan Trust  (DSLA)                    1/1
First Horizon Alternative Mortgage Sec. Tr (FHAT)   3/3
Freddie Mac Securities REMIC Trust   (FHL0)         1/2
Fannie Mae Grantor Trust  (FNM0)                    1/1
FNT Trust  (FNT0)                                   1/1
Greenpoint Mortgage Funding (GPM0)                  4/5
GSAA Trust  (GSAA)                                  1/1
Home Re  (HMRE)                                     1/1
Homestar Mortgage Acceptance Corp. (HMS0)           1/1
HomeBanc Mortgage Trust  (HMT0)                     3/4
Harborview Mortgage Loan Trust  (HVML)              1/4
IndyMac Loan Trust  (ILT0)                          4/4
Impac CMB Trust  (IMHE)                             5/12
IndyMac IMJA Mortgage Loan Trust  (IMJA)            1/1
IndyMac IMSC Mortgage Loan Trust  (IMSC)            2/2
IndyMac INDA Mortgage Loan Trust  (INA0)            3/3
IndyMac INDB Mortgage Loan Trust  (INDB)            1/1
IndyMac Residential Mortgage-Backed Trust (INRM)    2/2
IndyMac INDX Mortgage Loan Trust  (INX0)            2/2
Impac Secured Assets (ISC0)                         9/13
JPMorgan Alternative Loan Trust  (JMA0)             2/3
Lehman Mortgage Trust  (LMT0)                       6/22
Luminent Mortgage Trust  (LUM0)                     1/1
Lehman XS Trust (LXS0)                              1/1
MASTR Alternative Loan Trust  (MALT)                13/17
MASTR Adjustable Rate Mortgages Trust  (MARM)       2/2
Morgan Stanley Mortgage Loan Trust  (MSM0)          4/6
Wells Fargo Bank (NAA0)                             1/1
Opteum Mortgage Acceptance Corporation (OMAC)       1/1
PHH Alternative Mortgage Trust (PHHA)               1/1
PNC Mortgage Securities Corp. (PNC9)                1/1
Residential Asset Securitization Trust  (RAS0)      1/1
RALI/RAMP Trust (RFC0)                              9/12
RBSGC Mortgage Loan Trust  (RGC0)                   2/3
Structured Asset Mortgage Investments II (SAMI)     4/4
Structured Adjustable Rate Mortgage Loan Tr (SAR0)  4/6
Structured Asset Securities Corp. (SAS0)            7/7
SBI Home Equity Loan Trust  (SBI0)                  1/2
Terwin Mortgage Trust  (TMT0/TWM0)                  2/4
Washington Mutual Mtg.Pass-Thr. Cert. Tr (WAL0)     3/3
Wachovia Mortgage Loan Trust (WML0)                 1/1
WaMu Mortgage Pass-Through Certificates (WMS0)      3/3

Shelf      # IG         # Non-IG    # IG to       # Down/Up
Name       Affirmed     Affirmed    Non-IG        >3 notches
AGT0       6            0           0             0/0
AHA0       0            1           0             0/0
AHM0       3            28          7             17/1
BAA0       0            5           0             7/6
BAF0       0            17          1             1/0
BCP0       0            1           0             1/1
BSF0       0            10          0             0/0
CCF0       0            2           0             0/3
CMA0       0            6           0             0/1
CML0       0            3           4             7/0
CSF0       6            7           10            21/0
CSM0       0            45          0             0/9
CWA0       0            42          7             13/0
CWF0       0            8           8             10/4
DAA0       0            7           1             1/0
DAB0       0            0           0             0/0
DMS0       4            14          2             6/0
DSLA       0            1           3             5/0
FHAT       0            3           0             0/0
FHL0       0            0           0             0/0
FNM0       4            0           0             0/0
FNT0       0            0           0             0/0
GPM0       0            6           0             1/0
GSAA       0            2           0             3/0
GSR0       0            0           0             0/0
HMRE       0            0           0             0/0
HMS0       0            2           0             1/0
HMT0       0            9           1             2/1
HVML       3            1           0             0/0
ILT0       0            0           0             0/0
IMHE       0            1           4             8/0
IMJA       0            0           0             0/0
IMSC       0            0           0             0/0
INA0       0            7           0             0/0
INDB       0            4           0             0/0
INRM       0            0           0             0/0
INX0       0            4           4             4/0
ISC0       1            8           6             9/0
JMA0       0            2           0             0/0
LMT0       0            32          0             0/1
LUM0       0            1           0             0/0
LXS0       0            1           0             0/0
MALT       0            65          16            61/5
MARM       0            4           4             21/0
MSM0       0            16          0             7/0
NAA0       1            0           0             0/0
OMAC       4            2           0             0/1
PHHA       0            3           0             0/0
PNC9       0            0           0             0/0
RAS0       0            0           0             0/0
RFC0       0            8           6             13/0
RGC0       0            0           2             2/0
SAMI       0            8           0             0/1
SAR0       0            17          0             4/0
SAS0       0            6           2             4/18
SB70       0            2           1             6/0
SBI0       0            0           0             2/1
TMT0       0            4           0             0/1
TWM0       0            1           0             3/0
WAL0       0            10          0             0/0
WML0       0            3           0             0/0
WMS0       0            3           7             9/0

IG - Investment Grade
The tables below detail information by vintage and on each
reviewed shelf as of November 2012.

Structure Count

Vintage   Alt-A   Neg-Am   High-LTV  Lot Loan  Small Bal. Comm
Pre-05    81      12       4         1         1
2005      28      12       0         2         3
2006      27      20       0         3         3
2007      52      17       0         0         0
2008       3       1       0         0         0

Total DQ (%)

Vintage    Alt-A   Neg-Am  High-LTV  Lot Loan  Small Bal. Comm
1999       33.00
2000       29.39
2001       13.26
2002       13.11
2003       12.35
2004       14.75   21.83    12.32    78.64        0.00
2005       18.96   29.49             48.20        0.60
2006       25.76   48.33             91.88        4.93
2007       26.07   40.26
2008       26.54

Severe DQ (%)

Vintage    Alt-A   Neg-Am  High LTV  Lot Loan  Small Bal. Comm
1999       17.96
2000       24.74
2001        9.35
2002        8.59
2003        8.94
2004       11.37   17.28    9.05      78.64     0.00
2005       14.82   25.18              46.20     0.37
2006       21.10   43.21              89.22     3.01
2007       21.35   35.77
2008       22.39

Losses and Delinquencies*

Shelf     Avg. Pool    Cum. Loss   Serious DQ    Total DQ
Name      Factor (%)   Avg. (%)    Avg. (%)      Avg. (%)
AGT0      33.83         0.66        5.34          9.57
AHA0      48.48        25.28       32.18         36.34
AHM0      21.07        15.16       16.67         19.66
BAA0      26.32         0.86        6.48          8.87
BAF0      41.03         9.68       17.91         20.62
BCP0      45.31        11.77       19.92         24.85
BSF0      44.63        25.39       39.68         43.95
CCF0      16.59         5.02       19.77         22.48
CMA0      39.38         9.01       12.05         17.16
CML0      18.95         2.07       12.92         15.55
CSF0       5.36         0.91       11.97         15.24
CSM0      52.99         8.30       21.50         25.17
CWA0      27.65         8.14       27.45         31.77
CWF0      12.94         1.77       23.16         27.09
DAA0      39.70        16.03       28.57         31.91
DAB0      47.68        18.75       35.22         40.09
DMS0      11.65         0.97       12.30         15.56
DSLA       9.83         2.50       14.39         21.10
FHAT      33.87         5.46       13.79         18.27
FHL0      25.57         4.59       14.76         20.27
GPM0      39.17        24.97       35.22         39.08
GSAA      13.74         0.99       23.96         23.96
HMS0      16.76         2.33       12.34         13.03
HMT0      38.60        13.52       16.89         18.75
HVML      24.87        17.73       48.57         52.55
ILT0       5.28        20.80       85.70         87.57
IMHE      21.63         4.82        9.03         11.68
IMJA      44.43         7.61       16.80         22.10
IMSC      47.57        17.66       27.31         35.63
INA0      35.03         5.82       11.81         15.63
INDB      28.11        32.30       40.34         53.31
INRM       6.33        16.08       47.16         49.05
INX0       4.69         1.80       24.22         34.03
ISC0      32.57         9.78       13.58         17.33
JMA0      35.75         7.84       22.30         28.66
LMT0      32.02        10.14       21.18         27.16
LUM0      30.25        20.91       41.06         48.23
LXS0      37.71        28.45       32.31         37.51
MALT      24.04         1.39       10.59         15.10
MARM       7.14         0.42       16.74         22.11
MSM0      31.80         8.17       23.58         27.79
NAA0      32.34        18.70       31.73         36.22
OMAC      18.34         5.79       10.47         13.30
PHHA      48.01        11.23       21.57         25.34
PNC9       1.65         0.57       17.96         33.00
RAS0      47.30        13.44       21.12         28.41
RFC0      20.37         6.33       10.90         16.27
RGC0      39.25         7.15       14.57         19.10
SAMI      51.36        21.48       45.50         51.75
SAR0      40.61         9.55       23.73         28.06
SAS0      18.97         2.12       17.97         21.84
SB70       5.81         0.38        9.02         12.13
SBI0      31.05         0.72        1.87          2.98
TMT0      26.58        25.94       23.50         32.32
TWM0      17.71         3.28       10.23         11.46
WAL0      43.16         9.33       19.00         24.73
WML0      34.13        17.38       23.26         25.71
WMS0      11.77         1.22       12.86         16.57

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

In line with the factors described above, S&P revised its
remaining loss projections for all of the transactions in this
review from S&P's previous projections.  As a result of a majority
of these transactions having increased loss projections, 50% of
the rating actions in this review were downgrades and most of the
remaining actions were affirmations.

Despite the increase in remaining projected losses for a majority
of the transactions, S&P upgraded 83 classes from 30 transactions
and removed 13 of them from CreditWatch positive, 37 of them from
CreditWatch developing, and 12 of them from CreditWatch negative.
The 12 classes that were upgraded and removed from CreditWatch
negative were previously placed on CreditWatch negative due to
tail risk associated with the related structures having a small
amount of loans remaining.  The upgrades reflect sufficient credit
enhancement to support projected losses at the respective rating
level.  Some of these classes are the most senior tranches
outstanding in their respective transactions.  S&P's decisions on
these classes primarily reflected the structural mechanics of
these transactions, namely situations where cumulative loss
triggers embedded in the deals have failed, causing principal to
be distributed sequentially, which helps prevent credit support
erosion and increases the likelihood that these tranches will
receive their full share of principal payments prior to the
realization of S&P's projected losses.  Other classes have been
upgraded due to an extended loss curve that increases the amount
of excess spread available for credit support in S&P's
projections.

Lastly, the upgrades of some senior classes that receive principal
and interest from a particular loan group were as a result of
better projected group level performance.

S&P affirmed its ratings on 464 classes from 136 transactions and
removed 16 of them from CreditWatch negative, 18 of them from
CreditWatch developing, and three of them from CreditWatch
positive.  Of these, 421 classes are rated 'CCC (sf)' or 'CC
(sf)'.  S&P believes that the projected credit support for these
classes will remain insufficient to cover the revised projected
losses.  Conversely, the affirmations for classes with ratings
above 'CCC' reflect S&P's opinion that the credit support for
these classes will remain sufficient to cover the revised
projected losses.

S&P lowered its ratings on 614 classes from 120 transactions and
removed 390 of them from CreditWatch with negative implications
and 110 of them from CreditWatch with developing implications.  Of
the lowered ratings, S&P downgraded 96 classes out of investment-
grade, including 19 that S&P downgraded to 'CCC (sf)'.  Another
313 ratings remain at investment-grade after being lowered.  The
remaining downgraded classes already had speculative-grade ratings
prior to the actions.  S&P downgraded 65 classes to 'D (sf)' from
observed principal write-downs and 21 classes to 'D (sf)' from
interest shortfalls in accordance with S&P's interest shortfall
criteria.

Senior tranches accounted for the bulk of the lowered ratings
(552); the remaining downgrades affected mezzanine classes.
Contrary to the characteristics that distinguished the upgrades
and affirmations highlighted above, these downgraded tranches
generally did not exhibit either a high priority in payment or a
short projected life.

The downgrades were primarily from significantly greater lifetime
loss projections driven by increased loss severities and loans
classified as reperforming, which caused an increase in S&P's
projected default rates on non-delinquent loans.  Also, ratings
that S&P lowered but that remain at investment-grade were
primarily driven by its increased stress multiples applied to
ratings 'A (sf)' and above.

Six classes from six transactions will remain on CreditWatch
negative, and two classes from two transactions will remain on
CreditWatch developing.  The related structures within these
transactions are backed by small balance commercial loans and are
not in scope for this review.

Two ratings from two transactions were withdrawn due to the
classes being paid in full.  S&P withdrew four ratings from Home
Re 2005-2 Limited because the transaction has no loans remaining.
Each of the classes within the transaction previously carried a
rating of 'D (sf)'.  S&P withdrew 17 ratings from six transactions
issued by IndyMac Loan Trust and IndyMac Residential Mortgage-
Backed Trust as all the classes within each transaction previously
carried a rating of 'D (sf)'.  Each of these classes was not paid
by their final maturity date.  S&P withdrew its ratings on 39
classes from 18 transactions in accordance with its interest-only
criteria because the referenced classes no longer sustained
ratings above 'A+ (sf)'.  In addition, S&P withdrew its ratings on
Credit Suisse First Boston Mortgage Securities Corp. 2002-AR17 and
FNT Trust Series 2000-1 because the transactions had less than 20
loans outstanding.  Three classes from these transactions were
downgraded prior to withdrawal because of the tail risk associated
with the loan group of the respective class.  S&P addresses tail
risk in transactions by conducting additional loan-level analysis
that stresses the loan concentration risk within the applicable
transactions.  Each rating withdrawal follows the application of
our policy for withdrawal of ratings.

In accordance with S&P's counterparty criteria, it considered any
applicable hedges related to these securities when performing
these rating actions and resolving the CreditWatch placements.

Subordination, overcollateralization (when available), and excess
interest as applicable generally provide credit support for these
transactions.  Some classes may also benefit from bond insurance.
In these cases, the long-term rating on the class reflects the
higher of the rating on the bond insurer and the underlying credit
rating on the security without the benefit of such bond insurance.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com


* S&P Cuts Ratings on 95 Classes From 15 US RMBS Transactions
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 95
classes from 15 U.S. residential mortgage-backed securities (RMBS)
transactions.  Of these, Standard & Poor's removed 52 from
CreditWatch with negative implications and 32 from CreditWatch
developing.

In addition, S&P raised its ratings on three classes from one
transaction and removed one of these ratings from CreditWatch
developing.

S&P also affirmed its ratings on 47 classes from eight
transactions, removed four from CreditWatch negative, and took
five off CreditWatch developing.

Standard & Poor's also withdrew its ratings on 16 classes from
seven transactions; of these, 14 had been on CreditWatch negative,
and two had been on CreditWatch developing.  S&P withdrew 10 of
the ratings, which were from six transactions, because of S&P's
current interest-only criteria, which prompts the withdrawal of
the classes that would be rated below 'AA- (sf)'.  Five withdrawn
ratings from three transactions were because the classes have been
paid in full, and one was due to S&P's view of the potential for
performance volatility associated with collateral groups that
contain fewer than 20 loans.

Of the 22 structures reviewed, 14 are prime jumbo, five are Re-
REMIC, and two are synthetic risk-transfer deals.  The two U.S.
RMBS synthetic risk-transfer transactions reviewed were issued by
RESIX Finance Ltd.

The transactions in this review were issued between 1992 and 2007
and are backed by adjustable- and fixed-rate mortgage loans
secured primarily by first liens on one- to four-family
residential properties.

On Aug. 15, 2012, S&P placed its ratings on 110 classes from these
16 transactions on CreditWatch negative, positive, or developing,
along with ratings from a group of other RMBS securities due to
the implementation of S&P's recently revised criteria for
surveilling U.S. RMBS ratings assigned before 2009.  Ratings on
CreditWatch negative accounted for about 60% of the resolved
CreditWatch actions in this review, with the remainder ratings on
CreditWatch developing.  S&P completed its review of these
transactions using its revised assumptions, and thes rating
actions resolve these CreditWatch placements.

                               3 or fewer       More than 3
From         Affirmations      notches           notches
                             Up      Down      Up      Down
Watch Pos          0          0        0        0        0
Watch Neg          4          0       10        0       42
Watch Dev          5          1        2        0       30

The high percentage of CreditWatch negative placements reflected
S&P's projection that remaining losses for a majority of the prime
jumbo transactions will increase.  The ratings on certain
structures were on CreditWatch negative because of decreased
forecasted losses due to a higher multiple of loss coverage for
certain investment-grade rated tranches, as set forth in S&P's
revised criteria.

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

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

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

   -- S&P's extended liquidation curves that eroded projected
      credit support prior to when it would be needed.

For the re-REMIC structures reviewed, S&P intends its ratings to
address the timely payment of interest and ultimate payment of
principal.  S&P reviewed the interest and principal amounts due on
the underlying securities, which are then passed through to the
applicable re-REMIC classes.  S&P applied its loss projections,
incorporating its loss assumptions, to the underlying collateral
to identify the principal and interest amounts that could be
passed through from the underlying securities under S&P's rating
scenario stresses.  S&P stressed its loss projections at various
rating categories to assess whether the re-REMIC classes could
withstand the stressed losses associated with their ratings while
receiving timely payment of interest and principal consistent
with S&P's criteria.

In risk-transfer transactions, the owner of a pool of mortgage
loans (the protection buyer) enters a financial guarantee contract
with the issuer (the protection seller) of the securities.
Pursuant to the guarantee agreement, the protection seller
guarantees to pay the protection buyer an amount equal to
certain losses realized on the underlying pool of mortgage loans,
known as the reference portfolio.  The mortgage pools in the RESIX
transactions consist primarily of first-lien, fixed-rate, and
adjustable-rate prime jumbo mortgage loans.

In risk-transfer transactions, unlike traditional mortgage-backed
securitizations, the actual cash flow from the reference portfolio
is not paid to the issuer and ultimately to the transactions'
security holders.  Rather, the proceeds from the issuance of the
securities are deposited in an eligible account and are then
invested in eligible investments.  The interest payable to the
security-holders is paid from income earned on these investments
as well as from payments made by the protection buyer under the
financial guarantee contract.  The principal payable to the
security-holders is paid from funds initially deposited into the
eligible account.  Principal payments on the securities mirror the
principal payments made on the reference portfolio.

If S&P was unable to obtain loan-level information for a
transaction structure, it applied its criteria as outlined in
Paragraph 64 of "Methodology And Assumptions: U.S. RMBS
Surveillance Credit And Cash Flow Analysis For Pre-2009
Originations," which was published on Aug. 9, 2012.

S&P reviewed and withdrew its rating on Class A-2 from Housing
Securities Inc. because it is backed by a collateral group that
contains fewer than 20 loans.  If any of the remaining loans in
this pool were to default, the resulting loss could have a greater
effect on the pool's performance than if the pool consisted of a
larger number of loans.  Due to the small number of loans
remaining, this performance volatility could have an adverse
effect on the stability of the rating.

In addition, S&P withdrew its ratings on 15 other classes from six
transactions.  Ten of these ratings, which were from six
transactions, were withdrawn in accordance with S&P's current
interest-only criteria. few withdrew five ratings from three
transactions because the classes have been paid in full.

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

Of the 95 downgraded classes, S&P lowered its ratings on 39 to
speculative-grade from investment-grade.  Of these classes, S&P
lowered 30 to ratings between 'BB+ (sf)' and 'B- (sf)' and lowered
nine to the 'CCC (sf)' or 'CC (sf)' categories.  In addition, 35
of the lowered ratings remain at investment-grade.  The remaining
21 downgraded classes already had speculative-grade ratings prior
to the downgrades.

S&P affirmed its ratings on 38 classes in the 'CCC (sf)' or 'CC
(sf)' categories.  S&P believes that the projected credit support
for these classes will remain insufficient to cover the revised
base-case projected losses to these classes.

In accordance with S&P's counterparty criteria, it considered any
applicable hedges related to these securities when performing
these rating actions and resolving the CreditWatch placements.

For the prime jumbo transactions we review, subordination
generally provides the credit support, while overcollateralization
(prior to its depletion) and excess spread, when applicable,
provide support for additional structures.

When reviewing the risk-transfer transactions, S&P applied its
criteria described in "Methodology: U.S. RMBS Synthetic Risk
Transfers," published Feb. 6, 2009.  S&P looked at several
factors, including the recent performance of the prime collateral
backing these transactions, S&P's current projected losses, the
projected credit support to cover those losses, and the rating on
the applicable party responsible for making certain interest
payments (the protection buyer).

Temporary telephone contact numbers: Michael Graffeo, (1) 646-584-
7722); Jessica Barbara, (1) 201-341-9193; Terry Osterweil, (1)
718-986-8140

          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

Banc of America Funding 2005-3 Trust
Series 2005-3
                       Rating               Rating
Class      CUSIP       To                   From
1-A-4      05946XVL4   NR                   AA (sf)/Watch Dev
1-A-9      05946XVR1   BBB (sf)             AA (sf)/Watch Dev
1-A-10     05946XVS9   BB (sf)              AA (sf)/Watch Dev
1-A-11     05946XVT7   NR                   AA (sf)/Watch Dev
1-A-12     05946XVU4   AA (sf)              AA (sf)/Watch Dev
1-A-13     05946XW2   BB (sf)              AA (sf)/Watch Dev
1-A-14     05946XVW0   CC (sf)              AA (sf)/Watch Dev
1-A-18     05946XWA7   BBB (sf)             AA (sf)/Watch Dev
1-A-19     05946XWB5   BBB (sf)             AA (sf)/Watch Dev
1-A-20     05946XWC3   CCC (sf)             AA (sf)/Watch Dev
1-A-22     05946XWE9   AA (sf)              AA (sf)/Watch Dev
1-A-23     05946XWF6   BB (sf)              AA (sf)/Watch Dev
1-A-24     05946XWG4   CCC (sf)             AA (sf)/Watch Dev
1-A-25     05946XWH2   B (sf)               AA (sf)/Watch Dev
30-IO      05946XWL3   AA (sf)              AA (sf)/Watch Dev
30-PO      05946XWM1   CCC (sf)             AA (sf)/Watch Dev
B-1        05946XWX7   CC (sf)              CCC (sf)

GSR Mortgage Loan Trust 2005-9F
Series      2005-9F
                       Rating               Rating
Class      CUSIP       To                   From
1A-P       362341U56   D (sf)               CC (sf)
2A-P       362341U64   D (sf)               CC (sf)

Housing Securities Inc.
Series      1992-SL1
                       Rating               Rating
Class      CUSIP       To                   From
A-1        44182DCX5   A+ (sf)              AAA (sf)/Watch Neg
A-2        44182DCY3   NR                   AAA (sf)/Watch Neg

Lehman Mortgage Trust 2007-3
Series      2007-3
                       Rating               Rating
Class      CUSIP       To                   From
1-A3       52521JAC3   CC (sf)              CCC (sf)
2-A1       52521JAE9   D (sf)               CC (sf)

MASTR Asset Securitization Trust 2004-4
Series      2004-4
                       Rating               Rating
Class      CUSIP       To                   From
1-A-2      57643MAE4   A+ (sf)              AAA (sf)/Watch Neg
1-A-3      57643MAF1   A+ (sf)              AAA (sf)/Watch Neg
1-A-5      57643MBE3   NR                   AAA (sf)/Watch Neg
1-A-6      57643MAG9   A+ (sf)              AAA (sf)/Watch Neg
1-A-7      57643MAH7   A+ (sf)              AAA (sf)/Watch Neg
1-A-8      57643MAJ3   NR                   AAA (sf)/Watch Neg
2-A-5      57643MAP9   NR                   AAA (sf)/Watch Neg
2-A-6      57643MAQ7   BB- (sf)             AAA (sf)/Watch Neg
2-A-7      57643MBF0   BB- (sf)             AAA (sf)/Watch Neg
2-A-8      57643MBG8   B- (sf)              AAA (sf)/Watch Neg
3-A-1      57643MAR5   A (sf)               AAA (sf)/Watch Neg
PO         57643MAS3   B- (sf)              AAA (sf)/Watch Neg
15-A-X     57643MAT1   NR                   AAA (sf)/Watch Neg
30-A-X     57643MAU8   NR                   AAA (sf)/Watch Neg

MASTR Asset Securitization Trust 2004-6
Series      2004-6
                       Rating               Rating
Class      CUSIP       To                   From
1-A-2      57643MDU5   BB- (sf)             AAA (sf)/Watch Neg
2-A-7      57643MCU6   A (sf)               AAA (sf)/Watch Neg
2-A-8      57643MCV4   BB (sf)              AAA (sf)/Watch Neg
2-A-10     57643MCX0   AAA (sf)             AAA (sf)/Watch Neg
2-A-11     57643MCY8   BB (sf)              AAA (sf)/Watch Neg
2-A-12     57643MCZ5   BBB (sf)             AAA (sf)/Watch Neg
2-A-13     57643MDA9   BB (sf)              AAA (sf)/Watch Neg
2-A-14     57643MDB7   BB (sf)              AAA (sf)/Watch Neg
3-A-1      57643MDD3   BB (sf)              AAA (sf)/Watch Neg
4-A-1      57643MDE1   BB (sf)              AAA (sf)/Watch Neg
5-A-1      57643MDF8   BBB (sf)             AAA (sf)/Watch Neg
5-A-2      57643MDT8   BB- (sf)             AAA (sf)/Watch Neg
6-A-1      57643MDG6   BB (sf)              AAA (sf)/Watch Neg
7-A-1      57643MDH4   BB- (sf)             AAA (sf)/Watch Neg
15-PO      57643MDJ0   BB- (sf)             AAA (sf)/Watch Neg
30-PO      57643MDK7   BB- (sf)             AAA (sf)/Watch Neg
15-A-X     57643MDL5   NR                   AAA (sf)/Watch Neg
30-A-X     57643MDM3   AAA (sf)             AAA (sf)/Watch Neg
1-B-1      57643MDV3   B- (sf)              AA (sf)/Watch Dev
B-1        57643MDQ4   CCC (sf)             A (sf)/Watch Dev
1-B-2      57643MDW1   CCC (sf)             A (sf)/Watch Dev
B-2        57643MDR2   CCC (sf)             B (sf)/Watch Dev
1-B-3      57643MDX9   CCC (sf)             BBB (sf)/Watch Dev
1-B-4      57643MDY7   CCC (sf)             BB (sf)/Watch Dev

MASTR Asset Securitization Trust 2004-9
Series      2004-9
                       Rating               Rating
Class      CUSIP       To                   From
1-A-1      57643MFC3   BB (sf)              AAA (sf)/Watch Neg
2-A-2      57643MFE9   NR                   AAA (sf)/Watch Neg
2-A-3      57643MFF6   BBB (sf)             AAA (sf)/Watch Neg
2-A-4      57643MFG4   BBB (sf)             AAA (sf)/Watch Neg
3-A-4      57643MFL3   NR                   AAA (sf)/Watch Neg
3-A-5      57643MFM1   BB (sf)              AAA (sf)/Watch Neg
3-A-6      57643MFN9   BB (sf)              AAA (sf)/Watch Neg
3-A-7      57643MFP4   BB- (sf)             AAA (sf)/Watch Neg
4-A-1      57643MFQ2   BBB (sf)             AAA (sf)/Watch Neg
5-A-1      57643MFR0   BBB (sf)             AAA (sf)/Watch Neg
6-A-1      57643MFS8   BBB (sf)             AAA (sf)/Watch Neg
7-A-1      57643MFT6   AA (sf)              AAA (sf)/Watch Neg
PO         57643MFU3   BB (sf)              AAA (sf)/Watch Neg
15-A-X     57643MFV1   NR                   AAA (sf)/Watch Neg
30-A-X     57643MFW9   NR                   AAA (sf)/Watch Neg
8-A-2      57643MGG3   BBB (sf)             AAA (sf)/Watch Neg
15-B-1     57643MFZ2   B- (sf)              AA (sf)/Watch Dev
8-B-1      57643MGH1   CCC (sf)             A (sf)/Watch Dev
15-B-2     57643MGA6   CCC (sf)             BBB (sf)/Watch Dev
8-B-2      57643MGJ7   CCC (sf)             BB (sf)/Watch Dev
15-B-3     57643MGB4   CCC (sf)             B (sf)/Watch Dev

PNCMT Trust Series 2000-1
Series      2000-1
                       Rating               Rating
Class      CUSIP       To                   From
II-A-1     23321P5P9   AAA (sf)             AAA (sf)/Watch Neg
II-X       23321P5U8   AAA (sf)             AAA (sf)/Watch Neg
V-P        23321P5Y0   AA+ (sf)             AAA (sf)/Watch Neg

Popular Securities-Mortgage Trust 2004-1
Series      2004-1
                       Rating               Rating
Class      CUSIP       To                   From
A-3        733194AC8   AA+ (sf)             AAA (sf)/Watch Neg
A-4        733194AD6   AA+ (sf)             AAA (sf)/Watch Neg
A-5        733194AE4   AA+ (sf)             AAA (sf)/Watch Neg

Prime Mortgage Trust 2005-1
Series      2005-1
                       Rating               Rating
Class      CUSIP       To                   From
I-A-3      74160MGL0   BBB (sf)             AAA (sf)/Watch Neg
I-A-4      74160MGM8   NR                   AAA (sf)/Watch Neg
I-A-5      74160MGN6   BBB (sf)             AAA (sf)/Watch Neg
I-A-6      74160MGP1   BBB (sf)             AAA (sf)/Watch Neg
I-A-7      74160MGQ9   NR                   AAA (sf)/Watch Neg
I-A-8      74160MGZ9   BB (sf)              AAA (sf)/Watch Neg
I-PO       74160MGR7   BB (sf)              AAA (sf)/Watch Neg
II-A-3     74160MHC9   AA+ (sf)             AAA (sf)
II-A-4     74160MHD7   AA+ (sf)             AAA (sf)
II-A-5     74160MHE5   AA+ (sf)             AAA (sf)

RESIX Finance Limited
Series      2006-1-B8
                       Rating               Rating
Class      CUSIP       To                   From
B8         76116LCZ5   D (sf)               CC (sf)

RFMSI Series 2005-S6 Trust
Series      2005-S6
                       Rating               Rating
Class      CUSIP       To                   From
A-1        76111XXJ7   CCC (sf)             BB (sf)/Watch Dev
A-2        76111XXK4   CCC (sf)             BB (sf)/Watch Dev
A-3        76111XXL2   CCC (sf)             BB- (sf)/Watch Dev
A-4        76111XXM0   CCC (sf)             BB- (sf)/Watch Dev
A-5        76111XXN8   B (sf)               BB+ (sf)/Watch Dev
A-6        76111XXP3   CCC (sf)             BB- (sf)/Watch Dev
A-7        76111XXQ1   CCC (sf)             BB (sf)/Watch Dev
A-8        76111XXR9   CCC (sf)             BB- (sf)/Watch Dev
A-P        76111XXS7   CCC (sf)             BB- (sf)/Watch Dev

Sequoia Mortgage Trust 2004-12
Series      2004-12
                       Rating               Rating
Class      CUSIP       To                   From
A-1        81744FFY8   A (sf)               AAA (sf)/Watch Neg
A-2        81744FFZ5   AA (sf)              AAA (sf)/Watch Neg
X-A1       81744FGB7   AA (sf)              AAA (sf)/Watch Neg
X-B        81744FGD3   NR                   AA+ (sf)/Watch Neg
A-3        81744FGA9   AA (sf)              AAA (sf)/Watch Neg
B-1        81744FGF8   BB (sf)              AA+ (sf)/Watch Dev

Structured Asset Mortgage Investments Trust 1999-2
Series      1999-2
                               Rating
Class      CUSIP       To                   From
3-A        86358HHV4   AA+ (sf)             AAA (sf)/Watch Neg
3-X        86358HHW2   AA+ (sf)             AAA (sf)/Watch Neg

Structured Asset Securities Corporation Trust 2005-15
Series      2005-15
                       Rating               Rating
Class      CUSIP       To                   From
1-A1       86359DND5   B- (sf)              B- (sf)/Watch Dev
1-A2       86359DNE3   B (sf)               CCC (sf)
1-A4       86359DNG8   B (sf)               CCC (sf)
2-A1       86359DNK9   B (sf)               B (sf)/Watch Dev
2-A6       86359DNQ6   BB (sf)              B (sf)/Watch Dev
6-A1       86359DNZ6   CCC (sf)             B- (sf)
6-A2       86359DPA9   CCC (sf)             B- (sf)

RATINGS AFFIRMED

Banc of America Funding 2005-3 Trust
Series      2005-3
Class      CUSIP       Rating
B-2        05946XWY5   CC (sf)
B-3        05946XWZ2   CC (sf)

GSR Mortgage Loan Trust 2005-9F
Series      2005-9F
Class      CUSIP       Rating
1A-4       362341Q69   CCC (sf)
1A-6       362341Q85   CCC (sf)
1A-7       362341Q93   CCC (sf)
1A-9       362341R35   CCC (sf)
1A-10      362341R43   CCC (sf)
1A-14      362341R84   CCC (sf)
2A-2       362341S34   CCC (sf)
2A-6       362341S75   CCC (sf)
5A-1       362341T74   CC (sf)
6A-1       362341T90   CC (sf)

MASTR Asset Securitization Trust 2004-6
Series      2004-6
Class      CUSIP       Rating
B-3        57643MDS0   CC (sf)
B-4        57643MEB6   CC (sf)
B-5        57643MEC4   CC (sf)
1-B-5      57643MDZ4   CCC (sf)

MASTR Asset Securitization Trust 2004-9
Series      2004-9
Class      CUSIP       Rating
8-B-3      57643MGK4   CCC (sf)
30-B-3     57643MGE8   CC (sf)
15-B-4     57643MGP3   CCC (sf)
8-B-4      57643MGL2   CC (sf)
15-B-5     57643MGQ1   CC (sf)
8-B-5      57643MGM0   CC (sf)

RESIX Finance Limited
Series      2003-AB10S
Class      CUSIP       Rating
B10-S      76116LAX2   CCC (sf)

Sequoia Mortgage Trust 2004-12
Series      2004-12
Class      CUSIP       Rating
B-2        81744FGG6   CCC (sf)

Structured Asset Securities Corporation Trust 2005-15
Series      2005-15
Class      CUSIP       Rating
1-A5       86359DNH6   CCC (sf)
1-A6       86359DNJ2   CCC (sf)
2-A2       86359DNL7   CC (sf)
2-A4       86359DNN3   CC (sf)
2-A5       86359DNP8   CC (sf)
2-A7       86359DNR4   CC (sf)
2-A8       86359DNS2   CC (sf)
2-A9       86359DNT0   CC (sf)
3-A1       86359DNU7   CC (sf)
3-A2       86359DNV5   CC (sf)
4-A1       86359DNW3   CC (sf)
4-A2       86359DNX1   CC (sf)
5-A1       86359DNY9   CC (sf)
AP         86359DPC5   CC (sf)


* U.S. CMBS Delinquencies Begin Lower in 2013, Fitch Says
---------------------------------------------------------
U.S. CMBS delinquencies started 2013 on a positive note while
struggles continue for one of the more hard-hit regions, according
to the latest index results from Fitch Ratings.

CMBS late-pays declined eight basis points (bps) in January to
7.91% from 7.99% a month earlier. This marks the eighth straight
month of declines and the lowest level since October 2010 (when it
stood at 7.78%). In January, resolutions of $1.4 billion outpaced
additions to the index of $1.1 billion. However, Fitch-rated new
issuance volume of $600 million fell short of $2.9 billion in
portfolio runoff last month.

Offsetting the positive movement in overall delinquencies is
Georgia, which continues to be a problem spot. The two largest
loans entering the index last month - the $71.1 million Millennium
in Midtown (GSMS 2006-GG6) and $67.7 million Southlake Mall (BSCMS
2007-PWR18) are both located in Atlanta. This helped push the
delinquency rate for Georgia to 20%. This represents the second-
highest rate of any state with at least $5 billion in CMBS
outstanding (behind Nevada at 20.7%).

And it appears the worst is not over for this region.

Fitch took a closer look at Atlanta office loans greater than $10
million that were REO as of the start of last year. Of those, four
loans totaling $88 million were disposed of. It took an average of
18.2 months for those properties to be sold from the time they
were foreclosed upon (with an average loss severity of 78% of the
original balance).

Additionally, loss severities for another six Atlanta office
properties that were REO at the start of last year and remain
outstanding would be 52% based on recent appraisals. However,
Fitch expects actual severities to be higher.

Current and previous delinquency rates are:

-- Multifamily: 9.73% (from 10.12% in December)
-- Hotel: 8.76% (from 8.87%)
-- Industrial: 8.69% (from 8.61%)
-- Office: 8.33% (from 8.41%)
-- Retail: 7.43% (from 7.14%)




                            *********

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
e-mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Peter A.
Chapman at 215-945-7000 or Nina Novak at 202-241-8200.


                  *** End of Transmission ***