TCR_Public/130818.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, August 18, 2013, Vol. 17, No. 228


                            Headlines

AGATE BAY 2013-1: Fitch to Rate $3.47MM Cl. B-4 Certificates 'BB'
AJAX TWO: Moody's Affirms 'Caa3' Rating on Class C Notes
ALPINE SECURITIZATION: DBRS Confirms Bsf Rating on $22.91MM Debt
AMMC CLO VI: Moody's Affirms Ba1 Rating on $35MM Class D Notes
APIDOS CDO II: Moody's Raises Rating on Class D Notes to Ba1

ARROWPOINT CLO 2013-1: S&P Affirms 'BB' Rating on Class D Notes
ASHFORD CDO I: S&P Raises Rating on Class A-3L Notes to 'BB+'
AVENUE CLO II: Moody's Confirms Ba3 Rating on Class B-2L Notes
BANC OF AMERICA 2003-2: Fitch Affirms CCC Rating on Class J Certs
BANC OF AMERICA 2005-4: Fitch Affirms 'D' Rating on Class L Certs

BALLYROCK CLO III: Moody's Ups $45MM Cl. D Notes' Rating From Ba1
BALLYROCK CLO III: S&P Raises Rating on Class D Notes From 'B+'
BANC OF AMERICA: Moody's Takes Action on $141-Mil. of RMBS
BANK OF AMERICA 2005-6: Moody's Keeps C Ratings on 2 Cert Classes
CABELA'S CREDIT: Fitch Rates $9.6MM Class D Notes at 'BB'

CAPITAL TRUST 2004-1: Fitch Affirms 'D' Ratings on 5 Cert. Classes
CAPITAL TRUST 2005-1: Fitch Affirms 'D' Rating on Class B Trust
CARLYLE BRISTOL: Moody's Confirms B1 Rating on Class D Notes
CHINO REDEVELOPMENT: Moody's Confirms Ba1 Rating on RDA TABs
COMM 2007-C9: Moody's Affirms C Ratings on 7 Debt Classes

COMM 2013-300P: Fitch to Rate $28MM Class E Certificates 'BB+'
COMMERCIAL MORTGAGE 2007-GG11: S&P Keeps CCC Rating on Cl. B Notes
CREDIT SUISSE 2000-C1: S&P Affirms 'B-' Rating on Class H Notes
CREST 2001-1: Moody's Affirms Ca Rating on $30MM Class C Notes
DAVIS SQUARE IV: Moody's Cuts Rating on $0.6MM Cl. E Notes to Ba1

DENALI CAPITAL: S&P Affirms 'B+' Rating on Class B-2L Notes
DEUTSCHE BANK 2011-LC3: Fitch Affirms 'B' Rating on Class F Certs
FOUNDERS GROVE: Moody's Affirms 'Ba2' Rating on $27MM Cl. D Notes
GANNETT PEAK: S&P Affirms 'B+' Rating on 2 Note Classes
GS MORTGAGE 1999-C1: S&P Affirms 'CCC-' Rating on G Certificates

GS MORTGAGE 2011-GC3: Moody's Keeps Ratings over Rights Transfer
GS MORTGAGE 2012-GC6: Moody's Keeps Ratings After Rights Transfer
ICONS LTD: A.M. Best Cuts Rating on 3 Debt Classes to 'bb'
IMPAC CMB: Moody's Takes Action on $6.6BB of Alt-A RMBS
JP MORGAN 2003-LN1: Moody's Affirms C Ratings on 2 Cert Classes

JP MORGAN 2005-A8: Moody's Cuts Ratings on 5 Prime Jumbo RMBS
JP MORGAN 2005-LDP5: Fitch Affirms 'C' Ratings on 4 Certificates
JP MORGAN 2007-CIBC20: S&P Lowers Rating on Class H Notes to CCC-
JP MORGAN 2007-LDP12: S&P Lowers Rating on Class H Notes to 'D'
JP MORGAN 2008-C2: Fitch Lowers Rating on 12 Certs. to 'D'

LANDMARK VII: Moody's Raises Ratings on $14MM Class B-2L Notes
LB-UBS 2001-C3: S&P Lowers Rating on 2 Note Classes to 'D'
LEGG MASON I: Moody's Affirms Caa3 Rating on Class G Notes
MAPS CLO II: Moody's Corrects and Withdraws B2 and Baa3 Ratings
ML-CFC COMMERCIAL 2006-2: Moody's Keeps C Ratings on 6 Securities

MORGAN STANLEY 1999-WF1: Moody's Hikes Rating on Cl. N Certs to B2
MORGAN STANLEY 2005-6AR: Moody's Hikes Rating on 8 RMBS Tranches
MORGAN STANLEY 2013-C11: Fitch Rates $20.3MM Class G Certs 'B'
MT WILSON: S&P Raises Rating on Class E Notes to 'B+'
NATIONSTAR HOME 2006-B: Moody's Hikes Cl. AV-4 Debt Rating to Caa1

NORTH END CLO: S&P Assigns 'BB' Rating on Class E Notes
NORTHSTAR 2013-1: Moody's Assigns 'P)B3' Rating to Class C Notes
OCP CLO 2012-2: S&P Affirms 'BB' Rating on Class E Notes
OCTAGON INVESTMENT V: Moody's Hikes Ratings on 4 CLO Note Classes
PREFERRED TERM: Moody's Raises Rating on $88MM Notes From 'Ca'

PREFERRED TERM IX: Moody's Lifts Ratings on 3 Note Classes to Caa1
REVE SPC XVII: Moody's Raises Rating on $30MM Notes to 'Ba3'
RFSMI 2005-S7: Moody's Cuts Ratings on 3 RMBS Tranches
RIALTO REAL: Servicing Rights Transfer No Impact on Ratings
SANDELMAN REALTY I: Moody's Lifts Ratings on Four Note Classes

SDART 2013-A: S&P Assigns Prelim. 'BB+' Rating on Class E Notes
SHASTA CLO I: Moody's Affirms Ba2 Rating on $18MM of CLO Notes
SOLOMON MORTGAGE 2001-CB4: Amendments No Impact on Moody's Ratings
STUDENT LOAN 2007-1: S&P Puts 'B-' Rating on CreditWatch Negative
TABERNA PREFERRED III: Ratings Unchanged Following Trustee Switch

TRAPEZA CDO VII: Moody's Affirms Ca Ratings on 2 Debt Classes
TROPIC CDO II: Moody's Upgrades Rating on $35MM Cl. C Notes to B2
UBS-CITIGROUP 2011-C1: Rights Transfer No Impact on Ratings
UBS-CITIGROUP 2012-C1: Rights Transfer No Impact on Ratings
VIBRANT CLO II: S&P Assigns Preliminary B Rating on Class E Notes

WACHOVIA BANK 2003-C7: Moody's Cuts Rating on X-C Debt to B1
WACHOVIA BANK 2006-C24: Moody's Affirms Ratings on 14 Cert Classes
WF-RBS COMMERCIAL 2011-C2: Moody's Keeps B2 Rating on Cl. F Certs
WHITEHORSE III: S&P Raises Rating on Class B-2L Notes to BB+
WHITEHORSE VII: S&P Assigns Prelim. BB- Rating on Class B-2L Notes

* Fitch Takes Various Actions on 20 Trust Preferred CDOs
* Fitch Says Delinquencies and Foreclosures Decreasing
* Fitch Says U.S. CMBS Market Metrics Mostly Stable in 2Q
* Fitch Downgrades Various Distressed U.S. RMBS Bonds to 'Dsf'
* Fitch: Largest Post-Recession Drop for U.S. CMBS Delinquencies

* Moody's Lowers Ratings on 63 Alt-A, Option ARM RMBS Tranches
* Moody's Takes Action on $544MM of RMBS From Various Issuers
* S&P Withdraws Ratings on 79 Classes From 32 CDOs After Paydowns


                            *********


AGATE BAY 2013-1: Fitch to Rate $3.47MM Cl. B-4 Certificates 'BB'
-----------------------------------------------------------------
Fitch Ratings expects to rate Agate Bay Mortgage Trust 2013-1 as
follows:

-- $400,743,000 class A-1 certificates 'AAAsf'; Outlook Stable;
-- $400,743,000 class A-IO notional certificates 'AAAsf';
     Outlook Stable;
-- $10,637,000 class B-1 certificates 'AAsf'; Outlook Stable;
-- $8,466,000 class B-2 certificates 'Asf'; Outlook Stable;
-- $6,296,000 class B-3 certificates 'BBBsf'; Outlook Stable;
-- $3,473,000 class B-4 certificates 'BBsf'; Outlook Stable.

The $429,476,951 class A-IO-S notional certificate and $4,559,489
class B-5 certificates will not be rated by Fitch.

Key Rating Drivers

High-Quality Mortgage Pool: The collateral pool consists of 30-
year, fixed-rate, fully amortizing loans to borrowers with strong
credit profiles, low leverage and substantial liquid reserves. A
69.9% CLTV provides a significant buffer against potential home
price declines. Strong borrower quality is reflected in the 770
weighted average (WA) original FICO, $350,747 WA household income
and $322,789 WA liquid reserves.

Originators with Limited Performance History: A large portion of
the pool was originated by lenders with limited non-agency
performance history. While the significant contribution of loans
from these originators is a concern, Fitch considers the credit
enhancement (CE) on this transaction sufficient to mitigate the
originator risk.

High Geographic Concentration: The pool's primary concentration
risk is California, where 46.4% of the properties are located. In
addition, the metropolitan areas encompassing San Francisco, San
Jose, Oakland and Los Angeles combine for 36.1% of the collateral
balance and represent four of the top 10 regions. The regional
concentration resulted in an additional penalty of roughly 15% to
the pool's lifetime default expectation.

Transaction Provisions Enhance Performance: Similar to recent
transactions rated by Fitch, ABMT 2013-1 contains binding
arbitration provisions that may serve to provide timely resolution
to representation (rep) and warranty disputes. In addition, all
loans that become 120 days or more delinquent will be
automatically reviewed for breaches of reps and warranties.

Moderate Due Diligence Findings: Third-party loan-level due
diligence was conducted by Clayton Holdings LLC (Clayton) on 100%
of the pool. While the review resulted in minimal credit and
compliance findings, it identified 19% of the pool in Federal
Emergency Management Agency (FEMA) designated disaster areas as
part of its property valuation review. Fitch considered these
findings as part of its analysis and performed sensitivities
adjusting property values to account for potential damage.

Limited Operating History: Two Harbors Investment Corp. (Two
Harbors) was formed in 2009 and is a publicly held REIT. While
management has extensive mortgage industry experience, ABMT 2013-1
is Two Harbors' first securitization using its own depositor.
Fitch conducted a conference call with Two Harbors in June 2013 to
discuss its organizational structure, conduit strategy, due
diligence, and property valuation approaches and methodologies.
They have been active as a loan aggregator and investor in both
agency and non-agency residential mortgage-backed securities
(RMBS). Although the current form of Two Harbor's conduit
initiative is relatively new, Fitch did not identify material
weaknesses in its discussions with the company.

Robust Representation Framework: The representation, warranty and
enforcement mechanism (RW&E) framework is viewed positively by the
agency as it is consistent with Fitch's criteria. The transaction
benefits from life of loan representations and warranties (R&W),
as well as a backstop by the sponsor, TH TRS Corp., in case of
insolvency of the related originator. The sponsor's repurchase
obligations will also be guaranteed by its parent, Two Harbors,
for the life of each loan.

Seller Interests Aligned with Investors': A Two Harbors affiliate
is expected to be the initial subordinate investor in the
transaction and, thus, have a direct economic interest in the
performance of the transaction. As holder of the first-loss class
in the transaction, the controlling holder has an incentive to
maintain the credit quality of the asset pool, which would include
enforcing the repurchase obligations of the contributing
originators on defaulted loans.

Rating Sensitivities

Fitch's analysis incorporates sensitivity analyses to demonstrate
how the ratings would react to steeper market value declines
(MVDs) than assumed at both the metropolitan statistical area
(MSA) and national levels. The implied rating sensitivities are
only an indication of some of the potential outcomes and do not
consider other risk factors that the transaction may become
exposed to or be considered in the surveillance of the
transaction.

Fitch conducted sensitivity analysis on areas where the model
projected lower home price declines than that of the overall
collateral pool. The model currently projects sustainable MVDs
(sMVDs) at the MSA level. For one of the top 10 regions, Fitch's
SHP model does not project declines in home prices and for
another, the projected decline is less than 2%. These regions are
Chicago-Joliet-Naperville in Illinois (10.3%) and Dallas-Plano-
Irving in Texas (3.3%). Fitch conducted sensitivity analyses
assuming sMVDs of 10%, 15%, and 20% for this identified
metropolitan area. The sensitivity analyses indicated no impact on
ratings for all bonds in each scenario.

Another sensitivity analysis was focused on determining how the
ratings would react to steeper MVDs at the national level. The
analysis assumes MVDs of 10%, 20%, and 30%, in addition to the
model projected 14.7% for this pool. The analysis indicates there
is some potential rating migration with higher MVDs, compared with
the model projection.

Fitch's stress and rating sensitivity analysis are discussed in
the presale report titled 'Agate Bay Mortgage Trust, Series 2013-
1', dated Aug. 13, 2013.


AJAX TWO: Moody's Affirms 'Caa3' Rating on Class C Notes
--------------------------------------------------------
Moody's has affirmed the rating of two classes of Notes issued by
Ajax Two Limited. The affirmations are due to key transaction
parameters performing within levels commensurate with the existing
ratings levels. The rating action is the result of Moody's on-
going surveillance of commercial real estate collateralized debt
obligation (CRE CDO and Re-REMIC) transactions.

Moody's rating action is as follows:

Class B Floating Rate Deferrable Interest Notes, Due 2032,
Affirmed Aaa (sf); previously on Sep 6, 2012 Upgraded to Aaa (sf)

Class C Floating Rate Notes, Due 2032, Affirmed Caa3 (sf);
previously on Oct 7, 2011 Downgraded to Caa3 (sf)

Ratings Rationale:

Ajax two Limited is a static cash transaction backed by a
portfolio of asset backed securities (53.9% of the pool balance),
commercial mortgage backed securities (CMBS) (35.2%) and CRE CDO
(10.9%). As of the July 8, 2013 Trustee report, the aggregate Note
balance of the transaction, including Preferred Shares and D
Combination Note has decreased to $39.8 million from $383.9
million at issuance, with the paydown directed to the senior
outstanding classes Class A-1 , Class A-2A, Class A-2B and
mezzanine Class B Notes, as a result of the combination of
principal repayment of collateral and failing certain par value
tests. Currently, the transaction is under-collateralized by $2.9
million, primarily due to realized losses on the collateral.

Eight assets with a par balance of $18.3 million (49.5% of the
pool balance) were listed as defaulted securities as of the July
8, 2013 Trustee Report. Moody's expects significant losses to
occur on these assets once they are realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 5,548
compared to 4,137 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Aaa-Aa3 (24.7% compared to 42.7% at last
review), A1-A3 (0.0% compared to 2.0% at last review), Baa1-Baa3
(18.3% compared to 11.9% at last review), Ba1-Ba3 (0.0%, same as
last review), B1-B3 (0.0% same as last review), and Caa1-C (56.1%
compared to 42.7% at last review).

Moody's modeled a WAL of 2.8 years, compared to 2.9 years at last
review. The current WAL is based on assumptions about extensions
on the underlying collateral.

Moody's modeled a fixed WARR of 17.9% compared to 26.8 % at last
review.

Moody's modeled a MAC of 100.0%, compared to 2.3% at last review.
The increase in MAC is due to higher credit risk collateral
concentrated in fewer collateral names.

Moody's review incorporated CDOROM v2.8, one of Moody's CDO rating
models, which was released on March 25, 2013.

The cash flow model, CDOEdge v3.2.1.2, released on May 16, 2013,
was used to analyze the cash flow waterfall and its effect on the
capital structure of the deal.

Moody's analysis encompasses the assessment of stress scenarios.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. In general, the rated Notes are particularly
sensitive to changes in recovery rate assumptions. Holding all
other key parameters static, changing the recovery rate assumption
up from 17.9% to 27.9% or down to 7.9% would result in average
rating movement on the rated tranches of 0 notches upward and 0 to
1 notch downward respectively.

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

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

The hotel sector is performing strongly with nine straight
quarters of growth and the multifamily sector continues to show
increases in demand with a growing renter base and declining home
ownership. Recovery in the office sector continues at a measured
pace with minimal additions to supply. However, office demand is
closely tied to employment, where growth remains slow and
employers are considering decreases in the leased space per
employee. Also, primary urban markets are outperforming secondary
suburban markets. Performance in the retail sector continues to be
mixed with retail rents declining for the past four years, weak
demand for new space and lackluster sales driven by internet sales
growth. Across all property sectors, the availability of debt
capital continues to improve with robust securitization activity
of commercial real estate loans supported by a monetary policy of
low interest rates.

Moody's central global macroeconomic outlook indicates the global
economy has lost momentum over the past quarter as it tries to
recover. US GDP growth for 2013 is likely to remain close to 2%,
however US sequestration cuts that came into effect in March may
create a drag on the positive growth in the US private sector.
While the broad economic impact is unclear, the direct effect is
likely to shave 0.4% off US GDP growth in 2013. Continuing from
the previous quarter, Moody's believes that the three most
immediate risks are: i) the risk of an even deeper than currently
expected recession in the euro area, accompanied by deeper credit
contraction, potentially triggered by a further intensification of
the sovereign debt crisis; ii) slower-than-expected recovery in
major emerging markets following the recent slowdown; and iii) an
escalation of geopolitical tensions, resulting in adverse economic
developments.

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


ALPINE SECURITIZATION: DBRS Confirms Bsf Rating on $22.91MM Debt
----------------------------------------------------------------
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
November 30, 2012, reported portfolio provided by Credit Suisse,
the administrator of Alpine.

The $9,725,042,453 aggregate liquidity facilities as of November
30, 2012, are tranched as follows:

- $9,321,004,879 rated AAA (sf)
- $57,704,526 rated AA (sf)
- $78,372,662 rated A (sf)
- $66,134,419 rated BBB (sf)
- $52,430,808 rated BB (sf)
- $22,915,496 rated B (sf)
- $126,479,663 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.

DBRS models the prior (lagged) month(s) portfolio on an ongoing
basis to reflect changes in Alpine's portfolio composition and
credit quality.  The rating results are updated and posted on the
DBRS website.

The principal methodology is the Asset-Backed Commercial Paper
Criteria Report: U.S. & European ABCP Conduits, which can be found
on our website under Methodologies and private Rating Methodology
for Liquidity and Program Wide Enhancement Ratings.

This credit rating has been issued outside the European Union (EU)
and may be used for regulatory purposes by financial institutions
in the EU.


AMMC CLO VI: Moody's Affirms Ba1 Rating on $35MM Class D Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the rating of the following
notes issued by AMMC CLO VI, Limited:

$28,750,000 Class C Floating Rate Deferrable Notes Due 2018,
Upgraded to Aaa (sf); previously on July 15, 2013 Upgraded to Aa2
(sf) and Placed Under Review for Possible Upgrade

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

$228,000,000 Class A-1-A Floating Rate Notes Due 2018 (current
outstanding balance of $23,499,126), Affirmed Aaa (sf); previously
on June 30, 2006 Assigned Aaa (sf)

$25,000,000 Class A-1-R Variable Funding Floating Rate Notes Due
2018 (current outstanding balance of $2,576,659), Affirmed Aaa
(sf); previously on June 30, 2006 Assigned Aaa (sf)

$63,250,000 Class A-1-B Floating Rate Notes Due 2018, Affirmed Aaa
(sf); previously on June 30, 2011 Upgraded to Aaa (sf)

$70,000,000 Class A-2 Floating Rate Notes Due 2018 (current
outstanding balance of $19,771,715) , Affirmed Aaa (sf);
previously on June 30, 2011 Upgraded to Aaa (sf)

$17,500,000 Class B Floating Rate Notes Due 2018, Affirmed Aaa
(sf); previously on November 7, 2012 Upgraded to Aaa (sf)

$35,000,000 Class D Floating Rate Deferrable Notes Due 2018,
Affirmed Ba1 (sf); previously on June 30, 2011 Upgraded to Ba1
(sf)


APIDOS CDO II: Moody's Raises Rating on Class D Notes to Ba1
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Apidos CDO II Ltd.:

$13,000,000 Class C Floating Rate Notes Due 2018, Upgraded to A2
(sf); previously on July 15, 2013 Baa1 (sf) Placed Under Review
for Possible Upgrade;

$13,500,000 Class D Floating Rate Notes Due 2018, Upgraded to Ba1
(sf); previously on March 29, 2013 Upgraded to Ba2 (sf).

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

$195,000,000 Class A-1 Floating Rate Notes Due 2018 (current
outstanding balance of $63,439,100), Affirmed Aaa (sf); previously
on March 29, 2013 Affirmed Aaa (sf);

$100,000,000 Class A-2 Delayed Draw Notes Due 2018 (current
outstanding balance of $32,532,872), Affirmed Aaa (sf); previously
on March 29, 2013 Affirmed Aaa (sf);

$22,500,000 Class A-3 Floating Rate Notes Due 2018, Affirmed Aaa
(sf); previously on March 29, 2013 Upgraded to Aaa (sf).

In addition, Moody's confirmed the rating of the following notes:

$24,000,000 Class B Deferrable Floating Rate Notes Due 2018,
Confirmed at Aa1 (sf); previously on July 15, 2013 Upgraded to Aa1
(sf) and Placed Under Review for Possible Upgrade.

Ratings Rationale:

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the Class A-1 and A-2 notes
and an increase in the transaction's overcollateralization ratios
since the rating action in March 2013. Moody's notes that the
Class A-1 and A-2 notes have been paid down by approximately 48%
or $88 million since March 2013. Based on the latest trustee
report dated July 16, 2013, the Class A, Class B, Class C, and
Class D overcollateralization ratios are reported at 144.7%,
124.7%, 116.0%, and 108.1%, respectively, versus February 2013
levels of 133.3%, 119.5%, 113.1%, and 107.2%, respectively.

Moody's also notes that the deal has benefited from an improvement
in the credit quality of the underlying portfolio since March
2013. Based on the July 2013 trustee report, the weighted average
rating factor is currently 2373 compared to 2442 in February 2013.

In taking the foregoing actions, Moody's announced that it had
concluded its review of its ratings on the issuer's Class B Notes
and Class C Notes announced on July 15, 2013. At that time,
Moody's said that it had upgraded and placed certain of the
issuer's ratings on review primarily as a result of substantial
deleveraging of the senior notes and increases in OC ratios
resulting from high rates of loan collateral prepayments during
the first half of 2013.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, diversity
score, and weighted average recovery rate, are based on its
published methodology and 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 $183 million, defaulted par of $4.7 million, a
weighted average default probability of 15.40% (implying a WARF of
2451), a weighted average recovery rate upon default of 49.79%,
and a diversity score of 51. 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.

Apidos CDO II Ltd., issued in December of 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans and CLO tranches.

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2013.

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 Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2013.

In addition to the base case analysis, 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% (1961)

Class A-1: 0

Class A-2: 0

Class A-3: 0

Class B: +1

Class C: +2

Class D: +1

Moody's Adjusted WARF + 20% (2941)

Class A-1: 0

Class A-2: 0

Class A-3: 0

Class B: -1

Class C: -2

Class D: -1

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

Sources of additional performance uncertainties:

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.


ARROWPOINT CLO 2013-1: S&P Affirms 'BB' Rating on Class D Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Arrowpoint CLO 2013-1 Ltd./Arrowpoint CLO 2013-1 LLC's
$274.00 million floating-rate notes following the transaction's
effective date as of July 15, 2013.

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

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

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

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

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

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

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

Ratings Affirmed

Arrowpoint CLO 2013-1 Ltd./Arrowpoint CLO 2013-1 LLC

Class                      Rating                       Amount
                                                      (mil. $)
A-1                        AAA (sf)                     188.00
A-2                        AA (sf)                       35.00
B (deferrable)             A (sf)                        24.00
C (deferrable)             BBB (sf)                      14.00
D (deferrable)             BB (sf)                       13.00


ASHFORD CDO I: S&P Raises Rating on Class A-3L Notes to 'BB+'
-------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1LA, A-1LB, A-2L, A-3L, and B-1L notes from Ashford CDO I Ltd.,
a cash flow collateralized debt obligation (CDO) transaction
backed by primarily collateralized loan obligation (CLO) tranches
originated before 2007.

The upgrades reflect paydowns to class A-1LA notes since S&P's
April 2012 rating actions.

Principal amortization has resulted in $60.03 million in paydowns
to the class A-1LA notes since S&P's April 2012 rating actions
based on the March 5, 2012, trustee report.  The transaction's
overall overcollateralization (O/C) ratio tests have benefited
from the principal paydowns; the class A O/C test has increased to
126.31% from 117.53%, and the class B O/C test has increased to
104.11% from 91.81%.

The underlying portfolio's credit quality has also improved over
the same period.  According to the July 2013 trustee report, the
amount of 'CCC' rated collateral held in the transaction's asset
portfolio fell since S&P's April 2012 rating actions.  The
transaction held $18.35 million of 'CCC' rated collateral in
July 2013, down from $48.20 million back in the March 2012 trustee
report.

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

RATINGS RAISED

Ashford CDO I Ltd.
Class          Rating
          To           From
A-1LA     AA- (sf)     BBB+ (sf)
A-1LB     A+ (sf)      BBB+ (sf)
A-2L      BBB+ (sf)    BB- (sf)
A-3L      BB+ (sf)     B- (sf)
B-1L      B+ (sf)      CCC (sf)


AVENUE CLO II: Moody's Confirms Ba3 Rating on Class B-2L Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Avenue CLO II, Ltd.:

$22,500,000 Class A-3L Floating Rate Notes Due October 30, 2017,
Upgraded to Aaa (sf); previously on July 15, 2013 Upgraded to Aa1
(sf) and Placed Under Review for Possible Upgrade

$19,250,000 Class B-1L Floating Rate Notes Due October 30, 2017,
Upgraded to A1 (sf); previously on July 15, 2013 Upgraded to A3
(sf) and Placed Under Review for Possible Upgrade

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

$320,000,000 Class A-1L Floating Rate Notes Due October 30, 2017
(current outstanding balance of $53,030,634), Affirmed Aaa (sf);
previously on July 13, 2011 Upgraded to Aaa (sf)

$35,500,000 Class A-2L Floating Rate Notes Due October 30, 2017,
Affirmed Aaa (sf); previously on December 19, 2012 Upgraded to Aaa
(sf)

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

$19,000,000 Class B-2L Floating Rate Notes Due October 30, 2017
(current outstanding balance of $18,032,863), Confirmed at Ba3
(sf); previously on July 15, 2013 Ba3 (sf) Placed Under Review for
Possible Upgrade

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 December 2012. Moody's notes that the Class
A-1L Notes have been paid down by approximately 75% or $161.2
million since that time. Based on the latest trustee report dated
July 9, 2013, the Class A-2L, Class A-3L, Class B-1L and Class B-
2L overcollateralization ratios are reported at 154.7%, 132.6%,
118.1% and 107.1%, respectively, versus November 2012 levels of
129.3%, 118.6%, 110.8% and 104.3%, respectively. The
overcollateralization ratios reported in the July 2013 trustee
report do not include the July 30, 2013 payment distribution, when
$46 million of principal proceeds were used to pay down the Class
A-1L Notes.

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 July 2013 trustee
report, the weighted average rating factor is currently 2807
compared to 2495 in November 2012.

In taking the foregoing actions, Moody's announced that it had
concluded its review of its ratings on the issuer's Class A-3L, B-
1L and B-2L Notes announced on July 15, 2013. At that time,
Moody's said that it had upgraded and placed certain of the
issuer's ratings on review primarily as a result of substantial
deleveraging of the senior notes and increases in OC ratios
resulting from high rates of loan collateral prepayments during
the first half of 2013.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, diversity
score, and weighted average recovery rate, are based on its
published methodology and 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 $153.5 million, defaulted par of $23 million,
a weighted average default probability of 16.00% (implying a WARF
of 2773), a weighted average recovery rate upon default of 51.54%,
and a diversity score of 25. The default and recovery properties
of the collateral pool are incorporated in cash flow model
analysis where they are subject to stresses as a function of the
target rating of each CLO liability being reviewed. The default
probability is derived from the credit quality of the collateral
pool and Moody's expectation of the remaining life of the
collateral pool. The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool. In each case, historical and market
performance trends and collateral manager latitude for trading the
collateral are also factors.

Avenue CLO II, Ltd, issued in August 2005, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2013.

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 Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2013.

In addition to the base case analysis, 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% (2218)

Class A-1L: 0

Class A-2L: 0

Class A-3L: 0

Class B-1L: +2

Class B-2L: +1

Moody's Adjusted WARF + 20% (3328)

Class A-1L: 0

Class A-2L: 0

Class A-3L: 0

Class B-1L: -2

Class B-2L: -1

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

Sources of additional performance uncertainties:

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.


BANC OF AMERICA 2003-2: Fitch Affirms CCC Rating on Class J Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed 15 classes of Banc of America
Commercial Mortgage Inc. (BACM) commercial mortgage pass-through
certificates series 2003-2.

Key Rating Drivers

The affirmations are due to the pool performing in-line with
Fitch's expectations from the prior review. Fitch modeled losses
of 1.7% of the remaining pool; expected losses on the original
pool balance total 3.2%, including $50.7 million (2.9% of the
original pool balance) in realized losses to date. Fitch has
designated six loans (7.1%) as Fitch Loans of Concern, which
includes two specially serviced assets (2%).

As of the July 2013 distribution date, the pool's aggregate
principal balance has been reduced by 78.1% to $387.1 million from
$1.77 billion at issuance. Per the servicer reporting, 10 loans
(60.7% of the pool) are defeased. Interest shortfalls are
currently affecting classes J through P.

The largest contributor to expected losses is secured by a 480-
unit multifamily property in Bowling Green, OH (2.3% of the pool).
The property serves as student housing for a nearby university,
and as such experiences seasonality impact during the summer
months. The servicer reported a year-end 2012 debt service
coverage ratio of 0.89x, which compares to a year-end 2011 debt
service coverage ratio of 0.81x. The loan remains current as of
July 2013.

The next largest contributor to expected losses is specially-
serviced and secured by a 72,236-sf anchored retail center in
Madison, OH (1.5%). The loan entered special servicing in May
2013. The year-end 2012 net cash flow debt service coverage ratio
was 1.53x with a 57.5% physical occupancy. Anchor tenant Tops
supermarket (48,881-sf; 67.7% NRA) went dark in February 2005. The
borrower has recently been granted a 24 month maturity extension.

Rating Sensitivity

Rating Outlooks on classes A-1A through G remain Stable due to
increasing credit enhancement and continued paydown. The Rating
Outlook on class H remains Negative due to its low placement in
the class structure and the increasing concentration of the pool.

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

-- $21 million class H at 'Bsf'; Outlook to Stable from Negative;
-- $10.5 million class K at 'Csf'; RE 100%;
-- $7.2 million class L at 'Dsf'; RE 35%.

Fitch affirms the following classes as indicated:

-- $108.9 million class A-1A at 'AAAsf'; Outlook Stable;
-- $56.7 million class B at 'AAAsf'; Outlook Stable;
-- $21 million class C at 'AAAsf'; Outlook Stable;
-- $44.1 million class D at 'AAAsf'; Outlook Stable;
-- $23.1 million class E at 'AAsf'; Outlook Stable;
-- $21 million class F at 'Asf'; Outlook Stable;
-- $23.1 million class G at 'BBsf'; Outlook Stable;
-- $18.9 million class J at 'CCCsf'; RE 100%;
-- $0 class M at 'Dsf'; RE 0%;
-- $0 class N at 'Dsf'; RE 0%;
-- $0 class O at 'Dsf'; RE 0%;
-- $31.7 million class BW Rakes at 'AAAsf'; Outlook Stable.

The class A-1, A-2, A-3 and A-4 certificates have paid in full.
Fitch does not rate the class P and HS Rakes certificates. Fitch
previously withdrew the ratings on the interest-only class XC and
XP certificates.


BANC OF AMERICA 2005-4: Fitch Affirms 'D' Rating on Class L Certs
-----------------------------------------------------------------
Fitch Ratings has upgraded one class and affirmed 19 classes of
Banc of America Commercial Mortgage Inc. (BACM) commercial
mortgage pass-through certificates series 2005-4.

Key Rating Drivers

The upgrade is a result of additional defeasance since Fitch's
last rating action. Fitch modeled losses of 11.5% of the remaining
pool; expected losses on the original pool balance total 10.8%,
including $44.1 million (2.8% of the original pool balance) in
realized losses to date. Fitch has designated 41 loans (44.4%) as
Fitch Loans of Concern, which includes 18 specially serviced
assets (15.2%).

As of the July 2013 distribution date, the pool's aggregate
principal balance has been reduced by 30.4% to $1.1 billion from
$1.59 billion at issuance. Per the servicer reporting, two loans
(5% of the pool) are defeased and one larger loan is pending a
potential defeasance (7%). Interest shortfalls are currently
affecting classes F through P.

The largest contributor to expected losses is a specially-serviced
loan (3.3% of the pool), which is secured by a 535 unit
multifamily property and a 78,463 square foot (sf) office property
in Jenkintown, PA. The loan was transferred to special servicing
in January 2010 due to the borrower's request for relief. The
property has suffered from significant deferred maintenance and
city code violations. Per the special servicer, the majority of
the city code violations have been cleared, and deferred
maintenance items are being addressed. Litigation between the
special servicer and borrower is ongoing. Occupancy for the
residential and commercial space was a reported 49% and 69%
respectively, as of April 2013The loan is current as of July 2013.

The next largest contributor to expected losses (2.4% of the
pool), is secured by an 188,040 sf office building located in San
Juan Capistrano, CA. The top three tenants are Los Golondrinas
Mex. Food/Arturo Galindo Jr. (4%) lease expiry January 2019, Semi
Conductor Technology Associates Inc. (3%) lease expiry December
2013, and The Effect (3%) lease expiry December 2013.
Approximately (57%) of the tenant base expires within the next two
years: 2013 - 37%, 2013 - 20%. No other tenant represents more
than 2% of the total NRA. The year-end (YE) 2012 net operating
income (NOI) declined 10% from YE 2011 and 30% since issuance. The
property is performing below market in terms of occupancy, which
was 66% as of March 2013 with average in-place rents below market.
The loan remains current.

The third largest contributor to expected losses is a specially-
serviced (1.2%), which is secured by a 99,819 sf office property
located in Hoffman Estates, IL, built in 1992. The loan was
transferred to the special servicer in November 2009 for payment
default due to declines in occupancy. The special servicer
continues to pursue foreclosure. The property is currently 46.1%
occupied.

Rating Sensitivity

Rating Outlooks on classes A-5A through B remain Stable due to
sufficient credit enhancement and continued paydown. Rating
Outlooks on class C remains Negative due to the large number of
Fitch loans of concern and the potential for future defaults.

Fitch upgrades the following classes as indicated:

-- $97.1 million class A-J to 'BBBsf' from 'BBB-sf', Outlook
   Stable.

Fitch affirms the following classes and revises RE as indicated:

-- $485.9 million class A-5A at 'AAAsf', Outlook Stable;
-- $135.1 million class A3 and A4 at 'AAAsf', Outlook Stable;
-- $22.8 million class A-SB at 'AAAsf', Outlook Stable;
-- $69.4 million class A-5B at 'AAAsf', Outlook Stable;
-- $117.8 million class A-1A at 'AAAsf', Outlook Stable;
-- $31.7 million class B at 'BBsf', Outlook Stable;
-- $15.9 million class C at 'Bsf', Outlook Negative;
-- $29.7 million class D at 'CCCsf', RE 20%;
-- $17.8 million class E at 'CCsf', RE 0%;
-- $19.8 million class F at 'CCsf', RE 0%;
-- $17.8 million class G at 'Csf', RE 0%;
-- $23.8 million class H at 'Csf', RE 0%;
-- $7.9 million class J at 'Csf', RE 0%;
-- $7.9 million class K at 'Csf', RE 0%;
-- $3.6 million class L at 'Dsf', RE 0%;
-- $0 class M at 'Dsf'; RE 0%;
-- $0 class N at 'Dsf'; RE 0%
-- $0 class O at 'Dsf'; RE 0%.

Classes A-1 and A-2 are paid in full. Fitch does not rate the
class P certificates. Fitch previously withdrew the ratings on the
interest-only class XP and XC certificates.


BALLYROCK CLO III: Moody's Ups $45MM Cl. D Notes' Rating From Ba1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Ballyrock CLO III, Ltd.:

$33M Class C Deferrable Floating Rate Notes (current rated balance
$31,397,502), Upgraded to Aaa (sf); previously on July 15, 2013
Upgraded to A1 (sf) and Placed Under Review for Possible Upgrade;

$45M Class D Deferrable Floating Rate Notes (current rated balance
$43,563,181), Upgraded to Aa2 (sf); previously on July 15, 2013
Upgraded to Ba1 (sf) and Placed Under Review for Possible Upgrade.

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,
particularly since October 2012. Moody's notes that the Class S
Notes, Class A-1 Notes, Class A-2 Notes and Class B Notes have
been paid down in full since October 2012. Based on the latest
trustee report dated July 18, 2013 the Class C and Class D
overcollateralization ratios are reported at 130.6% and 111.8%,
respectively, versus October 2012 levels of 115.8% and 106.4%,
respectively. However, the July 18, 2013 trustee-reported OC
ratios do not yet reflect the July 25, 2013 payment distribution,
when $228.1 million of principal proceeds were used to pay down
the Class A-1 Notes, Class A-2 Notes, Class B Notes and Class C
Notes. Moody's notes that prior to the July 2013 paydowns, the
issuer had accumulated significant cash positions primarily
resulting from loan prepayments since July 2012, but had only
applied a small portion of such collections to note paydowns
during the January and April 2013 payment dates.

The key model inputs used by Moody's in its analysis, such as par,
weighted average rating factor, diversity score, and weighted
average recovery rate, are based on its published methodology and
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 $98.8 million,
defaulted par of $14.0 million, a weighted average default
probability of 11.06% (implying a WARF of 2356), a weighted
average recovery rate upon default of 50.7%, and a diversity score
of 20. 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.

Ballyrock CLO III, Ltd., issued in June 2005, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2013.

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 Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2013.

In addition to the base case analysis, 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% (1885)

Class C: 0

Class D: 0

Moody's Adjusted WARF + 20% (2827)

Class C: 0

Class D: 0

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

Sources of additional performance uncertainties:

1) Deleveraging: A 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 impact the notes' ratings.

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

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

4) Lack of portfolio granularity: The performance of the portfolio
depends to a large extent on the credit conditions of a few large
obligors that are rated, especially when they experience jump to
default.


BALLYROCK CLO III: S&P Raises Rating on Class D Notes From 'B+'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
C and D notes from Ballyrock CLO III Ltd., a U.S. collateralized
loan obligation (CLO) managed by Ballyrock Investment Advisors LLC
and removed them from CreditWatch positive.  At the same time, S&P
also removed its ratings on the class A-1, A-2, and B notes from
CreditWatch positive and subsequently withdrew them.  All of the
ratings had been placed on CreditWatch with positive implications
on May 17, 2013.

The upgrades mainly reflect increased credit support available to
the rated notes as the deal continues to amortize and pay down the
senior notes.  The rating withdrawals follow the complete
principal paydowns of the notes on their recent payment date.

The transaction's reinvestment period ended in July 2010.  Since
then, it has paid down the class A-1, A-2, and B notes completely
(a total paydown of $474 million) and approximately $1.6 million
to the class B notes.  This includes a paydown of approximately
$228.09 million on the July 2013 payment date.

The paydown of the notes increased the transaction's
overcollateralization (O/C) ratios.  The trustee reports the
following O/C ratios in the July 2013 monthly report:

   -- The class C O/C ratio is 130.60%, up from 116.07% in the
      January 2012 trustee report that S&P used for its February
      2012 analysis;

   -- The class D O/C ratio is 111.83%, higher than the 106.69%
      ratio in January 2012.

After the recent paydowns on the July 2013 payment date, the O/C
ratio will increase.  The class C O/C ratio will go up to 352.92%
and the class D O/C ratio will rise to 147.82%.

The transaction also has fewer defaulted obligations than it did
in January 2012.  Based on the July 2013 trustee report, which S&P
referenced for the rating actions, the transaction contained no
defaulted assets, down from the $4.11 million noted in the January
2012 trustee report, which S&P used for its rating action in
February 2012.  Furthermore, the amount of assets from obligors
rated in the 'CCC' category was reported at $14.13 million in July
2013, down from $16.69 million in January 2012.

S&P notes that the transaction has significant exposure to an
obligor currently rated 'CCC' with a negative outlook.  It is the
pool's largest obligor and constitutes approximately 12.39% of the
transaction's total performing par.

The upgrade on the class D notes was constrained by the largest
obligor default test, one of the two supplemental tests S&P
introduced as part of its revised corporate CDO criteria published
in 2009.

S&P 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 S&P will take rating
actions as it deems necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS RAISED AND REMOVED FROM CREDITWATCH

Ballyrock CLO III Ltd.
                         Rating
Class        To           From

C            AAA (sf)     BBB+ (sf)/Watch Pos
D            BBB+ (sf)    B+ (sf)/Watch Pos

RATINGS WITHDRAWN

Ballyrock CLO III Ltd.
                 Rating
Class        To           From
A-1          NR           AA+ (sf)/Watch Pos
A-2          NR           AA+ (sf)/Watch Pos
B            NR           AA+ (sf)/Watch Pos

NR - Not rated.

TRANSACTION INFORMATION
Issuer:              Ballyrock CLO III Ltd.
Co-issuer:           Ballyrock CLO III Inc.
Collateral manager:  Ballyrock Investment Advisors LLC
Trustee:             The Bank of New York Mellon
Transaction type:    Cash flow CDO

CDO - Collateralized debt obligation.


BANC OF AMERICA: Moody's Takes Action on $141-Mil. of RMBS
----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 23
tranches from six transactions backed by Alt-A loans, issued by
Banc of America.

Complete rating actions are as follows:

Issuer: Banc of America Alternative Loan Trust 2003-1

Cl. A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-3, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-4, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-5, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. A-6, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. A-PO, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Alternative Loan Trust 2003-10

Cl. 2-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-2, Downgraded to A3 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-3, Downgraded to A3 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-4, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 5-A-1, Downgraded to Ba1 (sf); previously on Mar 11, 2013
Downgraded to Baa3 (sf)

Cl. 6-A-2, Downgraded to Ba1 (sf); previously on Mar 11, 2013
Downgraded to Baa3 (sf)

Cl. 6-A-3, Downgraded to Ba1 (sf); previously on Mar 11, 2013
Downgraded to Baa3 (sf)

Issuer: Banc of America Alternative Loan Trust 2003-11

Cl. 5-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 5-A-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Alternative Loan Trust 2003-2

Cl. NC-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. NC-3, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Alternative Loan Trust 2003-7

Cl. 1-A-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-4, Downgraded to Ba2 (sf); previously on Jun 21, 2012
Confirmed at Ba1 (sf)

Cl. 2-A-PO, Downgraded to Ba2 (sf); previously on Mar 15, 2011
Downgraded to Ba1 (sf)

Issuer: Banc of America Funding 2004-1 Trust

Cl. 6-A-1, Downgraded to Ba1 (sf); previously on Apr 13, 2012
Confirmed at Baa1 (sf)

Cl. 8-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Ratings Rationale:

The actions are a result of the recent performance of the
underlying pools and reflect Moody's updated loss expectations on
the pools. The downgrades reflect the exposure of the affected
bonds to tail risk due to the pro-rata pay nature of the
transaction. The ratings of these securities are being capped to
A3 (sf) or below due to the tail risk.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in June 2013.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
8.2% in July 2012 to 7.4% in July 2013. Moody's forecasts an
unemployment central range of 7.0% to 8.0% for the 2013 year.
Moody's expects house prices to continue to rise in 2013.
Performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


BANK OF AMERICA 2005-6: Moody's Keeps C Ratings on 2 Cert Classes
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 16 classes of
Bank of America Commercial Mortgage Inc., Commercial Mortgage
Pass-Through Certificates, Series 2005-6 as follows:

Cl. A-4, Affirmed Aaa (sf); previously on Jan 3, 2006 Definitive
Rating Assigned Aaa (sf)

Cl. A-J, Affirmed A1 (sf); previously on Dec 10, 2010 Downgraded
to A1 (sf)

Cl. A-M, Affirmed Aaa (sf); previously on Jan 3, 2006 Definitive
Rating Assigned Aaa (sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Jan 3, 2006 Definitive
Rating Assigned Aaa (sf)

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

Cl. C, Affirmed A3 (sf); previously on Dec 10, 2010 Downgraded to
A3 (sf)

Cl. D, Affirmed Baa1 (sf); previously on Dec 10, 2010 Downgraded
to Baa1 (sf)

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

Cl. F, Affirmed Ba1 (sf); previously on Dec 10, 2010 Downgraded to
Ba1 (sf)

Cl. G, Affirmed B1 (sf); previously on Aug 23, 2012 Downgraded to
B1 (sf)

Cl. H, Affirmed Caa1 (sf); previously on Aug 23, 2012 Downgraded
to Caa1 (sf)

Cl. J, Affirmed Caa2 (sf); previously on Aug 23, 2012 Downgraded
to Caa2 (sf)

Cl. K, Affirmed Caa3 (sf); previously on Aug 23, 2012 Downgraded
to Caa3 (sf)

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

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

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

Ratings Rationale:

The affirmations of Classes A-4 through G are due to key
parameters, including Moody's loan to value (LTV) ratio, Moody's
stressed DSCR and the Herfindahl Index (Herf), remaining within
acceptable ranges. Based on Moody's current base expected loss,
the credit enhancement levels the affirmed classes is sufficient
to maintain their current rating.

The rating of Classes H through M are consistent with Moody's base
expected loss and thus are affirmed.

The rating of the interest-only (IO) class, Class XW, is
consistent with the expected credit performance of its referenced
classes and thus is affirmed.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for rated 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 rating action reflects a base expected loss of 5.0% of the
current pooled balance compared to 5.1% at last review. Moody's
based expected loss plus realized losses is now 6.2% of the
original pooled balance, which is the same as at last review.

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.

The principal methodology used in this rating was "Moody's
Approach to Rating Fusion U.S. CMBS Transactions" published in
April 2005.

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
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's 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 29 compared to 31 at Moody's prior review.

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.

Deal Performance:

As of the July 10, 2013 distribution date, the transaction's
aggregate pooled certificate balance has decreased by 20% to $2.2
billion from $2.7 billion at securitization. The deal contains
$180 million of non-pooled rake bonds tied to the KinderCare
Portfolio Loan, which brings the deal's total balance to $2.4
billion. The Certificates are collateralized by 135 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
less than 1% of the pool, has been defeased and is collateralized
with U.S. Government Securities. Two loans, representing 18% of
the pool, have investment grade credit assessments.

Twenty-eight 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 its ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Nineteen loans have liquidated at a loss from the pool, resulting
in an aggregate realized loss of $61 million (46% average loss
severity). Eight loans, representing 5% of the pool, are currently
in special servicing. The largest specially serviced loan is the
One Old County Road Loan ($47 million -- 2.1% of the pool), which
is secured by a 320,000 square foot (SF) office property in Long
Island, New York. The loan transferred to special servicing in
November 2010 due to Imminent Default. The property was 92% leased
as of May 2013 compared to 91% as of December 2011. The servicer
is dual tracking foreclosure and a possible loan modification.

The remaining specially serviced loans are secured by a mix of
office, industrial and self-storage properties. The servicer has
recognized an aggregate appraisal reduction of $51 million for
seven of the eight specially serviced loans. Moody's estimates an
aggregate $50 million loss from all the specially serviced loans
(42% average loss severity).

Moody's has assumed a high default probability for 12 poorly
performing loans representing 4% of the pool and has estimated a
$19 million aggregate loss (22% expected loss based on a 52%
probability of default) from these troubled loans.

Moody's was provided with full year 2011 and partial or full year
2012 operating results for 96% and 95% of the pool, respectively.
Moody's weighted average conduit LTV is 91% compared to 94% at
Moody's prior review. The conduit portion of the pool excludes
specially serviced, troubled and defeased loans as well as the two
loans with a credit assessments. 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 9.5%.

Moody's actual and stressed conduit DSCRs are 1.51X and 1.18X,
respectively, compared to 1.53X and 1.15X 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 277 Park Avenue
Loan ($260 million -- 11.9%), which represents a participation
interest in the senior component of a $500 million mortgage loan.
The loan is secured by a 1.8 million SF 50-story Class A office
tower located in Midtown Manhattan. The property is also
encumbered by $200 million in mezzanine debt. The property was 97%
leased as of December 2012, which is the same as at Moody's last
review. JP Morgan Chase Bank leases 75% of the net rentable area
(NRA) through March 2021. Moody's credit assessment and stressed
DSCR are A2 and 1.50X, respectively, which is the same as at last
review.

The second largest loan with a credit assessment is the KinderCare
Portfolio Loan ($136 million -- 6.2% of the pool), which
represents a participation interest in the senior component of
$587 million mortgage loan. The property's $180 million
subordinate B-note is collateral for six non-pooled raked classes
in this deal. The property is encumbered by $50 million of
mezzanine debt. The loan was originally secured by a portfolio of
713 properties located throughout 37 states. The portfolio is
master-leased to Knowledge Universe Education LLC (f.k.a.
Knowledge Learning Corporation; Moody's corporate family rating
B3, stable outlook). Moody's current credit assessment and
stressed DSCR are A3 and 2.04X, respectively, compared to A3 and
2.09X at last review.

The top three performing conduit loans represent 14.1% of the
pool. The largest loan is the Burnett Plaza Loan ($105 million --
4.8% of the pool), which is secured by a 40-story Class A office
property located in downtown Fort Worth, Texas. The property was
88% leased as March 2013 compared to 85% at Moody's last review.
The largest tenant, the General Services Administration, occupies
16% of the NRA under a lease that expires in September 2013.
Moody's current LTV and stressed DSCR are 106% and 0.97X,
respectively, compared to 102% and 1.01X at last review.

The second largest loan is the In Town Suites Loan ($104 million -
- 4.8% of the pool), which is secured by a portfolio of 40 In Town
Suites extended-stay hotels located in 33 cities across 16 states.
The properties were constructed between 1996 and 2001. An increase
in the portfolio's average weekly rate led to an increase in
performance. Moody's current LTV and stressed DSCR are 67% and
1.88X, respectively, compared to 72% and 1.77X at last review.

The third largest loan is the Omni Hotel -- San Diego Loan ($99
million -- 4.5% of the pool). The loan is secured by a 511-room
full-service hotel located in downtown San Diego, California. The
hotel is adjacent to the San Diego Padres' baseball stadium and is
located near the San Diego convention center. The property's
revenue per available room increased slightly to $152 in 2012 from
$149 in 2011, which led to an increase in property performance.
Moody's current LTV and stressed DSCR are 88% and 1.29X,
respectively, compared to 92% and 1.23X at last review.


CABELA'S CREDIT: Fitch Rates $9.6MM Class D Notes at 'BB'
---------------------------------------------------------
Fitch Ratings assigns the following ratings to Cabela's Credit
Card Master Note Trust's asset-backed notes, series 2013-II:

-- $100,000,000 class A-1 fixed-rate 'AAAsf'; Outlook Stable;
-- $197,500,000 class A-2 floating-rate 'AAAsf'; Outlook Stable;
-- $28,000,000 class B fixed-rate 'Asf'; Outlook Stable;
-- $14,875,000 class C fixed-rate 'BBBsf'; Outlook Stable;
-- $9,625,000 class D fixed-rate 'BBsf'; Outlook Stable.

Key Rating Drivers:

Fitch's ratings are based on the underlying receivables pool,
available credit enhancement, World's Foremost Bank's underwriting
and servicing capabilities, and the transaction's legal and cash
flow structures, which employ early redemption triggers.

The transaction structure is similar to series 2013-I, with credit
enhancement totaling 15% for class A, credit enhancement of 7% for
the class B, credit enhancement of 2.75% plus an amount from a
spread account for the class C, and credit enhancement of an
amount from a spread account for the class D notes only.

Rating Sensitivities:

Fitch models three different scenarios when evaluating the rating
sensitivity compared to expected performance for credit card
asset-backed securities transactions: 1) increased defaults; 2) a
reduction in monthly payment rate (MPR), and 3) a combination
stress of higher defaults and lower MPR.

Increasing defaults alone has the least impact on rating migration
even in the most severe scenario of a 75% increase in defaults.
The rating sensitivity to a reduction in MPR is more pronounced
with a moderate stress, of a 25% reduction, leading to possible
downgrades across all classes. The harshest scenario assumes both
stresses occur simultaneously. Similarly, the ratings would only
be downgraded under the moderate stress of a 40% increase in
defaults and 20% reduction in MPR; however the severe stress could
lead to more drastic downgrades to all classes.

To date, the transactions have exhibited strong performance with
all performance metrics within Fitch's initial expectations. For
further discussion of our sensitivity analysis, please see the
related presale report. For a discussion of the representations,
warranties, and enforcement mechanisms available to investors in
this transaction please see the related presale appendix.


CAPITAL TRUST 2004-1: Fitch Affirms 'D' Ratings on 5 Cert. Classes
------------------------------------------------------------------
Fitch Ratings has upgraded two and affirmed four classes of
Capital Trust RE CDO 2004-1 (Capital Trust 2004-1) reflecting
Fitch's base case loss expectation of 47.8%. Fitch's performance
expectation incorporates prospective views regarding commercial
real estate market value and cash flow declines.

Key Rating Drivers

The upgrades are due to deleveraging of the pool since the last
rating action, coupled with lower expected losses, particularly
related to improved performance of the largest asset in the pool.
Capital Trust 2004-1 is a commercial real estate (CRE)
collateralized debt obligation (CDO) managed by CT Investment
Management Co., LLC (CTIMCO). As of the July 2013 trustee report,
the CDO was invested as follows: B-notes (99.6%) and commercial
mortgage backed securities (CMBS) (0.4%). Since Fitch's last
rating action, the capital structure has paid down by $26.9
million. Realized losses over the same period were approximately
$18 million.

The transaction is highly concentrated with only seven assets
remaining in the portfolio. Approximately 47.6% of the pool is
currently defaulted while a further 32.8% are considered assets of
concern. Fitch expects significant losses on most of the assets as
they are generally highly leveraged subordinate positions.

Under Fitch's methodology, approximately 88.6% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress. Fitch estimates that average recoveries will be
46.1% reflecting the low recovery expectations upon default of the
CMBS tranches and real estate loans which are predominantly
subordinate positions.

The largest component of Fitch's base case loss expectation is a
922,385 square foot (sf) office property located within an office
complex (26.5%) located in New Hyde Park, NY. As of YE 2012,
occupancy had declined to 64.6% primarily due to tenants vacating
in the fourth quarter of 2012. Fitch modeled a substantial loss in
its base case scenario on this overleveraged position.

The next largest component of Fitch's base case loss expectation
was originally collateralized by four casino/hotel properties
located in Atlantic City, NJ, East Chicago, IN, Robinsonville, MS
and Tunica, MS (10.3%). The loan was foreclosed in November 2011
and the two remaining properties became REO assets. Fitch modeled
a substantial loss in its base case scenario on this overleveraged
position.
This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying CREL collateral in the portfolio and
uses the Portfolio Credit Model for the CMBS collateral.
Recoveries for the CREL collateral are based on stressed cash
flows and Fitch's long-term capitalization rates. The transaction
was not run through the cash flow model given the concentrated
nature of the portfolio.

Rating Sensitivities

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

Fitch has upgraded the following classes as indicated:

-- $24,143,210 class B to 'Bsf' from 'CCCsf'; Outlook Stable
    Assigned;

-- $19,444,000 class C to 'CCCsf' from 'CCsf'; RE 100%.

Fitch has affirmed the following classes as indicated:

-- $21,065,000 class D at 'Csf'; RE 45%;
-- $3,241,000 class E at 'Csf'; RE 0%;
-- $6,481,000 class F at 'Csf'; RE 0%;
-- $16,204,000 class G at 'Csf'; RE 0%.


CAPITAL TRUST 2005-1: Fitch Affirms 'D' Rating on Class B Trust
---------------------------------------------------------------
Fitch Ratings has affirmed eight classes of Capital Trust RE CDO
2005-1 (Capital Trust 2005-1). Fitch's base case loss expectation
for the transaction is 61.4%. Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market value and cash flow declines.

Key Rating Drivers

Capital Trust 2005-1 is a commercial real estate collateralized
debt obligation (CDO) managed by CT Investment Management Co., LLC
(CTIMCO). As of the July 2013 trustee report, the CDO was invested
as follows: senior notes (11.5%), B-notes (45.1%), mezzanine debt
(17.1%), commercial mortgage backed securities (CMBS) (14.4%) and
CDOs (11.9%). Since Fitch's last rating action, the capital
structure has paid down by $26.6 million. Realized losses over the
same period were approximately $76,919. As of the July 2013
trustee report, all overcollateralization (OC) are failing their
respective triggers.

The transaction is highly concentrated with only 13 assets
remaining in the portfolio. Approximately 49.2% of the pool is
currently defaulted while a further 22.3% are considered assets of
concern. Fitch expects significant losses on most of the assets as
they are generally highly leveraged subordinate positions.

Under Fitch's methodology, approximately 85.7% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress. Fitch estimates that average recoveries will be
28.4% reflecting the low recovery expectations upon default of the
CMBS tranches and real estate loans which are predominantly
subordinate.

The largest component of Fitch's base case loss is the expected
losses on the CMBS bond collateral. The second largest contributor
to loss is a defaulted B-note (11.9% of the pool) secured by a
full service hotel located in Long Beach, CA. The loan defaulted
at loan maturity in July 2012. Cash flow to the property declined
slightly since the last rating action as the loan continues to be
overleveraged. Fitch modeled a substantial loss in its base case
scenario.

The next largest component of Fitch's base case loss expectation
is a 922,385 square foot (sf) office property located within an
office complex (10.4%) located in New Hyde Park, NY. As of year-
end (YE) 2012, occupancy had declined to 64.6% primarily due to
tenants vacating in the fourth quarter of 2012. Fitch modeled a
substantial loss in its base case scenario on this overleveraged
position.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying CREL collateral in the portfolio and
uses the Portfolio Credit Model for the CMBS collateral.
Recoveries for the CREL collateral are based on stressed cash
flows and Fitch's long-term capitalization rates. The transaction
was not run through the cash flow model given the distressed
nature of the ratings.

Rating Sensitivities

The ratings on all notes may be subject to further downgrades as
losses are realized.

The affirmation of the class A-1 notes at 'CCC' reflects the
possibility going forward that interest and/or principal proceeds
will not be available to pay the timely interest class, especially
if there are further defaults or delinquencies on the underlying
collateral. Ultimate recoveries to the class; however, should be
substantial.

On March 20, 2012, the Trustee declared an event of default (EOD)
due to non-payment of full and timely accrued interest to the
class B notes. The class B notes are a non-deferrable class and
have been affirmed at 'Dsf' due to default in the timely payment
of their accrued interest. Noteholders had not given direction to
accelerate the notes or liquidate the portfolio at the time of
this review.

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

Fitch has affirmed the following classes as indicated:

-- $41,757,890 class A at 'CCCsf'; RE 100%;
-- $36,309,000 class B at 'Dsf'; RE 75%;
-- $21,110,000 class C at 'Csf'; RE 0%;
-- $14,354,000 class D at 'Csf'; RE 0%;
-- $15,199,000 class E at 'Csf'; RE 0%;
-- $6,755,000 class F at 'Csf'; RE 0%;
-- $6,755,000 class G at 'Csf'; RE 0%;
-- $10,133,000 class H at 'Csf'; RE 0%.


CARLYLE BRISTOL: Moody's Confirms B1 Rating on Class D Notes
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Carlyle Bristol CLO, Ltd.:

$25,000,000 Class B-1 Senior Secured Deferrable Floating Rate
Notes due 2019, Upgraded to Aa1 (sf); previously on July 15, 2013
Upgraded to Aa3 (sf) and Placed Under Review for Possible Upgrade;

$3,000,000 Class B-2 Senior Secured Deferrable Fixed Rate Notes
due 2019, Upgraded to Aa1 (sf); previously on July15, 2013
Upgraded to Aa3 (sf) and Placed Under Review for Possible Upgrade;

$8,000,000 Type I Composite Notes due 2019 (current rated balance
of $4,519,360.37), Upgraded to Aaa (sf); previously on July 15,
2013 Aa1 (sf) Placed Under Review for Possible Upgrade;

$4,000,000 Type II Composite Notes due 2019 (current rated balance
of $1,487,115.42), Upgraded to Aaa (sf); previously on July 15,
2013 Aa3 (sf) Placed Under Review for Possible Upgrade.

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

$382,000,000 Class A-1 Senior Secured Floating Rate Notes due 2019
(current outstanding balance of $135,600,099.93), Affirmed Aaa
(sf); previously on July 13, 2011 Upgraded to Aaa (sf);

$18,750,000 Class A-2 Senior Secured Floating Rate Notes due 2019,
Affirmed Aaa (sf); previously on July 15, 2013 Upgraded to Aaa
(sf).

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

$28,500,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2019, Confirmed at Ba1 (sf); previously on July 15, 2013 Ba1
(sf) Placed Under Review for Possible Upgrade;

$4,000,000 Class D Secured Deferrable Floating Rate Notes due
2019, Confirmed at B1 (sf); previously on July 15, 2013 B1 (sf)
Placed Under Review for Possible Upgrade.

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.
Moody's notes that the Class A-1 Notes have been paid down by
approximately 38% or $145.4 million since December 2012. Based on
the latest trustee report dated July 15, 2013, the Class A, Class
B, Class C and Class D overcollateralization ratios are reported
at 148.69%, 125.86%, 108.85% and 106.82% respectively, versus
December 2012 levels of 125.18%, 114.49%, 105.33% and 104.16%,
respectively. In taking the foregoing actions, Moody's also
announced that it had concluded its review of its ratings on the
issuer's Class B-1, Class B-2, Class C, Class D, Type I Composite
and Type II Composite notes announced on July 15, 2013. At that
time, Moody's said that it had upgraded and placed certain of the
issuer's ratings on review primarily as a result of substantial
deleveraging of the senior notes and increases in OC ratios
resulting from high rates of loan collateral prepayments during
the first half of 2013.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, diversity
score, and weighted average recovery rate, are based on its
published methodology and 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 $218 million, defaulted par of $14.9 million,
a weighted average default probability of 15.16% (implying a WARF
of 2461), a weighted average recovery rate upon default of 52.23%,
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 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.

Carlyle Bristol CLO, Ltd., issued in October 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2013. The methodology used in rating the Type I and Type II
Composite 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 Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2013.

In addition to the base case analysis, 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% (1968)

Class A-1: 0

Class A-2: 0

Class B-1: 0

Class B-2: 0

Class C: +2

Class D: +2

Type I: 0

Type II: 0

Moody's Adjusted WARF + 20% (2953)

Class A-1: 0

Class A-2: 0

Class B-1: -1

Class B-2: -1

Class C: 0

Class D: 0

Type I: 0

Type II: 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: A 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.


CHINO REDEVELOPMENT: Moody's Confirms Ba1 Rating on RDA TABs
------------------------------------------------------------
Moody's Investors Service has confirmed the Ba1 rating on the
Successor Agency to the Chino Redevelopment Agency (RDA) Series
1998A & 1998B and the Series 2001A & 2001B Tax Allocation Bonds
(TABs).

Rating Rationale:

The Ba1 rating reflects the risks and weakness that the
dissolution of redevelopment agencies (now known as successor
agencies) now adds to bond's credit profile. The confirmation of
the Ba1 rating incorporates the expectation that debt service
coverage, net of pass-through payments, will be narrow in some
semi-annual payment periods. The rating favorably takes into
account the large Merged Project area, the above average wealth
levels, and the high incremental assessed valuation (AV) to total
AV. The rating also reflects the risks associated with the project
area's high taxpayer concentration.

The bonds are secured by tax increment revenues of the Merged
Project Area.

Strengths:

- Large size of project area

- Above average wealth levels

- High incremental AV to total AV

Challenges:

- High taxpayer concentration

- Projected debt service coverage in the first half of each year
   will be below two times

- Narrow debt service coverage due to expected loss of revenue
   associated with Central City Project Area

What could move the rating-UP

- Significant and sustained increase in assessed valuation with
at
   least two times coverage in both periods

What could move the rating-DOWN

- Erosion of semi-annual debt service coverage levels

- Protracted assessed value decline

- Failure to implement and execute on plan to address projected
   semi-annual debt service coverage shortfalls

Rating Methodology:

The principal methodology used in this rating was Moody's Analytic
Approach To Rating California Tax Allocation Bonds published in
December 2003.



COMM 2007-C9: Moody's Affirms C Ratings on 7 Debt Classes
---------------------------------------------------------
Moody's Investors Service upgraded the ratings of 13 classes and
affirmed 13 classes of COMM 2007-C9 Commercial Mortgage Pass-
Through Certificates as follows:

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

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

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

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

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

Cl. A-J, Upgraded to Baa3 (sf); previously on Aug 22, 2012
Downgraded to Ba1 (sf)

Cl. AJ-FL, Upgraded to Baa3 (sf); previously on Aug 22, 2012
Downgraded to Ba1 (sf)

Cl. AM, Upgraded to Aa1 (sf); previously on Dec 2, 2010 Downgraded
to Aa2 (sf)

Cl. AM-FL, Upgraded to Aa1 (sf); previously on Dec 2, 2010
Downgraded to Aa2 (sf)

Cl. B, Upgraded to Ba1 (sf); previously on Aug 22, 2012 Downgraded
to Ba2 (sf)

Cl. C, Upgraded to Ba2 (sf); previously on Aug 22, 2012 Downgraded
to Ba3 (sf)

Cl. D, Upgraded to B1 (sf); previously on Aug 22, 2012 Downgraded
to B2 (sf)

Cl. E, Upgraded to B2 (sf); previously on Aug 22, 2012 Downgraded
to B3 (sf)

Cl. F, Upgraded to B3 (sf); previously on Dec 2, 2010 Downgraded
to Caa1 (sf)

Cl. G, Upgraded to Caa1 (sf); previously on Dec 2, 2010 Downgraded
to Caa2 (sf)

Cl. H, Upgraded to Caa2 (sf); previously on Dec 2, 2010 Downgraded
to Caa3 (sf)

Cl. J, Upgraded to Caa3 (sf); previously on Dec 2, 2010 Downgraded
to Ca (sf)

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

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

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

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

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

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

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

Cl. XP, Upgraded to Aa1 (sf); previously on Feb 22, 2012
Downgraded to Aa2 (sf)

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

Ratings Rationale:

The upgrades are due primarily to paydowns, amortization, and
overall improved performance of the deal.

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

The affirmations of the below-investment grade classes are due to
Moody's expected loss remaining within a range commensurate with
the in-place ratings.

The rating of the Class X-P IO bond is upgraded to reflect the
improved credit quality of its referenced classes. Class X-P is a
PAC IO and references the A-M and A-J bonds, which are upgraded in
this rating action.

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

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for rated 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 rating action reflects a base expected loss of
approximately 8.0% of the current deal balance. At last review,
Moody's base expected loss was approximately 8.3%. Moody's base
expected loss plus realized loss is 8.0% of the original
securitized deal balance compared to 8.7% at Moody's last review.

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.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. CMBS Conduit Transactions" published in
September 2000.

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 (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade underlying ratings is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's 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 23 compared to 24 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST (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.

Deal Performance:

As of the July 10, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 12% to $2.54
billion from $2.89 billion at securitization. The Certificates are
collateralized by 92 mortgage loans ranging in size from less than
1% to 11% of the pool, with the top ten loans representing 58% of
the pool. The pool contains no loans with investment-grade credit
assessments and no defeased loans.

Twenty-four loans, representing 23% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of its
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Nine loans have liquidated from the pool, contributing to an
aggregate realized loss to the trust of $27 million. Loans that
were liquidated from the pool averaged a 12% loss severity.
Currently, eight loans, representing 4% of the pool, are in
special servicing. Moody's estimates an aggregate $54 million loss
(52% expected loss) for all specially serviced loans.

Moody's has assumed a high default probability for 21 poorly-
performing loans representing 21% of the pool. Moody's analysis
attributes to these troubled loans an aggregate $76 million loss
(14% expected loss severity based on a 49% probability default).

Moody's was provided with full-year 2012 and partial year 2013
operating results for 94% and 35% of the performing pool,
respectively. Excluding troubled and specially serviced loans,
Moody's weighted average LTV is 111% compared to 110% at last full
review. Moody's net cash flow reflects a weighted average haircut
of 9.1% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.2%.

Excluding troubled and specially serviced loans, Moody's actual
and stressed DSCRs are 1.34X and 0.92X, respectively, compared to
1.37X and 0.93X 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 28% of the pool.
The largest loan is the 60 Wall Street Loan ($285 million -- 11%
of the pool). The loan represents two pooled pari passu loan
pieces of a $919.4 million loan which is secured by a Class A
office tower in the Financial District of Lower Manhattan. The
property is 100% leased to Deutsche Bank AG (Moody's senior
unsecured rating A2, stable outlook) until June 2022. Moody's
current LTV and stressed DSCR are 112% and 0.79X, respectively,
the same as at Moody's last review.

The second largest loan is the Waterview Loan ($210 million -- 8%
of the pool), which is secured by a 24-story Class A office
building in the Rosslyn section of Arlington, Virginia. The
property is 99% leased to The Corporate Executive Board (Moody's
senior unsecured rating B1, stable outlook) through January 2028.
The property commands higher rents than the submarket average due
to the high quality of the property and commanding views of nearby
Washington, DC. Moody's current LTV and stressed DSCR are 94% and
0.98X, unchanged from Moody's last review.

The third largest loan is the DDR Portfolio Loan ($221 million --
9% of the pool). The loan is secured by 52 anchored retail
properties located across ten states. Approximately three quarters
of the properties are grocery-anchored centers. Portfolio
occupancy was 88% as of year-end 2012, up slightly from 86% at
Moody's last review, but down from 96% at securitization. The loan
benefits from amortization. The loan sponsor is the real estate
investment trust DDR Corp. (Moody's senior unsecured rating Baa3,
positive outlook). Moody's current LTV and stressed DSCR are 118%
and 0.78X, respectively, compared to 120% and 0.76X at last
review.


COMM 2013-300P: Fitch to Rate $28MM Class E Certificates 'BB+'
--------------------------------------------------------------
Fitch Ratings has issued a presale report on COMM 2013-300P
Mortgage Trust commercial mortgage pass-through certificates.
Fitch expects to rate the transaction and assign Rating Outlooks
as follows:

-- $222,000,000 class A1 'AAAsf'; Outlook Stable;
-- $75,000,000 class A1P 'AAAsf'; Outlook Stable;
-- $297,000,000* class X-A 'AAAsf'; Outlook Stable;
-- $61,000,000 class B 'AA-sf'; Outlook Stable;
-- $42,000,000 class C 'A-sf'; Outlook Stable;
-- $57,000,000 class D 'BBB-sf'; Outlook Stable;
-- $28,000,000 class E 'BB+sf'; Outlook Stable.

* Interest-only and notional amount.

The expected ratings are based upon information received by the
issuer as of July 31, 2013.

The COMM 2013-300P certificates represent the beneficial interests
in the mortgage loan securing the 300 Park Avenue property located
in New York, NY. Proceeds of the loan were used to refinance
existing debt, pay closing costs, and return equity to the
sponsor. The certificates will follow a sequential-pay structure.

Key Rating Drivers

Low Trust Leverage: Fitch's stressed debt service coverage ratio
(DSCR) for the trust component of the debt is 1.32x, and the
stressed loan to value (LTV) is 67.2%. Additionally, the 'AAAsf'
rated debt is only $385 per square foot (psf) which implies the
property could sustain a 70% decline in value from its current $1
billion appraised value and still repay 'AAAsf' debt.

Credit Tenancy: As of July 2013, the property was 91.6% leased by
13 tenants and serves as the global headquarters for Colgate-
Palmolive ('AA-'; Stable Outlook by Fitch), which leases 65.3% of
the net rentable area (NRA) through June 2023.

Tenant Concentration and Rollover Risk: During the 10-year loan
term 98.8% of the leased NRA rolls, including the largest tenant,
Colgate-Palmolive, whose lease expires two months before the loan
matures. Colgate-Palmolive has demonstrated a commitment to the
property through long-term occupancy of 59 years, a 2008 early
lease renewal for 15 years, and recent and ongoing investments in
their space.

Limited Structural Features: The loan has no upfront reserves
other than real estate taxes, no structure in place to mitigate
the Colgate-Palmolive lease expiration, springing cash management,
and there is no carve-out guarantor.

Excellent Location: The property is located in the Grand Central
submarket (just south of the Plaza submarket) between 49th and
50th streets on the west side of Park Avenue. The location is four
blocks north of Grand Central Terminal and offers excellent
accessibility and proximity to public transportation.

Rating Sensitivities

Fitch found that the pool could withstand a 70.3% decline in value
and an approximately 56.3% decrease in the most recent actual cash
flow prior to experiencing $1 of loss to any 'AAAsf' rated class.

Fitch evaluated the sensitivity of the ratings of class A (rated
'AAAsf') and found that a 8% decline in Fitch net cash flow would
result in a one-category downgrade, while a 35% decline would
result in a downgrade to below investment grade.

The Rating Sensitivity section in the presale report includes a
detailed explanation of additional stresses and sensitivities. Key
Rating Drivers and Rating Sensitivities are further described in
the accompanying presale report.


COMMERCIAL MORTGAGE 2007-GG11: S&P Keeps CCC Rating on Cl. B Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-4 and A-1-A commercial mortgage pass-through certificates from
Commercial Mortgage Trust 2007-GG11, a U.S. commercial mortgage-
backed securities (CMBS) transaction.  At the same time, S&P
affirmed its ratings on eight other classes.

S&P's rating actions reflect 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 and
performance of all of the remaining assets in the pool, the
transaction structure, and the liquidity available to the trust.

"Our raised ratings on the class A-4 and A-1-A certificates
reflect our expected available credit enhancements for these
tranches, which we believe are greater than our most recent
estimate of necessary credit enhancement for the rating levels.
The upgrades also reflect our views regarding the current and
future performance of the transaction's collateral, as well as the
reduced trust balance, including the repayment in full of the
Scottsdale Fashion Square loan in March 2013," S&P said.

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

"While available credit enhancement may suggest positive rating
movement on the certificate classes, we affirmed our ratings
because our analysis also took into consideration our view on
available liquidity support and risks associated with potential
interest shortfalls in the future.  Specifically, we considered
the potential for the 12 specially serviced assets
($297.4 million, 14.9%) and the 24 loans on the master servicer's
watchlist ($825.7 million, 41.3%) to generate additional interest
shortfalls and decrease the liquidity support available to the
trust," S&P added.

S&P affirmed its 'AAA (sf)' ratings on the class XP and XC
interest-only (IO) certificates based on its 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

RATINGS RAISED

Commercial Mortgage Trust  2007-GG11
Commercial mortgage pass-through certificates
            Rating
Class   To           From           Credit enhancement (%)
A-4     AA- (sf)     BBB+ (sf)                       36.44
A-1-A   AA- (sf)     BBB+ (sf)                       36.44

RATINGS AFFIRMED

Commercial Mortgage Trust 2007-GG11
Commercial mortgage pass-through certificates

Class      Rating   Credit enhancement (%)
A-3        AAA (sf)                  36.44
A-AB       AAA (sf)                  36.44
A-M        BB  (sf)                  22.98
A-J        B- (sf)                   12.39
B          CCC (sf)                  11.38
C          CCC- (sf)                 10.04
XP         AAA (sf)                    N/A
XC         AAA (sf)                    N/A

N/A-Not applicable.


CREDIT SUISSE 2000-C1: S&P Affirms 'B-' Rating on Class H Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
G commercial mortgage pass-through certificates from Credit Suisse
First Boston Mortgage Securities Corp.'s series 2000-C1, a U.S.
commercial mortgage-backed securities (CMBS) transaction.
Concurrently, S&P affirmed its 'B- (sf)' rating on the class H
certificates from the same transaction (see list).

"Our rating actions follow our analysis of the transaction, which
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 raised rating on class G
also reflects our expected available credit enhancement for this
class, which we believe is greater than our most recent estimate
of necessary credit enhancement for the most recent rating levels.
Additionally, the upgrade reflects our views regarding the current
and future performance of the collateral supporting the
transaction, as well as the reduced pool trust balance," S&P said.

The affirmed rating on class H reflects S&P's expectation that the
available credit enhancement for this class will be within its
estimate of necessary credit enhancement required for the current
outstanding rating.  The affirmation also reflects the credit
characteristics and performance of the remaining loans, as well as
the transaction-level changes.

"While available credit enhancement levels may suggest further
positive rating movements on classes G and H, our analysis also
considered the number of loans on the master servicers' combined
watchlist ($2.7 million, 12.1%), accumulated interest shortfalls
outstanding as well as the liquidity support available to the
remaining classes.  As of the July 17, 2013, trustee remittance
report, the trust experienced interest shortfalls totaling $10,170
primarily due to an interest rate reductions ($9,886) related to
the modification of The Ponds Cooperative Homes Inc. loan
($4.9 million, 21.8%), which is a corrected mortgage loan that has
been returned to the master servicer.  The loan was previously
transferred to the special servicer in April 2010 due to imminent
maturity default and has been given multiple extensions since.
The loan is secured by a 144-unit multifamily cooperative housing
(co-op) property in Okemos, Mich.  According to the master
servicer, the modification terms included reducing the interest
rate to 6.5% from 8.9% and extending the new maturity date to
Jan. 1, 2015.  Class H has accumulated interest shortfalls
outstanding for 11 months and could potentially experience
additional interest shortfalls in the future should any of the
remaining loans be transferred to the special servicer.  The G
class certificates have experienced interest shortfalls one time
in the past," S&P added.

Using servicer-provided financial information, S&P calculated an
adjusted Standard & Poor's debt service coverage (DSC) ratio of
1.14x and a loan-to-value (LTV) ratio of 57.6% for 29 of the 34
remaining loans in the pool, which include 27 co-op loans
($12.9 million, 56.8%).  The DSC and LTV calculations exclude four
defeased loans ($1.8 million, 7.9%) and one nonreporting loan
($489,716, 2.2%).

As of the July 17, 2013, trustee remittance report, the collateral
pool had an aggregate trust balance of $22.6 million, down from
$1.1 billion at issuance.  The pool comprises 34 loans, down from
211 loans at issuance.  To date, the transaction has experienced
losses totaling $50.3 million, or 4.5% of the transaction's
original pool balance.  No loans are currently with the special
servicer.  The master servicers, Berkadia Commercial Mortgage LLC
and NCB FSB, reported seven loans ($2.7 million, 12.1%) on their
combined watchlist.  The largest loan on the master servicers'
combined watchlist is the Timber Ridge Apartments loan
($2.2 million, 9.7%).  The loan is secured by a 136-unit
multifamily apartment complex in Arlington, Texas. The loan is on
the master servicers' watchlist due to a low reported DSC of 0.57x
for year-end 2012.  The reported occupancy was 91.9% for the same
reporting period.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING RAISED

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2000-C1

                  Rating
Class          To          From     Credit enhancement (%)
G              A- (sf)     BBB- (sf)                 73.08

RATING AFFIRMED

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2000-C1

Class          Rating               Credit enhancement (%)
H              B- (sf)                               17.82


CREST 2001-1: Moody's Affirms Ca Rating on $30MM Class C Notes
--------------------------------------------------------------
Moody's has affirmed the rating of one class of Notes issued by
Crest 2001-1, Ltd. The affirmation is due to the key transaction
parameters performing within levels commensurate with the existing
ratings levels. The increased note redemption was offset by a
deterioration in the underlying collateral as evidenced by the
Moody's weighted average rating factor (WARF) and recovery rate
(WARR). The rating action is the result of Moody's on-going
surveillance of commercial real estate collateralized debt
obligation (CRE CDO and Re-Remic) transactions.

Moody's rating action is as follows:

$30,000,000 Class C Third Priority Fixed Rate Term Notes, Due
2034, Affirmed Ca (sf); previously on Sep 28, 2011 Downgraded to
Ca (sf)

Ratings Rationale:

Crest 2001-1, Ltd. is a static cash transaction backed by a
portfolio of commercial mortgage backed securities (CMBS) (100% of
the pool balance). As of the June 25, 2013 Trustee report, the
aggregate Note balance of the transaction, including preferred
shares, was $46.3 million down from $500 million at issuance, with
the paydown directed to the Class C Notes, as a result of
amortization of the underlying collateral and the failing of
certain par value tests.

There are two assets with a par balance of $17.5 million (58.7% of
the current pool balance) that are considered Defaulted Securities
as of the June 25, 2013 Trustee report. Both of these assets are
CMBS. While there have been limited realized losses to date,
Moody's does expect moderate losses to occur once they are
realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 6,155
compared to 3,674 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Aaa-Aa3 (22.4% compared to 18.4% at last
review), A1-A3 (0% the same as at last review), Baa1-Baa3 (15.0%
compared to 35.8% at last review), Ba1-Ba3 (0% compared to 12.2%
at last review), B1-B3 (0% the same as at last review), and Caa1-C
(62.6% compared to 33.7% at last review).

Moody's modeled a WAL of 4.8 years compared to 2.8 years at last
review. The current WAL is based upon assumptions about extensions
on the underlying collateral assets.

Moody's modeled a fixed WARR of 12.1% compared to 23.8% at last
review.

Moody's modeled a MAC of 100% compared to 3.3% at last review. The
increase in MAC is due to higher credit risk collateral
concentrated in a small number of collateral names.

Moody's review incorporated CDOROM v2.8, one of Moody's CDO rating
models, which was released on March 25, 2013.

The cash flow model, CDOEdge v3.2.1.2, which was released on May
16, 2013, was used to analyze the cash flow waterfall and its
effect on the capital structure of the deal.

Moody's analysis encompasses the assessment of stress scenarios.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
12.1% to 2.1% or up to 22.1% would not result in any further
rating movement on the rated tranche.

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 in the 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 continues to exhibit growth albeit at a slightly
slower pace. The multifamily sector should remain stable with
moderate growth. Gradual recovery in the office sector continues
and will be assisted in the next quarter when absorption is likely
to outpace completions. However, since office demand is closely
tied to employment, Moody's expects regional employment growth to
provide market differentiation. CBD markets continue to outperform
secondary suburban markets. The retail sector exhibited a slight
reduction in vacancies in the first quarter; the largest drop
since 2005. However, consumers continue to be cautious as
evidenced by sales growth continuing below historical trends.
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 outlook indicates the global
economy has lost momentum over the past quarter as it tries to
recover. US GDP growth for 2013 is likely to remain close to 2%,
however US sequestration cuts that came into effect in March may
create a drag on the positive growth in the US private sector.
While the broad economic impact is unclear, the direct effect is
likely to shave 0.4% off US GDP growth in 2013. Continuing from
the previous quarter, Moody's believes that the three most
immediate risks are: i) the risk of an even deeper than currently
expected recession in the euro area, accompanied by deeper credit
contraction, potentially triggered by a further intensification of
the sovereign debt crisis; ii) slower-than-expected recovery in
major emerging markets following the recent slowdown; and iii) an
escalation of geopolitical tensions, resulting in adverse economic
developments.

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


DAVIS SQUARE IV: Moody's Cuts Rating on $0.6MM Cl. E Notes to Ba1
-----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of the
following notes issued by Davis Square Funding IV, Ltd.:

$2,000,000 Class E Deferrable Floating Rate Notes Due 2040
(current balance of $612,069), Downgraded to Ba1 (sf); previously
on March 10, 2011 Upgraded to Aa2 (sf).

Ratings Rationale:

According to Moody's, the rating action taken on the notes is
primarily due to the concern that under certain circumstances the
Class E Notes might be exposed to sizable losses if a significant
majority of the underlying collateral is sold or redeemed before
the expected amortization in full of the Class E Notes in May
2015.

Moody's says that it has re-assessed the risk that unscheduled
sales or redemptions of collateral pose to holders of the Class E
Notes. Moody's notes that in consideration of the prior occurrence
of a default in paying interest on the Class E Notes, the
transaction's priority of payments specifies that the Class E
Notes are entitled to receive periodic interest, plus a scheduled
principal repayment of $26,611 on every monthly payment date.
However, absent an event of default, other noteholders have a
senior claim on principal repayment from sales or redemption
proceeds, and no other outstanding principal on the Class E Notes
is paid from such proceeds. In reviewing the potential that
unscheduled sales or redemptions of collateral prior to May 2015
may result in constraining the future availability of cashflow to
amortize the Class E Notes, Moody's concluded that the risk was
more compatible with a speculative grade rating. Davis Square
Funding IV, Ltd., issued in April 2005, is a collateralized debt
obligation backed primarily by a portfolio of RMBS originated from
2004 to 2007.

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

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. The main source
of uncertainty on the rating of Class E notes is the speed of
sales and/or unscheduled principal payment of the underlying
collateral. The deal is also subject to the uncertainty 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 did not use a cash flow model to analyze the default and
recovery properties of the collateral pool. The deal's ratings are
not expected to be sensitive to the typical range of changes (plus
or minus two rating notches on Caa-rated assets) in the rating
quality of the collateral that Moody's tests, and no sensitivity
analysis was performed.


DENALI CAPITAL: S&P Affirms 'B+' Rating on Class B-2L Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1L, A-1LR, A-2L, A-3L, and B-1L notes from Denali Capital CLO VI
Ltd., a U.S. collateralized loan obligation (CLO) managed by
Denali Capital LLC.  Simultaneously, S&P affirmed its rating on
the class B-2L notes.

At the same time, S&P removed all of the ratings from CreditWatch,
where they had been placed with positive implications on May 17,
2013.

The upgrades mainly reflect increased credit support available to
the rated notes as the deal continues to amortize and pay down the
senior notes.  The affirmation reflects sufficient credit support
available to the notes at the current rating level.

The transaction's reinvestment period ended in July 2012.  Since
then, it has paid down approximately $214 million and $77 million
to the class A-1L and class A-1LR notes, respectively.  Following
the paydowns, these notes are currently at approximately 22% of
their original issuance amounts.

The paydown of the notes increased the overcollateralization (O/C)
ratios in the transaction.  The trustee reports the following O/C
ratios in the July 2013 monthly report:

   -- The class A-2L ratio is 139.88%, up from 117.68% in the
      November 2011 trustee report that we used for our December
      2011 analysis.

   -- The class A-3L ratio is 121.90%, compared with 111.08% in
      November 2011.

   -- The class B-1L ratio is 110.64%, compared with 106.36% in
      November 2011.

   -- The class B-2L ratio is 103.59%, compared with 103.13% in
      November 2011.

The transaction also has fewer defaulted obligations than it did
in November 2011.  Based on the July 2013 trustee report, which
S&P referenced for the rating actions, the transaction contained
$5.71 million of defaulted assets, down from the $9.62 million
noted in the November 2011 trustee report, which S&P used for its
last rating action on December 2011.

The affirmation of the class B-2L notes was driven by the
application of the largest obligor default test, one of the two
supplemental tests S&P introduced as part of its revised corporate
CDO criteria published in 2009.

S&P 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 S&P will take rating
actions as it deems necessary.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Denali Capital CLO VI Ltd.
                         Rating
Class              To           From
A-1L               AAA (sf)     AA+ (sf)/Watch Pos
A-1LR              AAA (sf)     AA+ (sf)/Watch Pos
A-2L               AAA (sf)     A+ (sf)/Watch Pos
A-3L               AA+ (sf)     BBB+ (sf)/Watch Pos
B-1L               BBB+ (sf)    BBB- (sf)/Watch Pos
B-2L               B+ (sf)      B+ (sf)/Watch Pos

TRANSACTION INFORMATION
Issuer:              Denali Capital CLO VI Ltd.
Co-issuer:           Denali Capital CLO VI Ltd. (Delaware) LLC
Collateral manager:  Denali Capital LLC
Trustee:             The Bank of New York Mellon
Transaction type:    Cash flow CDO


DEUTSCHE BANK 2011-LC3: Fitch Affirms 'B' Rating on Class F Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed 17 classes of Deutsche Bank Securities
(DBUBS) commercial mortgage pass-through certificates series 2011-
LC3.

Key Rating Drivers

The rating affirmations are based on the stable performance of the
underlying collateral. Expected losses are in-line with issuance.
The transaction is highly concentrated with the top five and 10
largest loans accounting for 44% and 61%, respectively.
Additionally, the transaction has a large hotel concentration of
22.5% with the second and fourth largest loans being secured by
hotels.

The pool has experienced no delinquencies, nor have any loans been
specially serviced since issuance. Fitch has flagged one Loan of
Concern (7.2%).

As of the July 2013 distribution date, the pool's aggregate
principal balance has been reduced by 3.1% to $1.6 billion from
$1.65 billion at issuance. No loans are defeased. Interest
shortfalls are currently affecting class G.

The Fitch Loan of Concern (7.2%) is secured by a portfolio of
eight full-service hotels located across eight states consisting
of 2.342 rooms. The portfolio includes six Marriott hotels, one
Doubletree, and one Hilton. As of December 2012 the portfolio was
60% occupied with revenue per available room (RevPAR) of $89
compared to 59% and $83.11 for the prior year. The portfolio is on
the master servicer's watchlist due to borrower notification that
the Hilton Boston Woburn sustained damage due to Hurricane Irene.
Per the master servicer, as of February 2013, the restoration is
approximately 90% complete. The year end (YE) 2012 debt service
coverage ratio declined to 4.97x compared to 5.90x YE 2011 but
remains above that at issuance.

Rating Sensitivity

Rating Outlooks on classes A-1 through P-M5 remain Stable due to
sufficient credit enhancement and continued paydown and overall
stable pool performance. Initial Key Rating Drivers and Rating
Sensitivity are further described in the New Issue report
published on Sept. 8, 2011.

Fitch affirms the following classes:

-- $52.4 million class A-1 at 'AAAsf'; Outlook Stable;
-- $671.8 million class A-2 at 'AAAsf'; Outlook Stable;
-- $97.3 million class A-3 at 'AAAsf'; Outlook Stable;
-- $112.1 million class A-4 at 'AAAsf'; Outlook Stable;
-- $127.6 million class A-M at 'AAAsf'; Outlook Stable;
-- Interest-only Class X-A at 'AAAsf'; Outlook Stable;
-- $75.2 million class B at 'AAsf'; Outlook Stable;
-- $54.2 million class C at 'Asf'; Outlook Stable;
-- $73.4 million class D at 'BBB-sf'; Outlook Stable;
-- $19.2 million class E at 'BBsf'; Outlook Stable;
-- $19.2 million class F at 'Bsf'; Outlook Stable;
-- $134.7 million class PM-1 at 'AAAsf'; Outlook Stable;
-- Interest-only class PM-X at 'AAAsf'; Outlook Stable;
-- $32.9 million class PM-2 at 'AAsf'; Outlook Stable;
-- $28.9 million class PM-3 at 'Asf'; Outlook Stable;
-- $26.5 million class PM-4 at 'BBBsf'; Outlook Stable;
-- $20.9 million class PM-5 at 'BBB-sf'; Outlook Stable.

Fitch does not rate the interest-only class X-B or the class G
certificates.


FOUNDERS GROVE: Moody's Affirms 'Ba2' Rating on $27MM Cl. D Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Founders Grove CLO, Ltd.:

$6,600,000 Class C Deferrable Floating Rate Notes Due April 25,
2018, Upgraded to Aaa (sf); previously on July 15, 2013 Upgraded
to Aa1 (sf) and Placed Under Review for Possible Upgrade.

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

$50,000,000 Class A-1 Floating Rate Notes Due April 25, 2018
(current outstanding balance of $6,999,785.05), Affirmed Aaa (sf);
previously on September 15, 2011 Upgraded to Aaa (sf);

$170,500,000 Class A-2 Floating Rate Notes Due April 25, 2018
(current outstanding balance of $23,869,267), Affirmed Aaa (sf);
previously on September 15, 2011 Upgraded to Aaa (sf);

$20,100,000 Class B Floating Rate Notes Due April 25, 2018,
Affirmed Aaa (sf); previously on July 15, 2013 Upgraded to Aaa
(sf);

$27,300,000 Class D Floating Rate Notes Due April 25, 2018
(current outstanding balance of $25,122,733.17), Affirmed Ba2
(sf); previously on September 15, 2011 Upgraded to Ba2 (sf).

Ratings Rationale:

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the senior notes and an
increase in the transaction's overcollateralization ratios since
the rating action in January 2013. Moody's notes that the Class A
Notes have been paid down by approximately 43.9% or $44.4 million
since January 2013. Based on the latest trustee report dated July
15, 2013, the Class A/B, C and D overcollateralization ratios are
reported at 145.96%,135.07% and 105.19%, respectively, versus
January 2013 levels of 128.91% 122.69% and 103.66%, respectively.

Moody's also announced that it has concluded its review of its
ratings on the issuer's Class C Notes announced on July 15, 2013.
At that time, Moody's said that it had upgraded and placed certain
of the issuer's ratings on review primarily as a result of
substantial deleveraging of the senior notes and increases in OC
ratios resulting from high rates of loan collateral prepayments
during the first half of 2013.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, diversity
score, and weighted average recovery rate, are based on its
published methodology and 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 $82.4 million, defaulted par of $7.9 million,
a weighted average default probability of 17.65% (implying a WARF
of 2784), a weighted average recovery rate upon default of 53.12%,
and a diversity score of 33. 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.

Founders Grove CLO, Ltd, issued in April 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2013.

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 Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2013

In addition to the base case analysis, 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% (2227)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C: 0

Class D: +1

Moody's Adjusted WARF + 20% (3341)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C: 0

Class D: 0

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

Sources of additional performance uncertainties:

1) Deleveraging: A 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 resulted from Amendment and Extend to loan agreements.


GANNETT PEAK: S&P Affirms 'B+' Rating on 2 Note Classes
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1a, A-1b, A-2, B-1, B-2, and C notes from Gannett Peak CLO I
Ltd., a U.S. collateralized loan obligation (CLO) transaction
managed by THL Credit Senior Loan Strategies LLC.  At the same
time, S&P affirmed its ratings on the D-1 and D-2 notes.  S&P
removed all of the ratings on the notes from CreditWatch, where it
placed them with positive implications on July 9, 2013.

The upgrades primarily reflect paydowns to the class A-1
noteholders.  Since S&P's latest rating action in July 2012, the
A-1 notes have paid down a total of $256.24 million and are
currently about 40% of their original notional balance.

There have also been some improvements in the performance of the
transaction's underlying asset portfolio since July 2012.  As of
the July 2013 trustee report, the transaction had $0.94 million of
defaulted assets.  This was down from the $8.86 million noted in
the June 2012 report, which S&P referenced for its July 2012
rating action.  Furthermore, the amount of assets from obligors
rated in the 'CCC' category was reported at $30.13 million in July
2013, down from $45.65 million in July 2012.

S&P notes that the transaction has significant exposure to two
obligors that are at risk of restructuring in the near future.
One of the two obligors is the pool's second-largest obligor and
constitutes 3.53% of the transaction's total performing par.  The
other obligor is the 12th-largest and constitutes about 1.58%.

The upgrades also reflect an increase in the overcollateralization
(O/C) available to support the notes since the July 2012 rating
action.  The trustee reported a senior O/C of 137.02% at the A-2
level, higher than the 125.26% noted in the June 2012 report.  The
most subordinate O/C was 105.84% at the D-2 level, higher than the
104.67% at the time of the latest rating action.

Based on S&P's review of the cash flow and the supplemental test
results, it affirmed its ratings on the class D-1 and D-2 notes to
reflect the availability of sufficient credit support at the
current ratings.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

Gannett Peak CLO I Ltd.
                   Rating
Class         To           From
A-1a           AAA (sf)     AA+ (sf)/Watch Pos
A-1b          AAA (sf)     AA+ (sf)/Watch Pos
A-2           AAA (sf)     AA (sf)/Watch Pos
B-1           AA (sf)      A (sf)/Watch Pos
B-2           AA (sf)      A (sf)/Watch Pos
C             BBB+ (sf)    BB+ (sf)/Watch Pos
D-1           B+ (sf)      B+ (sf)/Watch Pos
D-2           B+ (sf)      B+ (sf)/Watch Pos

TRANSACTION INFORMATION
Issuer:             Gannett Peak CLO I Ltd.
Coissuer:           Gannett Peak CLO I Corp.
Collateral manager: THL Credit Senior Loan Strategies LLC
Underwriter:        Deutsche Bank Securities Inc.
Trustee:            The Bank of New York Mellon
Transaction type:   Cash flow CDO


GS MORTGAGE 1999-C1: S&P Affirms 'CCC-' Rating on G Certificates
----------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its 'CCC- (sf)' rating
on the class G commercial mortgage pass-through certificates from
GS Mortgage Securities Corp. II's series 1999-C1, a U.S.
commercial mortgage-backed securities (CMBS) transaction.

The affirmation follows S&P's 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 and
performance of all of the pool's remaining loans, the transaction
structure, and the trust's available liquidity.

The affirmation of S&P's 'CCC- (sf)' rating on the class G
principal and interest certificates reflects our expectation that
this class's available credit enhancement will be within S&P's
estimates for what is necessary for the current outstanding
rating.  The affirmation also reflects the transaction-level
changes.

While available credit enhancement levels may suggest positive
rating movement on class G, S&P's analysis also considered the
historical interest shortfalls the class has experienced as well
as the class's limited available liquidity support.

As of the July 18, 2013, trustee remittance report, the collateral
pool consisted of 22 loans with an aggregate pooled trust balance
of $20.7 million, down from $890.6 million at issuance.  Using
servicer-provided financial information, S&P calculated a Standard
& Poor's adjusted debt service coverage (DSC) of 1.22x and a
Standard & Poor's loan-to-value (LTV) ratio of 56.2% for 20 of the
pool's 22 remaining loans.  The DSC and LTV calculations exclude
one defeased loan ($0.6 million, 3.0%) and one hope note
($1.5 million, 7.3%).  To date, the transaction has experienced
losses totaling $33.9 million, or 3.8% of the transaction's
original pooled certificate balance.

The master servicer, Berkadia Commercial Mortgage LLC (Berkadia),
provided financial information for 97.0% of the nondefeased loans
in the pool, of which 2.9% was full-year 2011 and the remainder
was full-year 2012 data.  Nine loans ($6.1 million, 29.5%) in the
pool are on the master servicer's watchlist.  Details of the three
largest loans on the master servicer's watchlist are as follows:

   -- The Sahara View Apartments loan ($1.5 million, 7.5%), the
      second-largest nondefeased loan in the pool, is the largest
      loan on the master servicer's watchlist.  The loan is
      secured by an 81-unit multifamily property in Las Vegas.
      The loan is on the master servicer's watchlist because of a
      low reported DSC of 1.02x as of year-end 2012.  The reported
      occupancy was 83.8% for the same reporting period.

   -- The Days Inn-Stone Mountain loan ($1.1 million, 5.6%) is the
      second-largest loan on the master servicer's watchlist.  The
      loan is secured by an 81-room, limited service lodging
      property in Stone Mountain, Ga.  The loan appears on the
      watchlist because of a low reported DSC of 0.50x for year-
      end 2012.  The reported occupancy and average daily rate
      were 50.5% and $49.96, respectively, for the six months
      ended June 30, 2012.

   -- The Pinehill Plaza & Apartments loan ($0.9 million, 4.4%) is
      the third-largest loan on the master servicer's watchlist.
      The loan is secured by a 43-unit multifamily property in
      Pembroke Pines, Fla.  The loan appears on the watchlist
      because of a low reported DSC of 0.85x as of year-end 2012.
      The reported occupancy was 88.0% for the same reporting
      period.

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com


GS MORTGAGE 2011-GC3: Moody's Keeps Ratings over Rights Transfer
----------------------------------------------------------------
Moody's Investors Service was informed that Rialto Real Estate
Fund, LP, as the Controlling Class Representative, has elected to
terminate Midland Loan Services as the existing Special Servicer
(except with respect to the Stanley Hotel Whole Loan) and to
appoint Rialto Capital Advisors, LLC (Rialto) as the successor
Special Servicer (except with respect to the Stanley Hotel Whole
Loan). The Proposed Special Servicer Transfer and Replacement will
become effective upon satisfaction of the conditions precedent set
forth in the governing documents.

Moody's has reviewed the Proposed Special Servicer Replacement.
Moody's has determined that this proposed special servicing
replacement will not, in and of itself, and at this time, result
in a downgrade or withdrawal of the current ratings to any class
of certificates rated by Moody's for GS Mortgage Securities
Corporation II, Commercial Mortgage Pass-Through Certificates,
Series 2011-GC3 (the Certificates). Moody's opinion only addresses
the credit impact associated with the proposed designation and
transfer of special servicing rights. Moody's is not expressing
any opinion as to whether this change has, or could have, other
non-credit related effects that may have a detrimental impact on
the interests of note holders and/or counterparties.

The last rating action for GSMS 2011-GC3 was taken on March 20,
2013. The principal methodology used in this rating was "Moody's
Approach to Rating Fusion U.S. CMBS Transactions" published in
April 2005.

On March 20, 2013, Moody's affirmed the ratings of ten classes of
GS Mortgage Securities Trust 2011-GC3 Commercial Mortgage Pass-
Through Certificates Series 2011-GC3 as follows:

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

Cl. A-2, Affirmed Aaa (sf); previously on Apr 1, 2011 Definitive
Rating Assigned Aaa (sf)

Cl. A-3, Affirmed Aaa (sf); previously on Apr 1, 2011 Definitive
Rating Assigned Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on Apr 1, 2011 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Apr 1, 2011 Definitive
Rating Assigned Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on Apr 1, 2011 Definitive
Rating Assigned A3 (sf)

Cl. D, Affirmed Baa3 (sf); previously on Apr 1, 2011 Definitive
Rating Assigned Baa3 (sf)

Cl. E, Affirmed Ba2 (sf); previously on Apr 1, 2011 Definitive
Rating Assigned Ba2 (sf)

Cl. F, Affirmed B2 (sf); previously on Apr 1, 2011 Definitive
Rating Assigned B2 (sf)

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


GS MORTGAGE 2012-GC6: Moody's Keeps Ratings After Rights Transfer
-----------------------------------------------------------------
Moody's Investors Service was informed that Rialto Real Estate
Fund, LP, as the Controlling Class Representative, has elected to
terminate CWCapital Asset Management (CWCAM) as the existing
Special Servicer and to appoint Rialto Capital Advisors, LLC
(Rialto) as the successor Special Servicer. The Proposed Special
Servicer Transfer and Replacement will become effective upon
satisfaction of the conditions precedent set forth in the
governing documents.

Moody's has reviewed the Proposed Special Servicer Replacement.
Moody's has determined that this proposed special servicing
replacement will not, in and of itself, and at this time, result
in a downgrade or withdrawal of the current ratings to any class
of certificates rated by Moody's for GS Mortgage Securities
Corporation II, Commercial Mortgage Pass-Through Certificates,
Series 2012-GC6 (the Certificates). Moody's opinion only addresses
the credit impact associated with the proposed designation and
transfer of special servicing rights. Moody's is not expressing
any opinion as to whether this change has, or could have, other
non-credit related effects that may have a detrimental impact on
the interests of note holders and/or counterparties.

The last rating action for GSMS 2012-GC6 was taken on February 7,
2013. The principal methodology used in this rating was "Moody's
Approach to Rating Fusion U.S. CMBS Transactions" published in
April 2005.

On February 7, 2013, Moody's 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)


ICONS LTD: A.M. Best Cuts Rating on 3 Debt Classes to 'bb'
----------------------------------------------------------
A.M. Best Co. has downgraded the debt ratings on three tranches
and affirmed the debt ratings on three additional tranches on a
multi-tranche collateralized debt obligation (CDO) co-issued by
two bankruptcy remote special purpose vehicles: ICONS, Ltd.
(Cayman Islands) and ICONS CDO Corp. (Delaware) (collectively
known as ICONS and issuers).  The outlook for all ratings is
stable.  (See below for a detailed listing of the debt ratings.)

The principal balance of the rated notes are collateralized by a
pool of trust preferred securities, surplus notes and secondary
market securities (collectively, the capital securities),
primarily issued by small to medium-sized insurance companies.
The capital securities are pledged as security to the notes.
Interest paid by the issuers of the capital securities are the
primary source of funds to pay operating expenses of the issuers
and interest on the notes.  Repayment of the principal for the
notes is primarily funded from the redemption of the capital
securities.

These rating actions primarily reflect: (1) the current issuer
credit ratings (ICR) of the remaining issuers of the capital
securities and the number of terminated capital securities; (2) a
stress of up to 250% on the assumed marginal default rates of
insurers (derived from Best's Idealized Default Rates of
Insurers); (3) the amount of capital securities considered to be
in distress; (4) recoveries of 0% after defaults of the capital
securities; and (5) qualitative factors such as the effect of
interest rate spikes; subordination level associated with each
rated tranche; the adjacency of very high investment grade ratings
to very low non-investment grade ratings in the transaction's
capital structure; and the possibility that additional redemptions
of highly-rated entities will leave lower-rated companies in the
collateral pool.

The debt ratings could be upgraded or downgraded and/or the
outlook revised if there are material changes in the ICRs of the
remaining insurance carriers, an increase in the number of
defaulted capital securities or significant termination of the
number of existing capital securities.

The following debt ratings have been downgraded:

ICONS, Ltd. and ICONS CDO Corp.

  * "bb" from "bbb-" on $8 million Class C-1 Deferrable Mezzanine
     Notes Due 2034

  * "bb" from "bbb-" on $20 million Class C-2 Deferrable Mezzanine
     Notes Due 2034

  * "bb" from "bbb-" on $6 million Class C-3 Deferrable Mezzanine
     Notes Due 2034

The following debt ratings have been affirmed:

ICONS, Ltd. and ICONS CDO Corp.

-- "aaa" on $172 million Class A Senior Notes Due 2034
-- "aa" on $40 million Class B Senior Notes Due 2034
-- "b+" on $20 million Class D Deferrable Mezzanine Notes Due
2034

These are structured finance ratings.


IMPAC CMB: Moody's Takes Action on $6.6BB of Alt-A RMBS
-------------------------------------------------------
Moody's Investors Service upgraded the ratings of two tranches and
confirmed the ratings of 29 tranches backed by Alt-A RMBS loans,
issued by 6 Impac CMB Trust RMBS transactions

Complete rating actions are as follows:

Issuer: Impac CMB Trust Series 2003-11

Cl. 1-A-1, Confirmed at A3 (sf); previously on May 14, 2013 A3
(sf) Placed Under Review Direction Uncertain

Cl. 1-A-2, Confirmed at Baa2 (sf); previously on May 14, 2013 Baa2
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-1, Confirmed at Baa3 (sf); previously on May 14, 2013 Baa3
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-2, Confirmed at Ba3 (sf); previously on May 14, 2013 Ba3
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-3, Confirmed at B2 (sf); previously on May 14, 2013 B2
(sf) Placed Under Review Direction Uncertain

Issuer: Impac CMB Trust Series 2003-8

Cl. 1-A-1, Confirmed at Aa2 (sf); previously on May 14, 2013 Aa2
(sf) Placed Under Review Direction Uncertain

Cl. 1-A-2, Confirmed at A1 (sf); previously on May 14, 2013 A1
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-1, Confirmed at Baa1 (sf); previously on May 14, 2013 Baa1
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-2, Confirmed at Baa2 (sf); previously on May 14, 2013 Baa2
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-3, Confirmed at Baa2 (sf); previously on May 14, 2013 Baa2
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-4, Confirmed at Baa3 (sf); previously on May 14, 2013 Baa3
(sf) Placed Under Review Direction Uncertain

Issuer: Impac CMB Trust Series 2004-10

Cl. 1-A-1, Confirmed at B2 (sf); previously on May 14, 2013 B2
(sf) Placed Under Review Direction Uncertain

Underlying Rating: Confirmed at B2 (sf); previously on May 14,
2013 B2 (sf) Placed Under Review Direction Uncertain

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Cl. 1-A-2, Confirmed at Caa3 (sf); previously on May 14, 2013 Caa3
(sf) Placed Under Review Direction Uncertain

Underlying Rating: Confirmed at Caa3 (sf); previously on May 14,
2013 Caa3 (sf) Placed Under Review Direction Uncertain

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Cl. 2-A, Confirmed at Caa2 (sf); previously on May 14, 2013 Caa2
(sf) Placed Under Review Direction Uncertain

Underlying Rating: Confirmed at Caa2 (sf); previously on May 14,
2013 Caa2 (sf) Placed Under Review Direction Uncertain

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Cl. 3-A-1, Confirmed at Ba1 (sf); previously on May 14, 2013 Ba1
(sf) Placed Under Review Direction Uncertain

Cl. 3-A-2, Confirmed at B1 (sf); previously on May 14, 2013 B1
(sf) Placed Under Review Direction Uncertain

Cl. 3-M-1, Confirmed at Caa2 (sf); previously on May 14, 2013 Caa2
(sf) Placed Under Review Direction Uncertain

Issuer: Impac CMB Trust Series 2004-11 Collateralized Asset-Backed
Bonds, Series 2004-11

Cl. 1-A-1, Confirmed at Caa3 (sf); previously on May 14, 2013 Caa3
(sf) Placed Under Review Direction Uncertain

Underlying Rating: Confirmed at Caa3 (sf); previously on May 14,
2013 Caa3 (sf) Placed Under Review Direction Uncertain

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Cl. 1-A-2, Confirmed at Caa3 (sf); previously on May 14, 2013 Caa3
(sf) Placed Under Review Direction Uncertain

Underlying Rating: Confirmed at Caa3 (sf); previously on May 14,
2013 Caa3 (sf) Placed Under Review Direction Uncertain

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Cl. 2-A-1, Confirmed at Caa2 (sf); previously on May 14, 2013 Caa2
(sf) Placed Under Review Direction Uncertain

Issuer: Impac CMB Trust Series 2004-5 Collateralized Asset-Backed
Bonds, Series 2004-5

Cl. 1-A-1, Confirmed at Baa2 (sf); previously on May 14, 2013 Baa2
(sf) Placed Under Review Direction Uncertain

Cl. 1-A-2, Confirmed at A3 (sf); previously on May 14, 2013 A3
(sf) Placed Under Review Direction Uncertain

Cl. 1-A-3, Confirmed at Baa3 (sf); previously on May 14, 2013 Baa3
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-1, Confirmed at Ba2 (sf); previously on May 14, 2013 Ba2
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-2, Confirmed at B1 (sf); previously on May 14, 2013 B1
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-3, Confirmed at B2 (sf); previously on May 14, 2013 B2
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-4, Confirmed at Caa1 (sf); previously on May 14, 2013 Caa1
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-5, Upgraded to Caa2 (sf); previously on May 14, 2013 Caa3
(sf) Placed Under Review Direction Uncertain

Cl. 1-M-6, Upgraded to Ca (sf); previously on Jul 12, 2012
Confirmed at C (sf)

Issuer: Impac CMB Trust Series 2005-3 Collateralized Asset-Backed
Bonds, Series 2005-3

Cl. A-1, Confirmed at Caa1 (sf); previously on May 14, 2013 Caa1
(sf) Placed Under Review Direction Uncertain

Cl. A-3, Confirmed at Caa2 (sf); previously on May 14, 2013 Caa2
(sf) Placed Under Review Direction Uncertain

Underlying Rating: Confirmed at Caa2 (sf); previously on May 14,
2013 Caa2 (sf) Placed Under Review Direction Uncertain

Financial Guarantor: Financial Guaranty Insurance Company (Insured
Rating Withdrawn Mar 25, 2009)

Ratings Rationale:

These actions reflect recent performance of the underlying pools
and Moody's updated loss expectations on the pools. These rating
actions consist of 29 confirmations, and two upgrades. The
upgrades are due to an increase in the credit enhancement
available to the bonds.

The actions also reflect the correction of an error in the
Structured Finance Workstation (SFW) cash flow models used by
Moody's in rating these transactions, specifically in how the
models handle principal and interest allocation. The cash flow
models used in the past rating actions had incorrectly used
separate interest and principal waterfalls. However, the pooling
and servicing agreements for these transactions provide that all
collected principal and interest is commingled into one payment
waterfall to pay all promised interest due on bonds first, then to
pay scheduled principal. Due to the discovery of this error,
thirty of the tranches in these rating actions were placed on
review on May 14, 2013. The errors have been corrected, and these
rating actions take into account the correct interest and
principal waterfall.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in June 2013.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
8.2% in July 2012 to 7.4% in July 2013. Moody's forecasts an
unemployment central range of 7.0% to 8.0% for the 2013 year.
Moody's expects house prices to continue to rise in 2013.
Performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


JP MORGAN 2003-LN1: Moody's Affirms C Ratings on 2 Cert Classes
---------------------------------------------------------------
Moody's Investors Service upgraded the ratings of five classes and
affirmed nine CMBS classes of J.P. Morgan Chase Commercial
Mortgage Securities Corp. Commercial Mortgage Pass-Through
Certificates, Series 2003-LN1 as follows:

Cl. A-1A, Affirmed Aaa (sf); previously on Oct 9, 2003 Definitive
Rating Assigned Aaa (sf)

Cl. A-2, Affirmed Aaa (sf); previously on Oct 9, 2003 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aaa (sf); previously on Jul 9, 2007 Upgraded to
Aaa (sf)

Cl. C, Affirmed Aaa (sf); previously on Jul 26, 2007 Upgraded to
Aaa (sf)

Cl. D, Upgraded to Aaa (sf); previously on Jul 26, 2007 Upgraded
to Aa3 (sf)

Cl. E, Upgraded to Aa1 (sf); previously on Jul 26, 2007 Upgraded
to A2 (sf)

Cl. F, Upgraded to A2 (sf); previously on Aug 9, 2012 Downgraded
to Baa3 (sf)

Cl. G, Upgraded to Baa1 (sf); previously on Aug 9, 2012 Downgraded
to Ba2 (sf)

Cl. H, Upgraded to B1 (sf); previously on Aug 9, 2012 Downgraded
to B3 (sf)

Cl. J, Affirmed Caa2 (sf); previously on Aug 9, 2012 Downgraded to
Caa2 (sf)

Cl. K, Affirmed Ca (sf); previously on Aug 9, 2012 Downgraded to
Ca (sf)

Cl. L, Affirmed C (sf); previously on Aug 9, 2012 Downgraded to C
(sf)

Cl. M, Affirmed C (sf); previously on Sep 22, 2011 Downgraded to C
(sf)

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

Ratings Rationale:

The upgrades are due primarily to increased credit support from
paydown and amortization, plus the expectation of future paydown
from high-quality loans which are scheduled to mature in the
coming months. Over 70% of the current loan balance is due to
mature before year-end 2013. Of the loans with upcoming
maturities, the majority have debt yields, DSCRs and LTVs which
meet or exceed levels typically required for financing in the
current marketplace. Additionally, nearly one-third of the
maturing loan balance is represented by defeased loans.

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

The affirmations of the below-investment grade classes are due to
Moody's expected loss remaining within a range commensurate with
the in-place 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.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for rated 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 rating action reflects a base expected loss of
approximately 6.0% of the current deal balance. At last review,
Moody's base expected loss was approximately 4.6%. Moody's base
expected loss plus realized losses represents 4.6% of the original
securitized deal balance compared to 5.7% at Moody's last review.

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.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. CMBS Conduit Transactions" published in
September 2000.

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 (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade underlying ratings is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 30 compared to a Herf of 49 at Moody's prior
review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST (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.

Deal Performance:

As of the July 15, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 70% to $372 million
from $1.26 billion at securitization. The Certificates are
collateralized by 71 mortgage loans ranging in size from less than
1% to 8% of the pool, with the top ten loans (excluding
defeasance) representing 30% of the pool. The pool contains no
loans with investment-grade credit assessments. Twelve loans,
representing approximately 25% of the pool, are defeased and are
collateralized by U.S. Government securities.

Forty-eight loans, representing 55% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of its
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Seven loans have liquidated from the pool, contributing to an
aggregate realized loss to the trust of $33 million. Loans that
were liquidated from the pool averaged a 58% loss severity. As of
the last reporting date, two loans, representing 3% of the pool,
are in special servicing. Since the last reporting date, an
additional loan, the Senate Plaza Loan ($11 million -- 3% of the
pool) was transferred to the special servicer for maturity
default. Inclusive of the Senate Plaza Loan, Moody's estimates an
aggregate $12 million loss (52% expected loss) for all specially
serviced loans.

Moody's has assumed a high default probability for four poorly-
performing loans representing 10% of the pool. Moody's analysis
attributes to these troubled loans an aggregate $6 million loss
(16% expected loss severity based on a 50% probability default).

Moody's was provided with full-year 2011 operating results for 96%
of the performing pool. Excluding troubled and specially serviced
loans, Moody's weighted average LTV is 80%, the same as at Moody's
last review. Moody's net cash flow reflects a weighted average
haircut of 11.3% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.4%.

Excluding troubled and specially serviced loans, Moody's actual
and stressed DSCRs are 1.48X and 1.38X, respectively, compared to
1.56X and 1.42X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three performing conduit loans represent 18% of the pool.
The largest loan is the Sheraton Inner Harbor Hotel Loan ($28
million -- 8% of the pool), which is secured by a 337-unit full-
service hotel in downtown Baltimore, Maryland. Property financial
performance has been stable since Moody's last review. The loan
had a scheduled maturity date of October 15, 2013. Moody's current
LTV and stressed DSCR are 112% and 1.06X, respectively, compared
to 113% and 1.06X at last review.

The second largest loan is the Chasewood Office Portfolio Loan
($21 million -- 6% of the pool). The loan is secured by two
suburban office buildings located in the FM 1960 area of northwest
Houston, Texas. The property was 65% leased as of year-end 2012
compared to 70% at Moody's last review and 93% at securitization.
Property performance has suffered since 2011 when a tenant
occupying approximately 25% of the net rentable area vacated. The
space has since been only partially backfilled with new tenants.
Since Moody's last review, the largest tenant, CDM Resources
Management, renewed its lease through June 2020. CDM's prior lease
expired in August 2012. Despite this positive development, Moody's
continues to view this as a troubled loan due to ongoing high
vacancy at the property and high vacancy in the larger FM 1960
submarket. Moody's current LTV and stressed DSCR are 140% and
0.75X, respectively, compared to 135% and 0.79X at last review.

The third largest loan is the Piilani Shopping Center Loan ($17
million -- 5% of the pool). The loan is secured by a 66,000
square-foot retail center in Kihei, Hawaii. Property performance
has improved markedly since securitization. The retail center was
100% leased as of March 2013 compared to 94% at securitization.
Moody's current LTV and stressed DSCR are 59% and 1.61X,
respectively, compared to 71% and 1.33X at last review.


JP MORGAN 2005-A8: Moody's Cuts Ratings on 5 Prime Jumbo RMBS
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of six
tranches and upgraded the rating of one tranche from two RMBS
transactions issued by J.P. Morgan. The actions impact
approximately $111 million of RMBS issued from 2005.

Complete rating actions are as follows:

Issuer: J.P. Morgan Mortgage Trust 2005-A7

Cl. 2-A-2, Upgraded to B1 (sf); previously on Apr 6, 2010
Downgraded to B3 (sf)

Cl. 3-A-1, Downgraded to Caa1 (sf); previously on Apr 6, 2010
Downgraded to B2 (sf)

Issuer: J.P. Morgan Mortgage Trust 2005-A8

Cl. 1-A-3, Downgraded to Caa1 (sf); previously on Aug 29, 2012
Downgraded to B2 (sf)

Cl. 1-A-4, Downgraded to C (sf); previously on Apr 6, 2010
Downgraded to Ca (sf)

Cl. 2-A-6, Downgraded to Caa1 (sf); previously on Aug 29, 2012
Downgraded to B3 (sf)

Cl. 3-A-2, Downgraded to Caa1 (sf); previously on Aug 29, 2012
Downgraded to B3 (sf)

Cl. 6-A-2, Downgraded to Caa1 (sf); previously on Aug 29, 2012
Downgraded to B1 (sf)

Ratings Rationale:

The actions are a result of the recent performance of the
underlying pools and reflects Moody's updated loss expectations on
the pools. The downgrade rating actions reflect deterioration of
collateral performance. The upgrade rating action is a result of
faster pay-down of the bond due to high prepayments/fast
liquidations.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in June 2013.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
8.2% in July 2012 to 7.4% in July 2013. Moody's forecasts an
unemployment central range of 7.0% to 8.0% for the 2013 year.
Moody's expects house prices to continue to rise in 2013.
Performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


JP MORGAN 2005-LDP5: Fitch Affirms 'C' Ratings on 4 Certificates
----------------------------------------------------------------
Fitch Ratings has downgraded seven classes and affirmed 15 classes
of J.P. Morgan Chase Commercial Mortgage Series Corp. commercial
mortgage pass-through certificates series 2005-LDP5.

Key Rating Drivers

The downgrades are a result of further cash flow deterioration to
the underlying collateral of the pool. The affirmations are due to
sufficient credit enhancement relative to modeled losses.

Fitch modeled losses of 8.5% of the remaining pool; expected
losses on the original pool balance total 7%, including $22.9
million (0.5% of the original pool balance) in realized losses to
date. Fitch has designated 30 loans (21%) as Fitch Loans of
Concern, which includes nine specially serviced assets (10.4%).

As of the July 2013 distribution date, the pool's aggregate
principal balance has been reduced by 21.6% to $3.39 billion from
$4.33 billion at issuance. Per the servicer reporting, four loans
(1.1% of the pool) are defeased. Interest shortfalls are currently
affecting classes K through NR.

The largest contributor to expected losses is the specially-
serviced real estate owned (REO) property (2.5% of the pool),
which is secured by a 706,005 square foot (sf) mall located in
Hanover, MA. The loan transferred to special servicing in November
2009 due to imminent default and foreclosure of the property
occurred in February 2010. The special servicer reported occupancy
of in-line space was 86.9%, of which 76% were permanent tenants,
as of April 31, 2013. The property has not yet been listed for
sale.

The next largest contributor to expected losses is a specially-
serviced loan (2.9%), which is secured by a 526,245 sf office
complex located in Irving, TX. The loan transferred to the special
servicer in March 2012 due to a covenant default after failing to
fund reserves. The property is 100% leased to NEC America, Inc.,
however they subleased approximately 50% of their space to several
other small tenants. The special servicer reports the debt service
coverage ratio (DSCR) was 1.51 times (x) as of year-end 2012.

The third largest contributor to expected losses is the Atlantic
Development Portfolio loan (2.5%), which is secured by five office
complexes and two industrial properties located in Somerset and
Warren, NJ. The properties have suffered from poor performance
over the last several years with rents below market. The servicer
reported occupancy and DSCR was 73.8% and 0.81x as of year-end
2012. One of the buildings remains vacant.

Rating Sensitivity

Rating Outlooks on classes A-2 through A-M remain Stable due to
increasing credit enhancement and continued paydown. Classes B
through F also remain Stable due to stronger credit enhancement
relative to their ratings. The Rating Outlooks on classes A-J and
G are Negative, as future downgrades may be possible should
realized losses be greater than expected, particularly associated
with the first and third largest contributors to losses. Loss
expectations may increase on the REO property in Hanover, MA, if
additional tenants leave at their lease expirations.

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

-- $26.2 million class B to 'Asf' from 'AAsf', Outlook Stable;
-- $73.4 million class C to 'BBBsf' from 'Asf', Outlook Stable;
-- $42 million class D to 'BBB-sf' from 'Asf', Outlook Stable;
-- $21 million class E to 'BBsf' from 'BBBsf', Outlook Stable;
-- $52.5 million class F to 'Bsf' from 'BBsf', Outlook Stable;
-- $36.7 million class G to 'B-sf' from 'BBsf', Outlook Negative;
-- $63 million class K to 'CCsf' from 'CCCsf', RE 0%.

Fitch affirms the following classes, revises Outlooks and revises
REs as indicated:

-- $139.3 million class A-2 at 'AAAsf', Outlook Stable;
-- $171.5 million class A-3 at 'AAAsf', Outlook Stable;
-- $1.4 billion class A-4 at 'AAAsf', Outlook Stable;
-- $59.3 million class A-SB at 'AAAsf', Outlook Stable;
-- $261.6 million class A-1A at 'AAAsf', Outlook Stable;
-- $419.7 million class A-M at 'AAAsf', Outlook Stable;
-- $299 million class A-J at 'AAsf', Outlook to Negative from
     Stable;
-- $52.5 million class H at 'CCCsf', RE 5%.
-- $42 million class J at 'CCCsf', RE 0%;
-- $26.2 million class L at 'CCsf', RE 0%;
-- $15.7 million class M at 'CCsf', RE 0%;
-- $15.7 million class N at 'Csf', RE 0%;
-- $5.2 million class O at 'Csf', RE 0%;
-- $5.2 million class P at 'Csf', RE 0%;
-- $10.5 million class Q at 'Csf', RE 0%.

The class A-1 and A-2FL certificates have paid in full. Fitch does
not rate the class NR, HG-1, HG-2, HG-3, HG-4 and HG-5
certificates. Fitch previously withdrew the ratings on the
interest-only class X-1 and X-2 certificates.


JP MORGAN 2007-CIBC20: S&P Lowers Rating on Class H Notes to CCC-
-----------------------------------------------------------------
Standard & Poor's Ratings Services raised its rating on the class
A-SB commercial mortgage pass-through certificates from JPMorgan
Chase Commercial Mortgage Securities Trust 2007-CIBC20, a U.S.
commercial mortgage-backed securities (CMBS) transaction, to 'AAA
(sf)' from 'A+ (sf)'.  Concurrently, S&P lowered its ratings on
classes H and J to 'CCC- (sf)' and 'D (sf)', respectively.  In
addition, S&P affirmed its ratings on 15 other classes from the
same transaction.

S&P's rating actions follows 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 and performance of all of the remaining assets in
the pool, the transaction structure, and the liquidity available
to the trust

The upgrade reflects the results of S&P's cash flow analysis,
which indicates that class A-SB should receive its full repayment
of principal due to "time tranching," as described in "U.S. CMBS
'AAA' Scenario Loss And Recovery Application," published July 21,
2009.

The downgrades of the class H and J certificates reflect current
and projected interest shortfalls affecting these classes.  As of
the July 12, 2013, trustee remittance report, the trust
experienced monthly interest shortfalls totaling $344,424,
primarily related to appraisal subordinate entitlement reduction
amounts of $268,786 on six ($128.3 million, 5.8%) of the nine
($154.9 million, 7.0%) specially serviced assets and shortfalls
due to interest rate modification of $29,829, special servicing
fees of $32,320, and workout fees of $12,350.  The interest
shortfalls affected all classes subordinate to and including class
J.

S&P downgraded class H to 'CCC- (sf)' from 'CCC (sf)' due to
projected additional interest shortfalls that S&P anticipates may
affect the class from the nine specially serviced assets currently
with the special servicer, C-III Asset Management LLC (C-III).
S&P downgraded class J to 'D (sf)' due to recurring interest
shortfalls that it anticipate will continue in the near term.
Class J had accumulated interest shortfalls outstanding for 12
months in total.  In addition, based solely on S&P's valuation of
eight ($145.0 million, 6.5%) of the nine specially serviced
assets, S&P expects the trust to incur additional losses
approximating 3.2% of the original pool trust balance upon the
resolution and/or liquidation of these assets.  To date, the trust
has incurred losses totaling $91.3 million, or 3.6% of the
original pool trust balance.

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

S&P affirmed its 'AAA (sf)' ratings on the class X-1 and X-2
interest-only (IO) certificates based on S&P's 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 RAISED

JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC20
Commercial mortgage pass-through certificates

                    Rating
Class          To          From     Credit enhancement (%)
A-SB           AAA (sf)    A+ (sf)                   30.20

RATINGS LOWERED

JPMorgan Chase Commercial Mortgage Securities Trust
2007-CIBC20 Commercial mortgage pass-through certificates

                    Rating
Class          To          From    Credit enhancement (%)
H              CCC- (sf)   CCC (sf)                  3.33
J              D (sf)      CCC- (sf)                 1.90

RATINGS AFFIRMED

JPMorgan Chase Commercial Mortgage Securities Trust 2007-CIBC20
Commercial mortgage pass-through certificates

Class          Rating             Credit enhancement (%)
A-1A           A+ (sf)                             30.20
A-2            AAA (sf)                            30.20
A-3            AAA (sf)                            30.20
A-4            A+ (sf)                             30.20
A-M            BBB- (sf)                           18.76
A-MFX          BBB- (sf)                           18.76
A-J            BB- (sf)                            11.90
B              B+ (sf)                             10.47
C              B+ (sf)                              9.33
D              B (sf)                               8.05
E              B (sf)                               7.04
F              B- (sf)                              6.04
G              B- (sf)                              4.90
X-1            AAA (sf)                              N/A
X-2            AAA (sf)                              N/A

N/A-Not applicable.


JP MORGAN 2007-LDP12: S&P Lowers Rating on Class H Notes to 'D'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
from 'CCC- (sf)' on the class H commercial mortgage pass-through
certificates from JPMorgan Chase Commercial Mortgage Securities
Trust 2007-LDP12, a U.S. commercial mortgage-backed securities
(CMBS) transaction.  At the same time, S&P affirmed its ratings on
14 other classes from the same transaction.

S&P's rating actions reflects 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 and performance of all of the pool's remaining
assets, the transaction structure, and the trust's available
liquidity.

"We lowered our rating on the class H certificates to 'D (sf)'
because we believe the accumulated interest shortfalls will remain
outstanding for the foreseeable future.  As of the July 15, 2013,
trustee remittance report, the trust experienced monthly interest
shortfalls totaling $280,940, primarily related to appraisal
subordinate entitlement reduction amounts of $101,188 on six
($49.0 million, 2.4%) of the 13 specially serviced assets
($297.9 million, 14.8%), shortfalls because of deferred interest
on three modified subordinate hope notes ($19.8 million, 1.0%),
special servicing fees of $61,866, and workout fees of $6,980.
The interest shortfalls affected all the classes subordinate to
and including class H. We also downgraded class H because we
anticipate current and projected additional interest shortfalls
from the specially serviced assets will affect the class.  In
addition, based on our valuation of 10 ($232.0 million, 11.5%) of
the 13 specially serviced assets, we expect the trust to incur
additional losses approximating 3.7% of the original pool trust
balance upon the assets' resolution or liquidation.  To date, the
trust has incurred losses totaling $104.8 million or 4.2% of the
original pool trust balance," S&P said.

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

S&P affirmed its 'AAA (sf)' rating on the class X interest-only
(IO) certificates based on its 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 LOWERED

JPMorgan Chase Commercial Mortgage Securities Trust 2007-LDP12
Commercial mortgage pass-through certificates
            Rating
Class   To           From           Credit enhancement (%)
H       D (sf)       CCC- (sf)                        1.64

RATINGS AFFIRMED

JPMorgan Chase Commercial Mortgage Securities Trust 2007-LDP12
Commercial mortgage pass-through certificates

Class      Rating   Credit enhancement (%)
A-2        AAA (sf)                  32.05
A-3        AAA (sf)                  32.05
A-4        A- (sf)                   32.05
A-SB       AAA (sf)                  32.05
A-1A       A- (sf)                   32.05
A-M        BB+ (sf)                  19.63
A-J        B- (sf)                    9.86
B          B- (sf)                    8.77
C          B- (sf)                    7.38
D          CCC+ (sf)                  6.29
E          CCC (sf)                   5.67
F          CCC- (sf)                  4.43
G          CCC- (sf)                  3.03
X          AAA (sf)                    N/A

N/A-Not applicable.



JP MORGAN 2008-C2: Fitch Lowers Rating on 12 Certs. to 'D'
----------------------------------------------------------
Fitch Ratings has downgraded 13 and affirmed nine classes of
J.P. Morgan Chase Commercial Mortgage Securities Trust, series
2008-C2.

Key Rating Drivers

The downgrades reflect the expected losses after the sale of the
largest asset in the pool, The Shops at Dos Lagos (12.4% of the
pool).

The Shops at Dos Lagos, a $124 million real estate owned (REO)
retail property, was sold July 23, 2013 for $30 million. Including
advances, appraisal subordinate entitlement reductions (ASERs),
fees and other unpaid amounts of approximately $41 million, the
loan loss severity will be approximately 109% on the current loan
balance.

Realized losses to the trust will reflect the full principal
balance of $124 million. Losses are expected to be incurred as of
the Aug. 12, 2013 distribution date. Classes C through Q,
currently rated 'Csf' or 'Dsf' by Fitch, will be affected. These
classes rated 'Csf' are downgraded to 'Dsf'.

The additional amount of $11.4 million will cause permanent
shortfalls to the transaction. These amounts were part of the
total $27 million ASER (advances not made due to an appraisal
reduction). Therefore, the sales proceeds of $30 million will be
used to pay fees, expenses, advances and $16 million of the total
$27 million in ASER amounts. The remaining $11.4 million in ASER
amounts will not be repaid, while the most senior bondholders with
an interest shortfall will recover $16 million in interest. No
additional interest is expected to be taken from the trust due to
the disposition of the Dos Lagos asset.

The property is a 345,847 square foot (sf) lifestyle/entertainment
retail center built in 2006/2007; therefore, the property was not
fully stabilized, with no operating history. The loan transferred
to special servicing in October 2008 for monetary default after
the borrower indicated the property was significantly affected by
the downturn in the economy. The special servicer foreclosed on
the property and, along with a third party management team, worked
to stabilize occupancy. The last reported occupancy was 72.5%.

The property represented phase one of a two-phase, 534 acre
development that was significantly pressured by economic
conditions in 2009. The development included a residential
subsection, a golf course, hotel, office building, a senior
housing development and a 135 acre wildlife preserve. The retail
center was 95% occupied at issuance; however, occupancy steadily
declined to a low of 68% in early 2012. The borrower cited slower-
than-anticipated growth in the residential neighborhood for the
decline in performance, as tenant sales, rental rates and
ultimately occupancy declined.

Rating Sensitivities

The super senior classes' Rating Outlooks are revised to Negative
due to the erosion in credit enhancement and continued risk of
both principal and interest losses as the pool becomes more
concentrated. After the sale of The Shops at Dos Lagos, eight
loans (18.4%), including three REOs (1.8%) remain in the pool.
Downgrades are possible if expected losses increase or if these
classes are affected by repeated interest shortfalls.

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

-- $116.5 million class AM to 'CCsf' from 'CCCsf'; RE 50%
   from 100%;
-- $14.6 million class C to 'Dsf' from 'Csf'; RE 0%;
-- $10.2 million class D to 'Dsf' from 'Csf'; RE 0%;
-- $10.2 million class E to 'Dsf' from 'Csf'; RE 0%;
-- $13.1 million class F to 'Dsf' from 'Csf'; RE 0%;
-- $11.7 million class G to 'Dsf' from 'Csf'; RE 0%;
-- $16 million class H to 'Dsf' from 'Csf'; RE 0%;
-- $14.6 million class J to 'Dsf' from 'Csf'; RE 0%;
-- $14.6 million class K to 'Dsf' from 'Csf'; RE 0%.
-- $8.7 million class L to 'Dsf' from 'Csf'; RE 0%;
-- $4.4 million class M to 'Dsf' from 'Csf'; RE 0%;
-- $5.8 million class N to 'Dsf' from 'Csf'; RE 0%;
-- $4.4 million class P to 'Dsf' from 'Csf'; RE 0%;

The following classes are affirmed and Rating Outlooks and
Recovery Estimates revised as indicated:

-- $71.2 million class A-3 at 'Asf'; Outlook Negative from
   Stable;

-- $45.6 million class A-SB at 'Asf'; Outlook Negative from
   Stable;

-- $354.6 million class A-4 at 'Asf'; Outlook Negative from
   Stable;

-- $145 million class A-4FL at 'Asf'; Outlook Negative from
   Stable;

-- $60.4 million class A-1A at 'Asf'; Outlook Negative from
   Stable;

-- $61.2 million class AJ at 'Csf'; RE 0% from 40%;

-- $14.6 million class B at 'Csf'; RE 0%;

-- $2.9 million class Q at 'Dsf'; RE 0%;

-- $1.7 million class T at 'Dsf'; RE 0%.

Classes A-1 and A-2 have paid in full. Class X was previously
withdrawn.


LANDMARK VII: Moody's Raises Ratings on $14MM Class B-2L Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Landmark VII CDO, Ltd.:

$23,000,000 Class A-3L Floating Rate Notes Due July 15, 2018,
Upgraded to Aaa (sf); previously on July 15, 2013 Aa1 (sf) Placed
Under Review for Possible Upgrade

$14,000,000 Class B-1L Floating Rate Notes Due July 15, 2018,
Upgraded to A2 (sf); previously on July 15, 2013 Baa1 (sf) Placed
Under Review for Possible Upgrade

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

$229,500,000 Class A-1L Floating Rate Notes Due July 15, 2018
(current outstanding balance of $88,385,358.26), Affirmed Aaa
(sf); previously on April 25, 2013 Affirmed Aaa (sf)

$20,500,000 Class A-2L Floating Rate Notes Due July 15, 2018,
Affirmed Aaa (sf); previously on April 25, 2013 Upgraded to Aaa
(sf)

$14,000,000 Class B-2L Deferrable Floating Rate Notes Due July 15,
2018 (current outstanding balance of $12,780,861.58), Affirmed Ba3
(sf); previously on April 25, 2013 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 class A-1L Notes and an
increase in the transaction's overcollateralization ratios since
the rating action in April 2013. Moody's notes that the Class A-1L
Notes have been paid down by approximately 31% or $39.1 million
since April 2013. Based on the latest trustee report dated July 2,
2013, the Senior Class A, Class A, Class B-1L and Class B-2L
overcollateralization ratios are reported at 142.28%,123.14%,
113.82% and 106.26%, respectively, versus April 2013 levels of
132.76%, 118.07%, 110.62% and 104.59%, respectively. Moody's notes
that the overcollateralization ratios reported in the July 2, 2013
trustee report do not reflect the July 15, 2013 payment
distribution, when $39 million of principal proceeds were used to
pay down the Class A-1L Notes.

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 July 2013 trustee
report, the weighted average rating factor is currently 2866
compared to 2651 in April 2013.

Moody's also announced that it has concluded its review of its
ratings on the issuer's Class A-3L and Class B-1L Notes announced
on July 15, 2013. At that time, Moody's said that it had upgraded
and placed certain of the issuer's ratings on review primarily as
a result of substantial deleveraging of the senior notes and
increases in OC ratios resulting from high rates of loan
collateral prepayments during the first half of 2013.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, diversity
score, and weighted average recovery rate, are based on its
published methodology and 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 $164.4 million, defaulted par of $13.4
million, a weighted average default probability of 19.51%
(implying a WARF of 2960), a weighted average recovery rate upon
default of 51.06%, and a diversity score of 56. 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.

Landmark VII CDO, issued in April 2006, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2013.

In addition to the base case analysis, 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% (2368)

Class A-1L: 0

Class A-2L: 0

Class A-3L: 0

Class B-1L: +2

Class B-2L: +1

Moody's Adjusted WARF + 20% (3552)

Class A-1L: 0

Class A-2L: 0

Class A-3L: -1

Class B-1L: -2

Class B-2L: -1

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

Sources of additional performance uncertainties:

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

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


LB-UBS 2001-C3: S&P Lowers Rating on 2 Note Classes to 'D'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on six
classes of commercial mortgage pass-through certificates from
LB-UBS Commercial Mortgage Trust 2001-C3, a U.S. commercial
mortgage-backed securities (CMBS) transaction.  In addition, S&P
affirmed its ratings on three other classes from the same
transaction.

The rating actions follows S&P's 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 and performance of all of the remaining assets in
the pool, the transaction structure, and the liquidity available
to the trust.

S&P lowered its ratings to 'D (sf)' on classes J and K, based on
its belief that interest shortfalls on these two classes will
continue and that the accumulated interest shortfalls will remain
outstanding for the foreseeable future.  Classes J and K had
accumulated interest shortfalls outstanding for six consecutive
months and 11 months in total.

"We lowered our ratings to 'CCC- (sf)' on classes G and H,
reflecting the reduced liquidity support available to these
classes as a result of continued interest shortfalls and the
potential for continued interest shortfalls due to the specially
serviced assets.  As of the July 17, 2013 trustee remittance
report, the trust incurred monthly interest shortfalls totaling
$371,604, primarily from an appraisal subordinate entitlement
reduction (ASER) amount of $337,162, special servicing fees of
$15,296, the master servicer's recoupment of prior advances of
$6,880, and workout fees of $6,287. Classes G and H had
accumulated interest shortfalls outstanding for three and six
consecutive months, respectively," S&P said.  If classes G and H
continues to experience interest shortfalls for an extended period
of time, S&P could lower its ratings on these classes to 'D (sf)'.

"We lowered our ratings on classes E and F to 'BBB- (sf)' and
'B- (sf)', respectively, reflecting the reduced liquidity support
available to these classes as a result of continued interest
shortfalls from the specially serviced assets.  In addition, we
also considered the potential for additional interest shortfalls
from the five specially serviced assets ($73.3 million; 48.2%)
and/or the largest asset in the pool, the Vista Ridge Mall loan,
which is on the master servicer's watchlist due to low reported
debt-service coverage (DSC).  In addition, the Vista Ridge Mall
loan is a worked-out mortgage loan.  According to the transaction
documents, the special servicer is entitled to receive a workout
fee of 1% on each collection of principal and interest with
respect to a worked-out mortgage loan.  If this loan is
transferred to the special servicer, it could generate additional
interest shortfalls and further decrease the liquidity support
available to the trust," S&P added.

"We affirmed our 'AA (sf)' and 'A+ (sf)' ratings on classes C and
D, respectively, reflecting our expectation of available credit
enhancement for the affected tranches, which we believe will be
within our estimate of the necessary credit enhancement required
for the current outstanding ratings.  The affirmations also
reflect our view regarding the current and future performance of
the remaining assets, as well as the transaction-level changes,"
S&P noted.  Although available credit enhancement levels might
suggest positive rating movements on classes C and D, S&P affirmed
its ratings on these classes because its analysis also considered:

   -- The remaining small pool size;

   -- Five out of the remaining eight assets are delinquent and
      with the special servicer;

   -- The limited liquidity support available to these classes;
      And

   -- The potential for additional interest shortfalls.

S&P affirmed its 'AAA (sf)' rating on the class X interest-only
(IO) certificates based on its criteria for rating IO securities.

As of the July 17, 2013 trustee remittance report, the collateral
pool consisted of six loans and two real estate owned (REO) assets
with an aggregate principal balance of $151.9 million (down from
135 loans with an aggregate balance of $1.38 billion at issuance).
Currently, the trust consists of five specially serviced assets
($73.3 million; 48.2%), the defeased Rite Aid-Ramona loan
($2.9 million; 1.9%), which matures on March 10, 2020, and two
performing loans ($75.7 million; 49.9%).  To date, the transaction
experienced losses totaling $23.7 million, or 1.7% of the
transaction's original pooled certificate balance.  Details on the
two nondefeased performing loans, one of which is on the master
servicer's watchlist, are as follows:

   -- The Vista Ridge Mall loan ($72.3 million; 47.7%), the
      largest asset in the pool, is secured by 379,777 sq. ft. of
      a 1.05 million-sq.-ft. mall located in Lewisville, Texas,
      approximately 22 miles northwest of the Dallas central
      business district.  According to the March 31, 2013 rent
      roll, the mall consists of the following shadow anchors with
      Jan. 1, 2038 lease expirations (not part of the collateral):

   -- Dillard's Inc. (200,000 sq. ft.), Macy's Inc.
      (178,322 sq. ft.), Sears Holdings Corp. (147,148 sq. ft.),
      and J.C. Penney Co. Inc. (144,740 sq. ft.).  The loan is
      currently on the master servicer's watchlist because of low
      reported DSC.  (For the year ended Dec. 31, 2012, reported
      DSC was 0.98x.)  According to the March 31, 2013 rent roll,
      the collateral property was 78.1% occupied.  According to
      the master servicer, Wells Fargo Bank N.A., the property
      manager plans to improve the property's performance by
      increasing efforts to rent available units and to lower
      operating expenses.

   -- The Long's Drugs-San Pablo loan ($3.4 million; 2.2%) is
      secured by a 31,290-sq.-ft. retail property in San Pablo,
      Calif.  According to Wells Fargo, the sole tenant was
      previously Long's Drugs, but the property is now subleased
      to Ross Stores Inc. As of Dec. 31, 2012, reported DSC and
      occupancy were 1.00x and 100.0%, respectively.

                     SPECIALLY SERVICED ASSETS

As of the July 17, 2013 trustee remittance report, three loans and
two REO assets ($73.3 million; 48.2%) were with the special
servicer.  Details on the five specially serviced assets are as
follows:

   -- The Shoppingtown Mall REO asset ($37.3 million; 24.6%), the
      second-largest asset in the pool, is the largest asset with
      LNR Partners, LLC (LNR).  The asset consists of a
      773,634-sq.-ft. mall in Syracuse, N.Y.  The reported
      exposure is $40.3 million and a $26.9 million appraisal
      reduction amount (ARA) in effect against the asset.  The
      loan was transferred to special servicing on May 2, 2011
      because of imminent monetary default, and the property
      became REO on Dec. 30, 2011.  According to LNR, Jones Lang
      LaSalle has been engaged as the property manager and leasing
      agent.  S&P expects a significant loss upon the asset's
      eventual resolution.

   -- The Park Central REO asset ($27.9 million; 18.3%), the
      third-largest asset in the pool, consists of a
      343,419-sq.-ft. office property in Phoenix, Ariz.  The
      reported exposure is $29.6 million and a $12.7 million
      ARA in effect against the asset.  The loan was transferred
      to special servicing on July 18, 2011, because of monetary
      default, and the property became REO on May 2, 2012.
      According to LNR, they have effectuated several short-term
      lease extensions that include landlord termination clauses
      to allow for future redevelopment.  The reported occupancy
      is currently 71.0%, and reported DSC was 0.48x for year-end
      2012.  S&P expects a moderate loss upon the asset's eventual
      resolution.

   -- The River Bay Plaza loan ($3.9 million; 2.6%) is secured by
      a 79,298-sq.-ft. retail property in Riverview, Fla.  The
      reported exposure is $4.0 million.  The loan was transferred
      to special servicing on June 30, 2011, because of a maturity
      default.  The loan matured on June 11, 2011.  According to
      LNR, it filed for foreclosure on July 19, 2012, and is also
      negotiating with the borrower on resolution.  Reported DSC
      and occupancy were 0.95x and 87.2%, respectively, as of
      Dec. 31, 2012.  S&P expects a minimal loss, if any, upon the
      loan's eventual resolution.

   -- The CVS Plaza loan ($3.2 million; 2.1%) is secured by a
      24,131-sq.-ft retail property in West Orange, N.J.  The
      total reported exposure is $3.4 million.  The loan was
      transferred to special servicing on May 21, 2012, because of
      a monetary default.  According to LNR, the property is under
      contract for sale, and S&P anticipates that the loan will be
      repaid in full.  S&P expects a minimal loss, if any, upon
      the loan's eventual resolution.

   -- The 6341 Thompson Rd loan ($970,973; 0.6%) is secured by an
      87,968-sq.-ft. industrial property in Syracuse, N.Y.  The
      total reported exposure is $1.2 million.  The master
      servicer has deemed this loan nonrecoverable.  The loan was
      transferred to special servicing on Jan. 24, 2011, because
      of a monetary default.  According to LNR, the foreclosure
      sale occurred on June 20, 2013, and the lender was the
      prevailing bidder.  Once the deed is recorded, the property
      will become REO.  S&P expects a significant loss upon the
      loan's eventual resolution.

S&P considered minimal loss, as it relates to the above asset
resolutions, to be less than 25%; moderate loss to be between 26%
and 59%; and significant loss to be 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

Ratings Lowered

LB-UBS Commercial Mortgage Trust 2001-C3
Commercial mortgage pass-through certificates

                 Rating
Class      To            From        Credit enhancement (%)

E          BBB- (sf)     A- (sf)             59.87
F          B- (sf)       BBB (sf)            48.02
G          CCC- (sf)     BBB- (sf)           40.06
H          CCC- (sf)     B+ (sf)             29.84
J          D (sf)        CCC+ (sf)           16.20
K          D (sf)        CCC- (sf)           11.66

Ratings Affirmed

LB-UBS Commercial Mortgage Trust 2001-C3
Commercial mortgage pass-through certificates

Class      Rating                    Credit enhancement (%)

C          AA (sf)                           82.25
D          A+ (sf)                           71.71
X          AAA (sf)                          N/A

N/A-Not applicable.


LEGG MASON I: Moody's Affirms Caa3 Rating on Class G Notes
----------------------------------------------------------
Moody's Investors Service has affirmed the ratings of nine classes
of notes issued by Legg Mason Real Estate CDO I, Ltd. The
affirmations are due to key transaction parameters performing
within levels commensurate with the existing ratings levels. The
rating action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation and
collateralized loan obligation (CRE CDO CLO) transactions.

Moody's rating action is as follows:

Cl. A1-T, Affirmed Aaa (sf); previously on Apr 21, 2009 Confirmed
at Aaa (sf)

Cl. A1-R, Affirmed Aaa (sf); previously on Apr 21, 2009 Confirmed
at Aaa (sf)

Cl. A2, Affirmed A1 (sf); previously on Nov 3, 2010 Downgraded to
A1 (sf)

Cl. B, Affirmed Baa3 (sf); previously on Nov 3, 2010 Downgraded to
Baa3 (sf)

Cl. C, Affirmed Ba2 (sf); previously on Nov 3, 2010 Downgraded to
Ba2 (sf)

Cl. D, Affirmed B1 (sf); previously on Nov 3, 2010 Downgraded to
B1 (sf)

Cl. E, Affirmed B2 (sf); previously on Nov 3, 2010 Downgraded to
B2 (sf)

Cl. F-1, Affirmed Caa1 (sf); previously on Nov 3, 2010 Downgraded
to Caa1 (sf)

Cl. G, Affirmed Caa3 (sf); previously on Nov 3, 2010 Downgraded to
Caa3 (sf)

Ratings Rationale:

Legg Mason Real Estate CDO I, Ltd. is a static cash transaction
backed by a portfolio whole loans and senior participations (90.9%
of the pool balance), B-note debt (4.7%), commercial mortgage
backed securities (CMBS) (2.5%), and mezzanine debt (1.9%). As of
the July 25, 2013 payment date, the aggregate note balance of the
transaction, including income notes, has decreased to $397.8
million from $532.0 million at issuance, as a result of the
combination of junior notes cancellation to class D, class F-2,
and class G notes and of the paydown directed to the Class A1-R
and A1-T Notes from principal repayment of collateral and sales of
defaulted collateral. In general, holding all key parameters
static, the junior note cancellations results in slightly higher
expected losses and longer weighted average lives on the senior
Notes, while producing slightly lower expected losses on the
mezzanine and junior Notes. However, this does not cause, in and
of itself, a downgrade or upgrade of any outstanding classes of
notes.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 8,106
compared to 7,578 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Aaa-Aa3 (2.1% compared to 0.0% at last
review), A1-A3 (0.1% compared to 4.0% at last review), Baa1-Baa3
(0.3% compared to 1.8% at last review), Ba1-Ba3 (0.0% compared to
3.4% at last review), B1-B3 (10.3% compared to 2.3% at last
review), and Caa1-Ca/C (87.2% compared to 88.5% at last review).

Moody's modeled to a WAL of 2.9 years compared to 3.4 years at
last review. The current WAL is based on the assumption about
extensions on the underlying collateral.

Moody's modeled a fixed WARR of 52.8% compared to 53.8% at last
review.

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

Moody's review incorporated CDOROM v2.8, one of Moody's CDO rating
models, which was released on March 25, 2013.

The cash flow model, CDOEdge v3.2.1.2, released on May 16, 2013,
was used to analyze the cash flow waterfall and its effect on the
capital structure of the deal.

Moody's analysis encompasses the assessment of stress scenarios.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. In general, the rated notes are particularly
sensitive to changes in recovery rate assumptions. Holding all
other key parameters static, changing the recovery rate assumption
down from 52.8% to 42.8% or up to 62.8% would result in rating
movements on the rated tranches of 0 to 8 notches downward or 0 to
13 notches upward, respectively.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment given the weak pace of
recovery in the 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 continues to exhibit growth albeit at a slightly
slower pace. The multifamily sector should remain stable with
moderate growth. Gradual recovery in the office sector continues
and will be assisted in the next quarter when absorption is likely
to outpace completions. However, since office demand is closely
tied to employment, Moody's expects regional employment growth to
provide market differentiation. CBD markets continue to outperform
secondary suburban markets. The retail sector exhibited a slight
reduction in vacancies in the first quarter; the largest drop
since 2005. However, consumers continue to be cautious as
evidenced by sales growth continuing below historical trends.
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 outlook indicates the global
economy has lost momentum over the past quarter as it tries to
recover. US GDP growth for 2013 is likely to remain close to 2%,
however US sequestration cuts that came into effect in March may
create a drag on the positive growth in the US private sector.
While the broad economic impact in unclear, the direct effect is
likely to shave 0.4% off US GDP growth in 2013. Continuing from
the previous quarter, Moody's believes that the three most
immediate risks are: i) the risk of an even deeper than currently
expected recession in the euro area, accompanied by deeper credit
contraction, potentially triggered by a further intensification of
the sovereign debt crisis; ii) slower-than-expected recovery in
major emerging markets following the recent slowdown; and iii) an
escalation of geopolitical tensions, resulting in adverse economic
developments.

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


MAPS CLO II: Moody's Corrects and Withdraws B2 and Baa3 Ratings
---------------------------------------------------------------
Moody's Investors Service is correcting the rating history and
withdrawing the rating for the $3,000,000 Composite Notes due 2022
issued by MAPS CLO Fund II, Ltd. Components of the composite notes
were unwound in whole on June 3rd, 2010. However, Moody's was not
informed about the unwinding of the transaction at the time, and
the trustee continued to furnish Moody's with statements
indicating that the transaction remained outstanding. Based on the
information provided by the trustee, on October 12, 2011 Moody's
upgraded the rating to Baa3 (sf) from B2 (sf) on watch for
possible upgrade.

Moody's has now removed the October 12, 2011 Upgrade to Baa3 (sf),
June 22, 2011 B2 (sf) On Watch for Possible Upgrade, and withdrawn
the B2 (sf) rating on watch for possible upgrade as of June 3,
2010 because the obligation is not outstanding.


ML-CFC COMMERCIAL 2006-2: Moody's Keeps C Ratings on 6 Securities
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 17 classes of
ML-CFC Commercial Mortgage Trust 2006-2 as follows:

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

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

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

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

Cl. AJ, Affirmed Baa3 (sf); previously on Aug 30, 2012 Downgraded
to Baa3 (sf)

Cl. AM, Affirmed Aa2 (sf); previously on Dec 17, 2010 Downgraded
to Aa2 (sf)

Cl. B, Affirmed Ba2 (sf); previously on Aug 30, 2012 Downgraded to
Ba2 (sf)

Cl. C, Affirmed B2 (sf); previously on Aug 30, 2012 Downgraded to
B2 (sf)

Cl. D, Affirmed Caa3 (sf); previously on Aug 30, 2012 Downgraded
to Caa3 (sf)

Cl. E, Affirmed Ca (sf); previously on Aug 30, 2012 Downgraded to
Ca (sf)

Cl. F, Affirmed C (sf); previously on Aug 30, 2012 Downgraded to C
(sf)

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

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

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

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

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

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

Ratings Rationale:

The affirmations of the investment-grade P&I classes are due to
key parameters, including Moody's loan to value (LTV) ratio,
Moody's stressed debt service coverage ratio (DSCR) and the
Herfindahl Index (Herf), remaining within acceptable ranges. The
ratings of the below investment grade P&I classes are consistent
with Moody's expected loss and thus are affirmed. The ratings of
the IO Class, Class X, is consistent with the expected credit
performance of its referenced classes and thus affirmed.

Depending on the severity and timing of losses from specially
serviced loans, the credit enhancement level for rated 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 rating action reflects a base expected loss of 9.7% of the
current balance. At last full review, Moody's base expected loss
was 10.4%. Realized losses plus Moody's realized and base expected
loss is now 10.7% of the original securitized balance compared to
11.2% at last review.

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.

The principal methodology used in this rating was "Moody's
Approach to Rating Fusion U.S. CMBS Transactions" published in
April 2005.

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
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 37 compared to 41 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST (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.

Deal Performance:

As of the July 12, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 14% to $1.59
billion from $1.84 billion at securitization. The Certificates are
collateralized by 169 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten loans representing
36% of the pool. Six loans, representing 3% of the pool, have
defeased and are collateralized with U.S. Government securities.
One loan, representing 11% of the pool, has an investment grade
credit assessment.

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

Sixteen loans have been liquidated from the pool since
securitization, resulting in an aggregate $41.6 million loss (54%
loss severity on average). Currently 12 loans, representing 12% of
the pool, are in special servicing. The largest specially serviced
loan is the Penn Mutual Towers and Washington Square Garage Loan
($99.9 million -- 6.3% of the pool), which is secured by an
854,000 square foot (SF) mixed use complex located in Center City
Philadelphia, Pennsylvania. The loan was transferred to special
servicing in February 2011 due to imminent default and is in the
process of tracking towards a potential modification and or
assumption of the debt.

The remaining 11 specially serviced loans are secured by a mix of
property types. The master servicer has recognized an aggregate
$91.1 million appraisal reduction for the specially serviced
loans. Moody's has estimated an aggregate loss of $106.8 million
(57% expected loss on average) for all of the specially serviced
loans.

Moody's has assumed a high default probability for 30 poorly
performing loans representing 11% of the pool and has estimated a
$30.6 million loss (18% expected loss based on a 51% probability
default) from these troubled loans.

Moody's was provided with full year 2011 and 2012 operating
results for 98% and 97% of the performing pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 91% compared to 97% at last full review. Moody's
net cash flow reflects a weighted average haircut of 11% to the
most recently available net operating income. Moody's value
reflects a weighted average capitalization rate of 9.8 %.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.53X and 1.28X, respectively, compared to
1.42X and 1.14X 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 100 Summer Street Loan
($180 million -- 10.9% of the pool), which is secured by a 1.1
million SF Class A office building located in Boston,
Massachusetts. The property was 94% leased as of December 2012,
but dropped to 77% as of March 2013 after Cambridge Associates
(158,851 SF) vacated at its lease expiration in January. The loan
is sponsored by Blackstone and is interest only for the full term.
Moody's analysis reflects a stabilized value for this asset.
Moody's current credit assessment and stressed DSCR are A2 and
1.59X, respectively, compared to A2 and 1.80X at the last full
review.

The top three performing conduit loans represent 9% of the pool
balance. The largest loan is the 200 Paul Avenue Loan ($71.5
million -- 4.5% of the pool), which is secured by a 527,680 SF
telecommunications building located in close proximity to the main
fiber optic line that serves San Francisco. The property also
includes roughly 18,200 SF of Class B office space. The property
was 92% leased as of March 2013 compared to 96% at last full
review. Property performance has been stable and rental rates have
increased by over 56% since origination. The improvements and
build out of the space, have also helped attract higher rates.
Moody's LTV and stressed DSCR are 42% and 3.0X, respectively.

The second largest loan is the CNL-Cirrus MOB Portfolio III Loan
($45.9 million -- 2.9% of the pool), which is secured by five
medical office properties located in Texas and Oklahoma and
totaling 269,707 SF. The properties were 90% leased as of March
2013, compared to 93% at last full review. Property performance
declined slightly due to lower rental revenue coupled with
increased expenses. Moody's LTV and stressed DSCR are 94% and
1.12X, respectively, compared to 85% and 1.24X at last review.

The third largest loan is the BTR Capital Portfolio Loan ($29.4
million -- 1.8% of the pool), which is secured by seven mixed-use
properties (five industrial, one retail strip center and one
trailer storage land parcel) located in Baltimore, Maryland. The
loan transferred into special servicing in November 2010 but was
modified and transferred back to the master servicer in February
2012. The properties were 88% leased as of March 2013 compared to
83% at last review. Property performance has improved slightly due
to increases in base rent and recoveries, along with decreased
expenses. Moody's LTV and stressed DSCR are 115% and 0.94X,
respectively, compared to 131% and 0.83X at last full review.


MORGAN STANLEY 1999-WF1: Moody's Hikes Rating on Cl. N Certs to B2
------------------------------------------------------------------
Moody's Investors Service upgraded the ratings of three classes
and affirmed three classes of Morgan Stanley Capital I Inc.,
Commercial Mortgage Pass-Through Certificates, Series 1999-WF1 as
follows:

Cl. J, Affirmed Aaa (sf); previously on Sep 29, 2011 Upgraded to
Aaa (sf)

Cl. K, Affirmed Aaa (sf); previously on Aug 9, 2012 Upgraded to
Aaa (sf)

Cl. L, Upgraded to Aa3 (sf); previously on Aug 9, 2012 Upgraded to
Baa2 (sf)

Cl. M, Upgraded to Ba1 (sf); previously on Feb 24, 1999 Assigned
B3 (sf)

Cl. N, Upgraded to B2 (sf); previously on Feb 24, 1999 Assigned
Caa2 (sf)

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

Ratings Rationale:

The upgrades are due to increased credit support from paydowns and
amortization, anticipated paydowns from defeased and lowly
leveraged loans approaching maturity and overall stable pool
performance. The pool has paid down 32% since last review.

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

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for rated 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 rating of the IO Class, Class X, is consistent with the
expected credit performance of its referenced classes and thus is
affirmed.

Moody's rating action reflects a base expected loss of 2.9% of the
current balance compared to 6.2% at last review. Moody's realized
loss plus expected loss is now 0.4% of the original securitized
balance compared to 0.7% at last review.

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.

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.

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
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 11 compared to 15 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 8.4 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.

Deal Performance:

As of the July 15, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 96% to $35.5
million from $968.5 million at securitization. The Certificates
are collateralized by 23 mortgage loans ranging in size from less
than 1% to 17% of the pool, with the top ten loans representing
83% of the pool. Three loans, representing 2% of the pool, have
defeased and are secured by U.S. Government securities.

Seven loans, representing 26% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of its
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Six loans have been liquidated from the pool, resulting in a
realized loss of $3.4 million (31% loss severity on average).
Currently one loan, the Spring Hill Market Place Loan ($4.2
million -- 12% of the pool), is in special servicing. This loan
was secured by a four building retail property totaling 108,416
square feet (SF) and is located in Carpentersville, Illinois. The
loan was transferred to special servicing on June 16, 2010 due to
payment default. The property was recently sold by the Chapter 11
Trustee under bankruptcy court order. Net proceeds to the lender
were $5.5 million and will be applied in partial satisfaction of
the borrower's obligations per the bankruptcy court order. Moody's
expects a minimal loss on this loan.

Moody's has identified one loan, representing 1% of the pool that
has a high probability of default due to poor performance. Moody's
analysis incorporates a 20% expected loss for this loan.

Moody's was provided with full year 2012 and partial year 2013
financials for 100% and 58% of the pool, respectively. Excluding
specially serviced and troubled loans, Moody's weighted average
LTV is 36%, the same as at last review. Moody's net cash flow
reflects a weighted average haircut of 10% to the most recently
available net operating income. Moody's value reflects a weighted
average capitalization rate of 10.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.80X and 3.77X, respectively, compared to
1.80X and 3.57X 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 41% of the pool. The largest loan is
the Ward Office / Retail Portfolio ($6.1 million -- 17% of the
pool), which is secured by five properties located in Bel Air,
Maryland (3 suburban office, 2 unanchored retail). The largest
tenants include Gucci (20% of the NRA; lease expiration November
2027), Chanel (20% of the NRA; lease expiration October 2027) and
Tiffany & Co. (12% of the NRA; lease expiration October 2027). The
properties were 93% leased overall as of March 2013, compared to
92% as of December 2011. This loan fully amortizes during its loan
term. Moody's LTV and stressed DSCR are 30% and 3.54X,
respectively, compared to 35% and 3.01X at last review.

The second largest loan is the Silver Creek Shopping Center Loan
($4.4 million -- 12% of the pool), which is secured by 63,365 SF
retail property located in San Jose, California. The property was
100% leased as of March 2013 compared to 74% at last review.
Moody's LTV and stressed DSCR are 45% and 2.70X, respectively,
compared to 49% and 2.50X at last review.

The third largest loan is the Vista Oaks Apartment Loan ($4.1
million -- 11%), which is secured by a 108-unit multifamily
property located in Martinez, California. The property was 98%
leased as of March 2013 compared to 94% at last review. Moody's
LTV and stressed DSCR are 41% and 2.50X, respectively, compared to
44% and 2.34X at last review.


MORGAN STANLEY 2005-6AR: Moody's Hikes Rating on 8 RMBS Tranches
----------------------------------------------------------------
Moody's Investors Service has downgraded the rating of one tranche
and upgraded the ratings of eight tranches from two transactions
backed by Alt-A loans, issued by Morgan Stanley Mortgage Loan
Trust 2007-3XS and 2005-6AR, respectively.

Complete rating actions are as follows:

Issuer: Morgan Stanley Mortgage Loan Trust 2005-6AR

Cl. 1-A-1, Upgraded to Baa2 (sf); previously on Sep 4, 2012
Upgraded to Ba2 (sf)

Cl. 1-A-2, Upgraded to A2 (sf); previously on Sep 4, 2012 Upgraded
to Baa2 (sf)

Cl. 1-A-4, Upgraded to Ba1 (sf); previously on Sep 4, 2012
Upgraded to B1 (sf)

Cl. 1-M-1, Upgraded to Ba3 (sf); previously on Sep 4, 2012
Upgraded to B3 (sf)

Cl. 1-M-2, Upgraded to B2 (sf); previously on Sep 4, 2012 Upgraded
to Caa2 (sf)

Cl. 1-M-3, Upgraded to Caa2 (sf); previously on Sep 4, 2012
Upgraded to Ca (sf)

Cl. 1-M-4, Upgraded to Caa3 (sf); previously on Apr 26, 2010
Downgraded to C (sf)

Cl. 1-M-5, Upgraded to Ca (sf); previously on Apr 26, 2010
Downgraded to C (sf)

Issuer: Morgan Stanley Mortgage Loan Trust 2007-3XS

Cl. 2-A-1-A, Downgraded to Baa1 (sf); previously on Sep 4, 2012
Upgraded to A1 (sf)

Ratings Rationale:

The actions are primarily a result of the recent performance of
the underlying pools and reflect Moody's updated loss expectations
on the pools. The upgrades are a result of build-up in credit
enhancement on the bonds and stable performance of the underlying
pool.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in June 2013.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
8.2% in July 2012 to 7.4% in July 2013. Moody's forecasts an
unemployment central range of 7.0% to 8.0% for the 2013 year.
Moody's expects house prices to continue to rise in 2013.
Performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


MORGAN STANLEY 2013-C11: Fitch Rates $20.3MM Class G Certs 'B'
--------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Morgan Stanley Bank of America Merrill Lynch Trust,
series 2013-C11 commercial mortgage pass-through certificates.

-- $53,000,000 class A-1 'AAAsf'; Outlook Stable;
-- $142,000,000 class A-2 'AAAsf'; Outlook Stable;
-- $72,980,000 class A-AB 'AAAsf'; Outlook Stable;
-- $125,000,000 class A-3 'AAAsf'; Outlook Stable;
-- $206,448,000 class A-4 'AAAsf'; Outlook Stable;
-- $599,428,000* class X-A 'AAAsf'; Outlook Stable;
-- $49,239,000b class A-S 'AAAsf'; Outlook Stable;
-- $61,013,000b class B 'AA-sf'; Outlook Stable;
-- $144,505,000b class PST 'A-sf'; Outlook Stable;
-- $34,253,000b class C 'A-sf'; Outlook Stable;
-- $38,535,000a class D 'BBB-sf'; Outlook Stable;
-- $9,634,000a class E 'BBB-sf'; Outlook Stable;
-- $8,563,000a class F 'BB+sf'; Outlook Stable;
-- $20,338,000a class G 'Bsf'; Outlook Stable.

* Notional amount and interest only.
a Privately placed pursuant to Rule 144A.
b Classes A-S, B and C certificates may be exchanged for class PST
  Certificates, and class PST Certificates may be exchanged for
  class A-S, B and C certificates.

Fitch does not rate the $10,747,000 class H, the $24,576,746 class
J or the notional class X-B. The class X-A balance has been
reduced to $599,428,000 from $648,667,000 since Fitch issued its
expected ratings on July 29, 2013. The classes above reflect the
final ratings and deal structure.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 38 loans secured by 72 commercial
properties having an aggregate principal balance of approximately
$856.3 million as of the cutoff date. The loans were contributed
to the trust by Bank of America, National Association; Morgan
Stanley Mortgage Capital Holdings LLC; and CIBC Inc.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 79.3% of the properties
by balance, cash flow analysis of 87.5%, and asset summary reviews
on 89.9% of the pool.

Key Rating Drivers

Fitch Leverage: The Fitch debt service coverage ratio (DSCR) of
1.25x is slightly better than the 2012 DSCR of 1.24x, but worse
than the first-half 2013 DSCR of 1.36x. The Fitch loan-to-value
(LTV) of 101.8% is higher than the 2012 and first-half 2013
average LTVs of 97.2% and 99.8%, respectively.

Loan and Sponsor Concentration: The top 10 loans represent 67.0%
of the total balance, which is the highest of any Fitch-rated deal
since 2011. The average top 10 concentration of Fitch-rated
transactions in the first half of 2013 was 54.3%. Additionally,
Simon Property Group, L.P. is the sponsor of loans representing
17.5% of the pool.

Hotel Concentration: Hotel properties represent 24.6% of the pool,
which exceeds the 2012 and first-half 2013 average concentration
of 13.5% and 13.8%, respectively. Three loans in the top 10,
Marriott Chicago River North, Hilton Waterfront Beach Resort, and
the Beverly Garland Hotel, are secured by hotel properties.

Amortization and No Interest-Only Loans: The pool is scheduled to
amortize 15.4% prior to maturity. There are no interest-only
loans. Nine loans (46.5% of the pool) are partial interest-only
loans and 29 loans (53.5% of the pool) are balloon loans.
Approximately 82.5% of the pool consists of 10-year loans and
17.5% consists of five-year loans.

Rating Sensitivities

For this transaction, Fitch's net cash flow (NCF) was 18.4% below
the most recent reported net operating income (NOI) (for
properties for which NOI was provided, excluding properties that
were stabilizing during this period). Unanticipated further
declines in property-level NCF could result in higher defaults and
loss severity on defaulted loans and could result in potential
rating actions on the certificates. Fitch evaluated the
sensitivity of the ratings assigned to MSBAM 2013-C11 certificates
and found that the transaction displays average sensitivity to
further declines in NCF. In a scenario in which NCF declined a
further 20% from Fitch's NCF, a downgrade of the junior 'AAAsf'
certificates to 'Asf' could result. In a more severe scenario, in
which NCF declined a further 30% from Fitch's NCF, a downgrade of
the junior 'AAAsf' certificates to 'BBBsf' could result. The
presale report includes a detailed explanation of additional
stresses and sensitivities.

The master servicer will be Wells Fargo Bank, National
Association, rated 'CMS1-' by Fitch. The special servicer will be
Midland Loan Services, a Division of PNC Bank, National
Association, rated 'CSS1' by Fitch.


MT WILSON: S&P Raises Rating on Class E Notes to 'B+'
-----------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, D, and E notes from MT Wilson CLO Ltd., a cash flow
collateralized loan obligation transaction managed by Western
Asset Management Co. Ltd.  At the same time, S&P removed the class
B, C, and D notes from CreditWatch with positive implications and
affirmed its rating on the class A note.

Since S&P's December 2012 rating actions, the transaction further
paid down the class A noteholders by $146 million, to 18% of its
initial issuance amount.  As a result of the paydowns, the class
A/B overcollateralization (O/C) ratio has increased to 158%, from
131% in November 2012.  S&P did note that the transaction
continues to hold long-dated assets and that the portfolio has a
smaller number of unique obligors.  However, the paydowns have
provided a significant increase in credit support for these notes
to offset any potential market value risk associated with the sale
of the long-dated securities, as well as the concentration risks
that arise from a smaller portfolio.

Due to the portfolio's decreasing par balance resulting from the
transaction's amortization phase, the top obligor test constrains
the rating on the class E note to the 'B' rating category.

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

            STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATING AND CREDITWATCH ACTIONS

MT Wilson CLO Ltd.
              Rating
Class     To          From
B         AAA (sf)    AA+ (sf)/Watch Pos
C         AA+ (sf)    A+ (sf)/Watch Pos
D         BBB- (sf)   BB+ (sf)/Watch Pos
E         B+ (sf)     CCC+ (sf)

RATING AFFIRMED

MT Wilson CLO Ltd.

Class     Rating
A         AAA (sf)


NATIONSTAR HOME 2006-B: Moody's Hikes Cl. AV-4 Debt Rating to Caa1
------------------------------------------------------------------
Moody's Investors Service has confirmed the ratings of five
tranches and upgraded the ratings of two tranches from four
transactions issued by Nationstar, backed by Subprime mortgage
loans.

Complete rating actions are as follows:

Issuer: Nationstar Home Equity Loan Asset-Backed Certificates,
Series 2007-C

Cl. 1-AV-1, Confirmed at Caa3 (sf); previously on May 14, 2013
Caa3 (sf) Placed Under Review Direction Uncertain

Cl. 2-AV-2, Confirmed at Caa2 (sf); previously on May 14, 2013
Caa2 (sf) Placed Under Review Direction Uncertain

Issuer: Nationstar Home Equity Loan Trust 2006-B

Cl. AV-3, Upgraded to Ba3 (sf); previously on May 14, 2013 B3 (sf)
Placed Under Review Direction Uncertain

Cl. AV-4, Upgraded to Caa1 (sf); previously on May 14, 2013 Caa3
(sf) Placed Under Review Direction Uncertain

Issuer: Nationstar Home Equity Loan Trust 2007-A

Cl. AV-3, Confirmed at Caa2 (sf); previously on May 14, 2013 Caa2
(sf) Placed Under Review Direction Uncertain

Issuer: Nationstar Home Equity Loan Trust 2007-B

Cl. 1-AV-1, Confirmed at Caa3 (sf); previously on May 14, 2013
Caa3 (sf) Placed Under Review Direction Uncertain

Cl. 2-AV-2, Confirmed at Caa2 (sf); previously on May 14, 2013
Caa2 (sf) Placed Under Review Direction Uncertain

Ratings Rationale:

The rating actions reflect the recent performance of the
underlying pools and Moody's updated expected losses on the pools.
The rating actions also reflect correction of errors in the
Structured Finance Workstation (SFW) cash flow models previously
used by Moody's in rating these transactions.

The cash flow models used in the previous rating actions for these
transactions had incorrectly applied separate interest and
principal waterfalls. In the impacted deals, all collected
principal and interest is commingled into one payment waterfall to
pay all interest due on bonds first, and then to pay principal. As
stated in the deal's pooling and servicing agreements, principal
and interest collections in these deals are commingled first and
used to make payments on the bonds. With the commingling of funds,
principal proceeds can be used to pay accrued interest, which
could result in reduced principal recovery for the bonds
outstanding. Due to the discovery of these errors, these tranches
were placed on review on May 14, 2013. The errors have now been
corrected, and these rating actions reflect the changes.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in June 2013.

The primary sources of assumption uncertainty are Moody's central
macroeconomic forecast and performance volatility as a result of
servicer-related activity such as modifications. The unemployment
rate fell from 8.2% in July 2012 to 7.4% in July 2013. Moody's
forecasts an unemployment central range of 7.0% to 8.0% for 2013.
Moody's expects housing prices to continue to rise in 2013.
Performance of RMBS continues to remain highly dependent on
servicer activity such as modification-related principal
forgiveness and interest rate reductions. Any change resulting
from servicing transfers or other policy or regulatory change can
also impact the performance of these transactions.


NORTH END CLO: S&P Assigns 'BB' Rating on Class E Notes
-------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to North
End CLO Ltd./North End CLO LLC's $381.0 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 reflects S&P's view of:

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

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

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

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

   -- The collateral manager's experienced management team.

   -- S&P's projections regarding the timely interest and ultimate
      principal payments on the rated notes, which it assessed
      using its cash flow analysis and assumptions commensurate
      with the assigned ratings under various interest-rate
      scenarios, including LIBOR ranging from 0.28%-13.84%.

   -- 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
      rated notes' outstanding balance.

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

         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/1733.pdf

RATINGS ASSIGNED

North End CLO Ltd./North End CLO LLC

Class                Rating          Amount (mil. $)
A                    AAA (sf)                 246.50
B                    AA (sf)                   56.00
C (deferrable)       A (sf)                    29.50
D (deferrable)       BBB (sf)                  21.00
E (deferrable)       BB (sf)                   18.00
F (deferrable)       B (sf)                    10.00
Subordinated notes   NR                        32.50

NR-Not rated.


NORTHSTAR 2013-1: Moody's Assigns 'P)B3' Rating to Class C Notes
----------------------------------------------------------------
Moody's Investors Service has assigned the following provisional
ratings to notes to be issued by Northstar 2013-1, Ltd.:

   Class A Notes, Assigned (P)Aaa (sf)
   Class B Notes, Assigned (P)Baa3 (sf)
   Class C Notes, Assigned (P)B3 (sf)

Ratings Rationale:

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

Moody's provisional ratings of the Class A Notes, Class B Notes,
and Class C Notes address the expected loss posed to noteholders.
The provisional ratings reflect the risks due to defaults on the
underlying portfolio of loans, the transaction's legal structure,
and the characteristics of the underlying assets.

NStar 2013-1 is a static cash flow CRE CLO. The issued notes will
be collateralized initially by a pool of 10 commercial real estate
loans in the form of whole loans and senior participations ("A-
notes"). Approximately 80% of the assets are expected to be ramped
as of the closing date with a par amount of $425,228,536 and a
weighted average spread of 5.0%. The remaining par balance of
$106,083,964 may consist of additional whole loans and senior
participations; subject to certain eligibility criteria and
collateral quality tests. The ramp-up period is six (6) months
with a transaction effective date of February 2014.

NS Income Administration Agent, LLC is an affiliate of Northstar
and will provide administration services to the asset pool during
the ramp-up period and static period. Wells Fargo Bank, NA will
act as primary servicer of the underlying collateral.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CLO 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 CLO pool.
Moody's has completed credit assessments for all of the
collateral. Moody's modeled a WARF of 3600.

Moody's modeled to a WAL of 6.0 years as of the effective date.

Moody's modeled a fixed WARR of 52.1%.

Moody's modeled a MAC of 29.5% corresponding to a pair-wise
correlation of 35%.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on March 25, 2013.

The cash flow model, CDOEdge(R) v3.2.1.2, released on May 16,
2013, was used to analyze the cash flow waterfall and its effect
on the capital structure of the deal.

The performance of the notes is subject to uncertainty. The notes'
performance is sensitive to the performance of the underlying
portfolio, which in turn depends on economic and credit conditions
that may change. The servicing decisions of the master and special
servicer and surveillance by the Advisor with respect to the
collateral interests and oversight of the transaction will also
affect the performance of the rated notes.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate and rating factor assumptions of the
underlying collateral. Holding all other key parameters static,
stressing the recovery rate downward from 52% to 47% would result
in an average modeled rating movement on the rated notes of 1
notches downward. Holding all other key parameters static,
stressing the WARF from 3600 to 3958 would result in an average
modeled rating movement on the rated notes of 1 notch downward.

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 in the 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 continues to exhibit growth albeit at a slightly
slower pace. The multifamily sector should remain stable with
moderate growth. Gradual recovery in the office sector continues
and will be assisted in the next quarter when absorption is likely
to outpace completions. However, since office demand is closely
tied to employment, Moody's expects regional employment growth to
provide market differentiation. CBD markets continue to outperform
secondary suburban markets. The retail sector exhibited a slight
reduction in vacancies in the first quarter; the largest drop
since 2005. However, consumers continue to be cautious as
evidenced by sales growth continuing below historical trends.
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 outlook indicates the global
economy has lost momentum over the past quarter as it tries to
recover. US GDP growth for 2013 is likely to remain close to 2%,
however US sequestration cuts that came into effect in March may
create a drag on the positive growth in the US private sector.
While the broad economic impact in unclear, the direct effect is
likely to shave 0.4% off US GDP growth in 2013. Continuing from
the previous quarter, Moody's believes that the three most
immediate risks are: i) the risk of an even deeper than currently
expected recession in the euro area, accompanied by deeper credit
contraction, potentially triggered by a further intensification of
the sovereign debt crisis; ii) slower-than-expected recovery in
major emerging markets following the recent slowdown; and iii) an
escalation of geopolitical tensions, resulting in adverse economic
developments.

The V Score for this transaction is Medium/High. This V Score has
been assigned in a manner similar to the Medium/High V Score
assigned for the US CRE Derivatives sector, as described in the
special report titled, "V Scores and Parameter Sensitivities in
the U.S. CMBS Sector" dated March 27, 2009.

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

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


OCP CLO 2012-2: S&P Affirms 'BB' Rating on Class E Notes
--------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on OCP CLO
2012-2 Ltd./OCP CLO 2012-2 Corp.'s $471.875 million floating-rate
notes following the transaction's effective date as of Feb. 12,
2013.

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

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

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

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

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

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

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS AFFIRMED

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

Class                               Rating              Amount
                                                      (mil. $)
X-2                                 AAA (sf)              3.26
A1                                  AAA (sf)            162.50
A2                                  AAA (sf)            158.75
B                                   AA (sf)              65.63
C (deferrable)                      A (sf)               35.00
D (deferrable)                      BBB (sf)             22.50
E (deferrable)                      BB (sf)              20.00
Combination notes (deferrable)(i)   A (sf)              213.40

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


OCTAGON INVESTMENT V: Moody's Hikes Ratings on 4 CLO Note Classes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Octagon Investment Partners V, Ltd:

$21,000,000 Class B Senior Secured Deferrable Interest Notes due
November 28, 2018, Upgraded to Aaa (sf); previously on July 15,
2013 Upgraded to A1 (sf) and Placed Under Review for Possible
Upgrade

$12,000,000 Class C-1 Senior Secured Deferrable Interest Notes due
November 28, 2018, Upgraded to A3 (sf); previously on July 15,
2013 Ba1 (sf) Placed Under Review for Possible Upgrade

$3,000,000 Class C-2 Senior Secured Deferrable Interest Notes due
November 28, 2018, Upgraded to A3 (sf); previously on July 15,
2013 Ba1 (sf) Placed Under Review for Possible Upgrade

$4,500,000 Class D Subordinated Secured Deferrable Interest Notes
due November 28, 2018, Upgraded to Baa3 (sf); previously on July
15, 2013 Ba3 (sf) Placed Under Review for Possible Upgrade

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

$229,000,000 Class A-1 Senior Secured Notes due November 28, 2018,
(current outstanding balance of $92,239,843.33), Affirmed Aaa
(sf); previously on September 15, 2011 Upgraded to Aaa (sf)

$7,250,000 Class A-2 Senior Secured Notes (current outstanding
balance of $2,920,257.05), Affirmed Aaa (sf); previously on
September 15, 2011 Upgraded to Aaa (sf)

Ratings Rationale:

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the senior notes and an
increase in the transaction's overcollateralization ratios since
December 2012. Moody's notes that the Class A-1 and A-2 notes have
been paid down by approximately 60% or $141.1 million since the
end of the deal's reinvestment period in February 2012, including
$88.3 million since December 2012. Based on the latest trustee
report dated July 22, 2013, the Class A, Class B, Class C and
Class D overcollateralization ratios are reported at 160.7%,
131.7%,116.6% and 112.8%, respectively, versus December 2012
levels of 131.3%, 117.8%, 109.8%,107.6% respectively.

The rating actions taken on the notes also reflect a correction to
Moody's modeling of the priority of principal payments for the
Class D notes. Due to an input error at the time of the rating
action in September 2011, the Class D notes were incorrectly
modeled to receive principal pro-rata with the Class A-1 and A-2
notes, rather than receiving principal after the Class C notes.
This error has now been corrected, and these rating actions
reflect this change.

In taking the foregoing actions, Moody's also announced that it
had concluded its review of the rating on the issuer's Class B, C-
1, C-2 and D notes announced on July 15, 2013. At that time,
Moody's said that it had upgraded and placed certain of the
issuer's ratings on review primarily as a result of substantial
deleveraging of the senior notes and increases in OC ratios
resulting from high rates of loan collateral prepayments during
the first half of 2013.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, diversity
score, and weighted average recovery rate, are based on its
published methodology and 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 $152.96 million, no defaulted par, a weighted
average default probability of 16.09% (implying a WARF of 2525), a
weighted average recovery rate upon default of 48.46%, and a
diversity score of 42. The default and recovery properties of the
collateral pool are incorporated in cash flow model analysis where
they are subject to stresses as a function of the target rating of
each CLO liability being reviewed. The default probability is
derived from the credit quality of the collateral pool and Moody's
expectation of the remaining life of the collateral pool. The
average recovery rate to be realized on future defaults is based
primarily on the seniority of the assets in the collateral pool.
In each case, historical and market performance trends and
collateral manager latitude for trading the collateral are also
factors.

Octagon Investment Partners V, Ltd, issued in January 2003, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
May 2013.

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 Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2013.

In addition to the base case analysis, 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% (2020)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C-1: +3

Class C-2: +3

Class D: +2

Moody's Adjusted WARF + 20% (3030)

Class A-1: 0

Class A-2: 0

Class B: -1

Class C-1: -2

Class C-2: -2

Class D: -1

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

Sources of additional performance uncertainties:

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


PREFERRED TERM: Moody's Raises Rating on $88MM Notes From 'Ca'
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Preferred Term Securities, Ltd.

$90,000,000 Fixed Rate Mezzanine Notes (current balance
$88,184,210.66), Upgraded to Caa3 (sf); previously on October 22,
2010 Downgraded to Ca (sf).

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 as well
as the improvement in the credit quality of the underlying
portfolio since the last rating action in March 2012. Moody's
notes that the Senior notes have been paid down by approximately
$90 million since the last rating action, due to diversion of
excess interest proceeds and disbursement of principal proceeds
from redemptions of underlying assets. As a result of this
deleveraging, the Mezzanine Principal Coverage Test improved to
87.80% from 79.75% as calculated by Moody's. Going forward, the
Mezzanine Notes will continue to benefit from the diversion of
excess interest and the proceeds from future redemptions of any
assets in the collateral pool.

Moody's also notes that when the Senior Notes have been redeemed
the Mezzanine Notes will become senior and any missed current
interest payment on the notes may trigger an Event of Default.

Moody's also notes that the deal benefited from an improvement in
the credit quality of the underlying portfolio. Based on Moody's
calculation, the weighted average rating factor (WARF) improved to
843 compared to 1142 as of the last rating action date.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, diversity
score, and weighted average recovery rate, are based on its
published methodology and 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 $77.5
million , defaulted/deferring par of $59 million, a weighted
average default probability of 15.91% (implying a WARF of 843),
Moody's Asset Correlation of 33%, and a weighted average recovery
rate upon default of 10% In addition to the quantitative factors
that are explicitly modeled, qualitative factors are part of
rating committee considerations. Moody's considers the structural
protections in the transaction, the risk of triggering an Event of
Default, recent deal performance under current market conditions,
the legal environment, and specific documentation features. All
information available to rating committees, including
macroeconomic forecasts, inputs from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.

Preferred Term Securities, Ltd., issued on September 2000, is a
collateralized debt obligation backed by a portfolio of bank trust
preferred securities.

The portfolio of this CDO is mainly comprised of trust preferred
securities (TruPS) issued by small to medium sized U.S. community
banks that are generally not publicly rated by Moody's. To
evaluate the credit quality of bank TruPS without public ratings,
Moody's uses RiskCalc model, an econometric model developed by
Moody's KMV, to derive their credit scores. Moody's evaluation of
the credit risk for a majority of bank obligors in the pool relies
on FDIC financial data reported as of Q1-2013.

Moody's also evaluates the sensitivity of the rated transaction to
the volatility of the credit estimates, as described in Moody's
Cross Sector Rating Methodology "Updated Approach to the Usage of
Credit Estimates in Rated Transactions" published in October 2009.

The principal methodology used in this rating was "Moody's
Approach to Rating TRUP CDOs" published in May 2011.

The transaction's portfolio was modeled using CDOROM v.2.8 to
develop the default distribution from which the Moody's Asset
Correlation parameter was obtained. This parameter was then used
as an input in a cash flow model using CDOEdge.

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. Moody's analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased to 1700 points from the
base case of 843 the model-implied rating of the Mezzanine Notes
is one notch worse than the base case result. Similarly, if the
WARF is decreased to 750 points, the model-implied rating of the
Mezzanine Notes is one notch better than the base case result.

In addition, Moody's also performed a sensitivity analysis as
described in the Special Comment "Sensitivity Analyses on Deferral
Cures and Default Timing for Monitoring TruPS CDOs" published in
August 2012. Moody's ran alternative default-timing profile
scenarios to reflect the lower likelihood of a large spike in
defaults.

Summary of the impact 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:

Sensitivity Analysis:

Mezzanine Notes: +1

Moody's notes that this transaction is still subject to a high
level of macroeconomic uncertainty although its outlook on the
banking sector has changed to stable from negative. The pace of
FDIC bank failures continues to decline in 2013 compared to the
last few years, and some of the previously deferring banks have
resumed interest payment on their trust preferred securities.


PREFERRED TERM IX: Moody's Lifts Ratings on 3 Note Classes to Caa1
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by be Preferred Term Securities IX, Ltd.:

$245,000,000 Floating Rate Class A-1 Senior Notes Due April 3,
2033 (current balance of $78,564,218.82), Upgraded to Aaa (sf);
previously on August 5, 2013 Aa2 (sf) Placed Under Review for
Possible Upgrade;

$42,000,000 Floating Rate Class A-2 Senior Notes Due April 3,
2033, Upgraded to Aa2 (sf); previously on August 5, 2013 A2 (sf)
Placed Under Review for Possible Upgrade;

$33,000,000 Fixed/Floating Rate Class A-3 Senior Notes Due April
3, 2033, Upgraded to Aa2 (sf); previously on August 5, 2013 A2
(sf) Placed Under Review for Possible Upgrade;

$86,000,000 Floating Rate Class B-1 Mezzanine Notes Due April 3,
2033, Upgraded to Caa1 (sf); previously on March 27, 2009
Downgraded to Ca (sf);

$16,250,000 Fixed/Floating Rate Class B-2 Mezzanine Notes Due
April 3, 2033, Upgraded to Caa1 (sf); previously on March 27, 2009
Downgraded to Ca (sf);

$66,250,000 Fixed/Floating Rate Class B-3 Mezzanine Notes Due
April 3, 2033, Upgraded to Caa1 (sf); previously on March 27, 2009
Downgraded to Ca (sf).

Ratings Rationale:

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the Class A-1 notes, an
increase in the transaction's overcollateralization ratios, and an
improvement in the credit quality of the underlying portfolio
since September 2012.

Moody's notes that the Class A-1 Notes have been paid down by
approximately 44% or $61.7 million since September 2012, due to
disbursement of principal proceeds from redemptions of underlying
assets and diversion of excess interest proceeds. As a result of
this deleveraging, the Class A-1 notes' par coverage improved to
348% based on Moody's calculation. According to the latest trustee
report dated June 28, 2013, the Senior Principal Coverage Test is
reported at 177.95% (covenant 120%), versus September 2012 levels
of 147.73%. Going forward, the Class A-1 notes will continue to
benefit from the diversion of excess interest and the proceeds
from future redemptions of any assets in the collateral pool.

Moody's also notes that the deal benefited from an improvement in
the credit quality of the underlying portfolio. Based on Moody's
calculation, the weighted average rating factor (WARF) improved to
797 compared to 879 in March 2012. Since September 2012, two
previously deferring banks with a total par of $30 million have
resumed interest payments while four assets with a total par of
$52.8 million have redeemed at par.

In taking the foregoing actions, Moody's also announced that it
had concluded its review of its ratings on the issuer's Class A-1,
A-2 and A-3 Notes announced on August 5, 2013. At that time,
Moody's said that it had upgraded and placed certain of the
issuer's ratings on review primarily as a result of substantial
deleveraging of the senior notes, increases in the
overcollateralization (OC) ratios, and improvements in the credit
quality of the underlying portfolios.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, and
weighted average recovery rate are based on its published
methodology and 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 of $273.27 million,
defaulted/deferring par of $101.28 million, a weighted average
default probability of 17.22% (implying a WARF of 797), Moody's
Asset Correlation of 20.94%, and a weighted average recovery rate
upon default of 10%. In addition to the quantitative factors that
are explicitly modeled, qualitative factors are part of rating
committee considerations. Moody's considers the structural
protections in the transaction, the risk of triggering an Event of
Default, recent deal performance under current market conditions,
the legal environment, and specific documentation features. All
information available to rating committees, including
macroeconomic forecasts, inputs from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, may influence the
final rating decision.

Preferred Term Securities IX, Ltd., issued on March 26, 2003, is a
collateralized debt obligation backed by a portfolio of bank trust
preferred securities.

The portfolio of this CDO is mainly comprised of trust preferred
securities (TruPS) issued by small to medium sized U.S. community
banks that are generally not publicly rated by Moody's. To
evaluate the credit quality of bank TruPS without public ratings,
Moody's uses RiskCalc model, an econometric model developed by
Moody's KMV, to derive their credit scores. Moody's evaluation of
the credit risk for a majority of bank obligors in the pool relies
on FDIC financial data reported as of Q1-2013.

The principal methodology used in this rating was "Moody's
Approach to Rating TRUP CDOs" published in May 2011. Moody's also
evaluates the sensitivity of the rated transaction to the
volatility of the credit estimates, as described in Moody's Cross
Sector Rating Methodology "Updated Approach to the Usage of Credit
Estimates in Rated Transactions" published in October 2009.

The transaction's portfolio was modeled using CDOROM v.2.8.9 to
develop the default distribution from which the Moody's Asset
Correlation parameter was obtained. This parameter was then used
as an input in a cash flow model using CDOEdge.

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. Moody's analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased by 363 points from the
base case of 797, the model-implied rating of the A-1 notes is one
notch worse than the base case result.

In addition, Moody's also performed two additional sensitivity
analyses as described in the Special Comment "Sensitivity Analyses
on Deferral Cures and Default Timing for Monitoring TruPS CDOs"
published in August 2012. In the first sensitivity analysis,
Moody's gave par credit to banks that are deferring interest on
their TruPS but satisfy specific credit criteria and thus have a
strong likelihood of resuming interest payments. Under this
sensitivity analysis, Moody's gave par credit to $23.5 million of
bank TruPS. In the second sensitivity analysis, Moody's ran
alternative default-timing profile scenarios to reflect the lower
likelihood of a large spike in defaults.

Summary of the impact 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:

Sensitivity Analysis 1:

Class A-1: 0

Class A-2: 0

Class A-3: 0

Class B-1: +3

Class B-2: +3

Class B-3: +3

Sensitivity Analysis 2:

Class A-1: 0

Class A-2: 0

Class A-3: 0

Class B-1: +1

Class B-2: +1

Class B-3: +1

Moody's notes that this transaction is still subject to a high
level of macroeconomic uncertainty although Moody's outlook on the
banking sector has changed to stable from negative. The pace of
FDIC bank failures continues to decline in 2013 compared to the
last four years, and some of the previously deferring banks have
resumed interest payment on their trust preferred securities.


REVE SPC XVII: Moody's Raises Rating on $30MM Notes to 'Ba3'
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by REVE SPC Dryden XVII:

$25,000,000 UBS AG, London Branch CDS Reference Number 37585711
(DRYDEN XVII) (current balance 30,000,000) due September 20, 2014,
Upgraded to Ba3 (sf); previously on June 4, 2013 Reinstated to B1
(sf)

REVE SPC Dryden XVII, a corporate synthetic collateralized debt
obligation transaction. The CSO references a portfolio of
corporate senior unsecured and subordinated bonds.

Ratings Rationale:

Moody's upgrade rating action is the result of the shortened time
to maturity of the CSO, the level of credit enhancement remaining
in the transaction, and the improving credit quality of the
reference portfolio.

Since March 2011, the ten year weighted average rating factor
(WARF) of the portfolio has declined from 953 to 779, excluding
settled credit events. The credit quality of the portfolio
continues to improve with 9.3% of the portfolio rated B1 or below,
compared to 11.6% in March 2011.

The portfolio has experienced seven credit events on Federal Home
Loan Mortgage Corporation, Federal National Mortgage Association,
Lehman Brothers Holding Inc., Syncora Guarantee Inc., CIT Group
Inc., Ambac Assurance Corporation and Residential Capital LLC,
equivalent to 8.5% of the portfolio based on the portfolio
notional value at closing. Based on the June 2013 trustee report,
the subordination of the rated tranche has been reduced by 3.1%.

There are 1.1 years remaining until maturity.

The principal methodology used in this rating was "Moody's
Approach to Rating Corporate Collateralized Synthetic Obligations"
published in September 2009.

Moody's analysis for this transaction is based on CDOROM v2.8-9.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios. Results are given in terms of the number of
notches' difference versus the base case, where higher notches
correspond to lower expected losses, and vice-versa:

-- Moody's reviews a scenario consisting of reducing the maturity
    of the CSO by six months, keeping all other things equal. The
    result of this run is one notch higher than in the base case.

-- Market Implied Ratings ("MIRS") are modeled in place of the
    corporate fundamental ratings to derive the default
    probability of the reference entities in the portfolio. The
    gap between an MIR and a Moody's corporate fundamental rating
    is an indicator of the extent of the divergence in credit view
    between Moody's and the market. The result of this run is one
    notch lower than that of the base case.

-- Moody's performs a stress analysis consisting of defaulting
    all entities rated Caa1 and below. The result of this run is
    one notch lower than in the base case.

-- Moody's conducts a sensitivity analysis consisting of notching
    down by one the ratings of reference entities in the Banking,
    Finance, and Real Estate sectors. The result from this run is
    two notches below the one modeled under the base case.

-- This transaction has a 4.25% exposure to references in the
    Banking, Finance, Insurance and Real estate sector domiciled
    in Europe. Moody's conducted a stress scenario by applying a
    default probability to these references derived from the
    subordinated rating of the issuer and assigning a recovery
    rate of 90% if the reference is a senior unsecured bond, or
    10% if the reference is a subordinated bond. The result of
    this run is comparable to the base case.

Moody's notes that key model inputs used in its analysis are based
on the published methodology and may be different from the
manager/arranger's reported numbers. In particular, rating
assumptions for all publicly rated corporate credits in the
underlying portfolio have been adjusted for "Review for Possible
Downgrade", "Review for Possible Upgrade", or "Negative Outlook".

Moody's does not run a separate loss and cash flow analysis other
than the one already done by the CDOROM model. For a description
of the analysis, refer to the methodology and the CDOROM user's
guide on Moody's website.

Moody's analysis of CSOs is subject to uncertainties, the primary
sources of which include complexity, governance and leverage.
Although the CDOROM model captures many of the dynamics of the
Corporate CSO structure, it remains a simplification of the
complex reality. Of greatest concern are (a) variations over time
in default rates for instruments with a given rating, (b)
variations in recovery rates for instruments with particular
seniority/security characteristics and (c) uncertainty about the
default and recovery correlations characteristics of the reference
pool. Similarly on the legal/structural side, the legal analysis
although typically based in part on opinions (and sometimes
interpretations) of legal experts at the time of issuance, is
still subject to potential changes in law, case law and the
interpretations of courts and (in some cases) regulatory
authorities. The performance of this CSO is also dependent on on-
going decisions made by one or several parties, including the
Manager and the Trustee. Although the impact of these decisions is
mitigated by structural constraints, anticipating the quality of
these decisions necessarily introduces some level of uncertainty
in Moody's assumptions. Given the tranched nature of CSO
liabilities, rating transitions in the reference pool may have
leveraged rating implications for the ratings of the CSO
liabilities, thus leading to a high degree of volatility. All else
being equal, the volatility is likely to be higher for more junior
or thinner liabilities.

The base case scenario modeled fits into the central macroeconomic
scenario predicted by Moody's of a sluggish recovery scenario in
the corporate universe. Should macroeconomics conditions evolve,
the CSO ratings will change to reflect the new economic
developments.


RFSMI 2005-S7: Moody's Cuts Ratings on 3 RMBS Tranches
------------------------------------------------------
Moody's Investors Service has downgraded the ratings of three
tranches and upgraded the rating of one tranche from two RMBS
transactions issued by RFMSI. The actions impact approximately
$18.5 million of RMBS issued from 2005.

Complete rating actions are as follows:

Issuer: RFMSI Series 2005-S4 Trust

Cl. A-1, Upgraded to Ba1 (sf); previously on Jul 19, 2011
Confirmed at B1 (sf)

Issuer: RFMSI Series 2005-S7 Trust

Cl. A-4, Downgraded to Caa1 (sf); previously on Aug 30, 2012
Downgraded to B3 (sf)

Cl. A-5, Downgraded to Caa2 (sf); previously on Jul 19, 2011
Downgraded to Caa1 (sf)

Cl. A-7, Downgraded to C (sf); previously on Apr 12, 2010
Downgraded to Ca (sf)

Ratings Rationale:

The actions are a result of the recent performance of the
underlying pools and reflects Moody's updated loss expectations on
the pools. The downgrade rating actions reflect deterioration of
collateral performance. The upgrade rating action is a result of
faster pay-down of the bond due to high prepayments/fast
liquidations.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in June 2013.

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
8.2% in July 2012 to 7.4% in July 2013. Moody's forecasts an
unemployment central range of 7.0% to 8.0% for the 2013 year.
Moody's expects house prices to continue to rise in 2013.
Performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


RIALTO REAL: Servicing Rights Transfer No Impact on Ratings
-----------------------------------------------------------
Moody's Investors Service was informed that Rialto Real Estate
Fund, LP, as the Subordinate Class Representative, has elected to
terminate Midland Loan Services as the existing Special Servicer
(except with respect to the Port Charlotte Town Center
Participated Mortgage Loan) and to appoint Rialto Capital
Advisors, LLC (Rialto) as the successor Special Servicer (except
with respect to the Port Charlotte Town Center Participated
Mortgage Loan). The Proposed Special Servicer Transfer and
Replacement will become effective upon satisfaction of the
conditions precedent set forth in the governing documents.

Moody's has reviewed the Proposed Special Servicer Replacement.
Moody's has determined that this proposed special servicing
replacement will not, in and of itself, and at this time, result
in a downgrade or withdrawal of the current ratings to any class
of certificates rated by Moody's for WF-RBS Commercial Mortgage
Trust 2011-C2, Commercial Mortgage Pass-Through Certificates,
Series 2011-C2 (the Certificates). Moody's opinion only addresses
the credit impact associated with the proposed designation and
transfer of special servicing rights. Moody's is not expressing
any opinion as to whether this change has, or could have, other
non-credit related effects that may have a detrimental impact on
the interests of note holders and/or counterparties.

The last rating action for WF-RBS 2011-C2 was taken on March 7,
2013.

The principal methodology used in this rating was "Moody's
Approach to Rating Fusion U.S. CMBS Transactions" published in
April 2005.

On March 7, 2013, Moody's affirmed the ratings of 11 classes of
WF-RBS Commercial Mortgage Trust 2011-C2, Commercial Mortgage
Pass-Through Certificates, Series 2011-C2 as follows:

Cl. A-1, Affirmed Aaa (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Aaa (sf)

Cl. A-2, Affirmed Aaa (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Aaa (sf)

Cl. A-3, Affirmed Aaa (sf); previously on Mar 11, 2011 Assigned
Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on Mar 11, 2011 Assigned
Aaa (sf)

Cl. B, Affirmed Aa2 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed A2 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned A2 (sf)

Cl. D, Affirmed Baa3 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Baa3 (sf)

Cl. E, Affirmed Ba2 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Ba2 (sf)

Cl. F, Affirmed B2 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned B2 (sf)

Cl. X-A, Affirmed Aaa (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Aaa (sf)

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


SANDELMAN REALTY I: Moody's Lifts Ratings on Four Note Classes
--------------------------------------------------------------
Moody's has upgraded the ratings of four classes and affirmed the
ratings of four classes of Notes issued by Sandelman Realty CRE
CDO I, Ltd. The upgrades are due to rapid redemption of the senior
Notes as a result of the sale of assets since last review. The
affirmations are due to key transaction parameters performing
within levels commensurate with the existing ratings levels. The
rating action is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation and
collateralized loan obligation (CRE CDO CLO) transactions.

Moody's rating action is as follows:

Cl. C, Upgraded to B2 (sf); previously on Aug 27, 2010 Downgraded
to Ca (sf)

Cl. D, Upgraded to Caa2 (sf); previously on Aug 27, 2010
Downgraded to C (sf)

Cl. E, Upgraded to Caa3 (sf); previously on Aug 27, 2010
Downgraded to C (sf)

Cl. F, Upgraded to Caa3 (sf); previously on Aug 27, 2010
Downgraded to C (sf)

Cl. G, Affirmed C (sf); previously on Aug 27, 2010 Downgraded to C
(sf)

Cl. J, Affirmed C (sf); previously on Aug 27, 2010 Downgraded to C
(sf)

Cl. K, Affirmed C (sf); previously on Aug 27, 2010 Downgraded to C
(sf)

Cl. L, Affirmed C (sf); previously on Aug 27, 2010 Downgraded to C
(sf)

Ratings Rationale:

Sandelman Realty CRE CDO I, Ltd. is a currently static
(reinvestment period ended in March 2012) cash transaction backed
by a portfolio of whole loans (75.1% of the pool balance),
mezzanine loans (16.0%), and CRE CDO (8.9%). As of the July 18,
2013 Trustee report, the aggregate Note balance of the
transaction, including preferred shares, has decreased to $ 109.7
million from $507.0 million at issuance, with full paydown of the
A-1, A-2, and B Notes and partial paydown directed to the C Notes.
In addition to the paydown, the Note balance has also decreased as
a result of cancellation of junior Notes. In general, holding all
key parameters static, the junior note cancellations results in
slightly higher expected losses and longer weighted average lives
on the senior Notes, while producing slightly lower expected
losses on the mezzanine and junior Notes. However, this does not
cause, in and of itself, a downgrade or upgrade of any outstanding
classes of notes.

There is one asset with a par balance of $42.3 million (75.2% of
the current pool balance) that is considered defaulted as of the
July 18, 2013 Trustee report, compared to three defaulted
securities totaling $66.7 million par amount at last review.
Moody's does expect moderate losses to occur on the defaulted
asset once it is realized.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated assessments for the non-Moody's
rated collateral. Moody's modeled a bottom-dollar WARF of 8,360
compared to 5,650 at last review. The current distribution of
Moody's rated collateral and assessments for non-Moody's rated
collateral is as follows: Ba1-Ba3 (8.9% compared to 13.1% at last
review), and Caa1-C (91.1% compared to 60.1% at last review).

Moody's modeled a WAL of 3.1 years, the same as at last review.
The current WAL is based on the assumption about extensions on the
underlying collateral assets.

Moody's modeled a fixed WARR of 34.4%, compared to 28.8% at last
review.

Moody's modeled a MAC of 0%, compared to 9.6% at last review.

Moody's review incorporated CDOROM v2.8, one of Moody's CDO rating
models, which was released on March 25, 2013.

The cash flow model, CDOEdge v3.2.1.2, released on May 16, 2013,
was used to analyze the cash flow waterfall and its effect on the
capital structure of the deal.

Moody's analysis encompasses the assessment of stress scenarios.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
34.4% to 24.4% or up to 44.4% would result in a modeled rating
movement on the rated tranches 0 to 9 notches downward and 0 to 8
notches upward, respectively.

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

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment given the weak pace of
recovery in the 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 continues to exhibit growth albeit at a slightly
slower pace. The multifamily sector should remain stable with
moderate growth. Gradual recovery in the office sector continues
and will be assisted in the next quarter when absorption is likely
to outpace completions. However, since office demand is closely
tied to employment, Moody's expects regional employment growth to
provide market differentiation. CBD markets continue to outperform
secondary suburban markets. The retail sector exhibited a slight
reduction in vacancies in the first quarter; the largest drop
since 2005. However, consumers continue to be cautious as
evidenced by sales growth continuing below historical trends.
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 outlook indicates the global
economy has lost momentum over the past quarter as it tries to
recover. US GDP growth for 2013 is likely to remain close to 2%,
however US sequestration cuts that came into effect in March may
create a drag on the positive growth in the US private sector.
While the broad economic impact in unclear, the direct effect is
likely to shave 0.4% off US GDP growth in 2013. Continuing from
the previous quarter, Moody's believes that the three most
immediate risks are: i) the risk of an even deeper than currently
expected recession in the euro area, accompanied by deeper credit
contraction, potentially triggered by a further intensification of
the sovereign debt crisis; ii) slower-than-expected recovery in
major emerging markets following the recent slowdown; and iii) an
escalation of geopolitical tensions, resulting in adverse economic
developments.

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


SDART 2013-A: S&P Assigns Prelim. 'BB+' Rating on Class E Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Santander Drive Auto Receivables Trust 2013-A's
$800.00 million asset-backed notes.

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

The preliminary ratings are based on information as of Aug. 14,
2013.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

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

   -- The availability of 49.67%, 43.49%, 34.75%, 30.64%, and
      26.06% of credit support for the class A, B, C, D, and E
      notes, respectively, based on stress cash flow scenarios
      (including excess spread), which provide coverage of more
      than 3.50x, 3.00x, 2.30x, 1.93x, and 1.60x S&P's 13.50%-
      14.50% expected cumulative net loss.

   -- The timely interest and principal payments made under
      stressed cash flow modeling scenarios appropriate to the
      assigned preliminary ratings.

   -- S&P's expectation that under a moderate ('BBB') stress
      scenario, all else being equal, its ratings on the class A,
      B, and C notes will remain within one rating category of the
      assigned preliminary ratings during the first year, and its
      ratings on the class D and E notes will remain within two
      rating categories of the assigned preliminary ratings, which
      is within the outer bounds of our credit stability criteria

   -- The originator/servicer's history in the subprime/specialty
      auto finance business.

   -- S&P's analysis of eight years of static pool data on
      Santander Consumer USA Inc.'s lending programs.

   -- The transaction's payment/credit enhancement and legal
      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 Standard & Poor's 17g-7 Disclosure Report included in this
credit rating report is available at:

        http://standardandpoorsdisclosure-17g7.com/1737.pdf

PRELIMINARY RATINGS ASSIGNED

Santander Drive Auto Receivables Trust 2013-A

Class    Rating      Type          Interest         Amount
                                   rate        (mil. $)(i)
A-1      A-1+ (sf)   Senior        Fixed            114.00
A-2      AAA (sf)    Senior        Fixed            227.00
A-3      AAA (sf)    Senior        Fixed            176.26
B        AA (sf)     Subordinate   Fixed             85.48
C        A (sf)      Subordinate   Fixed            105.21
D        BBB+ (sf)   Subordinate   Fixed             48.22
E        BB+ (sf)    Subordinate   Fixed             43.83

(i) The interest rates and actual sizes of these tranches will be
    determined on the pricing date.


SHASTA CLO I: Moody's Affirms Ba2 Rating on $18MM of CLO Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Shasta CLO I Ltd.:

$38,000,000 Class A-2L Floating Rate Notes Due April 2021,
Upgraded to Aa1 (sf); previously on July 18, 2011 Upgraded to Aa2
(sf);

$26,000,000 Class A-3L Floating Rate Notes Due April 2021,
Upgraded to A2 (sf); previously on July 18, 2011 Upgraded to A3
(sf).

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

$296,000,000 Class A-1L Floating Rate Notes Due April 2021
(current balance of $286,570,908), Affirmed Aaa (sf); previously
on July 18, 2011 Upgraded to Aaa (sf);

$45,000,000 Class A-1LV Floating Rate Revolving Notes Due April
2021 (current balance of $43,566,523), Affirmed Aaa (sf);
previously on July 18, 2011 Upgraded to Aaa (sf);

$18,000,000 Class B-1L Floating Rate Notes Due April 2021,
Affirmed Baa3 (sf); previously on July 18, 2011 Upgraded to Baa3
(sf);

$18,000,000 Class B-2L Floating Rate Notes Due April 2021,
Affirmed Ba2 (sf); previously on July 18, 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 October 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 weighted average rating factor
(WARF) level of 2491 compared to the current covenant of 2950.
Additionally, the deal benefited from increases in modeled
weighted average spread (WAS) and weighted average recovery rate
(WARR). Moody's notes that the transaction's reported collateral
quality and overcollateralization ratio are stable since the last
rating action.

Moody's also notes that the key model inputs used by Moody's in
its analysis, such as par, weighted average rating factor,
diversity score, and weighted average recovery rate, are based on
its published methodology and 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 $446.9 million, defaulted par of $13.3
million, a weighted average default probability of 16.70%
(implying a WARF of 2491), a weighted average recovery rate upon
default of 49.17%, and a diversity score of 66. The default and
recovery properties of the collateral pool are incorporated in
cash flow model analysis where they are subject to stresses as a
function of the target rating of each CLO liability being
reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Shasta CLO I Ltd., issued in January 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 Global
Approach to Rating Collateralized Loan Obligations" published in
May 2013.

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 Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in May 2013.

In addition to the base case analysis, 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% (1993)

Class A-1L: 0

Class A-1LV: 0

Class A-2L: 0

Class A-3L: +3

Class B-1L: +3

Class B-2L: +1

Moody's Adjusted WARF + 20% (2989)

Class A-1L: 0

Class A-1LV: 0

Class A-2L: -2

Class A-3L: -2

Class B-1L: -1

Class B-2L: -1

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

Sources of additional performance uncertainties:

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.


SOLOMON MORTGAGE 2001-CB4: Amendments No Impact on Moody's Ratings
------------------------------------------------------------------
After the analysis of the credit impact of a proposal by Ocwen
Loan Servicing, LLC to amend its servicing agreement related to
the Solomon Mortgage Loan Trust, Series 2001-CB4, C-Bass Mortgage
Loan Asset Backed Notes to allow a servicer advance financing
facility to provide funding for Ocwen's advances and accrued but
unpaid servicing fees, Moody's Investors Service stated that such
amendment, in and of itself and at this time, did not result in
the downgrade or withdrawal of Moody's current ratings of the
securities issued in the affected transaction.

As a servicer for the affected transaction, Ocwen requested that
Moody's provide its opinion on whether the ratings of the
securities issued by the affected transaction, would be downgraded
or withdrawn as a result of its proposal.

Moody's believed that the proposal did not have an adverse effect
on the credit quality of the securities such that the Moody's
ratings were impacted. Moody's did not express an opinion as to
whether the proposal could have other, noncredit-related effects.

Moody's view is based primarily on its opinion that the amendments
do not alter the servicer's advancing obligations.

On July 23, 2012, Moody's corrected the watch status of two
tranches and downgraded the rating of one of these tranches from
C-BASS Mortgage Loan Asset Backed Notes, Series 2001-CB4, backed
by closed end second lien loans. Complete rating actions were as
follows:

Issuer: C-Bass Mortgage Loan Asset Backed Notes, Series 2001-CB4

Cl. IIM-2, Downgraded to Ba1 (sf); previously on Nov 3, 2010
Downgraded to Baa1 (sf)


STUDENT LOAN 2007-1: S&P Puts 'B-' Rating on CreditWatch Negative
-----------------------------------------------------------------
Standard & Poor's Ratings Services placed its 'B-' ratings on
Student Loan ABS Repackaging Trust Series 2007-1's class 6-A-l and
6-A-IO certificates on CreditWatch with negative implications.

The ratings on the class 6-A-l and 6-A-IO certificates are
dependent on the lower of: (i) the rating on Transferable Custody
Receipts relating to NCF Grantor Trust 2005-3, Series 2005-GT3 due
2033 class A-5-1 ('B- (sf)/Watch Neg); and (ii) the rating on
Deutsche Bank AG ('A/A-1').

The rating actions follows S&P's July 30, 2013, placement of its
'B- (sf)' rating on the underlying security on CreditWatch with
negative implications.  S&P could take subsequent rating actions
on the custody receipts due to changes in its rating on the
underlying security.

         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


TABERNA PREFERRED III: Ratings Unchanged Following Trustee Switch
-----------------------------------------------------------------
Moody's Investors Service has determined that appointment of
Deutsche Bank Trust Company Americas ("DBTCA") as Successor
Trustee pursuant to an Appointment and Assumption Agreement (the
"Agreement), dated as of August 8, 2013 by and among Taberna
Preferred Funding III, Ltd., as Issuer, Taberna Preferred Funding
III, Inc., as Co-Issuer and collectively, with the Issuer, the
"Co-Issuers", The Bank of New York Mellon Trust Company, National
Association (successor to JPMorgan Chase Bank, National
Association) as Retiring Trustee, DBTCA, as Successor Trustee and
TP Management LLC, as collateral manager, will not at this time
result in the withdrawal, reduction, or other adverse action of
Moody's current ratings of any class of notes issued by the
Issuer. Moody's does not express an opinion as to whether the
appointment of the Successor Trustee could have non-credit related
effects.

Moody's has been informed that the appointment of DBTCA as
Successor Trustee received the consent of the majority of the
Controlling Class.

In conjunction with its removal as Trustee, the Retiring Trustee
resigns as Calculation Agent, Collateral Administrator, Custodian,
Note Registrar, Preferred Share Paying Agent and all other
capacities under the indenture and the other Transaction
Documents.

Moody's carries these ratings for Taberna Preferred III:

Class A-1a; Caa2
Class A-1b; Caa2
Class A-1c; Caa2
Class A-2a; Caa3


TRAPEZA CDO VII: Moody's Affirms Ca Ratings on 2 Debt Classes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Trapeza CDO VII, Ltd.:

$194,000,000 Class A-1 First Priority Senior Secured Floating Rate
Notes Due 2035 (current balance of $105,957,416.97), Upgraded to
Aa2 (sf); previously on August 5, 2013 Upgraded to A2 (sf) and
Placed Under Review for Possible Upgrade;

$32,000,000 Class A-2 Second Priority Senior Secured Floating Rate
Notes Due 2035, Upgraded to A2 (sf); previously on August 5, 2013
Upgraded to Baa2 (sf) and Placed Under Review for Possible
Upgrade.

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

$56,600,000 Class B-1 Third Priority Secured Floating Rate Notes
Due 2035 (current balance of $61,579,248.60 including interest
shortfall), Affirmed Ca (sf); previously on March 27, 2009
Downgraded to Ca (sf);

$37,500,000 Class B-2 Third Priority Secured Fixed/Floating Rate
Notes Due 2035 (current balance of $41,754,926.46 including
interest shortfall), Affirmed Ca (sf); previously on March 27,
2009 Downgraded to Ca (sf).

Rationale:

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of Class A-1 Notes, increase in
the transaction's overcollateralization ratios and improvement in
the credit quality of the underlying portfolio since the last
review in 2012. In taking the foregoing actions, Moody's also
announced that it had concluded its review of its ratings on the
issuer's Class A-1 Notes and Class A-2 Notes announced on August
05, 2013. At that time, Moody's said that it had upgraded and
placed certain of the issuer's ratings on review primarily as a
result of substantial deleveraging of the senior notes, increases
in the overcollateralization (OC) ratios, and improvements in the
credit quality of the underlying portfolios.

Moody's notes that the Class A-1 Notes have been paid down by
approximately 16.5% or $20.9 million since August 2012, due to
diversion of excess interest proceeds and disbursement of
unscheduled principal proceeds from redemptions of underlying
assets. As a result of this deleveraging, the Class A-1 Notes' par
coverage improved to 176.1% from 129.3%, as calculated by Moody's.
Based on the latest trustee report dated July 19, 2013, the Class
A Overcollateralization Test is 135.1% (limit 138.1%), versus the
August 2012 level of 120.9%. Going forward, the Class A-1 notes
will continue to benefit from the diversion of excess interest and
the proceeds from future redemptions of any assets in the
collateral pool.

Moody's also notes that the deal benefited from an improvement in
the credit quality of the underlying portfolio. Based on Moody's
calculation, the weighted average rating factor (WARF) improved to
801 compared to 885 as of the last rating action date. The total
par amount that Moody's treated as defaulted or deferring declined
to $80.9 million compared to $90.9 million as of August 2012. The
decline is due to improvement in the credit quality and the
financial ratios of the banks that issued the two assets that were
assumed to be defaulted in the last review.

Moody's observed that the Class B notes continue to defer interest
due to Class A Overcollateralization test failure which results in
diversion of excess interest to pay the senior notes until the
coverage test is cured.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, and
weighted average recovery rate, are based on its published
methodology and 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 of $186.7 million,
defaulted/deferring par of $80.9 million, a weighted average
default probability of 18.58% (implying a WARF of 801), Moody's
Asset Correlation of 22.78%, and a weighted average recovery rate
upon default of 10%. In addition to the quantitative factors that
are explicitly modeled, qualitative factors are part of rating
committee considerations.

Moody's considers the structural protections in the transaction,
the risk of triggering an Event of Default, recent deal
performance under current market conditions, the legal
environment, and specific documentation features. All information
available to rating committees, including macroeconomic forecasts,
inputs from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, may influence the final rating decision.

Trapeza CDO VII, Ltd., issued on October 2004, is a collateralized
debt obligation backed by a portfolio of bank trust preferred
securities.

The portfolio of this CDO is mainly comprised of trust preferred
securities (TruPS) issued by small to medium sized U.S. community
banks that are generally not publicly rated by Moody's. To
evaluate the credit quality of bank TruPS without public ratings,
Moody's uses RiskCalc model, an econometric model developed by
Moody's KMV, to derive their credit scores. Moody's evaluation of
the credit risk for a majority of bank obligors in the pool relies
on FDIC financial data reported as of Q1-2013.

The principal methodology used in this rating was "Moody's
Approach to Rating TRUP CDOs" published in May 2011.

Moody's also evaluates the sensitivity of the rated transaction to
the volatility of the credit estimates, as described in Moody's
Cross Sector Rating Methodology "Updated Approach to the Usage of
Credit Estimates in Rated Transactions" published in October 2009.

The transaction's portfolio was modeled using CDOROM v.2.8 to
develop the default distribution from which the Moody's Asset
Correlation parameter was obtained. This parameter was then used
as an input in a cash flow model using CDOEdge.

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. Moody's analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased by 79 points from the
base case of 801, the model-implied rating of the Class A-1 Notes
is one notch worse than the base case result. Similarly, if the
WARF is decreased by 191 points, the model-implied rating of the
Class A-1 Notes is one notch better than the base case result.

In addition, Moody's also performed two additional sensitivity
analyses as described in the Special Comment "Sensitivity Analyses
on Deferral Cures and Default Timing for Monitoring TruPS CDOs"
published in August 2012. In the first, Moody's gave par credit to
banks that are deferring interest on their TruPS but satisfy
specific credit criteria and thus have a strong likelihood of
resuming interest payments. Under this sensitivity analysis,
Moody's gave par credit to $15 million of bank TruPS. In the
second sensitivity analysis, it ran alternative default-timing
profile scenarios to reflect the lower likelihood of a large spike
in defaults.

Summary of the impact 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:

Sensitivity Analysis 1:

Class A-1: 0

Class A-2: +1

Class B-1: +2

Class B-2: +2

Sensitivity Analysis 2:

Class A-1: 0

Class A-2: +1

Class B-1: 0

Class B-2: 0

Moody's notes that this transaction is still subject to a high
level of macroeconomic uncertainty although Moody's outlook on the
banking sector has changed to stable from negative. The pace of
FDIC bank failures continues to decline in 2013 compared to the
last few years, and some of the previously deferring banks have
resumed interest payment on their trust preferred securities.


TROPIC CDO II: Moody's Upgrades Rating on $35MM Cl. C Notes to B2
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Tropic CDO II, Ltd:

$145,000,000 Class A-1L Floating Rate Notes due April 2034
(current balance of $89,494,406.78), Upgraded to A1 (sf);
previously on August 5, 2013 Upgraded to A2 (sf) and Placed Under
Review for Possible Upgrade

$50,000,000 Class A-2L Floating Rate Notes due April 2034,
Upgraded to Baa2 (sf); previously on August 5, 2013 Upgraded to
Baa3 (sf) and Placed Under Review for Possible Upgrade

$35,000,000 Class A-3L Floating Rate Notes due April 2034,
Upgraded to B2 (sf); previously on August 5, 2013 Upgraded to Caa1
(sf) and Placed Under Review for Possible Upgrade

Ratings Rationale:

According to Moody's, the rating actions taken on the notes are
primarily a result of deleveraging of the Class A-1L Notes, an
increase in the transaction's overcollateralization ratios. The
deleveraging is due to the redemption of underlying assets and
diversion of excess interest after paying interest on the Class A-
1L, A-2L, and A-3L Notes. Moody's notes that the Class A-4L, A-4
and B-1L notes continue to defer interest due to the failure of
the Senior overcollateralization (OC) test.

Moody's notes that the Class A-1L Notes have been paid down by
approximately 16.2% or $17.3 million since October 2012, due to
the diversion of excess interest proceeds and disbursement of
principal proceeds from redemptions of underlying assets. Since
October 2012, two previously deferring banks with a total par of
$20 million have resumed interest payments while three assets with
a total par of $13.9 million have redeemed at par. As a result,
the Class A-1L notes' par coverage improved to 212% based on
Moody's calculation. According to the latest trustee report dated
July 8, 2013, the Senior, and Subordinate OC ratios are reported
at 109.02% (limit 120%) and 74.09% (limit 104.00%) respectively,
versus September 2012 levels of 95.74%, and 67.10%, respectively.
Going forward, the Class A-1L notes will continue to benefit from
the diversion of excess interest and the proceeds from future
redemptions of any assets in the collateral pool.

In taking the foregoing actions, Moody's also announced that it
had concluded its review of its ratings on the issuer's Class A-
1L, A-2L and A-3L Notes announced on August 5, 2013. At that time,
Moody's said that it had upgraded and placed certain of the
issuer's ratings on review primarily as a result of substantial
deleveraging of the senior notes, increases in the OC ratios, and
improvements in the credit quality of the underlying portfolios.

Moody's notes that the key model inputs used by Moody's in its
analysis, such as par, weighted average rating factor, and
weighted average recovery rate are based on its published
methodology and 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 $189.7million, defaulted/deferring par of
$109.6million, a weighted average default probability of 20.63%
(implying a WARF of 1351), Moody's Asset Correlation of 18.43%,
and a weighted average recovery rate upon default of 10%. In
addition to the quantitative factors that are explicitly modeled,
qualitative factors are part of rating committee considerations.
Moody's considers the structural protections in the transaction,
the risk of triggering an Event of Default, recent deal
performance under current market conditions, the legal
environment, and specific documentation features. All information
available to rating committees, including macroeconomic forecasts,
inputs from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, may influence the final rating decision.

Tropic CDO II, Ltd, issued on October 15, 2003, is a
collateralized debt obligation backed by a portfolio of bank and
REIT trust preferred securities.

The portfolio of this CDO is mainly comprised of trust preferred
securities (TruPS) issued by small to medium sized U.S. community
banks that are generally not publicly rated by Moody's. To
evaluate the credit quality of bank TruPS without public ratings,
Moody's uses RiskCalc model, an econometric model developed by
Moody's KMV, to derive their credit scores. Moody's evaluation of
the credit risk for a majority of bank obligors in the pool relies
on FDIC financial data reported as of Q1-2013. For REIT TruPS
without public ratings by Moody's, their credit quality is
assessed by Moody's REIT group using the REIT firms annual
financial reporting.

The methodologies used in this rating were "Moody's Approach to
Rating TRUP CDOs" published in May 2011, and "Updated Approach to
the Usage of Credit Estimates in Rated Transactions" published in
October 2009.

Moody's also evaluates the sensitivity of the rated transaction to
the volatility of the credit estimates, as described in Moody's
Cross Sector Rating Methodology "Updated Approach to the Usage of
Credit Estimates in Rated Transactions" published in October 2009.

The transaction's portfolio was modeled using CDOROM v.2.8.9 to
develop the default distribution from which the Moody's Asset
Correlation parameter was obtained. This parameter was then used
as an input in a cash flow model using CDOEdge.

Moody's performed a number of sensitivity analyses of the results
to certain key factors driving the ratings. Moody's analyzed the
sensitivity of the model results to changes in the portfolio WARF
(representing an improvement or a deterioration in the credit
quality of the collateral pool), assuming that all other factors
are held equal. If the WARF is increased by 79 points from the
base case of 1351, the model-implied rating of the A-1L notes is
one notch worse than the base case result. Similarly, if the WARF
is decreased by 211 points, the model-implied rating of the A-1L
notes is one notch better than the base case result.

In addition, Moody's also performed two additional sensitivity
analyses as described in the Special Comment "Sensitivity Analyses
on Deferral Cures and Default Timing for Monitoring TruPS CDOs"
published in August 2012. In the first sensitivity analysis,
Moody's gave par credit to banks that are deferring interest on
their TruPS but satisfy specific credit criteria and thus have a
strong likelihood of resuming interest payments. Under this
sensitivity analysis, Moody's gave par credit to $23.5 million of
bank TruPS. In the second sensitivity analysis, Moody's ran
alternative default-timing profile scenarios to reflect the lower
likelihood of a large spike in defaults.

Summary of the impact 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:

Sensitivity Analysis 1:

Class A-1L: +1

Class A-2L: +2

Class A-3L: +3

Class A-4L: +0

Class A-4: +0

Class B-1L: +0

Sensitivity Analysis 2:

Class A-1L: +0

Class A-2L: +1

Class A-3L: +1

Class A-4L: +0

Class A-4: +0

Class B-1L: +0

Moody's notes that this transaction is still subject to a high
level of macroeconomic uncertainty although Moody's outlook on the
banking sector has changed to stable from negative. The pace of
FDIC bank failures continues to decline in 2013 compared to the
last four years, and some of the previously deferring banks have
resumed interest payment on their trust preferred securities.


UBS-CITIGROUP 2011-C1: Rights Transfer No Impact on Ratings
-----------------------------------------------------------
Moody's Investors Service was informed that Rialto Real Estate
Fund, LP, as the Lead Directing Holder, and RREF CMBS AIV, LP, as
the Non-Lead Directing Holder, have elected to terminate Midland
Loan Services (Midland) as both the existing Special Servicer and
Pari Passu Loan Combination Special Servicer and to appoint Rialto
Capital Advisors, LLC, (Rialto) as the successor Special Servicer
and Pari Passu Loan Combination Special Servicer. The Proposed
Special Servicer Transfer and Replacement will become effective
upon satisfaction of the conditions precedent set forth in the
governing documents.

Moody's has reviewed the Proposed Special Servicer Replacement.
Moody's has determined that this proposed special servicing
replacement will not, in and of itself, and at this time, result
in a downgrade or withdrawal of the current ratings to any class
of certificates rated by Moody's for UBS-Citigroup Commercial
Mortgage Trust 2011-C1, Commercial Mortgage Pass-Through
Certificates, Series 2011-C1 (the Certificates). Moody's opinion
only addresses the credit impact associated with the proposed
designation and transfer of special servicing rights. Moody's is
not expressing any opinion as to whether this change has, or could
have, other non-credit related effects that may have a detrimental
impact on the interests of note holders and/or counterparties.

The last rating action for UBSC 2011-C1 was taken on November 20,
2012. The principal methodology used in this rating was "Moody's
Approach to Rating U.S. CMBS Conduit Transactions" published in
September 2000.

On January 4, 2012, Moody's assigned ratings to thirteen classes
of CMBS securities, issued by UBS-Citigroup Commercial Mortgage
Trust Commercial Mortgage Pass-Through Certificates 2011-C1.

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

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

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

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

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

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

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

Cl. B, Definitive Rating Assigned Aa2 (sf)

Cl. C, Definitive Rating Assigned A2 (sf)

Cl. D, Definitive Rating Assigned Baa1 (sf)

Cl. E, Definitive Rating Assigned Baa3 (sf)

Cl. F, Definitive Rating Assigned Ba2 (sf)

Cl. G, Definitive Rating Assigned B2 (sf)


UBS-CITIGROUP 2012-C1: Rights Transfer No Impact on Ratings
-----------------------------------------------------------
Moody's Investors Service was informed that RREF CMBS AIV, LP, as
the Directing Holder, has elected to terminate Midland Loan
Services (Midland) as both the existing Special Servicer and Pari
Passu Loan Combination Special Servicer and to appoint Rialto
Capital Advisors, LLC, (Rialto) as the successor Special Servicer
and Pari Passu Loan Combination Special Servicer. The Proposed
Special Servicer Transfer and Replacement will become effective
upon satisfaction of the conditions precedent set forth in the
governing documents.

Moody's has reviewed the Proposed Special Servicer Replacement.
Moody's has determined that this proposed special servicing
replacement will not, in and of itself, and at this time, result
in a downgrade or withdrawal of the current ratings to any class
of certificates rated by Moody's for UBS-Citigroup Commercial
Mortgage Trust 2012-C1, Commercial Mortgage Pass-Through
Certificates, Series 2012-C1 (the Certificates). Moody's opinion
only addresses the credit impact associated with the proposed
designation and transfer of special servicing rights. Moody's is
not expressing any opinion as to whether this change has, or could
have, other non-credit related effects that may have a detrimental
impact on the interests of note holders and/or counterparties.

The last rating action for UBSC 2012-C1 was taken on April 11,
2013. The principal methodology used in this rating was "Moody's
Approach to Rating U.S. CMBS Conduit Transactions" published in
September 2000.

On April 11, 2013, Moody's affirmed the ratings of 12 classes of
UBS Commercial Mortgage Trust 2012-C1, Commercial Mortgage Pass-
Through Certificates, Series 2012-C1 as follows:

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

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

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

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

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

Cl. B, Affirmed Aa2 (sf); previously on May 9, 2012 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed A2 (sf); previously on May 9, 2012 Definitive
Rating Assigned A2 (sf)

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

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

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

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

Cl. X-B, Affirmed Ba3 (sf); previously on May 9, 2012 Definitive
Rating Assigned Ba3 (sf)


VIBRANT CLO II: S&P Assigns Preliminary B Rating on Class E Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Vibrant CLO II Ltd./Vibrant CLO II LLC's
$335.40 million floating- and fixed-rate notes.

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

The preliminary ratings are based on information as of Aug. 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 asset manager's experienced management team.

   -- 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 0.2654%-12.5332%.

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

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

          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/1729.pdf

PRELIMINARY RATINGS ASSIGNED

Vibrant CLO II Ltd./Vibrant CLO II LLC
Class                     Rating                   Amount
                                                 (mil. $)
A-1                       AAA (sf)                 214.80
A-2A                      AA (sf)                   35.10
A-2B                      AA (sf)                   10.00
B (deferrable)            A (sf)                    28.90
C (deferrable)            BBB (sf)                  18.80
D (deferrable)            BB (sf)                   16.40
E (deferrable)            B (sf)                    11.40
Subordinated notes        NR                        31.50
M (deferrable)            NR                         1.00

NR-Not rated.


WACHOVIA BANK 2003-C7: Moody's Cuts Rating on X-C Debt to B1
------------------------------------------------------------
Moody's Investors Service downgraded the ratings of one class and
affirmed 14 classes of Wachovia Bank Commercial Mortgage Trust,
Commercial Mortgage Pass-Through Certificates, Series 2003-C7 as
follows:

Cl. A-2, Affirmed Aaa (sf); previously on Nov 6, 2003 Definitive
Rating Assigned Aaa (sf)

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

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

Cl. D, Affirmed Aa2 (sf); previously on Aug 21, 2008 Upgraded to
Aa2 (sf)

Cl. E, Affirmed A3 (sf); previously on Aug 16, 2012 Downgraded to
A3 (sf)

Cl. F, Affirmed Ba1 (sf); previously on Aug 16, 2012 Downgraded to
Ba1 (sf)

Cl. G, Affirmed B1 (sf); previously on Aug 16, 2012 Downgraded to
B1 (sf)

Cl. H, Affirmed B3 (sf); previously on Aug 16, 2012 Downgraded to
B3 (sf)

Cl. J, Affirmed Caa2 (sf); previously on Aug 16, 2012 Downgraded
to Caa2 (sf)

Cl. K, Affirmed C (sf); previously on Aug 16, 2012 Downgraded to C
(sf)

Cl. L, Affirmed C (sf); previously on Aug 16, 2012 Downgraded to C
(sf)

Cl. M, Affirmed C (sf); previously on Aug 16, 2012 Downgraded to C
(sf)

Cl. N, Affirmed C (sf); previously on Nov 11, 2010 Downgraded to C
(sf)

Cl. O, Affirmed C (sf); previously on Nov 11, 2010 Downgraded to C
(sf)

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

Ratings Rationale:

The affirmations for the five investment grade classes are due to
key parameters, including Moody's loan to value (LTV) ratio,
Moody's stressed DSCR and the Herfindahl Index (Herf), remaining
within acceptable ranges. Based on Moody's current base expected
loss, the credit enhancement levels for these classes are
sufficient to maintain their current ratings. The ratings of the
nine below investment grade classes are consistent with Moody's
expected loss and thus are affirmed.

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for rated 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 downgrade of the IO Class, Class X-C, is a result of the
decline in the WARF of its referenced classes, caused by the
paydowns of the highly rated classes.

Moody's rating action reflects a base expected loss of 21.5%
($63.0 million) of the current pooled balance compared to 9.7%
($63.7 million) at last review. Moody's base expected loss plus
cumulative realized losses is now 7.0% of the original pool
balance compared to 6.9% at the last review.

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.

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.

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
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's 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 34 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.

Deal Performance:

As of the July 15, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 70% to $299.9
million from $1.0 billion at securitization. The Certificates are
collateralized by 60 mortgage loans ranging in size from less than
1% to 14% of the pool, with the top ten loans representing 50% of
the pool. Eight loans, representing 9% of the pool, have defeased
and are secured by U.S. Government securities.

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

Three loans have been liquidated from the pool, resulting in an
aggregate realized loss of $6.4 million (29% loss severity on
average). Two loans, representing 22% of the pool, are currently
in special servicing. The largest specially serviced loan is the
Regency Square Mall Loan ($41.3 million -- 13.8% of the pool),
which represents a 50% participation interest in an $82.6 million
senior mortgage loan secured by a regional mall located in
Jacksonville, Florida. The mall totals 1.4 million total square
feet (SF), of which approximately 938,031 SF serves as loan
collateral. The mall anchors include Dillard's, Sears, JC Penney
and Belk. The loan was transferred to special servicing in April
2012 for imminent default. Total mall occupancy was 77% at year-
end 2012, down from 81% at year-end 2011. As of March 2013, the
mall's inline occupancy was just 25%. Several national retailers
vacated the mall following recent lease expirations, including
apparel retailers Express and Forever 21. Belk extended its lease
for one year past its original March 2013 expiration.

The second loan in the special servicing is the Columbia Place
Mall Loan ($25.7 million -- 8.6% of the pool), which is secured by
a regional mall located in Columbia, South Carolina. The mall
totals 970,000 SF, of which approximately 391,611 SF serves as
loan collateral. The loan was transferred to special servicing in
January 2012 for imminent default. The properly was 86% leased as
of June 2013. Moody's has estimated an aggregate $57 million loss
(85% expected loss on average) for these two specially serviced
loans.

Moody's has also assumed a high default probability for five
poorly performing loans representing 4% of the pool and has
estimated an aggregate $2.5 million loss (21% expected loss based
on a 50% probability default) from these troubled loans.

Moody's was provided with full year 2012 and partial year 2013
operating results for 86% and 30% of the pool's non-specially
serviced loans, respectively. Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 80% compared to
78% 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 8.9%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.34X and 1.26X, respectively, compared to
1.78X and 1.30X 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 16% of the pool
balance. The largest loan is the Hollywest at Western, LLP Loan
($22.7 million -- 7.6% of the pool), which is secured by a 120,000
SF grocery anchored retail center (Hollywest Promenade) located in
Los Angeles, California and a 30,000 SF single tenant retail
center (99 Cents Only Store) located in Las Vegas, Nevada.
Performance has improved due to higher revenues. The loan also
benefits from amortization. Moody's LTV and stressed DSCR are 80%
and 1.15X, respectively, compared to 91% and 1.01X at last review.

The second largest loan is the Yorba Linda Pines Apartments Loan
($13.7 million -- 4.6% of the pool), which is secured by a 120
unit multifamily property located in Yorba Linda, California. As
of December 2012 the property was 95% occupied compared to 96% as
of December 2011 and 97% at securitization. Performance has been
very stable. Moody's LTV and stressed DSCR are 82% and 1.08X,
respectively, compared to 85% and 1.05X at last review.

The third largest loan is the Golden Mall Building Loan ($11.2
million -- 3.7% of the pool), which is secured by a 139 unit
multifamily property located in Burbank, California. As of
December 2012 the property was 92% occupied compared to 99% as of
December 2011. Performance has improved due to higher revenues.
Moody's LTV and stressed DSCR are 77% and 1.26X, respectively,
compared to 86% and 1.13X at last review.


WACHOVIA BANK 2006-C24: Moody's Affirms Ratings on 14 Cert Classes
------------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 14 classes of
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-
Through Certificates, Series 2006-C24 as follows:

Cl. A-3, Affirmed Aaa (sf); previously on Apr 5, 2006 Definitive
Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed Aaa (sf); previously on Apr 5, 2006 Definitive
Rating Assigned Aaa (sf)

Cl. A-J, Affirmed Ba3 (sf); previously on Aug 30, 2012 Downgraded
to Ba3 (sf)

Cl. A-M, Affirmed A2 (sf); previously on Sep 29, 2011 Downgraded
to A2 (sf)

Cl. A-PB, Affirmed Aaa (sf); previously on Apr 5, 2006 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed B2 (sf); previously on Aug 30, 2012 Downgraded to
B2 (sf)

Cl. C, Affirmed B3 (sf); previously on Aug 30, 2012 Downgraded to
B3 (sf)

Cl. D, Affirmed Caa2 (sf); previously on Aug 30, 2012 Downgraded
to Caa2 (sf)

Cl. E, Affirmed Caa3 (sf); previously on Aug 30, 2012 Downgraded
to Caa3 (sf)

Cl. F, Affirmed Ca (sf); previously on Aug 30, 2012 Downgraded to
Ca (sf)

Cl. G, Affirmed C (sf); previously on Aug 30, 2012 Downgraded to C
(sf)

Cl. H, Affirmed C (sf); previously on Aug 30, 2012 Downgraded to C
(sf)

Cl. J, Affirmed C (sf); previously on Aug 30, 2012 Downgraded to C
(sf)

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

Ratings Rationale:

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

Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for rated 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 rating action reflects a base expected loss of 9.4% of the
current balance. At last review, Moody's base expected loss was
10.2%. Realized losses have increased from 4.5% of the original
balance to 4.9% since the prior review. Realized losses plus
Moody's expected loss is 11.5% of the original securitized balance
compared to 11.8% at last review.

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.

The principal methodology used in this rating was "Moody's
Approach to Rating U.S. CMBS Conduit Transactions" published in
September 2000.

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
credit assessment of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the credit assessment
level, is incorporated for loans with similar credit assessments
in the same transaction.

Moody's 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 25 compared to 26 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through a review
utilizing MOST (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.

Deal Performance:

As of the July 17, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 30% to $1.4 billion
from $2.0 billion at securitization. The Certificates are
collateralized by 96 mortgage loans ranging in size from less than
1% to 12% of the pool, with the top ten loans representing 53% of
the pool. No loans have defeased and there are no loans with an
investment grade credit assessment.

Twenty-one loans, representing 22% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of its
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Seventeen loans have been liquidated from the pool, resulting in
an aggregate realized loss of $99.1 million (72% loss severity on
average). Five loans, representing 9% of the pool, are currently
in special servicing. The largest specially serviced loan is the
Woodbridge Hilton Pool (2),(3) Loan ($34.3 million -- 2.5% of the
pool), which is secured by a mixed use 198-key Hilton Hotel and
124,126 square foot (SF) office building located in Iselin, New
Jersey. The loan transferred to special servicing in December 2010
due to imminent default. The borrower submitted a loan
modification proposal that was later rejected by the special
servicer. Foreclosure proceedings took place, and the borrower
subsequently filed for bankruptcy in December 2012 just prior to
the receivership hearing. No plan has been filed by the borrower
in the bankruptcy case.

The remaining four specially serviced loans are secured by a mix
of property types. Moody's estimates an aggregate $80.1 million
loss for the specially serviced loans (64% expected loss on
average).

Moody's has assumed a high default probability for six poorly
performing loans representing 6% of the pool and has estimated an
aggregate $17.9 million loss (20% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2012 operating results for 92%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 100% compared to 104% 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 9.1%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.34X and 1.03X, respectively, compared to
1.22X and 0.96X 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 Regency Portfolio Loan ($164.6 million -- 11.8%),
which is secured by ten retail properties (originally 13) totaling
1.4 million SF. The remaining properties are located in seven
states, with the largest concentrations in California and
Illinois. The portfolio was 97% leased as of December 2012
compared to 94% at last full review. Moody's LTV and stressed DSCR
are 94% and 1.01X, respectively, compared to 111% and 0.86X at
last full review.

The second largest loan is the 1818 Market Street Loan ($118.6
million -- 8.5%), which is secured by a 983,160 SF office building
located in Philadelphia, Pennsylvania. The property was 79% leased
as of December 2012 versus 80% at last review. Overall performance
is in line with last review. Moody's LTV and stressed DSCR are
114% and 0.85X, respectively, compared to 116% and 0.84X at last
full review.

The third largest loan is the Forum at Peachtree Parkway Loan
($84.0 million -- 6.0% of the pool), which is secured by a 389,159
SF retail center located in Norcross, Georgia. The center's major
tenants include Belk, Homegoods, Inc. and Barnes & Noble. The
center was 98% leased as of June 2013 compared to 90% leased as of
January 2011. The loan is interest-only for its entire ten-year
term maturing in March 2016. Moody's LTV and stressed DSCR are
126% and 0.73X, respectively, compared to 132% and 0.70X at last
full review.


WF-RBS COMMERCIAL 2011-C2: Moody's Keeps B2 Rating on Cl. F Certs
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 11 classes of
WF-RBS Commercial Mortgage Trust 2011-C2, Commercial Mortgage
Pass-Through Certificates, Series 2011-C2 as follows:

Cl. A-1, Affirmed Aaa (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Aaa (sf)

Cl. A-2, Affirmed Aaa (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Aaa (sf)

Cl. A-3, Affirmed Aaa (sf); previously on Mar 11, 2011 Assigned
Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on Mar 11, 2011 Assigned
Aaa (sf)

Cl. B, Affirmed Aa2 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Aa2 (sf)

Cl. C, Affirmed A2 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned A2 (sf)

Cl. D, Affirmed Baa3 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Baa3 (sf)

Cl. E, Affirmed Ba2 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Ba2 (sf)

Cl. F, Affirmed B2 (sf); previously on Mar 11, 2011 Definitive
Rating Assigned B2 (sf)

Cl. X-A, Affirmed Aaa (sf); previously on Mar 11, 2011 Definitive
Rating Assigned Aaa (sf)

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

Ratings Rationale:

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

The rating of the IO Classes, Class X-A and X-B, are consistent
with the credit quality of their referenced classes.

Moody's rating action reflects a base expected loss of $22.4
million or 1.8% of the current balance. At last review, Moody's
base expected loss was $21.8 million or 1.7%. Depending on the
timing of loan payoffs and the severity and timing of losses from
specially serviced loans, the credit enhancement level for
investment grade classes could decline below the current levels.
If future performance materially declines, the expected level of
credit enhancement and the priority in the cash flow waterfall may
be insufficient for the current ratings of these classes.

Primary sources of assumption uncertainty are the extent of growth
in the current macroeconomic environment 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 calls for US GDP
growth for 2013 that is likely to remain close to 2% as the
greater impetus from the US private sector is likely to broadly
offset the drag on activity from more restrictive fiscal policy.
Thereafter, we expect the US economy to expand at a somewhat
faster pace than is likely this year, closer to its long-run
average pace of growth. Risks to our forecasts remain skewed to
the downside despite recent positive developments. Moody's
believes that the three most immediate risks are: i) the risk of a
deeper than currently expected recession in the euro area
accompanied by deeper credit contraction, potentially triggered by
a further intensification of the sovereign debt crisis; ii)
slower-than-expected recovery in major emerging markets following
the recent slowdown; and iii) an escalation of geopolitical
tensions, resulting in adverse economic developments.

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

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 our 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 22, the same as at Moody's prior review.

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

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

Deal Performance:

As of the February 15, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 2% to $1.27 billion
from $1.30 billion at securitization. The Certificates are
collateralized by 50 mortgage loans ranging in size from less than
1% to 13% of the pool, with the top ten loans representing 57% of
the pool. The pool contains five loans with investment grade
credit assessments, representing 15% of the pool.

Two loans, representing 7% 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 our
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

No loans have been liquidated or are in special servicing. Moody's
did not identify any additional loans as being troubled.

Moody's was provided with full year 2011 and partial year 2012
operating results for 100% and 96% of the pool, respectively.
Moody's weighted average LTV for the conduit component is 83%
compared to 89% at last review. Moody's net cash flow reflects a
weighted average haircut of 8.8% 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 DSCR for the conduit component are
1.63X and 1.25X, respectively, compared to 1.51X and 1.14X 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 Borgata Ground
Leases Loan ($60.0 million -- 4.7% of the pool), which is secured
by five parcels of land underlying portions of the Borgata Hotel
Casino & Spa Complex in Atlantic City, New Jersey. The property is
leased pursuant to four separate ground leases, all of which
expire in December 2070. Performance has remained stable. Moody's
credit assessment and stressed DSCR are Baa1 and 1.03X,
respectively, the same as at last review.

The second largest loan with a credit assessment is the Westfield
Westland Mall Loan ($55.3 million -- 4.3% of the pool), which is
secured by 225,000 square feet (SF) of net rentable area (NRA)
contained within a 829,000 SF super-regional mall located in
Hialeah, Florida. The mall is anchored by Macy's, Sears and JC
Penney, all of which are owned by the respective tenants and not
included in the collateral. Occupancy as of September 2012 was
97%, the same as at last review. Performance has remained stable.
Moody's credit assessment and stressed DSCR are Baa2 and 1.44X,
respectively, compared to Baa2 and 1.47X at last review.

The third largest loan with a credit assessment is the Port
Charlotte Town Center Loan ($38.8 million -- 3.1% of the pool),
which is secured by 490,000 SF of NRA contained within a 774,000
SF super-regional mall in Port Charlotte, Florida. The mall
contains five anchors and a movie theater. The property is located
along Tamiami Trail (US 141). Occupancy as of September 2012 was
88% compared to 92% at last review and securitization. Moody's
credit assessment and stressed DSCR are Baa3 and 1.42X,
respectively, compared to Baa3 and 1.51X at last review.

The fourth largest loan with a credit assessment is the Showcase
Mall Phase II Loan ($22.5 million -- 1.8% of the pool), which is
secured by 42,000 SF of the Showcase Mall, a 332,000 SF retail
project fronting Las Vegas Boulevard and adjacent to the MGM. The
property is leased to two tenants (Grand Canyon Shops and Adidas)
as well as a kiosk leased to Vegas.com. Performance has remained
stable. Moody's credit assessment and stressed DSCR are Baa1 and
1.65X, respectively, compared to Baa3 and 1.58X at last review.

The fifth largest loan with a credit assessment is the Hilton
Garden Inn -- Mountain View Loan ($10.3 million -- 0.8% of the
pool), which is secured by a 160-room, full service hotel located
off of Camino Real, the main commercial thoroughfare connecting
San Jose and the San Francisco peninsula. The borrower developed
the property in 1999 for $14.2 million, excluding the value of the
land which the family has owned since 1952. Moody's credit
assessment and stressed DSCR are A2 and 2.62X, respectively,
compared to A2 and 2.24X at last review.

The top three performing conduit loans represent 26% of the pool.
The largest conduit loan is the Hollywood & Highland Loan ($163.7
million -- 12.9% of the pool), which is secured by three five-
story multi-tenant retail buildings and one six-story theater
located on Hollywood Blvd in Los Angeles, California. Tenants
include 50 retail shops, 25 restaurants/eateries, two nightclubs,
one multi-screen cinema, a grand ballroom, a bowling alley, and a
large event theater. Cirque du Soleil signed an agreement for 10
years that began in July 2011 and will produce 368 annual shows.
As of September 2012, the property was 89% leased as compared to
92% at last review. Moody's LTV and stressed DSCR are 62% and
1.48X, respectively, compared to 78% and 1.18X at last review.

The second largest loan is The Arboretum Loan ($88.7 million --
7.0% of the pool), which is secured by a Wal-Mart anchored retail
center totaling 563,000 SF located in Charlotte, North Carolina.
The property consists of 12 single-story buildings, five pad
sites, and a 16-screen movie theater. As of September 2012, the
property was 99% leased compared to 100% at last review. Moody's
LTV and stressed DSCR are 103% and 0.95X, respectively, compared
to 98% and 0.99X at last review.

The third largest loan is the 1412 Broadway Loan ($82.4 million --
6.5% of the pool), which is secured by a 24-story, Class B office
building located at the northeast corner of 39th Street and
Broadway in the Garment District of Manhattan in New York City.
The property was purchased by the borrower, Harbor Group
International, in December 2010 for $150 million. Of 412,000 SF of
leasable area, 24,000 SF (6%) is retail and 388,000 SF (94%) is
office with total occupancy of 95% as of September 2012, compared
to 92% at last review. Moody's LTV and stressed DSCR are 111% and
0.86X, respectively, compared to 102% and 0.93x at last review.


WHITEHORSE III: S&P Raises Rating on Class B-2L Notes to BB+
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1L, A-2L, A-3L, B-1L, and B-2L notes from WhiteHorse III Ltd.
At the same time S&P removed the class A-1L, A-2L, and A-3L notes
from CreditWatch with positive implications where they were placed
on July 9, 2013.  WhiteHorse III Ltd. is a collateralized loan
obligation (CLO) transaction managed by WhiteHorse Capital
Partners L.P. that closed in March 2006.

The transaction's reinvestment period ended in March 2012.  Since
then, the class A-1L notes have paid down more than $175 million,
including more than $40 million on the most recent August 2013
payment date, to reduce the remaining balance to $78.7 million.

The upgrades reflect the paydowns to the class A-1L notes, which
have helped create additional support to the subordinate notes.
The improvements are also evident in the class A, B-1, and B-2
overcollateralization ratios, which have increased since S&P's
July 2012 rating actions.

As of the July 23, 2013, trustee report, the transaction has
roughly $12.3 million of loans maturing after the legal final
maturity of the transaction in May 2018.  Exposure to these long-
dated assets subjects the transaction to potential market value
risk, as the manager may have to liquidate these securities when
the transaction matures in order to pay down the notes on their
final maturity date.  The rating actions reflect this potentially
negative exposure.

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 will 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

WhiteHorse III Ltd.

                   Rating
Class         To           From
A-1L          AAA (sf)     AA+ (sf)/Watch Pos
A-2L          AAA (sf)     A+ (sf)/Watch Pos
A-3L          AA+ (sf)     BBB+ (sf)/Watch Pos
B-1L          A- (sf)      BB- (sf)
B-2L          BB+ (sf)     CCC+ (sf)


WHITEHORSE VII: S&P Assigns Prelim. BB- Rating on Class B-2L Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to WhiteHorse VII Ltd./WhiteHorse VII LLC's $372.0 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 Aug. 14,
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
      (excluding excess spread) and cash flow structure, which can
      withstand the default rate projected by Standard & Poor's
      Ratings Services' CDO Evaluator model, as assessed by
      Standard & Poor's using the assumptions and methods outlined
      in its corporate collateralized debt obligation criteria.

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

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

   -- The portfolio manager's experienced management team.

   -- S&P's projections regarding the timely interest and ultimate
      principal payments on the preliminary rated notes, which it
      assessed using its cash flow analysis and assumptions
      commensurate with the assigned preliminary ratings under
      various interest-rate scenarios, including LIBOR ranging
      from 0.2654%-12.8655%.

   -- 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
      rated notes' outstanding balance.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

        http://standardandpoorsdisclosure-17g7.com/1738.pdf

PRELIMINARY RATINGS ASSIGNED

WhiteHorse VII Ltd./WhiteHorse VII LLC

Class                Rating          Amount (mil. $)
A-1L                 AAA (sf)                 238.80
A-2L                 AA (sf)                   52.40
A-3L (deferrable)    A (sf)                    31.20
B-1L (deferrable)    BBB (sf)                  20.00
B-2L (deferrable)    BB- (sf)                  20.80
B-3L (deferrable)    B (sf)                     8.80
Subordinated notes   NR                        38.82

NR-Not rated.


* Fitch Takes Various Actions on 20 Trust Preferred CDOs
--------------------------------------------------------
Fitch Ratings has taken the following rating actions on tranches
from 20 Collateralized Debt Obligations (CDOs) backed primarily by
Trust Preferred (TruPS) securities issued by banks:

-- Affirmed 79 tranches;
-- Upgraded 25 tranches;
-- Downgraded two tranches;
-- Marked two classes as paid-in-full;
-- Withdrew the rating on one note;
-- Assigned various Rating Outlooks.

The rating action report, titled 'Fitch Takes Various Rating
Actions on 20 TruPS CDOs', dated Aug. 9, 2013, details the
individual rating actions and portfolio characteristics for each
rated CDO.

Key Rating Drivers:

Credit Quality of Collateral: For most of the transactions, the
credit quality of the collateral portfolios, as measured by a
combination of Fitch's bank scores and ratings, remained stable or
improved. As reported in the rating action report, in 19 CDOs
average credit quality has improved since last review. Nine
transactions experienced new deferrals and defaults, with most of
new defaults deferring at last review.

Collateral Redemptions: Since last rating action, Fitch has
continued to observe a meaningful level of redemptions used to pay
down the senior-most notes in TruPS CDOs contributing to increased
credit enhancement (CE) levels for rated liabilities. The
magnitude of redemptions for each CDO is reported in the rating
action report. Redemptions averaged three issuers per deal or 8.3%
of collateral balances since the last rating action.

The impact of redemptions varies across TruPS CDOs. In more
seasoned transactions with a relatively small senior note balance,
prepayments provided a significant deleveraging effect. However,
potential upgrades were weighed against the risk of adverse
selection in the remaining portfolios and the likelihood of the
remaining balance to be outstanding for an extended period of
time.

Excess Spread and CDO Structure: Excess spread continued to
contribute to deleveraging most of the CDOs. Given the steady
trends of declining new defaults and deferrals and increasing
numbers of cures, Fitch updated its criteria to estimate and
credit the future levels of excess spread over a five-year horizon
in its rating analysis. The details of the analytical framework
are explained in the criteria 'Surveillance Criteria for TruPS
CDOs,' dated July 10, 2013.

Future levels of excess spread will be affected by the state of
the coverage tests. As reported in the rating action report, 11 of
the 20 CDOs are currently failing the most senior
overcollateralization test and nine are currently failing the
second-tier overcollateralization test.

Fitch estimated time to cure for the most senior
overcollateralization coverage test using its base prepayment
assumptions, as described in Fitch criteria. This estimate assumes
no new defaults, deferrals or cures and a flat interest rate
environment.

Across the 20 deals, this additional credit enhancement did not
provide a meaningful uplift to the passing ratings given the
haircuts applied to the base line of excess spread levels for
various rating stresses.

Resolution and Recovery of Defaults and Deferrals: The number of
cures continues to trend upward, as Fitch reports in its quarterly
Fitch Bank TruPS CDO index. Fitch assesses the likelihood of a
cure for a current deferral based on the score history of a
deferring issuer since deferral as described in its criteria.
Currently deferring issuers defined as 'strong' are assigned a
higher likelihood of curing than 'weak' deferrals.

Rating Sensitivities

Changes in the rating drivers described above could lead to rating
changes in the TruPS CDO notes.

To account for uncertainty around the pace of early redemptions,
and consequently, magnitude of future excess spread, Fitch's
rating analysis capped the levels of excess spread to the amounts
projected only over the near-term future.

In addition, to address potential risks of adverse selection and
increased portfolio concentration after likely redemptions by the
issuers with asset size of $15 billion or more, Fitch applied a
sensitivity scenario, as described in the criteria.


* Fitch Says Delinquencies and Foreclosures Decreasing
------------------------------------------------------
Fitch Ratings has taken various rating actions on 172 U.S. RMBS
transactions. The transactions reviewed consisted of 124
Manufactured Housing (MH), 30 Small Balance Commercial (SBC), and
18 securities sponsored by BV Legacy L.P., fka Bayview Financial,
L.P. (Bayview).

Fitch reviewed 789 classes; 736 classes were affirmed, 43 were
upgraded, 8 classes were downgraded, and 2 classes were withdrawn.

A spreadsheet detailing the actions can be found on Fitch's
website by performing a title search for 'U.S. RMBS Rating Actions
for Aug. 15, 2013' or by clicking the link. In addition, a summary
of the mortgage pool and bond analysis can be found by performing
a title search for 'RMBS Loss Metrics.'

Key Rating Drivers

Performance has generally remained stable for transactions in this
review and has resulted in little change in Fitch's expected loss
assumptions. A detailed list of Fitch's updated Probability of
Default (PD), Loss Severity (LS), and Expected Loss (XL) can be
found by performing a title search for 'RMBS Loss Metrics' at
www.fitchratings.com.

All but one of the downgrades were limited to one rating category
below their prior rating. One class, which held a non-investment
grade rating prior to the review, was downgraded two rating
categories due to interest shortfalls. The majority of the
downgrades affected distressed classes previously rated below
'Bsf' which now appear more certain to default.

Upgrades were limited to one rating category above their prior
rating due to historical cash flow volatility within the sectors
reviewed. The upgrades were driven by stable-to-improving
collateral performance and, in some cases, sequential-pay cashflow
features which are expected to pay off the upgraded classes within
a relatively short timeframe.

Rating Sensitivities:

Fitch uses pool level collateral data to analyze the MH, SBC, and
Bayview transactions. To determine the PD Fitch will use subprime
or Alt-A vintage average assumptions while the LS will typically
be determined by observed severities over the prior 12 months.
Specific assumptions used in the analysis are described in more
detailed below.

For MH transactions Fitch determines the PD using the subprime
vintage average derived from Fitch's non-prime loss model and
adjusted for pool specific performance. The LS assumption for each
transaction is determined by each issuer's 12 month historical
average. The cash flow analysis assumes Fitch's benchmark 10 year
CDR curve, a 10% CPR, zero advancing on delinquent loans and a
haircut to the WAC in the 'Asf-AAAsf' rating stresses.

The PD for SBC transactions is based on the Alt-A vintage average
derived from Fitch's non-prime loss model. The LS is determined by
each issuer's 12 month historical average and typically ranges
from 65%-80% in the base case. Fitch's cashflow analysis assumes
prepayment, loss-timing and servicer advancing behavior consistent
with Alt-A sector vintage averages.

When it is not possible to run cash flow analysis on SBC
transactions, Fitch will add one year of excess spread to the
credit enhancement (CE) and then compare CE to the expected loss
in each rating stress. In order for a class to be affirmed, its CE
must exceed the expected loss in its current rating stress.

Fitch uses pool level collateral data to analyze the Bayview
transactions. If the underlying collateral is small balance
commercial/mixed assets the default assumptions are based off of
the Alt-A vintage default assumptions from Fitch's non-prime loss
model and are adjusted for pool specific product composition and
performance. For the remaining asset types, Fitch uses the
subprime vintage default assumptions from Fitch's non-prime loss
model adjusted for pool specific product composition and
performance.

Fitch assumes a 75% base case loss severity for the loans in the
12 BFAT transactions. For the Bayview Revolvers and BFAT
resecuritizations an 80% severity is used if the collateral is
small balance commercial, a 90% severity is used if the assets are
first liens and a 100% severity is used for second liens.

The Bayview cash flow analysis assumes Fitch's benchmark CDR and
CPR curves, zero servicer advance rate for all second liens while
the advance rates for first liens reflected Alt-A or subprime
advance rates, and a haircut to the WAC in the 'Asf-AAAsf' rating
stresses.

Once Fitch determines the base case assumptions, the stressed
assumptions are determined using Fitch's loss model PD and
severity multiples. This in turn determines Fitch's expected
losses in the 'Bsf-AAAsf' stresses.

In addition to increasing losses at each rating category to
reflect increasingly stressful economic environments, Fitch
analyzes various loss-timing, prepayment, loan modification,
servicer advancing, and interest rate scenarios as part of the
cash flow analysis. Each class is analyzed with 43 different
combinations of loss, prepayment and interest rate projections.

The analysis includes rating stress scenarios from 'CCCsf' to
'AAAsf'. The 'CCCsf' scenario is intended to be the most-likely
base-case scenario. Rating scenarios above 'CCCsf' are
increasingly more stressful and less-likely outcomes. Although
many variables are adjusted in the stress scenarios, the primary
driver of the loss scenarios is the home price forecast
assumption. In the 'Bsf' scenario, Fitch assumes home prices
decline 10% below their long-term sustainable level. The home
price decline assumption is increased by 5% at each higher rating
category up to a 35% decline in the 'AAAsf' scenario.

Classes currently rated below 'Bsf' are at-risk to default at some
point in the future. As default becomes more imminent, bonds
currently rated 'CCCsf' and 'CCsf' will migrate towards 'Csf' and
eventually 'Dsf'.

The ratings of bonds currently rated 'Bsf' or higher will be
sensitive to future mortgage borrower behavior, which historically
has been strongly correlated with home price movements. Despite
recent positive trends, Fitch currently expects home prices
nationally to decline further before reaching a sustainable level.
While Fitch's ratings reflect this home price view, the ratings of
outstanding classes may be subject to revision to the extent
actual home price and mortgage performance trends differ from
those currently projected by Fitch.

The spreadsheet 'U.S. RMBS Rating Actions for Aug. 15, 2013'
provides the contact information for the performance analyst.


* Fitch Says U.S. CMBS Market Metrics Mostly Stable in 2Q
---------------------------------------------------------
In a report released on Aug. 14, 2013, Fitch Ratings sees
stabilization of trends in outstanding and newly issued U.S. CMBS
versus first quarter 2013.

The majority of outstanding Fitch-rated investment grade classes
maintained Stable Rating Outlooks, while second-quarter downgrades
declined over first quarter. 'CMBS downgrades will continue to
decline due to fewer loans transferring to special servicing and
fewer delinquencies,' said Managing Director Mary MacNeill. Most
second-quarter downgrades affected classes already rated
speculative grade or distressed.

New issuance metrics were stable quarter-over-quarter but have
worsened since last year. This was due to higher Fitch stressed
LTVs, more interest-only (IO) loans, and more loans having or
allowing additional debt. 'The increase in IO loans from a year
ago makes average debt service coverage ratios look better,' said
Managing Director Huxley Somerville. 'However, the loans are
poorer in quality and the Fitch LTV, which is up from a year ago,
should also be considered.' Fitch has increased its 'AAA' credit
enhancement requirements as additional debt and IO loans have
become more commonplace.

Mortgage rates in new issue CMBS remained stable quarter-over-
quarter. However, Fitch expects the early summer uptick in rates
to appear in third-quarter new issuance. Fitch will continue to
closely watch rate increases as the 2015-2017 maturity wave nears.

The U.S. Commercial Mortgage Market Metrics report is part of
Fitch's series of structured finance index reports. The report is
released quarterly and compares metrics quarter over quarter and
to the same quarter from a year ago.


* Fitch Downgrades Various Distressed U.S. RMBS Bonds to 'Dsf'
--------------------------------------------------------------
Fitch Ratings has downgraded 297 distressed bonds in 164 U.S. RMBS
transactions to 'Dsf'. The downgrades indicate that the bonds have
incurred a principal write-down. Of the bonds downgraded to 'Dsf',
290 classes were previously rated 'Csf' and 7 classes were rated
'CCsf'. All ratings below 'CCCsf' indicate a default is expected.
As part of this review, the Recovery Estimates (REs) of the
defaulted bonds were not revised. In addition, the review focused
only on the bonds which defaulted and did not include any other
bonds in the affected transactions.

Of the 297 classes affected by these downgrades, 167 are Prime, 75
are Alt-A, and 47 are Subprime. The remaining transaction types
are other sectors. Approximately, 64% of the bonds have an RE of
50%-100%, which indicates that the bonds will recover 50%-100% of
the current outstanding balance, while 24% have an RE of 0%.

A spreadsheet detailing Fitch's rating actions can be found at
'www.fitchratings.com' by performing a title search for 'Fitch
Downgrades 297 Distressed Bonds to 'Dsf' in 164 U.S. RMBS
Transactions'. These actions were reviewed by a committee of Fitch
analysts. The spreadsheet provides the contact information for the
performance analyst.

The spreadsheet also details Fitch's assignment of REs to the
transactions. The Recovery Estimate scale is based upon the
expected relative recovery characteristics of an obligation. For
structured finance, REs are designed to estimate recoveries on a
forward-looking basis.


* Fitch: Largest Post-Recession Drop for U.S. CMBS Delinquencies
----------------------------------------------------------------
A spate of dispositions from a single CMBS transaction resulted in
the largest drop in U.S. CMBS delinquencies since the end of the
recession, according to the latest monthly index results from
Fitch Ratings.

CMBS late-pays fell 40 basis points (bps) last month to 6.78%
(from 7.18% in June). Leading the fall were ORIX asset sales from
the LB-UBS 2007-C2 transaction, which alone accounted for $759
million (in stated loan balance) of dispositions. Following these
sales, the delinquency rate is now 2.23 percentage points below
its July 2011 peak of 9.01%.

The ORIX sales helped drive delinquency rates for all major
property types down last month. Delinquencies on office loans, a
recent underperformer, stood out by falling nearly 60 bps month-
over-month.

CMBS loans becoming delinquent also continued to diminish in size.
The average loan size of new entrants in July was just $8.5
million, with only four loans over $25 million entering the index.

Current and previous delinquency rates are:

-- Industrial: 9.56% (from 9.77% in June);
-- Hotel: 8.04% (from 8.35%);
-- Office: 7.59% (from 8.18%);
-- Multifamily: 7.41% (from 7.59%);
-- Retail: 6.37% (from 6.74%).


* Moody's Lowers Ratings on 63 Alt-A, Option ARM RMBS Tranches
--------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 63
tranches from 15 transactions backed by Alt-A and Option ARM RMBS
loans, issued by multiple issuers.

Complete rating actions are as follows:

Issuer: Bear Stearns Alt-A Trust 2006-8

Cl. III-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013
A2 (sf) Placed Under Review for Possible Downgrade

Issuer: Cendant Mortgage Corporation Pass-Through Certificates,
Series 2001-A

Cl. M, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A2 (sf)
Placed Under Review for Possible Downgrade

Issuer: Deutsche Mortgage Securities, Inc. Mortgage Loan Trust,
Series 2004-1

Cl. I-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. II-A-1, Downgraded to A3 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Issuer: MASTR Alternative Loan Trust 2003-5

Cl. 1-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

CL. 3-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 4-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 5-A-1, Downgraded to Ba1 (sf); previously on Apr 26, 2012
Downgraded to Baa2 (sf)

Cl. 6-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 7-A-1, Downgraded to Ba1 (sf); previously on Apr 26, 2012
Downgraded to Baa2 (sf)

Cl. 8-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 30-PO, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 30-B-1, Downgraded to B2 (sf); previously on Apr 26, 2012
Downgraded to Ba3 (sf)

Cl. 15-PO, Downgraded to Ba1 (sf); previously on Apr 26, 2012
Downgraded to Baa2 (sf)

Issuer: Nomura Asset Acceptance Corporation, Alternative Loan
Trust, Series 2003-A2

Cl. M1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Issuer: RALI Series 2001-QS13 Trust

A-P, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2 (sf)
Placed Under Review for Possible Downgrade

A-1, Downgraded to A3 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

Issuer: RALI Series 2002-QS14 Trust

A-10, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

A-11, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

A-12, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

A-P, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

Issuer: RALI Series 2003-QS1 Trust

A-8, Downgraded to Baa3 (sf); previously on Jun 19, 2013 A3 (sf)
Placed Under Review for Possible Downgrade

Underlying Rating: Downgraded to Baa3 (sf); previously on Jun 19,
2013 A3 (sf) Placed Under Review for Possible Downgrade

Financial Guarantor: MBIA Insurance Corporation (Upgraded to B3,
Outlook Positive on May 21, 2013)

A-13, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A2 (sf)
Placed Under Review for Possible Downgrade

A-14, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A2 (sf)
Placed Under Review for Possible Downgrade

A-P, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A2 (sf)
Placed Under Review for Possible Downgrade

Issuer: RFSC Series 2001-RM2 Trust

Cl. A-I, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. AP-I, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Issuer: Structured Asset Securities Corp 2002-5A

Cl. 1-A1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A3, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A4, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A1, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A2, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 3-A, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 4-A, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 5-A, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 6-A, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Issuer: Structured Asset Securities Corp 2003-20

CL. 1-A1, Downgraded to Baa3 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

CL. 1-AP, Downgraded to Baa3 (sf); previously on Jul 5, 2012
Downgraded to Baa1 (sf)

Cl. 2-A3, Downgraded to Ba1 (sf); previously on Jul 5, 2012
Downgraded to Baa2 (sf)

Cl. 2-A4, Downgraded to Ba1 (sf); previously on Jul 5, 2012
Downgraded to Baa2 (sf)

Cl. 3-A1, Downgraded to Baa3 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 3-AP, Downgraded to Baa3 (sf); previously on Jul 5, 2012
Downgraded to Baa1 (sf)

Issuer: Structured Asset Securities Corp Trust 2003-22A

Cl. 1-A, Downgraded to Ba1 (sf); previously on Jul 5, 2012
Downgraded to Baa1 (sf)

Cl. 2-A1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 3-A, Downgraded to Baa3 (sf); previously on Jul 5, 2012
Downgraded to Baa1 (sf)

Cl. 4-A, Downgraded to Baa3 (sf); previously on Jul 5, 2012
Downgraded to Baa1 (sf)

Issuer: Structured Asset Securities Corp Trust 2003-34A

Cl. 5-A4, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 5-A5, Downgraded to Ba3 (sf); previously on Jul 5, 2012
Downgraded to Ba1 (sf)

Issuer: Structured Asset Securities Corporation, Series 2005-10

Cl. 3-A1, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 3-A4, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 4-A1, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 4-A8, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 4-A9, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 4-A10, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 5-A1, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 5-A2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 5-A3, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 5-A6, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 5-A9, Downgraded to Caa1 (sf); previously on Aug 11, 2010
Downgraded to B2 (sf)

Cl. 5-A10, Downgraded to Caa1 (sf); previously on Feb 22, 2012
Downgraded to B2 (sf)

Issuer: WaMu Mortgage Pass-Through Certificates Series 2004-AR13
Trust

Cl. A-1A, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Ratings Rationale:

The actions are a result of the recent performance of the
underlying pools and reflect Moody's updated loss expectations on
the pools. In addition, the downgrades reflect the exposure of the
affected bonds to tail risk due to the pro-rata pay nature of the
transaction.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in June 2013.

Subject to the results of a stress scenario analysis, Moody's caps
the ratings of bonds exposed to tail-end risk to A3 (sf) or below,
unless the bonds are expected to pay off within a year or are
expected to pay off well before the underlying pool is expected to
be small pool (100 loans).

The primary source of assumption uncertainty is the uncertainty in
our central macroeconomic forecast and performance volatility due
to servicer-related issues. The unemployment rate fell from 8.2%
in July 2012 to 7.4% in July 2013. Moody's forecasts an
unemployment central range of 7.0% to 8.0% for the 2013 year.
Moody's expects house prices to continue to rise in 2013.
Performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


* Moody's Takes Action on $544MM of RMBS From Various Issuers
-------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 67
tranches and confirmed the ratings of 12 tranches backed by Prime
Jumbo RMBS loans, issued by miscellaneous issuers.

Complete rating actions are as follows:

Issuer: ABN AMRO Mortgage Corporation, Multi-Class Pass-Through
Certificates, Series 2003-12

Cl. 1A, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 2A, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 3A1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 3A2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-P, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Mortgage 2003-H Trust

Cl. 1-A-1, Downgraded to Baa3 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Mortgage 2003-I Trust

Cl. 3-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Issuer: Banc of America Mortgage 2004-I Trust

Cl. 3-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. 3-A-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Issuer: Bear Stearns ARM Trust 2003-3

Cl. IV-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Issuer: Bear Stearns ARM Trust 2003-6

Cl. II-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Issuer: Bear Stearns ARM Trust 2003-9

Cl. I-A-1, Downgraded to Baa2 (sf); previously on Mar 13, 2012
Confirmed at Baa1 (sf)

Cl. I-A-2, Downgraded to Baa2 (sf); previously on Mar 13, 2012
Confirmed at Baa1 (sf)

Cl. I-A-3, Downgraded to Baa2 (sf); previously on Mar 13, 2012
Confirmed at Baa1 (sf)

Cl. II-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. II-A-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. II-A-3, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. III-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013
A1 (sf) Placed Under Review for Possible Downgrade

Cl. III-A-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013
A1 (sf) Placed Under Review for Possible Downgrade

Cl. III-A-3, Downgraded to Baa1 (sf); previously on Jun 19, 2013
A1 (sf) Placed Under Review for Possible Downgrade

Cl. IV-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. IV-X-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. B-1, Downgraded to Caa1 (sf); previously on Mar 13, 2012
Downgraded to B1 (sf)

Issuer: Bella Vista Mortgage Trust 2004-1

Cl. I-A, Downgraded to Baa3 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. I-A-IO, Downgraded to B3 (sf); previously on Feb 22, 2012
Downgraded to B2 (sf)

Cl. I-M, Downgraded to B3 (sf); previously on Apr 22, 2011
Downgraded to Ba3 (sf)

Cl. I-B-1, Downgraded to Ca (sf); previously on Apr 22, 2011
Downgraded to Caa2 (sf)

Issuer: Chase Mortgage Finance Trust, Series 2003-S11

Cl. IIA-7, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Issuer: Chase Mortgage Finance Trust, Series 2004-S2

Cl. IA-4, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. IA-5, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. IIA-3, Downgraded to Baa3 (sf); previously on Nov 8, 2012
Downgraded to Baa2 (sf)

Cl. IIA-4, Downgraded to Baa3 (sf); previously on Nov 8, 2012
Downgraded to Baa2 (sf)

Cl. IIA-6, Downgraded to Baa3 (sf); previously on Nov 8, 2012
Downgraded to Baa2 (sf)

Cl. A-P, Downgraded to Baa3 (sf); previously on Nov 8, 2012
Downgraded to Baa1 (sf)

Issuer: CHL Mortgage Pass-Through Trust 2003-18

Cl. A-10, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-11, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-12, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. PO, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-24

Cl. A-9, Confirmed at A2 (sf); previously on Jun 19, 2013 A2 (sf)
Placed Under Review for Possible Downgrade

Cl. A-11, Confirmed at A2 (sf); previously on Jun 19, 2013 A2 (sf)
Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-28

Cl. A-2, Confirmed at A1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

Cl. A-3, Confirmed at A1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

Cl. A-11, Confirmed at A1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

Cl. A-12, Confirmed at A1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-34

Cl. A-7, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. A-8, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. A-12, Confirmed at A3 (sf); previously on Jun 19, 2013 A3 (sf)
Placed Under Review for Possible Downgrade

Cl. A-14, Confirmed at A3 (sf); previously on Jun 19, 2013 A3 (sf)
Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-4

Cl. 1-A-7, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A-13, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A-14, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A-15, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-1, Downgraded to A3 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-41

Cl. A-3, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-6, Downgraded to Baa2 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. PO, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A1
(sf) Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-46

Cl. 1-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 1-A-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 2-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 3-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 4-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 4-A-2, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 6-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. 7-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-54

Cl. A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. M, Downgraded to B3 (sf); previously on Apr 21, 2011
Downgraded to B1 (sf)

Issuer: CHL Mortgage Pass-Through Trust 2003-56

Cl. 3-A-7B, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust 2003-57

Cl. A-7, Confirmed at A1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

Cl. A-8, Confirmed at A1 (sf); previously on Jun 19, 2013 A1 (sf)
Placed Under Review for Possible Downgrade

Cl. A-10, Downgraded to Baa3 (sf); previously on Apr 21, 2011
Downgraded to Baa1 (sf)

Cl. A-11, Downgraded to Baa3 (sf); previously on Apr 21, 2011
Downgraded to Baa1 (sf)

Cl. PO, Downgraded to Baa3 (sf); previously on Apr 21, 2011
Downgraded to Baa1 (sf)

Issuer: CHL Mortgage Pass-Through Trust 2003-7

Cl. A-8, Downgraded to Baa3 (sf); previously on Apr 13, 2012
Downgraded to Baa2 (sf)

Cl. A-9, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A3
(sf) Placed Under Review for Possible Downgrade

Cl. A-10, Downgraded to Ba2 (sf); previously on Apr 13, 2012
Downgraded to Baa2 (sf)

Issuer: CHL Mortgage Pass-Through Trust 2004-4

Cl. A-24, Confirmed at A3 (sf); previously on Jun 19, 2013 A3 (sf)
Placed Under Review for Possible Downgrade

Cl. A-25, Confirmed at A3 (sf); previously on Jun 19, 2013 A3 (sf)
Placed Under Review for Possible Downgrade

Issuer: CHL Mortgage Pass-Through Trust, Series 2002-J5

Cl. 2-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Cl. 3-A-1, Downgraded to Baa1 (sf); previously on Jun 19, 2013 A2
(sf) Placed Under Review for Possible Downgrade

Ratings Rationale:

The actions are a result of the recent performance of the
underlying pools and reflect Moody's updated loss expectations on
the pools. In addition, the downgrades reflect the exposure of the
affected bonds to tail risk due to the pro-rata pay nature of the
transactions.

The principal methodology used in these ratings was "US RMBS
Surveillance Methodology" published in June 2013.

As detailed in the methodology noted, subject to the results of a
stress scenario analysis, Moody's caps the ratings of bonds
exposed to tail-end risk to A3 (sf) or below, unless the bonds are
expected to pay off within a year or are expected to pay off well
before the underlying pool is expected to be small pool (100
loans).

The primary source of assumption uncertainty is the uncertainty in
Moody's central macroeconomic forecast and performance volatility
due to servicer-related issues. The unemployment rate fell from
8.2% in July 2012 to 7.4% in July 2013. Moody's forecasts an
unemployment central range of 7.0% to 8.0% for the 2013 year.
Moody's expects house prices to continue to rise in 2013.
Performance of RMBS continues to remain highly dependent on
servicer procedures. Any change resulting from servicing transfers
or other policy or regulatory change can impact the performance of
these transactions.


* S&P Withdraws Ratings on 79 Classes From 32 CDOs After Paydowns
-----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 79
classes of notes from 26 collateralized loan obligation (CLO)
transactions, three collateralized debt obligation (CDO)
transactions backed by commercial mortgage backed securities
(CMBS), one CDO transaction backed by mezzanine structured finance
assets, one CDO transaction backed by a pool of trust preferred
securities, and one CDO retranche transaction.

The withdrawals follow the complete paydown of the notes on their
most recent payment dates.

The following transactions redeemed their classes in full after
providing notice to S&P that the equity holders directed optional
redemptions:

   -- AMMC CLO III Limited;

   -- Halcyon Structured Asset Management Long Secured/Short
      Unsecured CLO 2006-1 Ltd.;

   -- LCM VIII L.P./LCM VIII Corp.;

   -- Market Square CLO Ltd.;

   -- Wind River CLO II-Tate Investors Ltd.

         STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

            http://standardandpoorsdisclosure-17g7.com

RATINGS WITHDRAWN

AMMC CLO III, Limited
                            Rating
Class               To                  From
A                   NR                  AAA (sf)
B                   NR                  A+ (sf)
C                   NR                  A+ (sf)
D                   NR                  BBB+ (sf)

Ares XVIII CLO Ltd.
                            Rating
Class               To                  From
A-2 Notes           NR                  AAA (sf)

Canyon Capital CLO 2004-1 Ltd.
                            Rating
Class               To                  From
A-1-A Notes         NR                  AAA (sf)
A-1-B Notes         NR                  AAA (sf)
A-2-A Notes         NR                  AAA (sf)
A-2-B Notes         NR                  AAA (sf)
B Notes             NR                  AAA (sf)
C Notes             NR                  BBB+ (sf)
D Notes             NR                  BB+ (sf)

Carlyle Global Market Strategies CLO 2013-2 Ltd.
                            Rating
Class               To                  From
X                   NR                  AAA (sf)

CoLTS 2005-2 Ltd.
                            Rating
Class               To                  From
D Notes             NR                  BBB+ (sf)

Crest 2003-2 Ltd.
                            Rating
Class               To                  From
A-1                 NR                  A- (sf)
A-2                 NR                  A- (sf)
A-3                 NR                  BBB+ (sf)

Crest Clarendon Street 2002-1 Ltd.
                            Rating
Class               To                  From
B-1 Notes           NR                  BBB+ (sf)
B-2 Notes           NR                  BBB+ (sf)

CSAM Funding II
                            Rating
Class               To                  From
A Notes             NR                  AAA (sf)

Diversified Asset Securitization Holdings III L.P.
                            Rating
Class               To                  From
A-1L Notes          NR                  BB+ (sf)
A-2 Notes           NR                  BB+ (sf)

Dryden XXVI Senior Loan Fund XXVI
                            Rating
Class               To                  From
X Notes             NR                  AAA (sf)

Essex Park CDO Ltd.
                            Rating
Class               To                  From
B-1 Notes           NR                  AAA (sf)
B-2 Notes           NR                  AAA (sf)
C-1 Notes           NR                  AA+ (sf)
C-2 Notes           NR                  AA+ (sf)

Forest Creek CLO Ltd.
                            Rating
Class               To                  From
B-2L Notes          NR                  CCC- (sf)

Galaxy IV CLO Ltd.
                            Rating
Class               To                  From
B Notes             NR                  AAA (sf)
C Notes             NR                  AA+ (sf)
D Fixed Notes       NR                  BBB- (sf)
D Floating Notes    NR                  BBB- (sf)

GSC Partners Gemini Fund Limited
                            Rating
Class               To                  From
C                   NR                  AAA (sf)

Halcyon Structured Asset Management
Long Secured/Short Unsecured CLO 2006-1
Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)
B                   NR                  AAA (sf)
C                   NR                  AA+ (sf)
D                   NR                  A- (sf)
E                   NR                  BB+ (sf)

Landmark III CDO Ltd.
                            Rating
Class               To                  From
A-3L                NR                  AA+ (sf)
B-1L                NR                  CCC+ (sf)

LCM VIII L.P./LCM VIII Corp.
                            Rating
Class               To                  From
A Notes             NR                  AAA (sf)
B Notes             NR                  AA+ (sf)
C Notes             NR                  A+ (sf)
D Notes             NR                  BBB+ (sf)

Longhorn CDO III Ltd.
                            Rating
Class               To                  From
D-1                 NR                  CCC+ (sf)
D-2                 NR                  CCC+ (sf)

Market Square CLO Ltd.
                            Rating
Class               To                  From
B                   NR                  AA+ (sf)
C                   NR                  A- (sf)
D                   NR                  B+ (sf)

Metropolis II LLC 2010-02
                            Rating
Class               To                  From
A Notes             NR                  AAA (sf)

Monument Park CDO Ltd.
                            Rating
Class               To                  From
B                   NR                  A+ (sf)

Navigator CDO 2004 Ltd.
                            Rating
Class               To                  From
B-1 Notes           NR                  AAA (sf)
B-2 Notes           NR                  AAA (sf)

Newcastle CDO IV Limited
                            Rating
Class               To                  From
I                   NR                  BB+ (sf)
II-FL Def           NR                  B+ (sf)
II-FX Def           NR                  B+ (sf)
III-FL Def          NR                  CCC+ (sf)
III-FX Def          NR                  CCC+ (sf)
IV-FL Def           NR                  CCC- (sf)
IV-FX Def           NR                  CCC- (sf)
V Def               NR                  CC (sf)

Northwoods Capital IX, Limited
                            Rating
Class               To                  From
X Notes             NR                  AAA (sf)

OWS CLO I Ltd.
                            Rating
Class               To                  From
A-2 Notes           NR                  AAA (sf)
X-1 Notes           NR                  AAA (sf)
X-2 Notes           NR                  AAA (sf)

Sagamore CLO Ltd.
                            Rating
Class               To                  From
B Notes             NR                  BBB- (sf)

Sheridan Square CLO Ltd.
                            Rating
Class               To                  From
X Notes             NR                  AAA (sf)

Southport CLO, Limited
                            Rating
Class               To                  From
B Notes             NR                  AAA (sf)

Trapeza CDO III LLC
                            Rating
Class               To                  From
A1A                 NR                  A+ (sf)

Venture II CDO 2002, Limited
                            Rating
Class               To                  From
B Notes             NR                  A+ (sf)

Venture III CDO Ltd.
                            Rating
Class               To                  From
A-2                 NR                  AAA (sf)

Wind River CLO II-Tate Investors Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)
A-2                 NR                  AAA (sf)
B-1                 NR                  AA+ (sf)
B-2                 NR                  AA+ (sf)
C                   NR                  BB+ (sf)
D-1                 NR                  CCC- (sf)
D-2                 NR                  CCC- (sf)
Type 1 Composite    NR                  CCC- (sf)

NR-Not Rated



                            *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers"
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR.  Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors" Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Washington, D.C., USA.
Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Valerie Udtuhan, Howard C. Tolentino, 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.


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