TCR_Public/140112.mbx          T R O U B L E D   C O M P A N Y   R E P O R T E R

            Sunday, January 12, 2014, Vol. 18, No. 11

                            Headlines

ACA ABS 2003-2: Fitch Affirms Junk Rating on Nine Note Classes
ACA CLO 2006-2: Moody's Affirms 'Ba1' Rating on Class D Notes
AIRLIE CLO 2006-I: Moody's Hikes Rating on $8MM Cl. D Notes to Ba1
AMERICAN CREDIT 2014-1: S&P Assigns Prelim. BB Rating on D Notes
APHEX CAPITAL 2007-4: Moody's Affirms C Rating on 2 Note Classes

APHEX CAPITAL 2007-7SR: Moody's Affirms C Rating on 3 Note Classes
APIDOS CLO XVI: S&P Assigns 'BB' Rating on Class D Notes
ARES XXI: Moody's Affirms Ba2 Rating on $15MM Class D Notes
ARGENT SECURITIES: Moody's Lowers Rating on Cl. M-2 Debt to Ba2
ATLAS SENIOR: S&P Affirms BB Rating on Class E Notes

BALLYROCK CLO 2013-1: S&P Affirms BB Rating on Class E Notes
BATTALION CLO IV: S&P Affirms 'BB' Rating on Class D Notes
BEAR STEARNS 1999-CLF1: Moody's Affirms Ba1 Rating on Cl. C Certs
BEAR STEARNS 2007-TOP28: DBRS Lowers Rating on Cl. L Debt to 'D'
BLACK DIAMOND: S&P Assigns Preliminary BB Rating on Class D Notes

C-BASS CBO VII: Moody's Raises Rating on $14.6MM Notes to 'Caa3'
CATHEDRAL LAKE: S&P Assigns Preliminary BB Rating on Class D Notes
CD 2007-CD4: S&P Affirms 'CCC' Rating on Class B Notes
CITIGROUP 2008-C7: S&P Affirms B- Rating on 2 Note Classes
COMM 2013-CCRE13: Fitch Rates Class F Certificates 'Bsf'

COPPER RIVER: Moody's Affirms Ba2 Rating on $23.8MM Cl. E Notes
CRYSTAL COVE: Fitch Affirms 'Csf' Ratings on 5 Debt Classes
FOOTHILL CLO I: Moody's Ups Rating on $19MM Class E Notes to 'Ba1'
GALLATIN CLO 2013-1: S&P Affirms BB Rating on Class E Notes
GMAC COMMERCIAL 2001-C1: Fitch Affirms Dsf Rating on Class N Notes

GMAC COMMERCIAL 2000-C1: Moody's Ups Rating on Cl. K Certs to Caa2
HEWETT'S ISLAND VI: Moody's Raises Rating on $16MM Notes to Ba2
HILDENE CLO I: Moody's Rates $6MM Class F Notes 'B2'
JP MORGAN 2005-CIBC12: Moody's Affirms 'C' Ratings 2 CBMS Classes
JP MORGAN 2006-CIBC17: Fitch Affirms CC Rating on Cl. A-J Certs

JP MORGAN 2006-LDP9: S&P Lowers Rating on 3 Note Classes to D
JP MORGAN 2007-LDP10: Fitch Affirms 'D' Ratings on 2 Cert Classes
JP MORGAN 2014-FBLU: S&P Assigns Prelim. BB- Rating on Cl. E Notes
MCF CLO III: S&P Assigns BB Rating on Class E Notes
MIDOCEAN CREDIT: S&P Assigns Prelim. BB Rating on Class E Notes

MORGAN STANLEY 2007-3: Moody's Hikes Ratings on 3 Notes to 'Caa3'
NEWCASTLE CDO VIII: Fitch Affirms CCC Ratings on 7 Note Classes
NEWCASTLE CDO IX: Fitch Affirms CCCsf Rating on 4 Debt Classes
OFSI FUND III: Moody's Raises Ratings on Two Note Classes to 'Ba2'
OHA LOAN 2013-1: S&P Affirms 'BB' Rating on Class E Notes

REAL ESTATE 2006-1: Moody's Affirms 'B1' Rating on Cl. J Certs
SAPPHIRE VALLEY: Moody's Affirms 'Ba2' Rating on Class E Notes
SDART 2014-1: Fitch Rates $60.15-Mil. Class E Notes 'BBsf'
SDART 2014-1: S&P Assigns Prelim. BB+ Rating on Cl. E Notes
VITALITY RE V: S&P Assigns Prelim. 'BB+' Rating on Class B Notes

WACHOVIA BANK 2006-C25: Fitch Cuts Class G Certs Rating to 'Csf'
WAVE SPC 2007-1: Moody's Affirms 'Ca' Ratings on 5 Classes
WELLS FARGO 2011-C2: Fitch Affirms 'Bsf' Rating on Class F Notes

* Fitch Cuts Ratings on 35 Bonds in 19 CMBS Transactions to 'D'
* Fitch Lowers 181 Distressed Bonds in 108 RMBS Deals to 'Dsf'
* Moody's Takes Action on $496MM of Alt-A RMBS Issued 2005-2006
* Moody's Raises Rating on $533 Million of RMBS Issued From 2005
* S&P Withdraws Ratings on 26 Classes from 12 CDO Transactions

* S&P Lowers Four Ratings from Three U.S. CMBS Transactions
* S&P Lowers 6 Ratings on 4 U.S. CMBS Transactions to Dsf


                             *********


ACA ABS 2003-2: Fitch Affirms Junk Rating on Nine Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed nine classes of notes issued by ACA ABS
2003-2, Limited (ACA 2003-2), as follows:

  -- $39,496,883 class A-1SD notes at 'Csf';
  -- $84,925,038 class A-1SU notes at 'Csf';
  -- $2,696,033 class A-1SW notes at 'Csf';
  -- $108,000,000 class A-1J notes at 'Csf';
  -- $51,000,000 class A-2 notes at 'Csf';
  -- $44,397,036 class A-3 notes at 'Csf';
  -- $9,431,457 class B-F notes at 'Csf';
  -- $21,041,933 class B-V notes at 'Csf';
  -- $6,053,342 class C notes at 'Csf'.

The rating affirmations on all classes of notes are due to the
amount of expected losses from the distressed and defaulted
portion of collateral (rated 'CCsf' and lower) in the current
portfolio exceeding each note's respective credit enhancement (CE)
level.  As such, Fitch expects the full repayment of principal and
deferred interest (in the case of deferrable classes) prior to or
at maturity appears highly unlikely, therefore default seems
inevitable for all nine classes.

Since Fitch's last rating review in January 2013, the class A-1SD,
A-1SU, and A-1SW (collectively, class A-1S) notes received
approximately $48 million in principal proceeds.  Although the CE
to the A-1S notes has subsequently increased as a result of this
deleveraging, it still remains significantly below the expected
losses.  In addition, interest collections are currently unable to
support the full payment of interest due on the class A-1S notes,
as well as the other two non-deferrable classes -- the class A-1J
and class A-2 notes.  Over the last four payment dates, principal
proceeds have been used to cover interest shortfalls to these
classes.  The remaining four deferrable classes -- the class A-3,
B-F, B-V, and class C notes -- have not received any distributions
over the last year and remain significantly undercollateralized.

This transaction has limited sensitivity to further negative
migration given the distressed ratings of the notes.  However,
there is potential for non-deferrable classes to be downgraded to
'Dsf' should they experience any interest payment shortfalls.

This review was conducted under the framework described in the
reports 'Global Structured Finance Rating Criteria' and 'Global
Rating Criteria for Structured Finance CDOs'.  Neither a cash flow
model framework nor Fitch's Structured Finance Portfolio Credit
Model was included in this review, as expected losses from
defaulted and distressed collateral exceed the CE level of the
senior-most class of notes.  Fitch believes that the probability
of default can be evaluated without factoring potential losses
from the performing portion of the portfolio.

ACA ABS 2003-2 is a cash flow structured finance collateralized
debt obligation (SF CDO) that closed on Nov. 6, 2003 and was
managed by ACA Management, LLC until April 2008, when management
duties were transferred to Solidus Capital, LLC.  Presently the
portfolio is comprised of residential mortgage-backed securities
(61.8%), SF CDOs (22.8%), real estate investment trust (REIT)
securities (11.7%), and commercial mortgage-backed securities
(3.7%), from the 2002 through 2006 vintages.


ACA CLO 2006-2: Moody's Affirms 'Ba1' Rating on Class D Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by ACA CLO 2006-2, Limited:

U.S.$18,800,000 Class B Deferrable Floating Rate Notes Due January
20, 2021, Upgraded to Aa1 (sf); previously on June 11, 2013
Upgraded to Aa2 (sf)

U.S.$10,000,000 Class C Deferrable Floating Rate Notes Due January
20, 2021, Upgraded to A2 (sf); previously on June 11, 2013
Upgraded to A3 (sf)

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

U.S.$225,100,000 Class A-1 Senior Secured Floating Rate Notes Due
January 20, 2021 (current outstanding balance of $119,190,436),
Affirmed Aaa (sf); previously on June 11, 2013 Affirmed Aaa (sf)

U.S.$18,500,000 Class A-2 Senior Secured Floating Rate Notes Due
January 20, 2021, Affirmed Aaa (sf); previously on June 11, 2013
Upgraded to Aaa (sf)

U.S.$10,800,000 Class D Deferrable Floating Rate Notes Due January
20, 2021, Affirmed Ba1 (sf); previously on June 11, 2013 Upgraded
to Ba1 (sf)

ACA CLO 2006-2, Limited issued in December 2006, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans. The portfolio is managed by CVC
Credit Partners, LLC. The transaction's reinvestment period ended
in January 2013.

RATINGS RATIONALE

These rating actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's over-
collateralization ratios since the last rating action in June
2013. The Class A-1 notes have been paid down by approximately 31%
or $54.6 million since June 2013. Based on the trustees' December
2013 report, the over-collateralization (OC) ratios for the Class
A, Class B, Class C and Class D Notes are 141.3%, 124.3%, 116.9%
and 109.8%, respectively, up from 130.3%, 118.7%, 113.4%, and
108.1%, respectively.

The deal has benefited from an improvement in the credit quality
of the portfolio since June 2013. Based on the trustee's December
2013 report, the weighted average rating factor is currently 2360
compared to 2509 in May 2013.

Methodology Used for the Rating Action

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

Factors that Would Lead to an Upgrade or Downgrade of the Ratings

This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings:

1) Macroeconomic uncertainty: CLO performance is subject to a)
uncertainty about credit conditions in the general economy and b)
the large concentration of upcoming speculative-grade debt
maturities, which could make refinancing difficult for issuers.

2) Collateral Manager: Performance can also be affected positively
or negatively by a) the manager's investment strategy and behavior
and b) differences in the legal interpretation of CLO
documentation by different transactional parties owing to embedded
ambiguities.

3) Collateral credit risk: A shift towards collateral of better
credit quality, or better credit performance of assets
collateralizing the transaction than Moody's current expectations,
can lead to positive CLO performance. Conversely, a negative shift
in credit quality or performance of the collateral can have
adverse consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace. Deleveraging of the CLO
could accelerate owing to high prepayment levels in the loan
market and/or collateral sales by the manager, which could have a
significant impact on the notes' ratings. Note repayments that are
faster than Moody's current expectations will usually have a
positive impact on CLO notes, beginning with those with the
highest payment priority.

5) Recovery of defaulted assets: Fluctuations in the market value
of defaulted assets reported by the trustee and those that Moody's
assumes as having defaulted could result in volatility in the
deal's OC levels. Further, the timing of recoveries and whether a
manager decides to work out or sell defaulted assets create
additional uncertainty. 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.
Realization of higher than assumed recoveries would positively
impact the CLO.

In addition to the base case analysis, Moody's also conducted
sensitivity analyses to test the impact of a number of default
probabilities on the rated notes. Below is a summary of the impact
of different default probabilities (expressed in terms of WARF) on
all of the rated notes (by the difference in the number of notches
versus the current model output, for which a positive difference
corresponds to lower expected loss):

Moody's Adjusted WARF -- 20% (2009)

Class A-1: 0

Class A-2: 0

Class B: +1

Class C: +3

Class D: +2

Moody's Adjusted WARF + 20% (3014)

Class A-1: 0

Class A-2: 0

Class B: -2

Class C: -2

Class D: -1

Loss and Cash Flow Analysis

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," published in November 2013.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base
case, Moody's analyzed the collateral pool as having a performing
par and principal proceeds balance of $192.9 million, defaulted
par of $7.0 million, a weighted average default probability of
15.87% (implying a WARF of 2511), a weighted average recovery rate
upon default of 49.81%, a diversity score of 52 and a weighted
average spread of 3.13%.

Moody's incorporates the default and recovery properties of the
collateral pool in cash flow model analysis where they are subject
to stresses as a function of the target rating on each CLO
liability reviewed. Moody's derives the default probability from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate for future defaults is based primarily on the seniority of
the assets in the collateral pool. In each case, historical and
market performance and the collateral manager's latitude for
trading the collateral are also factors.


AIRLIE CLO 2006-I: Moody's Hikes Rating on $8MM Cl. D Notes to Ba1
------------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of the following notes issued by Airlie CLO 2006-I, Ltd.:

   -- U.S. $31,000,000 Class C Senior Secured Deferrable Floating
      Rate Notes Due May 20, 2020, Upgraded to A2 (sf); previously
      on July 29, 2013 Upgraded to Baa1 (sf);

   -- U.S. $8,000,000 Class D Senior Secured Deferrable Floating
      Rate Notes Due May 20, 2020, Upgraded to Ba1 (sf);
      previously on July 29, 2013 Affirmed Ba3 (sf)

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

   -- U.S. $287,000,000 Class A-1 Senior Secured Floating Rate
      Notes Due May 20, 2020 (current outstanding balance
      $71,280,307), Affirmed Aaa (sf); previously on July 29, 2013
      Affirmed Aaa (sf);

   -- U.S. $16,000,000 Class A-2 Senior Secured Floating Rate
      Notes Due May 20, 2020, Affirmed Aaa (sf); previously on
      July 29, 2013 Affirmed Aaa (sf); and

   -- U.S. $16,500,000 Class B Senior Secured Deferrable Floating
      Rate Notes Due May 20, 2020, Affirmed Aaa (sf); previously
      on July 29, 2013 Upgraded to Aaa (sf)

Airlie CLO 2006-I, Ltd., issued in May 2006, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

                         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
July 2013.  Moody's notes that the Class A-1 Notes have been paid
down by approximately 36% or $39.6 million since July 2013.  Based
on the latest trustee report dated Dec. 6, 2013, the Class A,
Class B, Class C and Class D overcollateralization ratios are
reported at 167.2%, 144.6%, 115.3% and 109.5%, respectively,
versus July 2013 levels 156.4%, 138.4%, 113.8% and 108.8%,
respectively.  The December 2013 trustee overcollateralization
ratios do not reflect the December 20, 2013 payment of
$18.2 million to Class A-1 Notes.

             Methodology Underlying the Rating Action

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

Factors that Would Lead to an Upgrade or Downgrade of the Ratings
Moody's notes that this transaction is subject to a number of
factors and circumstances that could lead to either an upgrade or
downgrade of the ratings, as described below:

1) Macroeconomic uncertainty: CLO performance may be negatively
impacted by a) uncertainties of credit conditions in the general
economy and b) the large concentration of upcoming speculative-
grade debt maturities which may create challenges for issuers to
refinance.

2) Collateral Manager: Performance may also be impacted, either
positively or negatively, by a) the manager's investment strategy
and behavior and b) divergence in legal interpretation of CLO
documentation by different transactional parties due to embedded
ambiguities.

3) Collateral credit risk: A shift towards holding collateral of
better credit quality, or better than expected credit performance
of the underlying assets collateralizing the transaction, can lead
to positive CLO performance.  Conversely, a negative shift in
credit quality or performance of the underlying collateral can
have adverse consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace.  Deleveraging of the CLO
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.  Faster than expected note repayment
will usually have a positive impact on CLO notes, beginning with
those having the highest payment priority.

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.  Below is a summary of the impact
of different default probabilities (expressed in terms of WARF
levels) on all rated notes (shown in terms of the number of
notches' difference versus the current model output, where a
positive difference corresponds to lower expected loss), assuming
that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2079)
Class A-1: 0
Class A-2: 0
Class B: 0
Class C: +2
Class D: +2

Moody's Adjusted WARF + 20% (3119)
Class A-1: 0
Class A-2: 0
Class B: 0
Class C: -2
Class D: -1

Loss and Cash Flow Analysis

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score, and the weighted
average recovery rate, are based on its published methodology and
could be different from the trustee's reported numbers.  In its
base case, Moody's analyzed the underlying collateral pool as
having a performing par and principal proceeds balance of
$158.1 million, no defaulted par, a weighted average default
probability of 16.50% (implying a WARF of 2599), a weighted
average recovery rate upon default of 52.28%, a diversity score of
34 and a weighted average spread of 2.97%.

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.

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 2013.


AMERICAN CREDIT 2014-1: S&P Assigns Prelim. BB Rating on D Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to American Credit Acceptance Receivables Trust 2014-1's
$204.82 million asset-backed notes series 2014-1.

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

The preliminary ratings are based on information as of Jan. 6,
2014.  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 availability of approximately 57.0%, 46.4%, 38.3%, and
      34.8% of credit support for the class A, B, C, and D notes,
      respectively, based on break-even stressed cash flow
      scenarios (including excess spread), which provide coverage
      of more than 2.10x, 1.70x, 1.35x, and 1.25x its expected net
      loss range of 26.40%-26.90% for the class A, B, C, and D
      notes, respectively.

   -- The timely interest and principal payments made to the
      preliminary rated notes by the assumed legal final maturity
      dates under its stressed cash flow modeling scenarios that
      S&P believes is appropriate for the assigned preliminary
      ratings.

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

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

   -- The backup servicing arrangement with Wells Fargo Bank N.A.

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

   -- The transaction's legal structure.

PRELIMINARY RATINGS ASSIGNED

American Credit Acceptance Receivables Trust 2014-1

Class     Rating       Type            Interest         Amount
                                       rate        (mil. $)(i)
A         AA (sf)      Senior          Fixed            120.00
B         A (sf)       Subordinate     Fixed             39.50
C         BBB (sf)     Subordinate     Fixed             31.32
D         BB (sf)      Subordinate     Fixed             14.00

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


APHEX CAPITAL 2007-4: Moody's Affirms C Rating on 2 Note Classes
----------------------------------------------------------------
Moody's Investors Service announced that it has affirmed the
ratings on the following notes issued by Aphex Capital NSCR
2007-4, Ltd.:

   -- Cl. A-1, Affirmed C (sf); previously on Mar 1, 2013
      Downgraded to C (sf);

   -- Cl. A-2, Affirmed C (sf); previously on Mar 1, 2013 Affirmed
      C (sf)

                         RATINGS RATIONALE

Moody's has affirmed the ratings on the transaction because its
key transaction metrics are commensurate with existing ratings.
The affirmation is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO
Synthetic) transactions.

Aphex Capital NSCR 2007-4 is a static synthetic transaction backed
by a portfolio of credit default swaps referencing 100% commercial
mortgage backed securities (CMBS).  The CMBS reference obligations
were securitized in 2005 (39.5%) and 2006 (60.5%).  Currently,
75.3% of the reference obligations are rated by Moody's.

Moody's has identified the following as key indicators of the
expected loss in CRE CDO transactions: the weighted average rating
factor (WARF), the weighted average life (WAL), the weighted
average recovery rate (WARR), and Moody's asset correlation (MAC).
Moody's typically models these 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 updated its assessments for the reference obligations
it does not rate.  The rating agency modeled a bottom-dollar WARF
of 6720, compared to 6347 at last review.  The current ratings on
the Moody's-rated reference obligations and the assessments of the
non-Moody's rated reference obligations follow: Baa1-Baa3 and 7.1%
compared to 6.6% at last review; Ba1-Ba3 and 9.0% compared to
10.0% at last review; B1-B3 and 9.0% compared to 11.7% at last
review; and Caa1-Ca/C and 74.9%, compared to 71.7% at last review.

Moody's modeled a WAL of 2.7 years, compared to 3.4 years at last
review.  The WAL is based on assumptions about extensions on the
underlying reference obligations.

Moody's modeled a variable WARR with a mean of 2.8%, compared to a
mean of 2.9% at last review.

Moody's modeled a MAC of 0.0%, compared to 100.0% at last review.
The greater MAC is due to higher risk reference obligations
concentrated in fewer names.

Methodologies Underlying the Rating Action:

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

Factors that would lead to an upgrade or downgrade of the rating
The performance of the notes is subject to uncertainty, because it
is sensitive to the performance of the underlying portfolio, which
in turn depends on economic and credit conditions that are subject
to change.  The servicing decisions of the master and special
servicer and surveillance by the operating advisor with respect to
the collateral interests and oversight of the transaction will
also affect the performance of the rated notes.

Moody's Parameter Sensitivities: Changes to any one or more of the
key parameters could have rating implications for some of the
rated notes, although a change in one key parameter assumption
could be offset by a change in one or more of the other key
parameter assumptions.  The rated notes are particularly sensitive
to changes in the ratings of the reference obligations and credit
assessments.  However, in light of the performance indicators
noted above, Moody's believes that it is unlikely that the ratings
announced today are sensitive to any further changes.

The primary sources of uncertainty in Moody's assumptions are the
extent of growth in the current macroeconomic environment given
the weak recovery and commercial real estate property markets.

Commercial real estate property values continue to improve
modestly, 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, sustained growth will not be possible until investment
increases steadily for a significant period, non-performing
properties are cleared from the pipeline and fears of a euro area
recession abate.


APHEX CAPITAL 2007-7SR: Moody's Affirms C Rating on 3 Note Classes
------------------------------------------------------------------
Moody's Investors Service announced that it has affirmed the
ratings on the following notes issued by Aphex Capital NSCR 2007-
7SR, Ltd.:

   -- U.S. $54,000,000 Class A-2 Credit Linked Variable Floating
      Rate Notes Due December 2038, Affirmed C (sf); previously on
      Mar 1, 2013 Affirmed C (sf);

   -- U.S. $10,000,000 Class A-1B Credit Linked Variable Floating
      Rate Notes Due December 2038, Affirmed C (sf); previously on
      Mar 1, 2013 Downgraded to C (sf);

   -- U.S. $116,000,000 Class A-1A Credit Linked Variable Floating
      Rate Notes Due December 2038, Affirmed C (sf); previously on
      Mar 1, 2013 Downgraded to C (sf)

                         RATINGS RATIONALE

Moody's has affirmed the ratings on the transaction because its
key transaction metrics are commensurate with existing ratings.
The affirmation is the result of Moody's on-going surveillance of
commercial real estate collateralized debt obligation (CRE CDO
Synthetic) transactions.

Aphex Capital NSCR 2007-7SR is a static synthetic transaction
backed by a portfolio of credit default swaps referencing 100%
commercial mortgage backed securities (CMBS).  The CMBS reference
obligations were securitized in 2006 (78.2%) and 2007 (21.8%).
Currently, 78.1% of the reference obligations are rated by
Moody's.

Moody's has identified the following as key indicators of the
expected loss in CRE CDO transactions: the weighted average rating
factor (WARF), the weighted average life (WAL), the weighted
average recovery rate (WARR), and Moody's asset correlation (MAC).
Moody's typically models these 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 updated its assessments for the reference obligations
it does not rate.  The rating agency modeled a bottom-dollar WARF
of 8491, compared to 8207 at last review. The current ratings on
the Moody's-rated reference obligations and the assessments of the
non-Moody's rated reference obligations follow: Ba1-Ba3 and 1.8%
compared to 3.3% at last review; B1-B3 and 3.6% compared to 6.7%
at last review; and Caa1-Ca/C and 94.6%, compared to 90.0% at last
review.

Moody's modeled a WAL of 3.3 years, compared to 3.8 at last
review.  The WAL is based on assumptions about extensions on the
underlying reference obligations.

Moody's modeled a variable WARR with a mean of 0.4%, compared to a
mean of 0.7% at last review.

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

Methodologies Underlying the Rating Action:

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

Factors that would lead to an upgrade or downgrade of the rating
The performance of the notes is subject to uncertainty, because it
is sensitive to the performance of the underlying portfolio, which
in turn depends on economic and credit conditions that are subject
to change.  The servicing decisions of the master and special
servicer and surveillance by the operating advisor with respect to
the collateral interests and oversight of the transaction will
also affect the performance of the rated notes.

Moody's Parameter Sensitivities: Changes to any one or more of the
key parameters could have rating implications for some of the
rated notes, although a change in one key parameter assumption
could be offset by a change in one or more of the other key
parameter assumptions.  The rated notes are particularly sensitive
to changes in the ratings of the reference obligations and credit
assessments.  However, in light of the performance indicators
noted above, Moody's believes that it is unlikely that the ratings
announced are sensitive to any further changes.

The primary sources of uncertainty in Moody's assumptions are the
extent of growth in the current macroeconomic environment given
the weak recovery and commercial real estate property markets.

Commercial real estate property values continue to improve
modestly, 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, sustained growth will not be possible until investment
increases steadily for a significant period, non-performing
properties are cleared from the pipeline and fears of a euro area
recession abate.


APIDOS CLO XVI: S&P Assigns 'BB' Rating on Class D Notes
--------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Apidos
CLO XVI/Apidos CLO XVI LLC's $571 million fixed- and floating-rate
notes.

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

The ratings reflect S&P's view of:

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

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

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

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

   -- The collateral manager's experienced management team.

   -- S&P's projections regarding the timely interest and ultimate
      principal payments on the rated notes, which S&P assessed
      using its cash flow analysis and assumptions commensurate
      with the assigned ratings under various interest-rate
      scenarios, including LIBOR ranging from 0.239%-13.839%.

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

          STANDARD & POOR'S 17G-7 DISCLOSURE REPORT

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

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

        http://standardandpoorsdisclosure-17g7.com/2052.pdf

RATINGS ASSIGNED

Apidos CLO XVI/Apidos CLO XVI LLC


Class                 Rating                 Amount
                                           (mil. $)
X                     AAA (sf)                 3.75
A-1                   AAA (sf)               383.00
A-2A                  AA (sf)                 34.50
A-2B                  AA (sf)                 30.00
B (deferrable)        A (sf)                  46.00
C (deferrable)        BBB (sf)                31.25
D (deferrable)        BB (sf)                 27.50
E (deferrable)        B (sf)                  15.00
Subordinated notes    NR                      54.00

NR-Not rated.


ARES XXI: Moody's Affirms Ba2 Rating on $15MM Class D Notes
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Ares XXI CLO Ltd.:

U.S. $25,000,000 Class A-2 Floating Rate Notes Due December 19,
2018, Upgraded to Aa1 (sf); previously on September 1, 2011
Upgraded to Aa3 (sf)

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

U.S. $333,000,000 Class A-1 Floating Rate Notes Due December 19,
2018, Affirmed Aaa (sf); previously on September 1, 2011 Upgraded
to Aaa (sf)

U.S. $25,000,000 Class B Deferrable Floating Rate Notes Due
December 19, 2018, Affirmed A3 (sf); previously on September 1,
2011 Upgraded to A3 (sf)

U.S. $18,000,000 Class C Floating Rate Notes Due December 19,
2018, Affirmed Baa3 (sf); previously on September 1, 2011 Upgraded
to Baa3 (sf)

U.S. $15,000,000 Class D Floating Rate Notes Due December 19,
2018, Affirmed Ba2 (sf); previously on September 1, 2011 Upgraded
to Ba2 (sf)

Ares XXI CLO Ltd. issued in December 2006, is a collateralized
loan obligation "CLO" backed primarily by a portfolio of senior
secured loans. The portfolio is managed by Ares Management LLC.
The transaction's reinvestment period will end in February 2014.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes
reflect the benefit of the short period of time remaining before
the end of the deal's reinvestment period in February 2014. In
consideration of the reinvestment restrictions applicable during
the amortization period, and therefore limited ability to effect
significant changes to the current collateral pool, Moody's
analyzed the deal assuming a higher likelihood that the collateral
pool characteristics will continue to maintain a positive buffer
relative to certain covenant requirements. In particular, the deal
is assumed to benefit from lower WARF of 2474 compared to the
level in December 2012. Moody's also notes that the transaction's
reported overcollateralization ratios are stable since December
2012.

Moody's notes that the underlying portfolio includes a number of
investments in securities that mature after the maturity date of
the notes. Based on the December 2013 trustee report, securities
that mature after the maturity date of the notes currently make up
approximately 4.87% of the underlying portfolio. These investments
potentially expose the notes to market risk in the event of
liquidation at the time of the notes' maturity. Notwithstanding
the improvement in credit quality of the portfolio, Moody's
affirmed the rating of the Class D notes due to the market risk
posed by the exposure to these long-dated assets.

Methodology Underlying the Rating Action

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

Factors that Would Lead to an Upgrade or Downgrade of the Ratings

Moody's notes that this transaction is subject to a number of
factors and circumstances that could lead to either an upgrade or
downgrade of the ratings, as described below:

1) Macroeconomic uncertainty: CLO performance may be negatively
impacted by a) uncertainties of credit conditions in the general
economy and b) the large concentration of upcoming speculative-
grade debt maturities which may create challenges for issuers to
refinance.

2) Collateral Manager: Performance may also be impacted, either
positively or negatively, by a) the manager's investment strategy
and behavior and b) divergence in legal interpretation of CLO
documentation by different transactional parties due to embedded
ambiguities.

3) Collateral credit risk: A shift towards holding collateral of
better credit quality, or better than expected credit performance
of the underlying assets collateralizing the transaction, can

lead to positive CLO performance. Conversely, a negative shift in
credit quality or performance of the underlying collateral can
have adverse consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will commence and at what pace. Deleveraging of the CLO
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. Faster than expected note repayment
will usually have a positive impact on CLO notes, beginning with
those having the highest payment priority.

5) 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. Realization of higher than assumed recoveries would
positively impact the CLO.

6) 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. This risk is borne first by investors having the
lowest seniority in the capital structure. Moody's assumes an
asset's terminal value upon liquidation at maturity to be equal to
the lower of an assumed liquidation value (depending on the extent
to which the asset's maturity lags that of the liabilities) and
the asset's current market value. In consideration of the size of
the deal's exposure to long-dated assets, which increases its
sensitivity to the liquidation assumptions used in the rating
analysis, Moody's ran different scenarios considering a range of
liquidation value assumptions. However, actual long-dated asset
exposure and prevailing market prices and conditions at the CLO's
maturity will drive the extent of the deal's realized losses, if
any, from long-dated assets.

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. Below is a summary of the impact of
different default probabilities (expressed in terms of WARF
levels) on all rated notes (shown in terms of the number of
notches' difference versus the current model output, where a
positive difference corresponds to lower expected loss), assuming
that all other factors are held equal:

Moody's Adjusted WARF -- 20% (1979)

Class A-1: 0

Class A-2: +1

Class B: +3

Class C: +2

Class D: +1

Moody's Adjusted WARF + 20% (2969)

Class A-1: 0

Class A-2: -2

Class B: -2

Class C: 0

Class D: -2

Loss and Cash Flow Analysis

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score, and the weighted
average recovery rate, are based on its published methodology and
could be different from the trustee's reported numbers. In its
base case, Moody's analyzed the underlying collateral pool as
having a performing par and principal proceeds balance of $427.9
million, defaulted par of $1.9 million, a weighted average default
probability of 15.40% (implying a WARF of 2474), a weighted
average recovery rate upon default of 50.40%, a diversity score of
56 and a weighted average spread of 3.05%.

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.

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 2013.


ARGENT SECURITIES: Moody's Lowers Rating on Cl. M-2 Debt to Ba2
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of two
tranches and upgraded the rating of one tranche from three
transactions backed by Subprime mortgage loans.

Complete rating actions are as follows:

Issuer: Argent Securities Inc., Series 2004-PW1
Cl. M-2, Downgraded to Ba2 (sf); previously on Mar 18, 2013
Downgraded to Baa3 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2004-13
Cl. AF-4, Upgraded to Baa2 (sf); previously on Mar 6, 2013
Upgraded to Ba1 (sf)

Issuer: CWABS, Inc., Asset-Backed Certificates, Series 2003-BC6
Cl. M-1, Downgraded to Ba2 (sf); previously on Apr 16, 2012
Downgraded to Baa3 (sf)

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

Factors that would lead to an upgrade or downgrade of the rating
Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment
rate.  The unemployment rate fell to 7% in November 2013 from 7.8%
in November 2012.  Moody's forecasts an unemployment central range
of 6.5% to 7.5% for the 2014 year.  Deviations from this central
scenario could lead to rating actions in the sector.  House prices
are another key driver of US RMBS performance.  Moody's expects
house prices to continue to rise in 2014.  Lower increases than
Moody's expects or decreases could lead to negative rating
actions.  Finally, 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.


ATLAS SENIOR: S&P Affirms BB Rating on Class E Notes
----------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on Atlas
Senior Loan Fund III Ltd./Atlas Senior Loan Fund III LLC's
$370.80 million floating-rate notes following the transaction's
effective date as of Oct. 2, 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 our opinion that
the portfolio collateral purchased by the issuer, as reported to
us by the trustee and collateral manager, in combination with the
transaction's structure, provides sufficient credit support to
maintain the ratings that we assigned on the transaction's closing
date.  The effective date reports provide a summary of certain
information that we used in our analysis and the results of our
review based on the information presented to us," S&P said.

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

For a CLO that has not purchased its full target level of
portfolio collateral by the closing date, S&P's ratings on the
closing date and prior to its effective date review are generally
based on the application of its criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to 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 noted.

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

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

RATINGS AFFIRMED

Class                Rating         Amount (Mil. $)
A                    AAA (sf)               251.20
B                    AA (sf)                 44.00
C (deferrable)       A (sf)                  35.20
D (deferrable)       BBB (sf)                22.40
E (deferrable)       BB (sf)                 18.00


BALLYROCK CLO 2013-1: S&P Affirms BB Rating on Class E Notes
------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Ballyrock CLO 2013-1 Ltd./Ballyrock CLO 2013-1 LLC's class A, B,
C, D, and E notes following the transaction's effective date as of
Oct. 18, 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 our opinion that
the portfolio collateral purchased by the issuer, as reported to
us by the trustee and collateral manager, in combination with the
transaction's structure, provides sufficient credit support to
maintain the ratings that we assigned on the transaction's closing
date.  The effective date reports provide a summary of certain
information that we used in our analysis and the results of our
review based on the information presented to us," S&P said.

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

For a CLO that has not purchased its full target level of
portfolio collateral by the closing date, S&P's ratings on the
closing date and prior to its effective date review are generally
based on the application of its criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to 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 S&P's published effective date report, it discusses its
analysis of the information provided by the transaction's trustee
and collateral manager in support of their request for effective
date rating affirmation.  In most instances, S&P intends to
publish an effective date report each time it issues an effective
date rating affirmation on a publicly rated U.S. cash flow CLO.

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

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

Class                      Rating                       Amount
                                                      (mil. $)
A                          AAA (sf)                     252.00
B                          AA (sf)                       42.00
C (deferrable)             A (sf)                        35.20
D (deferrable)             BBB (sf)                      22.80
E (deferrable)             BB (sf)                       16.40


BATTALION CLO IV: S&P Affirms 'BB' Rating on Class D Notes
----------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Battalion CLO IV Ltd./Battalion CLO IV LLC's $378.00 million
floating-rate notes following the transaction's effective date as
of Nov. 27, 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 our opinion that
the portfolio collateral purchased by the issuer, as reported to
us by the trustee and collateral manager, in combination with the
transaction's structure, provides sufficient credit support to
maintain the ratings that we assigned on the transaction's closing
date.  The effective date reports provide a summary of certain
information that we used in our analysis and the results of our
review based on the information presented to us," S&P said.

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

For a CLO that has not purchased its full target level of
portfolio collateral by the closing date, S&P's ratings on the
closing date and prior to its effective date review are generally
based on the application of its criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to 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 noted.

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.

RATINGS AFFIRMED

Battalion CLO IV Ltd./Battalion CLO IV LLC

Class                      Rating                       Amount
                                                       (mil. $)
A-1                        AAA (sf)                     241.00
A-2                        AA (sf)                       50.00
B (deferrable)             A (sf)                        35.00
C (deferrable)             BBB (sf)                      22.00
D (deferrable)             BB (sf)                       19.00
E (deferrable)             B (sf)                        11.00


BEAR STEARNS 1999-CLF1: Moody's Affirms Ba1 Rating on Cl. C Certs
-----------------------------------------------------------------
Moody's Investors Service affirmed the ratings of four classes of
Bear Stearns Commercial Mortgage Securities Inc., Corporate Lease-
Backed Certificates, Series 1999-CLF1 as follows:

Cl. A-4, Affirmed Aaa (sf); previously on Feb 28, 2013 Affirmed
Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Feb 28, 2013 Affirmed Aa3
(sf)

Cl. C, Affirmed Ba1 (sf); previously on Feb 28, 2013 Affirmed Ba1
(sf)

Cl. X, Affirmed Aaa (sf); previously on Feb 28, 2013 Affirmed Aaa
(sf)

RATINGS RATIONALE

The ratings of three P&I classes were affirmed because the
transaction's key metric, the weighted average rating factor
(WARF), is within acceptable ranges. The rating on the IO class
was affirmed based on the credit performance (or the weighted
average rating factor or WARF) of the referenced class.

FACTORS THAT WOULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATING

The ratings of Credit Tenant Lease (CTL) deals are primarily based
on the senior unsecured debt rating (or the corporate family
rating) of the tenants leasing the real estate collateral
supporting the bonds. Other factors that are also considered are
Moody's dark value of the collateral (value based on the property
being vacant or dark), which is used to determine a recovery rate
upon a loan's default and the rating of the residual insurance
provider, if applicable. Factors that may cause an upgrade of the
ratings include an upgrade in the rating of the corporate tenant
or significant loan paydowns or amortization which result in a
higher dark loan to value. Factors that may cause a downgrade of
the ratings include a downgrade in the rating of the corporate
tenant or the residual insurance provider.

METHODOLOGY UNDERLYING THE RATING ACTION

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

Moody's used a Gaussian copula model, incorporated in its public
CDO rating model CDOROMv2.10-15, to generate a portfolio loss
distribution to assess the ratings.

DEAL PERFORMANCE

The CTL pool consists of 119 loans secured by properties leased to
18 tenants. The largest exposures are Koninklijke Ahold ($13.4
million -- 9.1% of the pool; senior unsecured rating: Baa2 --
positive outlook); United States Postal Service ($13.4 million --
9.1% of the pool; senior unsecured rating: Aaa -- stable outlook)
and JPMC ($11.0 million -- 7.5% of the pool; senior unsecured
rating: A3 -- stable outlook). 73% of the tenants have a Moody's
rating and Moody's has completed updated credit assessments for
the non-Moody's rated tenants. The bottom-dollar weighted average
rating factor (WARF) for this pool is 2077 compared to 2023 at the
last review. WARF is a measure of the overall quality of a pool of
diverse credits. The bottom-dollar WARF is a measure of default
probability.


BEAR STEARNS 2007-TOP28: DBRS Lowers Rating on Cl. L Debt to 'D'
----------------------------------------------------------------
DBRS Inc. has downgraded the rating for one class of Bear Stearns
Commercial Mortgage Securities Trust, Series 2007-TOP28 as
follows:

-- Class L to D (sf) from C (sf)

In addition, DBRS has removed the Interest in Arrears designation
assigned to Class L.

DBRS has also removed the Interest in Arrears designations from
Classes J and K as previous interest shortfalls to both classes
were repaid with the December 2013 remittance report.

Prospectus ID #148 (Glen Eagles Plaza) was liquidated with the
December 2013 remittance report for a cumulative loss of $985,369
to the trust, which caused the realized loss to Class L and
corresponding ratings downgrade. The loan was secured by an
unanchored retail property located in Edmond, Oklahoma, and
experienced a decline in property performance in 2010 after
several tenants vacated the property. The loan ultimately went
delinquent and was transferred to the special servicer in March
2012. The loan was liquidated with the December 2013 remittance
report, resulting in a loss severity of 33.3%.

As of the December 2013 remittance report, 11 loans have
liquidated from the trust, with cumulative losses totaling $29.0
million. Two loans remain in special servicing, with a combined
balance of $19.1 million (1.3% of the current pool balance).


BLACK DIAMOND: S&P Assigns Preliminary BB Rating on Class D Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Black Diamond CLO 2013-1 Ltd./Black Diamond CLO 2013-1
LLC's $370.80 million floating-rate notes.

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

The preliminary ratings are based on information as of Jan. 8,
2014.  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 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 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 0.2419%-13.8385%.

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

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

PRELIMINARY RATINGS ASSIGNED

Black Diamond CLO 2013-1 Ltd./Black Diamond CLO 2013-1 LLC

Class                 Rating               Amount
                                         (mil. $)
X                     AAA (sf)               2.10
A-1                   AAA (sf)             246.90
A-2                   AA (sf)               53.70
B (deferrable)        A (sf)                29.30
C (deferrable)        BBB (sf)              21.70
D (deferrable)        BB (sf)               17.10
Subordinated notes    NR                    42.10

NR--Not rated.


C-BASS CBO VII: Moody's Raises Rating on $14.6MM Notes to 'Caa3'
----------------------------------------------------------------
Moody's Investors Service has upgraded the rating on notes issued
by C-Bass CBO VII Ltd.:

  US$27,000,000 Class D Fourth Priority Secured Floating Rate
  Deferrable Interest Notes Due 2038 (current outstanding balance
  of $14,575,580.43), Upgraded to Caa3 (sf); previously on May 9,
  2013 Affirmed Ca (sf).

Ratings Rationale

The rating action is due primarily to the deleveraging of the
Class C Notes and an increase in the transaction's over-
collateralization ratios since the last rating action in May 2013.
The Class C Notes have paid down by approximately 66.6%, or $9.1
million, since May 2013. Based on the trustee's November 2013
report, the over-collateralization ratio of the Class C Notes and
Class D Notes are 744.38% and 177.59%, respectively, versus
355.51% and 149.67%, respectively, in May 2013.

Methodology Underlying the Rating Action

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

Factors that would lead to an upgrade or downgrade of the rating

This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings, as described below:

Primary causes of uncertainty about assumptions are the extent of
any slowdown in growth in the current macroeconomic environment
and in the residential real estate property markets. The
residential real estate property market is subject to uncertainty
about housing prices; the pace of residential mortgage
foreclosures, loan modifications and refinancing; the unemployment
rate; and interest rates.

Loss and Cash Flow Analysis

To model the loss distribution for SF CDOs, Moody's applies a
Monte Carlo simulation framework in Moody's CDOROM(TM) v2.10.15.
This framework generates defaults at the same frequency as that
indicated by the adjusted default probability (the default
probability associated with the current rating, multiplied by the
Resecuritization Stress) for each credit in the pool.
Specifically, Moody's simulates correlated defaults by applying a
normal (or Gaussian) copula model to the asset correlation
framework. Applying the distributional assumptions, including the
correlation between recovery values, generates recovery rates for
defaulted credits. The simulated defaults and recoveries for each
of the Monte Carlo scenarios define the reference pool's loss
distribution.

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

The rating action factors in a number of sensitivity analyses and
stress scenarios, discussed below. Below is a summary of the
impact on all of the rated notes in terms of the difference in the
number of notches versus the current model output, in which a
positive difference corresponds to a lower expected loss:

Caa rated assets notched up by 2 rating notches:

Class D: +1

Caa rated assets notched down by 2 rating notches:

Class D: 0


CATHEDRAL LAKE: S&P Assigns Preliminary BB Rating on Class D Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Cathedral Lake CLO 2013 Ltd./Cathedral Lake CLO 2013
Corp.'s $324.5 million fixed- and floating-rate notes.

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

The preliminary ratings are based on information as of Jan. 8,
2014.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

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

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

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

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

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

   -- The collateral manager's experienced management team.

   -- S&P's projections regarding the timely interest and ultimate
      principal payments on the preliminary rated notes, which S&P
      assessed using its cash flow analysis and assumptions
      commensurate with the assigned preliminary ratings under
      various interest-rate scenarios, including LIBOR ranging
      from 0.2429%-13.8385%.

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

PRELIMINARY RATINGS ASSIGNED

Cathedral Lake CLO 2013 Ltd./Cathedral Lake CLO 2013 Corp.

Class                Rating           Amount
A-1A                 AAA (sf)         169.80
A-1B                 AAA (sf)          50.00
A-2                  AA (sf)           40.25
B (deferrable)       A (sf)            28.00
C (deferrable)       BBB (sf)          20.00
D (deferrable)       BB (sf)           16.45
Subordinated notes   NR                38.50


CD 2007-CD4: S&P Affirms 'CCC' Rating on Class B Notes
------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on 12
classes of commercial mortgage pass-through certificates,
including the class XC, XP, and XW interest-only (IO)
certificates, from CD 2007-CD4 Commercial Mortgage Trust, a U.S.
commercial mortgage-backed securities (CMBS) transaction.

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

The rating affirmations on the principal and interest paying
classes reflect S&P's expectation that the available credit
enhancement for these classes will be within its estimated
necessary credit enhancement requirement for the current
outstanding ratings.  The affirmations also reflect S&P's review
of the loans' credit characteristics and the remaining loans'
performance.  In addition, S&P's analysis also considered the 38
assets with the special servicer, CWCapital Asset Management LLC,
($1.15 billion, 23.0%).

S&P affirmed its rating on the class XC, XP and XW IO certificates
to reflect its current criteria for rating IO securities.

RATINGS AFFIRMED

CD 2007-CD4 Commercial Mortgage Trust
Commercial mortgage pass-through certificates

Class              Rating     Credit enhancement (%)
A-2B               AAA (sf)                    37.24
A-3                AAA (sf)                    37.24
A-SB               AAA (sf)                    37.24
A-4                AAA (sf)                    37.24
A-1A               AAA (sf)                    37.24
A-MFX              BB+ (sf)                    24.07
A-MFL              BB+ (sf)                    24.07
A-J                CCC+ (sf)                   12.39
B                  CCC (sf)                    11.57
XP                 AAA (sf)                      N/A
XC                 AAA (sf)                      N/A
XW                 AAA (sf)                      N/A

N/A-Not applicable.


CITIGROUP 2008-C7: S&P Affirms B- Rating on 2 Note Classes
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on four
classes of commercial mortgage pass-through certificates from
Citigroup Commercial Mortgage Trust 2008-C7, a U.S. commercial
mortgage-backed securities (CMBS) transaction.  At the same time,
S&P affirmed its ratings on six classes of certificates from the
same transaction.

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

The upgrades reflect S&P's expectation of the available credit
enhancement, which S&P believes is greater than its most recent
estimate of necessary credit enhancement for the respective rating
levels.  The upgrades also reflect S&P's views regarding the
current and future performance of the transaction's collateral as
well as the deleveraging of the trust balance.

S&P affirmed its ratings on the principal and interest
certificates because it expects 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 S&P's review of the
remaining assets' credit characteristics and performance as well
as transaction-level changes.

The affirmation of the rating on the class X interest-only (IO)
certificates reflects S&P's current criteria for rating IO
securities.

RATINGS RAISED

Citigroup Commercial Mortgage Trust 2008-C7
Commercial mortgage pass-through certificates

            Rating
Class    To         From      Credit enhancement (%)
A-4      AAA (sf)   A- (sf)                    34.17
A-1A     AAA (sf)   A- (sf)                    34.17
A-M      BBB (sf)   BB (sf)                    19.55
A-MA     BBB (sf)   BB (sf)                    19.55

RATINGS AFFIRMED
Citigroup Commercial Mortgage Trust 2008-C7
Commercial mortgage pass-through certificates

Class    Rating               Credit enhancement (%)
A-SB     AAA (sf)                              34.17
A-J      B- (sf)                                8.21
A-JA     B- (sf)                                8.21
B        CCC (sf)                               6.75
C        CCC- (sf)                              5.29
X        AAA (sf)                                N/A

N/A-Not applicable.


COMM 2013-CCRE13: Fitch Rates Class F Certificates 'Bsf'
--------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Deutsche Bank Securities, Inc.'s COMM 2013-CCRE13
commercial mortgage pass-through certificates:

-- $51,735,000 class A-1 'AAAsf'; Outlook Stable;
-- $187,219,000 class A-2 'AAAsf'; Outlook Stable;
-- $72,741,000 class A-SB 'AAAsf'; Outlook Stable;
-- $175,000,000 class A-3 'AAAsf'; Outlook Stable;
-- $287,132,000 class A-4 'AAAsf'; Outlook Stable;
-- (a)$878,846,000 class X-A 'AAAsf'; Outlook Stable;
-- (c)$105,019,000 class A-M 'AAAsf'; Outlook Stable;
-- (c)$46,982,000 class B 'AA-sf'; Outlook Stable;
-- (c)$204,511,000 class PEZ 'A-sf'; Outlook Stable;
-- (c)$52,510,000 class C 'A-sf'; Outlook Stable;
-- (a)(b)$154,765,000 class X-B 'BBB-sf'; Outlook Stable;
-- (b)$55,273,000 class D 'BBB-sf'; Outlook Stable;
-- (b)$22,110,000 class E 'BBsf'; Outlook Stable;
-- (b)$9,673,000 class F 'Bsf'; Outlook Stable.

(a) Notional amount and interest only.
(b) Privately placed pursuant to rule 144A.
(c) Class A-M, class B, and class C certificates may be exchanged
    for class PEZ certificates, and class PEZ certificates may be
    exchanged for class A-M, class B, and class C certificates.

Fitch does not rate the $71,856,197 interest-only class X-C, the
40,073,197 class G, or the $20,000,000 class SLG non-pooled
component of the St. Louis Galleria loan, certificates.

The classes above reflect the final ratings and deal structure.
The certificates represent the beneficial ownership interest in
the trust, primary assets of which are 53 loans secured by 73
commercial properties having an aggregate principal balance of
approximately $1.105 billion, as of the cutoff date. The loans
were contributed to the trust by German American Capital
Corporation, Cantor Commercial Real Estate Lending, L.P., KeyBank,
National Association, and Liberty Island Group I, LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 67.7% of the properties
by balance, cash flow analysis of 89.4%, and asset summary reviews
on 89.4% of the pool.

Key Rating Drivers

Fitch Leverage: This transaction has lower leverage than other
recent Fitch-rated fixed-rate deals. The pool's Fitch loan to
value (LTV) of 94.7% is lower than the 2012 and first-half 2013
averages of 97.2% and 99.8%, respectively. However, excluding the
two credit opinion loans, the pool's Fitch LTV is 103.8%. The
pool's Fitch debt service coverage ratio (DSCR) of 1.26x is
slightly higher than the 2012 average of 1.24x and below the
first-half 2013 average of 1.36x. The conduit DSCR is 1.19x,
excluding the two credit opinion loans.

Property Type Concentrations: The pool has a higher than average
concentration of office and hotel properties. Office properties
make up 30.4% of the pool compared with 22.3% for transactions in
the first half of 2013. Hotel properties represent 21.3% of the
pool, including loans three and six. This is higher than the 2013
first-half average of 13.8%.

Pool Concentration: The 10 largest loans represent 61.5% of the
total pool balance, which is higher than the average first-half
2013 top 10 concentration of 54.3%.

Credit Opinion Loans: Two loans (20.4%) of the pool have
investment-grade credit opinions; 60 Hudson Street has an
investment-grade credit opinion of 'AAsf' and the pooled component
of St. Louis Galleria has an investment-grade credit opinion of
'BBB-sf'.

Rating Sensitivities

For this transaction, Fitch's net cash flow (NCF) was 9.22% below
the full-year 2012 net operating income (NOI) (for properties that
2012 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 severities on
defaulted loans, and could result in potential rating actions on
the certificates. Fitch evaluated the sensitivity of the ratings
assigned to COMM 2013-CCRE13 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
'BBB+sf' 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 'BBB-' could result. The presale report
includes a detailed explanation of additional stresses and
sensitivities on pages 75-76.

The master and special servicer is Wells Fargo Bank, National
Association, rated 'CMS1-' and 'CSS2- by Fitch.


COPPER RIVER: Moody's Affirms Ba2 Rating on $23.8MM Cl. E Notes
---------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of the following notes issued by Copper River CLO, Ltd.:

   -- U.S. $18,330,000 Class A-2B Senior Secured Floating Rate
      Notes Due 2021, Upgraded to Aaa (sf); previously on July 29,
      2011 Confirmed Aa1 (sf)U.S. $49,000,000 Class B Senior
      Secured Floating Rate Notes Due 2021, Upgraded to Aa2 (sf);
      previously on July 29,2011 Confirmed Aa3 (sf)

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

   -- U.S. $137,670,000 Class A-1A Senior Secured Floating Rate
      Notes Due 2021, Affirmed Aaa (sf); previously on Jan. 16,
      2007 Assigned Aaa (sf);

   -- U.S. $180,000,000 Class A-1B Senior Secured Delay Settle
      Floating Rate Notes Due 2021, Affirmed Aaa (sf); previously
      on Jan. 16, 2007 Assigned Aaa (sf);

   -- U.S. $165,000,000 Class A-2A Senior Secured Floating Rate
      Notes Due 2021, Affirmed Aaa (sf); previously on Jan. 16,
      2007 Assigned Aaa (sf);

   -- U.S. $47,600,000 Class C Secured Deferrable Floating Rate
      Notes Due 2021, Affirmed A3 (sf); previously on July 29,
      2011 Upgraded to A3 (sf);

   -- U.S. $35,000,000 Class D Secured Deferrable Floating Rate
      Notes Due 2021, Affirmed Baa3 (sf); previously on July 29,
      2011 Upgraded to Baa3 (sf);

   -- U.S. $23,800,000 Class E Secured Deferrable Floating Rate
      Notes Due 2021, Affirmed Ba2 (sf); previously on July 29,
      2011 Upgraded to Ba2 (sf)

Copper River CLO, Ltd., issued in January 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.  The transaction is managed by Guggenheim
Partners.  The transaction's reinvestment period will end in
January 2014.

                         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 January 2014.  In
consideration of the reinvestment restrictions applicable during
the amortization period, and therefore limited ability to effect
significant changes to the current collateral pool, Moody's
analyzed the deal assuming a higher likelihood that the collateral
pool characteristics will continue to maintain a positive buffer
relative to certain covenant requirements.  In particular, the
deal is assumed to benefit from lower WARF, higher spread and
diversity levels compared to the covenant level.  Moody's modeled
a WARF of 3383, WAS of 4.57% and diversity of 59, compared to the
current covenant levels of 3572, 3.50% and 55, respectively.

Moody's also notes that the transaction's reported
overcollateralization ratios are stable.

              Methodology used for the Rating Action

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

Factors that would lead to an upgrade or downgrade of the rating
Moody's notes that this transaction is subject to a number of
factors and circumstances that could lead to either an upgrade or
downgrade of the ratings, as described below:

1) Macroeconomic uncertainty: CLO performance may be negatively
impacted by a) uncertainties of credit conditions in the general
economy and b) the large concentration of upcoming speculative-
grade debt maturities which may create challenges for issuers to
refinance.

2) Collateral Manager: Performance may also be impacted, either
positively or negatively, by a) the manager's investment strategy
and behavior and b) divergence in legal interpretation of CLO
documentation by different transactional parties due to embedded
ambiguities.

3) Collateral credit risk: A shift towards holding collateral of
better credit quality, or better than expected credit performance
of the underlying assets collateralizing the transaction, can lead
to positive CLO performance.  Conversely, a negative shift in
credit quality or performance of the underlying collateral can
have adverse consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will commence and at what pace.  Deleveraging of the CLO
may accelerate due to high prepayment levels in loan market and/or
collateral sales by the manager, which may have significant impact
on the notes' ratings.  Faster than expected note repayment will
usually have a positive impact on CLO notes, beginning with those
having the highest payment priority.

5) 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.  Realization of higher than assumed recoveries
would positively impact the CLO.

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.  Below is a summary of the impact
of different default probabilities (expressed in terms of WARF
levels) on all rated notes (shown in terms of the number of
notches' difference versus the current model output, where a
positive difference corresponds to lower expected loss), assuming
that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2706)
Class A-1A: 0
Class A-1B: 0
Class A-2A: 0
Class A-2B: 0
Class B: +2
Class C: +2
Class D: +2
Class E: +2
Moody's Adjusted WARF + 20% (4059)
Class A-1A: 0
Class A-1B: 0
Class A-2A: 0
Class A-2B: -1
Class B: -2
Class C: -2
Class D: -1
Class E: -1
Loss and Cash Flow Analysis

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 November 2013.  The
key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score, the weighted
average recovery rate and weighted average spread, are based on
its published methodology and could 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 $735.7 million, defaulted par of
$10.6 million, a weighted average default probability of 26.28%
(implying a WARF of 3383), a weighted average recovery rate upon
default of 49.44%, a diversity score of 59 and a weighted average
spread of 4.57%.

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.


CRYSTAL COVE: Fitch Affirms 'Csf' Ratings on 5 Debt Classes
-----------------------------------------------------------
Fitch Ratings has taken the following actions on the ratings of 17
notes from three structured finance collateralized debt
obligations (SF CDOs):

Crystal Cove CDO, Ltd:

-- $128,490,568 class A-1 notes affirmed at 'Csf' and withdrawn;
-- $70,000,000 class A-2 notes affirmed at 'Csf' and withdrawn;
-- $39,700,000 class B notes affirmed at 'Csf' and withdrawn;
-- $20,701,261 class C-1 notes affirmed at 'Csf' and withdrawn;
-- $1,950,847 class C-2 notes affirmed at 'Csf' and withdrawn.

Kleros Preferred Funding, Ltd:

-- $356,800,300 class A-1 notes affirmed at 'Csf' and withdrawn;
-- $60,614,986 class A-2 notes affirmed at 'Csf' and withdrawn;
-- $45,571,851 class B notes affirmed at 'Csf' and withdrawn;
-- $12,681,085 class C notes affirmed at 'Csf' and withdrawn;
-- $8,836,882 class D notes affirmed at 'Csf' and withdrawn.

South Coast Funding III, Ltd:

-- $142,481,679 class A-1A notes affirmed at 'Csf' and
    withdrawn;
-- $56,465,893 class A-1B notes affirmed at 'Csf' and withdrawn;
-- $38,000,000 class A-2 notes affirmed at 'Dsf' and withdrawn;
-- $12,000,000 class A-3A notes affirmed at 'Dsf' and withdrawn;
-- $9,000,000 class A-3B notes affirmed at 'Dsf' and withdrawn;
-- $12,067,052 class B notes affirmed at 'Csf' and withdrawn;
-- $37,955,779 class C notes affirmed at 'Csf' and withdrawn.

Key Rating Drivers

The class A-2, A-3A, and A-3B notes from South Coast Funding III,
Ltd, are non-deferrable classes, which continue to experience
interest shortfalls due to an acceleration that began in February
2010. As such, these three classes were affirmed at 'Dsf'. The
remaining 14 classes are undercollateralized. These notes were
affirmed at 'Csf' to reflect Fitch's expectation that the full
payment of interest and principal prior to or at maturity is
unlikely.

Subsequently, the ratings on all 17 notes have been withdrawn
since they are no longer considered to be relevant to Fitch's
coverage due to a lack of investor interest.


FOOTHILL CLO I: Moody's Ups Rating on $19MM Class E Notes to 'Ba1'
------------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of the following notes issued by Foothill CLO I, Ltd.:

U.S.$30,000,000 Class B Senior Secured Floating Rate Notes Due
February 22, 2021, Upgraded to Aaa (sf); previously on August 9,
2011 Upgraded to Aa3 (sf)

U.S.$28,000,000 Class C Senior Secured Deferrable Floating Rate
Notes Due February 22, 2021,Upgraded to A1 (sf); previously on
August 9, 2011 Upgraded to A3 (sf)

U.S.$25,000,000 Class D Secured Deferrable Floating Rate Notes Due
February 22, 2021, Upgraded to Baa2 (sf); previously on August 9,
2011 Upgraded to Baa3 (sf)

U.S.$19,000,000 Class E Secured Deferrable Floating Rate Notes Due
February 22, 2021, Upgraded to Ba1 (sf); previously on August 9,
2011 Upgraded to Ba3 (sf)

U.S. $6,000,000 Type I Class Q Notes Due February 22, 2021
(current outstanding rated balance of $3,314,110), Upgraded to A2
(sf); previously on August 9, 2011 Upgraded to Ba1 (sf)

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

U.S. $357,000,000 Class A Senior Secured Floating Rate Notes Due
2021(current outstanding rated balance of $355,164,362), Affirmed
Aaa (sf); previously on March 15, 2007 Assigned Aaa (sf)

Foothill CLO I, Ltd., issued in February 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes
reflect the benefit of the short period of time remaining before
the end of the deal's reinvestment period in February 2014. In
consideration of the reinvestment restrictions applicable during
the amortization period, and therefore limited ability to effect
significant changes to the current collateral pool, Moody's
analyzed the deal assuming a higher likelihood that the collateral
pool characteristics will continue to maintain a positive buffer
relative to certain covenant requirements. In particular, the deal
is assumed to benefit from lower WARF and higher weighed average
spread levels compared to the covenant levels. Moody's modeled a
WARF and weighted average spread of 2529 and 3.18% compared to the
covenant levels of 2710 and 1.95%. Moody's also notes that the
transaction's reported overcollateralization ratios are stable.

Methodology Underlying the Rating Action

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

Factors that Would Lead to an Upgrade or Downgrade of the Ratings

Moody's notes that this transaction is subject to a number of
factors and circumstances that could lead to either an upgrade or
downgrade of the ratings, as described below:

1) Macroeconomic uncertainty: CLO performance may be negatively
impacted by a) uncertainties of credit conditions in the general
economy and b) the large concentration of upcoming speculative-
grade debt maturities which may create challenges for issuers to
refinance.

2) Collateral Manager: Performance may also be impacted, either
positively or negatively, by a) the manager's investment strategy
and behavior and b) divergence in legal interpretation of CLO
documentation by different transactional parties due to embedded
ambiguities.

3) Collateral credit risk: A shift towards holding collateral of
better credit quality, or better than expected credit performance
of the underlying assets collateralizing the transaction, can lead
to positive CLO performance. Conversely, a negative shift in
credit quality or performance of the underlying collateral can
have adverse consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace. Deleveraging of the CLO
may accelerate due to high prepayment levels in loan market and/or
collateral sales by the manager, which may have significant impact
on the notes' ratings. Faster than expected note repayment will
usually have a positive impact on CLO notes, beginning with those
having the highest payment priority.

5) 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. Realization of higher than assumed recoveries would
positively impact the CLO.

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. Below is a summary of the impact of
different default probabilities (expressed in terms of WARF
levels) on all rated notes (shown in terms of the number of
notches' difference versus the current model output, where a
positive difference corresponds to lower expected loss), assuming
that all other factors are held equal:

Moody's Adjusted WARF -- 20% (2024)

Class A: 0

Class B: 0

Class C: +3

Class D: +3

Class E: +2

Type I Class Q: +3

Moody's Adjusted WARF + 20% (3035)

Class A: 0

Class B: -1

Class C: -2

Class D: -1

Class E: -1

Type I Class Q: -2

Loss and Cash Flow Analysis

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 November 2013.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score, the weighted
average recovery rate and weighted average spread, are based on
its published methodology and could be different from the
trustee's reported numbers. In its base case, Moody's analyzed the
underlying collateral pool as having a performing par and
principal proceeds balance of $502.6 million, defaulted par of
$98.7 thousand, a weighted average default probability of
15.96%(implying a WARF of 2529), a weighted average recovery rate
upon default of 50.56%, a diversity score of 57 and a weighted
average spread of 3.18%.

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.


GALLATIN CLO 2013-1: S&P Affirms BB Rating on Class E Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Gallatin CLO V 2013-1 Ltd./Gallatin CLO V 2013-1 LLC's
$270.75 million fixed- and floating-rate notes following the
transaction's effective date as of Sept. 30, 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 its 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 S&P's published effective date report, it discusses its
analysis of the information provided by the transaction's trustee
and collateral manager in support of their request for effective
date rating affirmation.  In most instances, S&P intends to
publish an effective date report each time it issues an effective
date rating affirmation on a publicly rated U.S. cash flow CLO.

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

RATINGS AFFIRMED

Gallatin CLO V 2013-1 Ltd./Gallatin CLO V 2013-1 LLC

Class               Rating           Amount (mil. $)
A                   AAA (sf)                  177.00
B-1                 AA (sf)                    29.25
B-2                 AA (sf)                     8.00
C (deferrable)      A (sf)                     23.00
D-1 (deferrable)    BBB (sf)                    8.25
D-2 (deferrable)    BBB (sf)                    7.00
E (deferrable)      BB (sf)                    12.50
F (deferrable)      B (sf)                      5.75


GMAC COMMERCIAL 2001-C1: Fitch Affirms Dsf Rating on Class N Notes
------------------------------------------------------------------
Fitch Ratings has affirmed eight classes of GMAC Commercial
Mortgage Securities, Inc., commercial mortgage pass-through
certificates series 2001-C1.

Key Rating Drivers

The affirmation of class F is the result of sufficient credit
enhancement relative to the ratings.

Fitch modeled losses of 42.4% of the remaining pool; expected
losses on the original pool balance total 10%, including $82.5
million (9.6% of the original pool balance) in realized losses to
date.  There are two remaining loans in the pool, one of which is
specially serviced (60.4%).  As of the December 2013 distribution
date, the pool's aggregate principal balance has been reduced by
99% to $8.8 million from $864.1 million at issuance. Interest
shortfalls are currently affecting classes G through P.

The specially-serviced asset is two office buildings with an
aggregate 127,755 square feet (sf) of space located in Mobile, AL.
The property became real estate owned (REO) in April 2011.  The
property's occupancy has remained at approximately 64% over the
last year.

The remaining performing loan (39.6%), Live Oak Village Shopping
Center, is a 106,283 sf retail center in Gulf Breeze, FL, which is
part of Pensacola Beach.  The last servicer reported occupancy was
85% as of year-end 2012, although 50% of its space rolls within
the next two years.  The loan passed its anticipated repayment
date in March 2011.

Rating Sensitivity

The Rating Outlook on class F is Stable due to the expected to pay
off from either the liquidation of the specially serviced asset or
the last performing loan.

Fitch affirms the following classes and revises Outlooks as
indicated:

-- $574,997 class F at 'BBsf', Outlook to Stable from Negative;
-- $8.2 million class G at 'Dsf', RE 0%;
-- $0 class H at 'Dsf', RE 0%;
-- $0 class J at 'Dsf', RE 0%;
-- $0 class K at 'Dsf', RE 0%;
-- $0 class L at 'Dsf', RE 0%;
-- $0 class M at 'Dsf', RE 0%;
-- $0 class N at 'Dsf', RE 0%.

Fitch does not rate the class P certificates. Fitch previously
withdrew the rating on class O and X-1 certificates.

Classes A-1, A-2, B, C, D, E and X-2 have been paid in full.

Wachovia Defeasance GMAC 2001-C1 LLC operates as a subsidiary of
Wells Fargo Bank, National Association.  Its headquarters are
located in Charlotte, NC 28288, United States.


GMAC COMMERCIAL 2000-C1: Moody's Ups Rating on Cl. K Certs to Caa2
------------------------------------------------------------------
Moody's Investors Service has upgraded the rating of one class and
affirmed the rating of one class of GMAC Commercial Mortgage
Securities, Inc., Series 2000-C1 Mortgage Pass-Through
Certificates as follows:

Cl. K, Upgraded to Caa2 (sf); previously on Mar 8, 2013 Affirmed
Caa3 (sf)

Cl. X, Affirmed Caa3 (sf); previously on Mar 8, 2013 Affirmed Caa3
(sf)

RATINGS RATIONALE

The rating on Class K was upgraded due to significant paydowns and
an increase in defeasance to 100% of the current pool balance.
Class K has realized an aggregate loss of 10.6%, which is
reflected in the rating. The rating on the IO class, Class X, was
affirmed based on the credit performance of the referenced
classes.

Moody's rating action do not anticipate a further loss. Moody's
base expected loss plus realized losses is now 3.6% of the
original pooled balance, the same at the last review. Moody's
provides a current list of base expected losses for conduit and
fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.

FACTORS THAT WOULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATING

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range can
indicate that the collateral's credit quality is stronger or
weaker than Moody's had previously expected.

Factors that could lead to an upgrade of the ratings include a
significant amount of loan paydowns or amortization, an increase
in the pool's share of defeasance or an improvement in pool
performance.

Factors that could lead to a downgrade of the ratings include a
decline in the performance of the pool, loan concentration, an
increase in realized and expected losses from specially serviced
and troubled loans or interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

The principal methodology used in this rating was "Moody's
Approach to Rating CMBS Large Loan/Single Borrower Transactions"
published in July 2000.

DESCRIPTION OF MODELS USED

The methodological approach used in this action is based on the
credit analysis of the single loan as well as the expected loss of
the remaining P&I bond. The loan, which has defeased, is
collateralized with US Government securities. The cash flows from
the securities are structured to exactly match the loan's
scheduled mortgage payments, including the balloon payment. Due to
the defeasance, this loan now has a credit assessment of Aaa. The
ratings of the bond is supported by this loan's credit assessment
along with the realized losses to date.

No model was used in the analysis of this transaction.

DEAL PERFORMANCE

As of the December 16, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 99.97% to $272,174
from $879.9 million at securitization. The certificates are
collateralized by one mortgage loan. The one loan is defeased and
secured by US government securities.

Thirty-two loans have been liquidated from the pool, resulting in
an aggregate realized loss of $31.7 million (for an average loss
severity of 19%). There are currently no loans in special
servicing.


HEWETT'S ISLAND VI: Moody's Raises Rating on $16MM Notes to Ba2
---------------------------------------------------------------
Moody's Investors Service upgraded the ratings on the following
notes issued by Hewett's Island CLO VI, Ltd.:

   -- U.S. $27,500,000 Class B Second Priority Senior Secured
      Floating Rate Notes Due 2019, Upgraded to Aaa (sf);
      previously on May 3, 2013 Upgraded to Aa2 (sf)

   -- U.S. $15,500,000 Class C Third Priority Senior Secured
      Deferrable Floating Rate Notes Due 2019, Upgraded to Aa1
      (sf); previously on May 3, 2013 Upgraded to A2 (sf)

   -- U.S. $15,500,000 Class D Fourth Priority Mezzanine Secured
      Deferrable Floating Rate Notes Due 2019, Upgraded to Baa1
      (sf); previously on May 3, 2013 Affirmed Ba1 (sf)

   -- U.S. $16,000,000 Class E Fifth Priority Mezzanine Secured
      Deferrable Floating Rate Notes Due 2019 (current outstanding
      balance of $13,414,792), Upgraded to Ba2 (sf); previously on
      May 3, 2013 Affirmed Ba3 (sf)

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

   -- U.S. $50,000,000 Class A-R First Priority Senior Secured
      Floating Rate Revolving Notes Due 2019 (current outstanding
      balance of $94,844,378), Affirmed Aaa (sf); previously on
      May 3, 2013 Affirmed Aaa (sf)

   -- U.S. $255,500,000 Class A-T First Priority Senior Secured
      Floating Rate Term Notes Due 2019 (current outstanding
      balance of $18,560,544), Affirmed Aaa (sf); previously on
      May 3, 2013 Affirmed Aaa (sf)

Hewett's Island CLO VI, Ltd., issued in May 2007, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans.  The portfolio is managed by
Commercial Industrial Finance Corp.  The transaction's
reinvestment period ended in June 2013.

                         RATINGS RATIONALE

These rating actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's
overcollateralization ratios since the last rating action in May
2013.  The Class A Notes have been paid down by approximately
59.0% or $163.1 million since May 2013.  Based on the latest
trustee December 3, 2013 report, the overcollateralization (OC)
ratio for Class A/B is 134.0%, up from 118.4%, that of the Class
C, 122.2%, up from 112.7%, that of Class D, 112.4%, up from 107.5%
and that of Class E, 105.0%, up from 103.3% in April 2013.  The OC
ratios reported in the December 2013 trustee report do not include
the December payment distribution, when $19.6 million of principal
proceeds were used to pay down the Class A Notes.

The deal has benefited from an improvement in the credit quality
of the portfolio since the last rating action.  Based on the
trustee's December 2013 report, the weighted average rating factor
is currently 2358 compared to 2524 in April 2013.  Since the last
rating action, the manager has sold all assets rated C or Ca by
Moody's, which has contributed to the WARF improvement.

             Methodology Underlying the Rating Action

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

Factors that would lead to an upgrade or downgrade of the rating
This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings:

1) Macroeconomic uncertainty: CLO performance is subject to a)
uncertainty about credit conditions in the general economy and b)
the large concentration of upcoming speculative-grade debt
maturities, which could make refinancing difficult for issuers.

2) Collateral Manager: Performance can also be affected positively
or negatively by a) the manager's investment strategy and behavior
and b) differences in the legal interpretation of CLO
documentation by different transactional parties owing to embedded
ambiguities.

3) Collateral credit risk: A shift towards collateral of better
credit quality, or better credit performance of assets
collateralizing the transaction than Moody's current expectations,
can lead to positive CLO performance.  Conversely, a negative
shift in credit quality or performance of the collateral can have
adverse consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace.  Deleveraging of the CLO
could accelerate owing to high prepayment levels in the loan
market and/or collateral sales by the manager, which could have
significant impact on the notes' ratings.  Note repayments that
are faster than Moody's current expectations will usually have a
positive impact on CLO notes, beginning with those with the
highest payment priority.

5) Recovery of defaulted assets: Fluctuations in the market value
of defaulted assets reported by the trustee and those that Moody's
assumes as having defaulted could result in volatility in the
deal's OC levels.  Further, the timing of recoveries and whether a
manager decides to work out or sell defaulted assets create
additional uncertainty.

In addition to the base case analysis, Moody's also conducted
sensitivity analyses to test the impact of a number of default
probabilities on the rated notes.  Below is a summary of the
impact of different default probabilities (expressed in terms of
WARF) on all of the rated notes (by the difference in the number
of notches versus the current model output, for which a positive
difference corresponds to lower expected loss):

Moody's Adjusted WARF -- 20% (2004)
Class A-T: 0
Class A-R: 0
Class B: 0
Class C: +1
Class D: +3
Class E: +1
Moody's Adjusted WARF + 20% (3006)
Class A-T: 0
Class A-R: 0
Class B: 0
Class C: -2
Class D: -2
Class E: -2
Loss and Cash Flow Analysis

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 November 2013.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score, and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers.  In its base
case, Moody's analyzed the collateral pool as having a performing
par and principal proceeds balance of $196.4 million, no defaulted
par, a weighted average default probability of 14.35% (implying a
WARF of 2505), a weighted average recovery rate upon default of
50.53%, a diversity score of 50 and a weighted average spread of
3.0%.

Moody's incorporates the default and recovery properties of the
collateral pool in cash flow model analysis where they are subject
to stresses as a function of the target rating on each CLO
liability reviewed.  Moody's derives the default probability from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool.  The average
recovery rate for future defaults is based primarily on the
seniority of the assets in the collateral pool.  n each case,
historical and market performance and the collateral manager's
latitude for trading the collateral are also factors.


HILDENE CLO I: Moody's Rates $6MM Class F Notes 'B2'
----------------------------------------------------
Moody's Investors Service has assigned ratings to seven classes of
Notes issued by Hildene CLO I Ltd.

Moody's rating action is as follows:

U.S.$187,500,000 Class A Senior Secured Floating Rate Notes due
2026 (the "Class A Notes"), Definitive Rating Assigned Aaa (sf)

U.S.$28,500,000 Class B-1 Senior Secured Floating Rate Notes due
2026 (the "Class B-1 Notes"), Definitive Rating Assigned Aa2 (sf)

U.S.$10,000,000 Class B-2 Senior Secured Fixed Rate Notes due 2026
(the "Class B-2 Notes"), Definitive Rating Assigned Aa2 (sf)

U.S.$16,500,000 Class C Deferrable Mezzanine Floating Rate Notes
due 2026 (the "Class C Notes"), Definitive Rating Assigned A2 (sf)

U.S.$18,500,000 Class D Deferrable Mezzanine Floating Rate Notes
due 2026 (the "Class D Notes"), Definitive Rating Assigned Baa3
(sf)

U.S.$14,500,000 Class E Deferrable Mezzanine Floating Rate Notes
due 2026 (the "Class E Notes"), Definitive Rating Assigned Ba3
(sf)

U.S.$6,000,000 Class F Deferrable Mezzanine Floating Rate Notes
due 2026 (the "Class F Notes"), Definitive Rating Assigned B2 (sf)

The Class A Notes, the Class B-1 Notes, the Class B-2 Notes, the
Class C Notes, the Class D Notes, the Class E Notes and the Class
F Notes are referred to herein, collectively, as the "Rated
Notes."

RATINGS RATIONALE

Moody's ratings of the Rated Notes address the expected losses
posed to noteholders. The ratings reflect the risks due to
defaults on the underlying portfolio of assets, the transaction's
legal structure, and the characteristics of the underlying assets.

Hildene CLO I is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated first lien senior
secured corporate loans. At least 90% of the portfolio must
consist of senior secured loans, cash, and eligible investments,
and up to 10% of the portfolio may consist of senior secured
bonds, senior secured notes, high yield bonds, second lien loans
and senior, unsecured loans. The portfolio is approximately 83%
ramped as of the closing date.

Hildene Leveraged Credit, LLC (the "Manager") will direct the
selection, acquisition and disposition of the assets on behalf of
the Issuer and may engage in trading activity, including
discretionary trading, during the transaction's four year
reinvestment period. Thereafter, the Manager may reinvest
unscheduled principal payments and proceeds from sales of credit
risk assets, subject to certain restrictions.

In addition to the Rated Notes, the Issuer issued subordinated
notes. The transaction incorporates interest and par coverage
tests which, if triggered, divert interest and principal proceeds
to pay down the notes in order of seniority.

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3.2.1
of the "Moody's Global Approach to Rating Collateralized Loan
Obligations" rating methodology published in November 2013.

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

Par amount: $300,000,000

Diversity Score: 55

Weighted Average Rating Factor (WARF): 2340

Weighted Average Spread (WAS): 3.70%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 43.0%

Weighted Average Life (WAL): 8 years.

Methodology Underlying the Rating Action

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

Factors that would lead to an upgrade or downgrade of the rating

The performance of the Rated Notes is subject to uncertainty. The
performance of the Rated Notes is sensitive to the performance of
the underlying portfolio, which in turn depends on economic and
credit conditions that may change. The Manager's investment
decisions and management of the transaction will also affect the
performance of the Rated Notes.

Together with the set of modeling assumptions above, Moody's
conducted an additional sensitivity analysis, which was an
important component in determining the ratings assigned to the
Rated Notes. This sensitivity analysis includes increased default
probability relative to the base case.

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

Percentage Change in WARF -- increase of 15% (from 2340 to 2875)

Rating Impact in Rating Notches

Class A Notes: 0

Class B-1 Notes: -1

Class B-2 Notes: -1

Class C Notes: -1

Class D Notes: -1

Class E Notes: 0

Class F Notes: 0

Percentage Change in WARF -- increase of 30% (from 2340 to 3250)

Rating Impact in Rating Notches

Class A Notes: -1

Class B-1 Notes: -3

Class B-2 Notes: -3

Class C Notes: -4

Class D Notes: -2

Class E Notes: -1

Class F Notes: -3

The V Score for this transaction is Medium/High. This V Score has
been assigned in a manner similar to the Medium/High V Score
assigned for the global cash flow CLO sector, as described in the
special report titled "V Scores and Parameter Sensitivities in the
Global Cash Flow CLO Sector," dated July 6, 2009 and available on
www.moodys.com.

The score for the "Experience of, Arrangements Among and Oversight
of the Transaction Parties," a sub-category of the V Score, is
Medium, which is higher than that of the benchmark CLO, which is
Low/Medium. The score of Medium reflects the fact that the
transaction will be the first CLO managed by the Manager. This
higher score for "Experience of, Arrangements Among and Oversight
of the Transaction Parties" does not, however, cause this
transaction's overall composite V Score of Medium/High to differ
from that of the CLO sector benchmark.

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.


JP MORGAN 2005-CIBC12: Moody's Affirms 'C' Ratings 2 CBMS Classes
-----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings on 12 classes
in J.P. Morgan Chase Commercial Mortgage Securities Corp.,
Commercial Mortgage Pass Through Certificates, Series 2005-CIBC12
as follows:

Cl. A-3A2, Affirmed Aaa (sf); previously on Feb 1, 2013 Affirmed
Aaa (sf)

Cl. A-3B, Affirmed Aaa (sf); previously on Feb 1, 2013 Affirmed
Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on Feb 1, 2013 Affirmed Aaa
(sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Feb 1, 2013 Affirmed
Aaa (sf)

Cl. A-M, Affirmed Aa2 (sf); previously on Feb 1, 2013 Affirmed Aa2
(sf)

Cl. A-J, Affirmed Baa3 (sf); previously on Feb 1, 2013 Affirmed
Baa3 (sf)

Cl. B, Affirmed Ba3 (sf); previously on Feb 1, 2013 Affirmed Ba3
(sf)

Cl. C, Affirmed B3 (sf); previously on Feb 1, 2013 Downgraded to
B3 (sf)

Cl. D, Affirmed Caa3 (sf); previously on Feb 1, 2013 Downgraded to
Caa3 (sf)

Cl. E, Affirmed C (sf); previously on Feb 1, 2013 Downgraded to C
(sf)

Cl. F, Affirmed C (sf); previously on Feb 1, 2013 Downgraded to C
(sf)

Cl. X-1, Affirmed Ba3 (sf); previously on Feb 1, 2013 Affirmed Ba3
(sf)

RATINGS RATIONALE

The ratings on the six investment grade P&I classes were affirmed
because the transaction's key metrics, including Moody's loan-to-
value (LTV) ratio, Moody's stressed debt service coverage ratio
(DSCR) and the transaction's Herfindahl Index (Herf), are within
acceptable ranges. The ratings on the five below investment grade
P&I classes were affirmed because the ratings are consistent with
Moody's expected loss.

The rating on the IO class was affirmed based on the credit
performance (or the weighted average rating factor or WARF) of the
referenced classes.

Moody's rating action reflects a base expected loss of 6.8% of the
current balance compared to 6.6% at Moody's last review. Moody's
base expected loss plus realized losses is now 9.9% of the
original pooled balance compared to 9.8% at the last review.
Moody's provides a current list of base expected losses for
conduit and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.

FACTORS THAT WOULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATING

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range can
indicate that the collateral's credit quality is stronger or
weaker than Moody's had previously expected. Factors that could
lead to an upgrade of the ratings include a significant amount of
loan paydowns or amortization, an increase in the pool's share of
defeasance or an improvement in pool performance. Factors that
could lead to a downgrade of the ratings include a decline in the
performance of the pool, loan concentration, an increase in
realized and expected losses from specially serviced and troubled
loans or interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

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

DESCRIPTION OF MODELS USED

Moody's review used the excel-based CMBS Conduit Model v 2.64,
which it uses 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 Moody's uses to
estimate Moody's value). Conduit model results at the B2 (sf)
level are based on a paydown analysis using the individual loan-
level Moody's LTV ratio. Moody's may consider other concentrations
and correlations in its analysis. Based on the model pooled credit
enhancement levels of Aa2 (sf) and B2 (sf), the required credit
enhancement on 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, Moody's merges the credit enhancement for loans with
investment-grade credit assessments with the conduit model credit
enhancement for an overall model result. Moody's incorporates
negative pooling (adding credit enhancement at the credit
assessment level) for loans with similar credit assessments in the
same transaction.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 49, compared to 53 at Moody's last review.

DEAL PERFORMANCE

As of the December 12, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 41% to $1.28
billion from $2.17 billion at securitization. The certificates are
collateralized by 138 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten loans constituting 32%
of the pool. Five loans, constituting 2% of the pool, have
defeased and are secured by US government securities.

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

Twenty-eight loans have been liquidated from the pool, resulting
in an aggregate realized loss of $128 million (for an average loss
severity of 40%). Eight loans, constituting 7% of the pool, are
currently in special servicing. The largest specially serviced
loan is the Three Office Building Loan, formerly known as the LXP-
ISS loan ($40 million - 3% of the pool), which is secured by three
office buildings containing a total of 289,000 square feet (SF)
located in Atlanta, Georgia. The buildings are currently 83%
leased to IBM (Moody's senior unsecured rating Aa3, stable
outlook) through May 2018 at below market rents, a more than 70%
reduction from previous in-place rent. The loan failed to pay off
at its maturity in May 2013, and the special servicer indicates it
is pursuing foreclosure, which is expected to occur in March 2014.

The remaining seven specially serviced loans are secured by a mix
of property types. Moody's estimates an aggregate $53 million loss
for the specially serviced loans (56% expected loss on average).

Moody's has assumed a high default probability for 12 poorly
performing loans, constituting 6% of the pool, and has estimated
an aggregate loss of $14 million (an 18% expected loss based on a
50% probability default) from these troubled loans.

Moody's received full year 2011 operating results for 95% of the
pool, full year 2012 operating results for 96% of the pool and
full or partial year 2013 operating results for 74% of the pool.
Moody's weighted average conduit LTV is 88% compared to 93% at
Moody's last review. Moody's conduit component excludes loans with
credit assessments, defeased and CTL loans, and specially serviced
and troubled loans. Moody's net cash flow (NCF) reflects a
weighted average haircut of 11.2% to the most recently available
net operating income (NOI). Moody's value reflects a weighted
average capitalization rate of 9.0%.

Moody's actual and stressed conduit DSCRs are 1.51X and 1.16X,
respectively, compared to 1.46X and 1.10X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 16% of the pool balance. The
largest loan is the Universal Hotel Portfolio Loan ($100 million -
- 8% of the pool), which is a pari passu interest in a $400
million first mortgage loan secured by three full service hotel
properties. The three hotels are all located in Orlando, Florida
and total 2,400 guest rooms. The property is also encumbered by
$50 million B-note, which secures $50 million of rake bonds in
this deal. The three hotels were all constructed between 1999 and
2002. All are considered luxury hotels and are located within
Orlando's Universal Theme Park. The portfolio's performance has
declined slightly since last review. Revenue per available room
(RevPAR) decreased by 2% to $192 through September 2013 from $198
at last review. RevPAR has recovered from the downturn and is now
42% greater than the portfolio's low of $135 in 2009. Moody's LTV
and stressed DSCR are 74% and 1.57X, respectively, compared to 74%
and 1.56X at last review.

The second largest loan is the Promenade at Westlake Loan ($66
million -- 5% of the pool), which is secured by a 202,000 SF
retail center located in Thousand Oaks, California. The property
was 98% leased as of September 2013 compared to 95% at last
review. The loan is benefitting from amortization and matures in
July 2015. Moody's LTV and stressed DSCR are 84% and 1.06X,
respectively, compared to 89% and 1.00X at the last review.

The third largest loan is the Fort Steuben Loan ($39 million -- 3%
of the pool), which is secured by a 690,000 SF regional mall in
Steubenville, Ohio. The largest tenant is a Wal-Mart Super Store
(31% of the NRA, expiration date of August 2027); other anchors
include Sears, JC Penney and Dick's Sporting Goods. The mall is
shadow anchored by Macy's (not part of the collateral). As of
September 2013, the total mall was 90% leased. The property is
subject to rollover risk with three out of the four largest
collateral anchors (representing 33% of the NRA) having lease
expirations prior to the loan maturity date of July 2017. Moody's
LTV and stressed DSCR are 129% and 0.75X, respectively, compared
to 127% and 0.76X at the last review.


JP MORGAN 2006-CIBC17: Fitch Affirms CC Rating on Cl. A-J Certs
---------------------------------------------------------------
Fitch Ratings has affirmed 19 classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp (JPMCC) commercial mortgage
pass-through certificates series 2006-CIBC17.

Key Rating Drivers

The affirmations are due to relatively stable performance of the
remaining pool as well as no significant change in modeled losses.
Fitch modeled losses of 18.5% of the remaining pool; expected
losses on the original pool balance total 18.4%, including $42.6
million (1.7% of the original pool balance) in realized losses to
date.  Fitch has designated 50 Fitch Loans of Concern(43.9%),
which includes 17 specially serviced assets (21.6%).

As of the December 2013 distribution date, the pool's aggregate
principal balance has been reduced by 9.5% to $2.3 billion from
$2.54 billion at issuance.  No loans are defeased. Interest
shortfalls are currently affecting classes D through NR.

The largest contributor to expected losses continues to be the
specially-serviced Bank of America Plaza (11.5% of the pool), a
1.3 million square foot (sf), class A office property located in
downtown Atlanta, GA.  The largest tenants are Trautman Sanders,
LLC (25%) and Bank of America (14%) with lease expirations in
2022.  The loan was transferred to special servicing in February
2011 and is currently real estate owned (REO).  The property has
suffered declining occupancy since 2011 resulting from tenant's
vacating and downsizing space, in addition to challenging market
conditions.  The property was 51% occupied as of November 2013.
The special servicer is currently working on stabilizing the asset
by launching a new website and marketing campaign in addition to
several planned improvements, which once completed should increase
leasing momentum at the property.  Per REIS, as of 3rd quarter
(3Q) 2013, the Atlanta office market vacancy is 20.3% with asking
rents $21.64 sf.

The next largest contributor to expected losses is the Westfield
Shoppingtown Independence loan (4.8%), which is secured by a
1,014,971 sf (493,432 sf of collateral) regional mall located in
Wilmington, NC.  The non-owned anchors include Sears, Belk, and
Dillard's.  The largest tenants include JC Penney 22.7% lease
expiration Aug. 31, 2016, Life Community Church (2.9%), expiration
June 30, 2014, College of Wilmington & Day Spa (2.8%) expiration
April 30, 2020.  The fiscal year end June 30, 2013 debt service
coverage ratio (DSCR) is 0.80x with mall occupancy at 95.22%(
occupancy representing the collateral is 88% as of June 30, 2013).
Per the master servicer, 31% of the leases roll within the next
six months, of which 16% has renewed, 11% has or will be vacating,
and the intentions of the remaining 5% are unknown.  Although
occupancy has remained stable, income continues to decline year
over year due to lower base rents for new and renewing tenants.
Per REIS as of 3Q'13, the Wilmington Metro Retail market vacancy
is 15.9% with asking rents $15.77.

The third largest contributor to expected losses is the specially-
serviced City View Portfolio (2.5%), seven multifamily properties
consisting of 2,226 units located in the Greenspoint section of
Houston, TX.  The loan was transferred to special servicing in
February 2010 due to imminent default and is currently REO.  The
decline in portfolio performance is due to a significant fire at
one of the properties, in addition to an increase in expenses at
another property with significant crime issues.  As of December
2013, the portfolio is 88% occupied; 94% excluding the down units.

Rating Sensitivity

Rating Outlooks on classes A-3 through A-1A remain Stable due to
increasing credit enhancement and continued paydown. The rating
outlook on class A-M remains Negative due to declines in
performance of some of the larger loans of concern.

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

-- $203 million class A-J at 'CCsf', RE 25%.

Fitch affirms the following classes as indicated:

-- $30.6 million class A-3 at 'AAAsf'; Outlook Stable;
-- $1.2 billion class A-4 at 'AAAsf'; Outlook Stable;
-- $50.3 million class A-SB at 'AAAsf'; Outlook Stable;
-- $274.8 million class A-1A at 'AAAsf'; Outlook Stable;
-- $253.7 million class A-M at 'BBsf'; Outlook Negative;
-- $44.4 million class B at 'Csf', RE 0%;
-- $19 million class C at 'Csf', RE 0%;
-- $34.9 million class D at 'Csf', RE 0%;
-- $31.7 million class E at 'Csf', RE 0%;
-- $34.9 million class F at 'Csf', RE 0%;
-- $31.7 million class G at 'Csf', RE 0%;
-- $31.7 million class H at 'Csf', RE 0%;
-- $9.5 million class J at 'Csf', RE 0%;
-- $9.5 million class K at 'Csf', RE 0%;
-- $9.5 million class L at 'Csf', RE 0%;
-- $3.2 million class M at 'Csf', RE 0%;
-- $1.6 million class N at 'Dsf', RE 0%;
-- $0 class P at 'Dsf', RE 0%.

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

Headquartered in New York, New York, JPMorgan Chase & Co. --
http://www.jpmorganchase.com/-- , a financial holding company,
provides various financial services worldwide.  Its Consumer and
Community Banking segment provides deposits, investment products
and services, lending, and cash management and payment solutions
to consumers and small businesses; mortgage origination and
servicing; and residential mortgages and home equity loans.


JP MORGAN 2006-LDP9: S&P Lowers Rating on 3 Note Classes to D
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on nine
classes of commercial mortgage pass-through certificates from two
U.S. commercial mortgage-backed securities (CMBS) transactions
because of current and potential interest shortfalls.

S&P lowere its ratings on seven of these classes to 'D (sf)'
because they have accumulated interest shortfalls outstanding for
six to 16 months and S&P expects them to remain outstanding for
the foreseeable future.  The recurring interest shortfalls for the
respective certificates are primarily because of one or more of
the following factors:

   -- Appraisal subordinate entitlement reduction (ASER) amounts
      in effect for specially serviced assets.

   -- The lack of servicer advancing for loans where the servicer
      has made nonrecoverable advance declarations.

   -- Interest rate modifications related to corrected mortgage
      loans; and

   -- Special servicing fees.

S&P's analysis primarily considered the ASER amounts based on
appraisal reduction amounts (ARAs) calculated using recent Member
of the Appraisal Institute (MAI) appraisals.  S&P also considered
servicer-nonrecoverable advance declarations and special servicing
fees that S&P believes will likely cause recurring interest
shortfalls.

The servicer implements ARAs and resulting ASER amounts according
to each respective transaction's terms.  Typically, these terms
call for an ARA equal to 25% of the stated principal balance of a
loan to be implemented automatically when a loan is 60 days past
due and an appraisal or other valuation is not available within a
specified timeframe.  S&P primarily considered ASER amounts based
on ARAs calculated from MAI appraisals when deciding which classes
from the affected transactions to downgrade to 'D (sf)'.  This is
because ARAs based on a principal balance haircut are highly
subject to change, or even reversal, once the special servicer
obtains the MAI appraisals.

Servicer-nonrecoverable advance declarations can prompt shortfalls
from a lack of debt-service advancing, the recovery of previously
made advances being deemed nonrecoverable, or the failure to
advance trust expenses when nonrecoverable declarations have been
determined. Trust expenses may include, but are not limited to,
property operating expenses, property taxes, insurance payments,
and legal expenses.

   JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP9

S&P lowered its ratings on the class A-J, B, and C certificates
from JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP9
to 'D (sf)' to reflect accumulated interest shortfalls outstanding
for eight months and its expectation that interest shortfalls will
continue for the foreseeable future.  According to the Dec. 16,
2013, trustee remittance report, the net interest shortfalls
totaling approximately $1.71 million resulted primarily from:

   -- ASER amounts ($830,832) related to 16 ($334.1 million, 9.1%)
      of the 21 ($892.8 million, 24.2%) assets that are currently
      with the special servicer, CW Capital Asset Management LLC
      (CWCapital). This ASER amount was offset by $1.77 million in
      one-time ASER recoveries primarily related to the Prescott
      Gateway and Crossroads Center assets loan's liquidation;

   -- Shortfalls due to modified interest rate reductions
      ($1.37 million).

   -- Special servicing fees ($110,478).

   -- Interest reductions due to nonrecoverability determinations
      ($86,339).

   -- Work-out fees ($7,763).

The current reported interest shortfalls have affected all classes
subordinate to and including Class A-J. As of the Dec. 16, 2013,
trustee remittance report, ARAs totaling $349.3 million were in
effect for 20 assets.

   JPMorgan Chase Commercial Mortgage Securities Trust 2007-LDP11

S&P lowered its ratings on five classes from JPMorgan Chase
Commercial Mortgage Securities Trust 2007-LDP11.  S&P lowered the
class C, D, E, and F certificates to 'D (sf)' to reflect
accumulated interest shortfalls outstanding between six and 16
months, and the expectation that interest shortfalls will continue
for the foreseeable future.  S&P lowered its ratings on the class
G and H certificates to reflect current interest shortfalls and
the potential for them to continue in the near term.  According to
the Dec. 16, 2013, trustee remittance report, the net interest
shortfalls totaling $2.95 million resulted primarily from:

   -- Net ASER amounts ($1.92 million) related to 32
      ($735.6 million, 17.2%) of the 42 ($1.23 billion, 28.6%)
      that are currently with the special servicer, CWCapital.
      The ASER amount is the net of ASER recoveries of $134,730
      related to the Embassy Suites Hotel and Executive Meeting
      Center loan;

   -- Shortfalls due to modified interest rate reductions
      ($750,081).

   -- Special servicing fees ($219,002).

   -- An interest reduction due to nonrecoverability
      determinations ($67,685).

   -- Reimbursed interest on outstanding advances ($71,257)

   -- Work-out fees ($24,046).

The current reported interest shortfalls have affected all classes
subordinate to and including classes A through J.  As of the
Dec. 16, 2013, trustee remittance report, there were ARAs totaling
$438.0 million in effect for 35 assets.

RATINGS LOWERED

JPMorgan Chase Commercial Mortgage Securities Trust 2006-LDP9
Commercial mortgage pass-through certificates

                                               Reported
         Rating                Credit     interest shortfalls
Class  To        From  enhancement(%)    Current  Accumulated
A-J   D(sf)      B-(sf)          8.68   (263,006)   3,280,378
B     D (sf)     CCC- (sf)       6.04    332,449    2,659,590
C     D(sf)      CCC-(sf)        5.22    104,460      835,683


JPMorgan Chase Commercial Mortgage Securities Trust 2007-LDP11
Commercial mortgage pass-through certificates
                                               Reported
         Rating                Credit     interest shortfalls
Class  To         From   enhancement(%)  Current  Accumulated
A-J    CCC-(sf)   B-(sf)         13.37   187,312    1,540,575
B      CCC-(sf)   B-(sf)         12.58   163,711      999,367
C      D(sf)      CCC(sf)        10.69   392,898    2,398,433
D      D(sf)      CCC-(sf)        9.43   261,930    1,598,945
E      D(sf)      CCC-(sf)        8.80   130,968      904,774
F      D(sf)      CCC-(sf)        7.69   229,192    3,048,913


JP MORGAN 2007-LDP10: Fitch Affirms 'D' Ratings on 2 Cert Classes
-----------------------------------------------------------------
Fitch Ratings has affirmed all classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust, commercial mortgage pass-
through certificates, series 2007-LDP10 (JPMCC 2007-LDP10).

Key Rating Drivers

The affirmations are due to the relatively stable performance of
the remaining pool that is in-line with Fitch's expectation at the
last rating action. Fitch modeled losses of 21.8% of the remaining
pool; expected losses on the original pool balance total 19%,
including $182.3 million (3.4% of the original pool balance) in
realized losses to date. Fitch has designated 88 loans (56%) as
Fitch Loans of Concern, which includes 29 specially serviced
assets (24.5%).

Rating Sensitivity

The Negative Outlooks reflect the high concentration of specially
serviced assets and the uncertainty regarding their workouts and
final disposition. Distressed classes (those rated below 'B') may
be subject to further downgrades as additional losses are
realized.

As of the November 2013 distribution date, the pool's aggregate
principal balance has been reduced by 28.6% to $3.8 billion from
$5.3 billion at issuance. Three loans (1.7% of the pool) have been
defeased. As of the November 2013 remittance report, cumulative
interest shortfalls are currently affecting the junior 'AAA'
classes through class NR.

The largest contributor to modeled losses is the third largest
loan, the Skyline Portfolio (5.3% of the pool). The collateral
consists of a portfolio of eight office buildings totaling
approximately 2.6 million square feet (sf) located in Falls
Church, VA. The loan was transferred to special servicing in March
2012 for imminent default. The sponsor cited the Base Realignment
and Closure statute (BRAC) as contributing to recent and upcoming
vacancies at the properties. The pari passu loan was modified in
October 2013 with the $203.4 million pari passu portion in the
transaction split into a $105 million A-note and a $98.4 million
B-note. The loan maturity was extended to February 2022 with a
one-year extension option if certain performance metrics are
attained.

The second largest contributor to modeled losses is the Solana
loan (3.7%), the third largest specially serviced asset in the
pool. The loan was transferred to special servicing in March 2009
for imminent default. The collateral is a large mixed-use
development located in Westlake, TX consisting of 11 office
buildings, a retail center, a health club, and a 294-key Marriott
hotel. This asset was identified as part of a multi-asset
marketing plan. According to servicer notes, bids are anticipated
in November/December. The latest reported appraisal from May 2013
indicates a value significantly below the loan amount.

The third largest contributor to modeled losses is the StratREAL
Industrial Portfolio II loan (4.2%), the second largest specially
serviced asset in the pool. The portfolio transferred to special
servicing in December 2012 for imminent payment default. The
collateral originally consisted of a portfolio of 10 industrial
properties totaling over 5 million sf located across four regional
markets: the Memphis, TN MSA, the Columbus, OH MSA, the
Sacramento, CA MSA, and the Nashville, TX MSA. The two Sacramento
properties have since been sold and released from the portfolio
with proceeds allocated to the loan. As of June 2013, the weighted
average portfolio occupancy of the remaining eight properties
(comprising over 4 million sf) is 63%, down significantly from the
92% reported at issuance. Two of these properties are fully
vacant, three are occupied by single tenants, and three have
individual occupancies ranging from 37% to 84%. The latest
reported appraisals from first quarter 2013 indicate an aggregate
value significantly below the loan amount.

Fitch affirms the following classes as indicated:

-- $418 million class A-1A at 'AAAsf', Outlook Negative;
-- $174.6 million class A-2 at 'AAAsf', Outlook Negative;
-- $1.7 billion class A-3 at 'AAAsf', Outlook Negative;
-- $83.5 million class A-3S at 'AAAsf', Outlook Negative;
-- $359 million class A-M at 'Bsf'; Outlook Negative;
-- $174.1 million class A-MS at 'Bsf'; Outlook Negative;
-- $200.7 million class A-J at 'CCCsf'; RE 15%;
-- $145.8 million class A-JS at 'CCCsf'; RE 15%;
-- $100 million class A-JFL at 'CCCsf'; RE 15%;
-- $71.8 million class B at 'CCsf'; RE 0%;
-- $34.8 million class B-S at 'CCsf'; RE 0%;
-- $26.9 million class C at 'CCsf'; RE 0%;
-- $13.1 million class C-S at 'CCsf'; RE 0%;
-- $49.4 million class D at 'CCsf'; RE 0%;
-- $23.9 million class D-S at 'CCsf'; RE 0%;
-- $40.4 million class E at 'CCsf'; RE 0%;
-- $19.6 million class E-S at 'CCsf'; RE 0%;
-- $44.9 million class F at 'Csf'; RE 0%;
-- $21.8 million class F-S at 'Csf'; RE 0%;
-- $44.9 million class G at 'Csf'; RE 0%;
-- $21.8 million class G-S at 'Csf'; RE 0%;
-- $16.4 million class H at 'Dsf'; RE 0%;
-- $7.9 million class H-S at 'Dsf'; RE 0%;
-- $0 class J at 'Dsf'; RE 0%;
-- $0 class K at 'Dsf'; RE 0%;
-- $0 class L at 'Dsf'; RE 0%;
-- $0 class M at 'Dsf'; RE 0%;
-- $0 class N at 'Dsf'; RE 0%;
-- $0 class P at 'Dsf'; RE 0%.

The class A-1, A-1S, A-2S, A-2SFX, and A-2SFL certificates have
paid in full. Fitch does not rate the fully depleted class NR
certificates. Fitch previously withdrew the rating on the
interest-only class X certificates.


JP MORGAN 2014-FBLU: S&P Assigns Prelim. BB- Rating on Cl. E Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to J.P. Morgan Chase Commercial Mortgage Securities Trust
2014-FBLU's $535.0 million commercial mortgage pass-through
certificates series 2014-FBLU.

The note issuance is a commercial mortgage-backed securities
transaction backed by one two-year, floating-rate commercial
mortgage loan totaling $535.0 million, secured by a first priority
lien mortgage on the borrowers' fee simple interest and leasehold
interest in the 1,594 room Fontainebleau Miami Beach, a first
priority rent and lease assignment encumbering: the borrowers'
interests in the rents and leases relating to the property, the
borrowers' assigned contract rights related to the property,
including related intellectual property, the borrowers' rights
under certain contracts to provide rental arrangement services to
owners of residential condominium units that are made available to
guests of the hotel at the property, and certain assigned
collateral accounts related to the property.

The preliminary ratings are based on information as of Jan. 9,
2014.  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 collateral's
historical and projected performance, the sponsor's and manager's
experience, the trustee-provided liquidity, the loan's terms, and
the transaction's structure.  S&P determined that the loan has a
beginning and ending loan-to-value ratio of 78.3%, based on S&P's
value of the property backing the transaction.

PRELIMINARY RATINGS ASSIGNED

J.P. Morgan Chase Commercial Mortgage Securities Trust 2014-FBLU

Class(i)           Rating             Amount ($)
A                  AAA (sf)          205,000,000
X-CP               A- (sf)       340,000,000(ii)
X-EXT              A- (sf)       340,000,000(ii)
B                  AA- (sf)           77,000,000
C                  A- (sf)            58,000,000
D                  BBB- (sf)          76,000,000
E                  BB- (sf)          119,000,000

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

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


MCF CLO III: S&P Assigns BB Rating on Class E Notes
---------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to MCF CLO
III LLC's $263.0 million floating-rate notes.

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

The ratings reflect S&P's view of:

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

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

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

   -- The diversified collateral portfolio, which consists
      primarily of middle-market senior secured term loans.

   -- The collateral manager's experienced management team.

   -- S&P's projections regarding the timely interest and ultimate
      principal payments on the rated notes, which S&P assessed
      using its cash flow analysis and assumptions commensurate
      with the assigned ratings under various interest-rate
      scenarios, including LIBOR ranging from 0.24%-12.16%.

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

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

RATINGS ASSIGNED

MCF CLO III LLC

Class                 Rating               Amount
                                         (mil. $)
A                     AAA (sf)             173.25
B                     AA (sf)               25.00
C (deferrable)        A (sf)                22.25
D (deferrable)        BBB (sf)              17.00
E (deferrable)        BB (sf)               25.50
Subordinated notes    NR                    42.90

NR--Not rated.


MIDOCEAN CREDIT: S&P Assigns Prelim. BB Rating on Class E Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to MidOcean Credit CLO II/MidOcean Credit CLO II LLC's
$372.00 million floating-rate notes.

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

The preliminary ratings are based on information as of Jan. 7,
2014.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

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

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

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

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

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

   -- The collateral manager's experienced management team.

   -- S&P's projections regarding the timely interest and ultimate
      principal payments on the preliminary rated notes, which S&P
      assessed using its cash flow analysis and assumptions
      commensurate with the assigned preliminary ratings under
      various interest-rate scenarios, including LIBOR ranging
      from 0.2386%-12.8177%.

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

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

PRELIMINARY RATINGS ASSIGNED

MidOcean Credit CLO II/MidOcean Credit CLO II LLC

Class                 Rating             Amount (mil $)
A                     AAA (sf)                   250.00
B                     AA (sf)                     56.00
C (deferrable)        A (sf)                      25.00
D (deferrable)        BBB (sf)                    21.00
E (deferrable)        BB (sf)                     20.00
Income notes          NR                          42.75

NR--Not rated.


MORGAN STANLEY 2007-3: Moody's Hikes Ratings on 3 Notes to 'Caa3'
-----------------------------------------------------------------
Moody's Investors Service announced the following rating action on
Morgan Stanley Managed ACES SPC Series 2007-3:

U.S. $30,000,000 Class IC Secured Floating Rate Notes due 2014,
Upgraded to Caa3 (sf); previously on March 4, 2009 Downgraded to
Ca (sf);

U.S. $5,200,000 Class IA Secured Floating Rate Notes due 2014,
Upgraded to Caa3 (sf); previously on March 4, 2009 Downgraded to
Ca (sf);

EUR 15,000,000 Class IB Secured Floating Rate Notes due 2014,
Upgraded to Caa3 (sf); previously on March 4, 2009 Downgraded to
Ca (sf).

This transaction is a corporate synthetic collateralized debt
obligation (CSO) referencing a portfolio of corporate senior
unsecured bonds, originally rated in 2007.

Ratings Rationale

The rating action is due to the shortened time to maturity of the
CSO, which has a remaining life of 0.22 years. The current
subordination of the tranches is 0.4% and the tranches are likely
to reach the scheduled maturity without incurring a loss.

Since the last rating review in May 2013, the credit quality of
the portfolio has been stable. The portfolio's ten-year weighted
average rating factor (WARF) has increased slightly to 933 from
922, excluding settled credit events. Moody's rates the majority
of the reference credits investment grade with none rated Ca (sf)
or lower.

Based on the trustee's December 2013 report, 14 credit events,
equivalent to 11.15% of the portfolio based on the portfolio's
notional value at closing, have taken place. Since inception, the
subordination of the rated tranches has declined by 3.35% due to
credit events on Aiful Corporation, Ambac Assurance Corporation,
Chemtura Corporation, CIT Group Inc., Federal National Mortgage
Association, Glitnir Banki HF, Kaupthing Banki HF, Landsbanki
Islands HF, Lehman Brothers Holdings Inc., Residential Capital,
LLC, The PMI Group Inc., Thomson, Washington Mutual, Inc., and
Syncora Guarantee Inc.

Methodology Underlying the Rating Action

The principal methodology used in this rating was "Moody's
Approach to Rating Corporate Synthetic Collateralized Debt
Obligations" published in November 2013.

Factors that Would Lead to an Upgrade or Downgrade of the Ratings

These transactions are subject to a high level of uncertainty,
primarily because of 1) unexpected volatility in the credit and
macroeconomic environment; 2) divergence in the legal
interpretation of documentation by different transactional parties
because of embedded ambiguities; and 3) unexpected changes in the
portfolio composition as a result of the actions of the
transaction parties.

For CSOs, the performance of the credit default swaps can be
affected either positively or negatively by 1) variations over
time in default rates for instruments with a given rating; 2)
variations in recovery rates for instruments with particular
seniority/security characteristics; and 3) uncertainty about the
default and recovery correlations characteristics of the reference
pool. Given the tranched nature of CSO liabilities, rating
transitions in the reference pool can have leveraged rating
implications for the ratings of the CSO liabilities that could
lead to a high degree of rating volatility, which is likely to be
higher for the more junior or thinner liabilities.

In addition to the base case analysis described above, Moody's
also conducted sensitivity analyses, discussed below. Results are
in the form of the difference in the number of notches from the
base case, in which a higher number of notches corresponds to
lower expected losses, and vice-versa.

Moody's conducted a sensitivity analysis in which the adverse
selection adjustment is removed and the default probabilities of
reference credits in over-concentrated sectors is adjusted by the
equivalent of the average gap between our ratings and the
corresponding MIRs, capped at zero. The result of this run was one
notch higher than in the base case.

In addition to the quantitative factors Moody's models explicitly,
rating committees also consider qualitative factors in the rating
process. These qualitative factors include a transaction's
structural protections, recent deal performance in the current
market environment, the legal environment, specific documentation
features and the portfolio manager's track record. All information
available to rating committees, including macroeconomic forecasts,
input from other Moody's analytical groups, market factors, and
judgments regarding the nature and severity of credit stress on
the transactions, can influence the final rating decision.


NEWCASTLE CDO VIII: Fitch Affirms CCC Ratings on 7 Note Classes
---------------------------------------------------------------
Fitch Ratings has affirmed all classes of Newcastle CDO VIII 1,
Ltd./Newcastle CDO VIII 2, Ltd./ Newcastle CDO VIII, LLC
(collectively, Newcastle CDO VIII) reflecting Fitch's base case
loss expectation of 41.9%. Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market value and cash flow declines.

Key Rating Drivers

The affirmations are due to relatively stable performance of the
collateral since the last rating action.  Since the last rating
action and as of the December 2013 trustee report, the transaction
has paid down by $257.1 million from the full repayment of eight
assets, the partial payoff of another asset, and the amortization
of several other assets in the pool.  The transaction has also
realized losses of approximately $44.2 million over the same
period from a partial loss on a corporate debt asset and a full
loss on a commercial mortgage-backed security (CMBS) bond.  As of
the December 2013 trustee report, all overcollateralization (OC)
and interest coverage tests were in compliance.

As of the December 2013 trustee report and per Fitch
categorizations, the collateralized debt obligation (CDO) was
substantially invested as follows: real estate bank
loans/corporate debt (22.3%), CMBS (20.6%), commercial real estate
(CRE) mezzanine debt (19.1%), residential mortgage-backed
securities (RMBS: 11.2%), CRE CDOs (10.5%), whole loans (7.4%), B-
notes (5.5%), and principal cash (3.4%).  The percentage of
defaulted assets and Fitch Loans of Concern is 1.9% and 17.9%,
respectively, compared to 3% and 7.9% at the last rating action.

Two assets (1.9%) were reported as defaulted, which include one
CMBS (1.1%) and one RMBS (0.8%) bond.  Fitch classified four
additional assets (17.9%) as Loans of Concern.

The CRE loan portion of the collateral is comprised mostly of
subordinate debt (24.6% of the pool consists of either mezzanine
loans or B-notes).  In addition, the CRE loan collateral is
comprised entirely of non-traditional property types, which
include hotel (25.9%), golf (4.7%), and healthcare (1.4%), all of
which typically exhibit greater performance volatility than
traditional property types.  The weighted average Fitch derived
rating of the non-CRE loan portion of the collateral has remained
at 'B-/CCC+' since the last rating action.

Under Fitch's methodology, approximately 58% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled average cash flow
decline is 7% from, generally, trailing 12-month third and fourth
quarter 2013.  Modeled recoveries are below average at 27.8% due
to the high percentage of subordinate debt.

The largest component of Fitch's base case loss expectation is a
mezzanine loan (6.5% of the pool) secured by an interest in a
portfolio initially comprised of 12 full-service hotels totaling
4,718 keys located in Puerto Rico, Jamaica, and Florida.  Three
hotels have since been released. Performance has remained
significantly below underwritten expectations at issuance.  Fitch
modeled a term default and a full loss on this overleveraged
position in its base case scenario.

The second largest component of Fitch's base case loss expectation
is a mezzanine loan (4.7%) secured by an interest in a portfolio
of golf courses located across the United States.  Fitch modeled a
term default and a full loss on this overleveraged position in its
base case scenario.

The third largest component of Fitch's base case loss expectation
is a mezzanine loan (2.4%) secured by an interest in a 424-room
full-service hotel located in Boston, MA.  Fitch modeled a term
default and a full loss on this overleveraged position in its base
case scenario.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio tests to project future default levels
for the underlying portfolio.  Recoveries for the CRE loan portion
of the collateral are based on stressed cash flows and Fitch's
long-term capitalization rates.  The non-CRE loan portion of the
collateral was analyzed in the Portfolio Credit Model according to
the 'Global Rating Criteria for Structured Finance CDOs'.  The
combined default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Rating Criteria for Structured Finance CDOs'.

The breakeven rates for classes I-A through III are generally
consistent with the ratings listed below.

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

Newcastle CDO VIII is a CRE CDO managed by Newcastle Investment
Corp.  The CDO exited its reinvestment period in November 2011.
The CDO was originally issued as a $950 million CRE CDO; however,
in April and September 2009, notes with a face amount totaling
$80.19 million were surrendered to the trustee for cancellation,
which has resulted in greater cushion to the OC ratios.

Rating Sensitivities

The ratings of classes I-A and I-AR are expected to remain stable
and reflect the continued paydown of these classes and their
seniority in the capital structure.  If the transaction continues
to delever and the underlying collateral continues to repay at
higher than expected recoveries, the senior classes may be
upgraded, although adverse selection of the pool remains a
concern.

The Negative Outlooks on classes I-B through III reflects the
pool's collateral concentrations and the potential for future
downgrades if there is deterioration in loan performance or if the
ratings of the underlying rated securities migrate downward.  The
distressed classes are subject to downgrade as losses are realized
or if realized losses exceed Fitch's expectations.

Fitch affirms the following classes:

-- $180.9 million class I-A at 'BBsf'; Outlook Stable;
-- $23.5 million class I-AR at 'BBsf'; Outlook Stable;
-- $38 million class I-B at 'BBsf'; Outlook Negative;
-- $42.8 million class II at 'BBsf'; Outlook Negative;
-- $42.8 million class III at 'Bsf'; Outlook Negative;
-- $28.5 million class V at 'CCCsf'; RE 0%;
-- $22.6 million class VIII at 'CCCsf'; RE 0%;
-- $6 million class IX-FL at 'CCCsf'; RE 0%;
-- $7.6 million class IX-FX at 'CCCsf'; RE 0%;
-- $18.7 million class X at 'CCCsf'; RE 0%;
-- $24.1 million class XI at 'CCCsf'; RE 0%;
-- $28.5 million class XII at 'CCCsf'; RE 0%.

Class S has paid in full. Fitch previously withdrew the ratings on
classes IV, VI, and VII. Fitch does not rate the preferred shares.

Headquartered in George Town, Cayman Islands, Newcastle CDO VIII
1, Limited is managed by Newcastle Investment Corp.


NEWCASTLE CDO IX: Fitch Affirms CCCsf Rating on 4 Debt Classes
--------------------------------------------------------------
Fitch Ratings has affirmed all classes of Newcastle CDO IX Ltd./
LLC (Newcastle CDO IX) reflecting Fitch's base case loss
expectation of 37.9%.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market value and cash flow declines.

Key Rating Drivers

The affirmations are due to relatively stable performance of the
collateral since the last rating action.  Since the last rating
action and as of the December 2013 trustee report, the transaction
has paid down by $189.2 million from the full repayment of seven
assets, the partial payoff of another asset, and the amortization
of several other assets in the pool.  The transaction has also
realized losses of $19.1 million over the same period from a
partial loss on a corporate debt asset.  As of the December 2013
trustee report, all overcollateralization (OC) and interest
coverage tests were in compliance.

As of the December 2013 trustee report and per Fitch
categorizations, the collateralized debt obligation (CDO) was
substantially invested as follows: commercial real estate (CRE)
mezzanine debt (29.7%), corporate debt (19.2%), B-notes (14.9%),
CRE CDOs (10.3%), commercial mortgage-backed securities (CMBS;
9.5%), preferred equity (9.2%), whole loans/A-notes (3.1%),
principal cash (2.2%), and residential mortgage-backed securities
(RMBS; 1.8%).  The percentage of defaulted assets and Fitch Loans
of Concern has increased to 2.4% and 27.6%, respectively, compared
to 1.8% and 18.2% at the last rating action.  Two assets (1.4%),
both secured by the same property, were reported as defaulted,
which include one CMBS rake bond (0.3%) and a mezzanine loan
(2.1%). Fitch classified eight additional assets (27.6%) as Loans
of Concern.

The CRE loan portion of the collateral is comprised mostly of
subordinate debt (53.9% of the pool is comprised of mezzanine
loans, B-notes, or preferred equity).  In addition, the CRE loan
collateral is comprised mostly of non-traditional property types,
which include hotel (27.2%), construction (9.2%), and golf (6.8%),
all of which typically exhibit greater performance volatility and
uncertainty than traditional property types. The weighted average
Fitch derived rating of the non-CRE loan portion of the collateral
has improved slightly to 'B/B-' from 'B-/CCC+' at the last rating
action.

Under Fitch's methodology, approximately 60.5% of the portfolio is
modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled average cash flow
decline is 7% from, generally, trailing 12-month third and fourth
quarter 2013.  Modeled recoveries are below average at 37.3% due
to the higher percentage of subordinate debt.

The largest component of Fitch's base case loss expectation is
preferred equity (9.2% of the pool) on a construction project of a
super-regional mall and retail/entertainment facility located in
East Rutherford, New Jersey.  The project's original business plan
was stalled due to the economic downturn and multiple delays and
cost overruns.  A replacement developer has been selected and
negotiations to secure minimum financing to continue the
construction of the project remain in progress.  The original loan
was recently restructured whereby the existing lender debt was
subordinated to additional debt from new construction financing
and new equity contributions by the replacement developer.

The second largest component of Fitch's base case loss expectation
is a mezzanine loan (6.8%) secured by an interest in a portfolio
of golf courses located across the United States.  Fitch modeled a
term default and a full loss on this overleveraged position in its
base case scenario.

The third largest component of Fitch's base case loss expectation
is a mezzanine loan (4.3%) secured by an interest in a portfolio
that was initially comprised of 12 full service hotels totaling
4,718 keys located in Puerto Rico, Jamaica, and Florida.  Three
hotels have since been released.  Performance has remained
significantly below underwritten expectations at issuance. Fitch
modeled a term default and a full loss on this overleveraged
position in its base case scenario.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio tests to project future default levels
for the underlying portfolio.  Recoveries for the CRE loan portion
of the collateral are based on stressed cash flows and Fitch's
long-term capitalization rates.  The non-CRE loan portion of the
collateral was analyzed in the Portfolio Credit Model according to
the 'Global Rating Criteria for Structured Finance CDOs'.  The
combined default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Rating Criteria for Structured Finance CDOs'.
The breakeven rates for classes A-1 through G are generally
consistent with the ratings listed below.

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

Newcastle CDO IX is a CRE CDO managed by Newcastle Investment
Corp.  The CDO exited its reinvestment period in May 2012.  The
CDO was originally issued as an $825 million CRE CDO; however, in
April and September 2009, notes with a face amount of $64.525
million were surrendered to the trustee for cancellation, which
has resulted in greater cushion to the OC ratios.

Rating Sensitivities

The ratings of classes A-1 and A-2 are expected to remain stable.
The Stable Outlook on class A-1 reflects the continued paydown of
the class and its seniority in the capital structure.  The Stable
Outlook on class A-2 reflects positive cushion in Fitch's
modeling.  If the transaction continues to delever and the
underlying collateral continues to repay at higher than expected
recoveries, the senior classes may be upgraded, although adverse
selection of the pool remains a concern.

The Negative Outlooks on classes B through G reflects the pool's
collateral concentrations and the potential for future downgrades
if there is deterioration in loan performance or if the ratings of
the underlying rated securities migrate downward.  The distressed
classes are subject to downgrade as losses are realized or if
realized losses exceed Fitch's expectations.

Fitch affirms the following classes:

-- $111.1 million class A-1 at 'BBBsf'; Outlook Stable;
-- $115.5 million class A-2 at 'BBsf'; Outlook Stable;
-- $37.1 million class B at 'BBsf'; Outlook Negative;
-- $24.8 million class E at 'BBsf'; Outlook Negative;
-- $18.6 million class F at 'Bsf'; Outlook Negative;
-- $11.3 million class G at 'Bsf'; Outlook Negative;
-- $18.1 million class H at 'CCCsf'; RE 100%;
-- $21.7 million class J at 'CCCsf'; RE 100%;
-- $19.6 million class K at 'CCCsf'; RE 0%;
-- $23.7 million class L at 'CCCsf'; RE 0%.

Class S has paid in full.  Fitch has previously withdrawn the
ratings on classes C and D.  Fitch does not rate class M and the
preferred shares.

Headquartered in George Town, Cayman Islands Newcastle CDO VIII 1,
Limited is managed by Newcastle Investment Corp.


OFSI FUND III: Moody's Raises Ratings on Two Note Classes to 'Ba2'
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by OFSI Fund III, Ltd.:

U.S. $36,500,000 Class C Third Priority Subordinated Deferrable
Notes Due 2019, Upgraded to Aa2 (sf); previously on July 15, 2013
Upgraded to Aa3 (sf)

U.S. $28,750,000 Class D Fourth Priority Subordinated Deferrable
Notes Due 2019, Upgraded to Baa2 (sf); previously on July 15, 2013
Upgraded to Baa3 (sf)

U.S. $11,500,000 Class E-1 Fifth Priority Subordinated Deferrable
Notes Due 2019, Upgraded to Ba2 (sf); previously on July 15, 2013
Affirmed Ba3 (sf)

U.S. $9,125,000 Class E-2 Fifth Priority Subordinated Deferrable
Notes Due 2019, Upgraded to Ba2 (sf); previously on July 15, 2013
Affirmed Ba3 (sf)

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

U.S. $200,000,000 Class A-1 First Priority Senior Notes due 2019
(current outstanding balance of $77,475,402), Affirmed Aaa (sf);
previously on July 15, 2013 Affirmed Aaa (sf)

U.S. $140,625,000 Class A-2 First Priority Delayed Draw Senior
Notes due 2019 (current outstanding balance of $54,474,892),
Affirmed Aaa (sf); previously on July 15, 2013 Affirmed Aaa (sf)

U.S. $39,500,000 Class B Second Priority Senior Notes Due 2019,
Affirmed Aaa (sf); previously on July 15, 2013 Upgraded to Aaa
(sf)

U.S. $25,500,000 Class I Combination Notes Due 2019 (current rated
balance of $3,266,470), Affirmed A3 (sf); previously on July 15,
2013 Upgraded to A3 (sf)

OFSI Fund III, Ltd. issued in September 2006, is a collateralized
loan obligation ("CLO") backed primarily by a portfolio of senior
secured loans, with significant exposure to middle market loans.
The portfolio is managed by Orchard First Source Asset Management,
LLC. The transaction's reinvestment period ended in September
2012.

RATINGS RATIONALE

These rating actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's over-
collateralization ratios since the last rating action in July
2013. The Class A-1 and A-2 Notes have been paid down collectively
by approximately 26% or $46.5 million since July 2013. Based on
the trustees' December 2013 report, the over-collateralization
(OC) ratios for the Class A/B, Class C, Class D, and Class E Notes
are 163.6% , 136.1%, 120.2% and 110.9%, respectively, up from
142.9%, 125.5%, 114.6% and 107.8%, respectively.

Nevertheless, the credit quality of the portfolio has deteriorated
since the July 2013. Based on the trustee's December 2013 report,
the weighted average rating factor is currently 3104 compared to
2929 in June 2013.

Methodology Used for the Rating Action

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

Factors that would lead to an upgrade or downgrade of the rating

This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings:

1) Macroeconomic uncertainty: CLO performance is subject to a)
uncertainty about credit conditions in the general economy and b)
the large concentration of upcoming speculative-grade debt
maturities, which could make refinancing difficult for issuers.

2) Collateral Manager: Performance can also be affected positively
or negatively by a) the manager's investment strategy and behavior
and b) differences in the legal interpretation of CLO
documentation by different transactional parties owing to embedded
ambiguities.

3) Collateral credit risk: A shift towards collateral of better
credit quality, or better credit performance of assets
collateralizing the transaction than Moody's current expectations,
can lead to positive CLO performance. Conversely, a negative shift
in credit quality or performance of the collateral can have
adverse consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will continue and at what pace. Deleveraging of the CLO
could accelerate owing to high prepayment levels in the loan
market and/or collateral sales by the manager, which could have a
significant impact on the notes' ratings. Note repayments that are
faster than Moody's current expectations will usually have a
positive impact on CLO notes, beginning with those with the
highest payment priority.

5) Recovery of defaulted assets: Fluctuations in the market value
of defaulted assets reported by the trustee and those that Moody's
assumes as having defaulted could result in volatility in the
deal's OC levels. Further, the timing of recoveries and whether a
manager decides to work out or sell defaulted assets create
additional uncertainty. 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.
Realization of higher than assumed recoveries would positively
impact the CLO.

6) Exposure to credit estimates: The deal contains a large number
of securities whose default probabilities Moody's has assessed
through credit estimates. If Moody's does not receive the
necessary information to update its credit estimates in a timely
fashion, the transaction could be negatively affected by any
default probability adjustments Moody's assumes in lieu of updated
credit estimates.

In addition to the base case analysis, Moody's also conducted
sensitivity analyses to test the impact of a number of default
probabilities on the rated notes. Below is a summary of the impact
of different default probabilities (expressed in terms of WARF) on
all of the rated notes (by the difference in the number of notches
versus the current model output, for which a positive difference
corresponds to lower expected loss):

Moody's Adjusted WARF -- 20% (2720)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C: +1

Class D: +2

Class E-1: +1

Class E-2: +1

Class I Combination: +1

Moody's Adjusted WARF + 20% (4080)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C: -2

Class D: -2

Class E-1: -1

Class E-2: -1

Class I Combination: -1

Loss and Cash Flow Analysis

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," published in November 2013.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base
case, Moody's analyzed the collateral pool as having a performing
par and principal proceeds balance of $284.6 million, defaulted
par of $6.1 million, a weighted average default probability of
22.12% (implying a WARF of 3400), a weighted average recovery rate
upon default of 47.80%, a diversity score of 35 and a weighted
average spread of 4.09%.

Moody's incorporates the default and recovery properties of the
collateral pool in cash flow model analysis where they are subject
to stresses as a function of the target rating on each CLO
liability reviewed. Moody's derives the default probability from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate for future defaults is based primarily on the seniority of
the assets in the collateral pool. In each case, historical and
market performance and the collateral manager's latitude for
trading the collateral are also factors.

A material proportion of the collateral pool includes debt
obligations whose credit quality Moody's assesses through credit
estimates. Moody's analysis reflects adjustments with respect to
the default probabilities associated with credit estimates.
Specifically, Moody's assumed an equivalent of Caa3 for assets
with credit estimates that have not been updated within the last
15 months, which represent approximately 0.60% of the collateral
pool.


OHA LOAN 2013-1: S&P Affirms 'BB' Rating on Class E Notes
---------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on OHA
Loan Funding 2013-1 Ltd./OHA Loan Funding 2013-1 Inc.'s
$471.90 million floating- and fixed-rate notes following the
transaction's effective date as of Nov. 1, 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 our opinion that
the portfolio collateral purchased by the issuer, as reported to
us by the trustee and collateral manager, in combination with the
transaction's structure, provides sufficient credit support to
maintain the ratings that we assigned on the transaction's closing
date.  The effective date reports provide a summary of certain
information that we used in our analysis and the results of our
review based on the information presented to us," S&P said.

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

For a CLO that has not purchased its full target level of
portfolio collateral by the closing date, S&P's ratings on the
closing date and prior to its effective date review are generally
based on the application of its criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to 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 added.

In S&P's published effective date report, it discusses its
analysis of the information provided by the transaction's trustee
and collateral manager in support of their request for effective
date rating affirmation.  In most instances, S&P intends to
publish an effective date report each time it issues an effective
date rating affirmation on a publicly rated U.S. cash flow CLO.

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

RATINGS AFFIRMED

OHA Loan Funding 2013-1 Ltd./OHA Loan Funding 2013-1 Inc.

Class                      Rating                       Amount
                                                       (mil. $)
A                          AAA (sf)                     304.60
B-1                        AA (sf)                       41.70
B-2                        AA (sf)                       30.00
C (deferrable)             A (sf)                        30.20
D (deferrable)             BBB (sf)                      26.70
E (deferrable)             BB (sf)                       23.70
F (deferrable)             B (sf)                        15.00


REAL ESTATE 2006-1: Moody's Affirms 'B1' Rating on Cl. J Certs
--------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of 16 classes
of Real Estate Asset Liquidity Trust Commercial Mortgage Pass-
Through Certificates, Series 2006-1 as follows:

Cl. A-1, Affirmed Aaa (sf); previously on Feb 7, 2013 Affirmed Aaa
(sf)

Cl. A-2, Affirmed Aaa (sf); previously on Feb 7, 2013 Affirmed Aaa
(sf)

Cl. B, Affirmed Aa2 (sf); previously on Feb 7, 2013 Affirmed Aa2
(sf)

Cl. C, Affirmed A2 (sf); previously on Feb 7, 2013 Affirmed A2
(sf)

Cl. D-1, Affirmed Baa2 (sf); previously on Feb 7, 2013 Affirmed
Baa2 (sf)

Cl. D-2, Affirmed Baa2 (sf); previously on Feb 7, 2013 Affirmed
Baa2 (sf)

Cl. E-1, Affirmed Baa3 (sf); previously on Feb 7, 2013 Affirmed
Baa3 (sf)

Cl. E-2, Affirmed Baa3 (sf); previously on Feb 7, 2013 Affirmed
Baa3 (sf)

Cl. F, Affirmed Ba1 (sf); previously on Feb 7, 2013 Affirmed Ba1
(sf)

Cl. G, Affirmed Ba2 (sf); previously on Feb 7, 2013 Affirmed Ba2
(sf)

Cl. H, Affirmed Ba3 (sf); previously on Feb 7, 2013 Affirmed Ba3
(sf)

Cl. J, Affirmed B1 (sf); previously on Feb 7, 2013 Affirmed B1
(sf)

Cl. K, Affirmed B2 (sf); previously on Feb 7, 2013 Affirmed B2
(sf)

Cl. L, Affirmed B3 (sf); previously on Feb 7, 2013 Affirmed B3
(sf)

Cl. XC-1, Affirmed Ba3 (sf); previously on Feb 7, 2013 Affirmed
Ba3 (sf)

Cl. XC-2, Affirmed Ba3 (sf); previously on Feb 7, 2013 Affirmed
Ba3 (sf)

RATINGS RATIONALE

The ratings on the P&I classes were affirmed because the
transaction's key metrics, including Moody's loan-to-value (LTV)
ratio, Moody's stressed debt service coverage ratio (DSCR) and the
transaction's Herfindahl Index (Herf), are within acceptable
ranges. The ratings on the IO classes, Classes X-C1 and X-C2, were
affirmed based on the credit performance of the referenced
classes.

Moody's rating action reflects a base expected loss of 1.6% of the
current balance compared to 1.4% at Moody's last review. Moody's
base expected loss plus realized losses is now 0.9% of the
original pooled balance, the same at the last review. Moody's
provides a current list of base expected losses for conduit and
fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.

FACTORS THAT WOULD LEAD TO AN UPGRADE OR DOWNGRADE OF THE RATING

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. Performance that falls outside the given range can
indicate that the collateral's credit quality is stronger or
weaker than Moody's had previously expected.

Factors that could lead to an upgrade of the ratings include a
significant amount of loan paydowns or amortization, an increase
in the pool's share of defeasance or an improvement in pool
performance.

Factors that could lead to a downgrade of the ratings include a
decline in the performance of the pool, loan concentration, an
increase in realized and expected losses from specially serviced
and troubled loans or interest shortfalls.

METHODOLOGY UNDERLYING THE RATING ACTION

The methodologies used in this rating were "Moody's Approach to
Rating Fusion U.S. CMBS Transactions" published in April 2005, and
"Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000.

DESCRIPTION OF MODELS USED

Moody's review used the excel-based CMBS Conduit Model v 2.64,
which it uses 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 Moody's uses to
estimate Moody's value). Conduit model results at the B2 (sf)
level are based on a paydown analysis using the individual loan-
level Moody's LTV ratio. Moody's may consider other concentrations
and correlations in its analysis. Based on the model pooled credit
enhancement levels of Aa2 (sf) and B2 (sf), the required credit
enhancement on 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, Moody's merges the credit enhancement for loans with
investment-grade credit assessments with the conduit model credit
enhancement for an overall model result. Moody's incorporates
negative pooling (adding credit enhancement at the credit
assessment level) for loans with similar credit assessments in the
same transaction.

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

When the Herf falls below 20, Moody's uses the excel-based Large
Loan Model v 8.6 and then reconciles and weights the results from
the conduit and large loan 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. Moody's also further adjusts these
aggregated proceeds for any pooling benefits associated with loan
level diversity and other concentrations and correlations.

DEAL PERFORMANCE

As of the December 12, 2013 distribution date, the transaction's
aggregate certificate balance has decreased by 43% to $227.6
million from $396.2 million at securitization. The certificates
are collateralized by 51 mortgage loans ranging in size from less
than 1% to 15% of the pool, with the top ten loans constituting
67% of the pool. Two loans, constituting 19% of the pool, have
investment-grade credit assessments. Five loans, constituting 6%
of the pool, have defeased and are secured by Canadian government
securities.

Ten loans, constituting 17% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews
the watchlist to assess which loans have material issues that
could affect performance.

No loans have liquidated from the pool and there are no loans
currently in special servicing. Moody's has assumed a high
moderate default probability for one poorly performing loans,
constituting 1% of the pool.

Moody's received full year 2011 operating results for 83% of the
pool and full year 2012 operating results for 98% of the pool.
Moody's weighted average conduit LTV is 69% compared to 74% at
Moody's last review. Moody's conduit component excludes loans with
credit assessments, defeased and CTL loans, and specially serviced
and troubled loans. Moody's net cash flow (NCF) reflects a
weighted average haircut of 11% to the most recently available net
operating income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.4%.

Moody's actual and stressed conduit DSCRs are 1.54X and 1.71X,
respectively, compared to 1.46X and 1.55X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The largest loan with a credit assessment is the Crombie Portfolio
Loan ($34.7 million -- 15.3% of the pool), which is secured by a
portfolio of six retail and mixed-use properties across three
Canadian provinces (Newfoundland, Nova Scotia & New Brunswick)
originally totaling 824,000 square feet (SF). One property, the
Carleton Mall, prepaid in December 2013 so is no longer part of
the collateral. Year-end 2012 average occupancy was 79% -- a s
decrease from the 82% reported the prior year. Performance remains
stable. Moody's credit assessment and stressed DSCR are Baa2 and
1.61X, respectively, compared to Baa2 and 1.46X at last review.

The second largest loan with a credit assessment is the Royal
Centre Loan ($8.2 million -- 3.6% of the pool), which is secured
by a 163,000 SF office building located in Vaughan, Ontario, a
northern suburb of Toronto. The largest tenant is the Royal Bank
of Canada (Moody's Senior Unsecured Rating, Aa3, Stable Outlook),
with a lease through May 2021. Occupancy was 89% as of October
2013, compared to 87% at Moody's last review. The loan continues
to amortize. Moody's current credit assessment and stressed DSCR
are Aaa and 2.32X, respectively, compared to Aaa and 2.2X at last
review.

The top three conduit loans represent 28.7% of the pool. The
largest conduit loan is The Landing Loan ($26.2 million -- 11.5%
of the pool), which is secured by a 183,000 SF, seven-story office
building in the Gastown district of downtown Vancouver, British
Columbia. The property was 95% leased as of April 2013, the same
as last review. The largest tenant is Intrawest Corporation (10%
of the NRA), the owner and operator of several North American
destination resorts. Moody's current LTV and stressed DSCR are 70%
and 1.4X, respectively, compared to 79% and 1.24X at last review.

The second largest conduit loan is the Dominion Square Loan ($25.8
million -- 11.3% of the pool). The loan is Pari Passu (50%) with
REALT 2006-2 and is secured by a 12-story 365,000 SF, mixed-use
building located in downtown Montreal, Quebec. Local and state
government agencies represent 26% of the tenancy in the building.
As of March 2013, the property was 97% leased compared to 87% at
the last review. Moody's current LTV and stressed DSCR are 88% and
1.11X, respectively, compared to 100% and 0.98X at last review.

The third largest conduit loan is the InnVest Portfolio Loan
($13.4 million -- 5.9% of the pool), which is secured by a
portfolio of two full service hotels located in London and
Toronto, Ontario. Performance has continued to improve since
Moody's last review. Moody's current LTV and stressed DSCR are 80%
and 1.43X, respectively, compared to 103% and 1.1X at last review.


SAPPHIRE VALLEY: Moody's Affirms 'Ba2' Rating on Class E Notes
--------------------------------------------------------------
Moody's Investors Service has affirmed the ratings of the
following notes issued by Sapphire Valley CDO I, Ltd.:

US$418,500,000 Class A Senior Notes Due 2022 (current outstanding
balance of $356,047,463.94), Affirmed Aaa (sf); previously on
June 4, 2013 Affirmed Aaa (sf)

US$73,000,000 Class B Senior Notes Due 2022, Affirmed Aa2 (sf);
previously on June 4, 2013 Affirmed Aa2 (sf)

US$20,000,000 Class C Deferrable Mezzanine Notes Due 2022,
Affirmed A2 (sf); previously on June 4, 2013 Affirmed A2 (sf)

US$20,000,000 Class D Deferrable Mezzanine Notes Due 2022,
Affirmed Baa3 (sf); previously on June 4, 2013 Affirmed Baa3 (sf)

US$18,000,000 Class E Deferrable Mezzanine Notes Due 2022
(current outstanding balance of $12,956,700.45), Affirmed Ba2
(sf); previously on June 4, 2013 Affirmed Ba2 (sf)

Sapphire Valley CDO I, Ltd. issued in December 2006, is a
collateralized loan obligation ("CLO") backed primarily by a
portfolio of senior secured loans and CLO tranches. The portfolio
is managed by Babson Capital Management LLC. The transaction's
reinvestment period will end in January 2014.

Ratings Rationale

The rating affirmations on the notes are primarily a result of the
stable performance in the credit quality of the underlying
portfolio since the last rating action in June 2013. Additionally,
the affirmations reflect the benefit of the short period of time
remaining before the end of the deal's reinvestment period in
January 2014. In light of the reinvestment restrictions during the
amortization period, and therefore the limited ability of the
manager to effect significant changes to the current collateral
pool, Moody's analyzed the deal assuming a higher likelihood that
the collateral pool characteristics will maintain a positive
buffer relative to certain covenant requirements. In particular,
Moody's assumed that the deal will benefit from lower WARF and
higher spread. Furthermore, the transaction's reported collateral
quality and OC ratios has/have been stable since the last rating
action.

Methodology Used for the Rating Action

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

Factors that would lead to an upgrade or downgrade of the rating

This transaction is subject to a number of factors and
circumstances that could lead to either an upgrade or downgrade of
the ratings:

1) Macroeconomic uncertainty: CLO performance is subject to a)
uncertainty about credit conditions in the general economy and b)
the large concentration of upcoming speculative-grade debt
maturities, which could make refinancing difficult for issuers.

2) Collateral Manager: Performance can also be affected positively
or negatively by a) the manager's investment strategy and behavior
and b) differences in the legal interpretation of CLO
documentation by different transactional parties owing to embedded
ambiguities.

3) Collateral credit risk: A shift towards collateral of better
credit quality, or better credit performance of assets
collateralizing the transaction than Moody's current expectations,
can lead to positive CLO performance. Conversely, a negative shift
in credit quality or performance of the collateral can have
adverse consequences for CLO performance.

4) Deleveraging: An important source of uncertainty in this
transaction is whether deleveraging from unscheduled principal
proceeds will commence and at what pace. Deleveraging of the CLO
could accelerate owing to high prepayment levels in the loan
market and/or collateral sales by the manager, which could have a
significant impact on the notes' ratings. Note repayments that are
faster than Moody's current expectations will usually have a
positive impact on CLO notes, beginning with those with the
highest payment priority.

5) Recovery of defaulted assets: Fluctuations in the market value
of defaulted assets reported by the trustee and those that Moody's
assumes as having defaulted could result in volatility in the
deal's OC levels. Further, the timing of recoveries and whether a
manager decides to work out or sell defaulted assets create
additional uncertainty. 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.
Realization of higher than assumed recoveries would positively
impact the CLO.

6) Concentration Risk: The portfolio includes a material
concentration in CLO securities. Moody's views CLOs as highly
correlated, and the specific CLO securities that the issuer has
invested in have longer average lives and are of relatively better
average credit quality than the loans in the portfolio. Therefore,
as the deal further seasons and amortizes, the CLO securities,
currently representing 24% of the total collateral, may comprise
an even larger portion of the portfolio.

7) Counterparty risk: The issuer has significant investments in
CLO tranches, a portion of which is referenced under a total
return swap with Bank of America, N.A. (BANA). The rating of the
notes may be exposed to uncertainties over the credit quality of
BANA and any future deterioration in BANA's creditworthiness could
negatively impact the ratings on the notes.

In addition to the base case analysis, Moody's also conducted
sensitivity analyses to test the impact of a number of default
probabilities on the rated notes. Below is a summary of the impact
of different default probabilities (expressed in terms of WARF) on
all of the rated notes (by the difference in the number of notches
versus the current model output, for which a positive difference
corresponds to lower expected loss):

Moody's Adjusted WARF -- 20% (1829)

Class A: 0

Class B: +1

Class C: +3

Class D: +3

Class E: +1

Moody's Adjusted WARF + 20% (2676)

Class A: 0

Class B: -2

Class C: -3

Class D: -2

Class E: -1

Loss and Cash Flow Analysis

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," published in 2013.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, diversity score and the weighted
average recovery rate, are based on its published methodology and
could differ from the trustee's reported numbers. In its base
case, Moody's analyzed the collateral pool as having a performing
par and principal proceeds balance of $538.3 million, defaulted
par of $5.6 million, a weighted average default probability of
15.79% (implying a WARF of 2230), a weighted average recovery rate
upon default of 46.94%, a diversity score of 62 and a weighted
average spread of 3.0%.

Moody's incorporates the default and recovery properties of the
collateral pool in cash flow model analysis where they are subject
to stresses as a function of the target rating on each CLO
liability reviewed. Moody's derives the default probability from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate for future defaults is based primarily on the seniority of
the assets in the collateral pool. In each case, historical and
market performance and the collateral manager's latitude for
trading the collateral are also factors.


SDART 2014-1: Fitch Rates $60.15-Mil. Class E Notes 'BBsf'
----------------------------------------------------------
Fitch Ratings assigns the following expected ratings to the notes
issued by Santander Drive Auto Receivables Trust 2014-1:

  -- $228,000,000 class A-1 notes 'F1+sf';
  -- $85,275,000 class A-2A notes 'AAAsf'; Outlook Stable;
  -- $255,825,000 class A-2B notes 'AAAsf'; Outlook Stable;
  -- $87,280,000 class A-3 notes 'AAAsf'; Outlook Stable;
  -- $138,990,000 class B notes 'AAsf'; Outlook Stable;
  -- $140,740,000 class C notes 'Asf'; Outlook Stable;
  -- $69,490,000 class D notes 'BBBsf'; Outlook Stable;
  -- $60,150,000 class E notes 'BBsf'; Outlook Stable.

Weaker Credit Quality: 2014-1 is backed by marginally weaker
collateral versus prior 2013 pools and non-Santander Consumer USA
(SCUSA) collateral totals 9.4%.  The pool exhibits modestly weaker
credit scores versus 2013-5, an increase in loans with terms of
60+ months to 90.7% (the highest level to date), a higher WA loan-
to-value (LTV), lower new vehicles (35.1%), and more trucks/SUVs
(40.5%).

Adequate Credit Enhancement: The cash flow distribution is a
sequential pay structure.  Initial hard credit enhancement (CE) is
unchanged from 2013-5.

Stable Portfolio/Securitization Performance: Performance of
SCUSA's portfolio and 2010-2012 securitizations has been strong
with low losses, supported by the economic rebound, and strong
used vehicle values.  However, recent 2013 portfolio and
securitization losses have risen and are tracking slightly above
the 2012 vintage, driven by marginally weaker collateral
underwritten combined with lower recoveries as used vehicle values
have softened.

Stable Corporate Health: SCUSA recorded solid financial results
recently and has been profitable since 2007. Fitch rates
Santander, majority owner of SCUSA, 'BBB+/F2' with a Stable Rating
Outlook.

Consistent Origination/Underwriting/Servicing: SCUSA demonstrates
adequate abilities as originator, underwriter, and servicer, as
evidenced by historical portfolio delinquency, loss experience,
and securitization performance.

Legal Structure Integrity: The legal structure of the transaction
should provide that a bankruptcy of SCUSA would not impair the
timeliness of payments on the securities.


SDART 2014-1: S&P Assigns Prelim. BB+ Rating on Cl. E Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Santander Drive Auto Receivables Trust 2014-1's
$1,065.75 million automobile receivables-backed notes series
2014-1.

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

The preliminary ratings are based on information as of Jan. 6,
2014.  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 availability of 51.09%, 43.54%, 34.77%, 30.28%, and
      25.48% 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 13.00%-
      14.00% 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, our 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 S&P's 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.

PRELIMINARY RATINGS ASSIGNED

Santander Drive Auto Receivables Trust 2014-1

Class    Rating      Type            Interest           Amount
                                     rate(i)       (mil. $)(i)
A-1      A-1+ (sf)   Senior          Fixed             228.000
A-2-A    AAA (sf)    Senior          Fixed              85.275
A-2-B    AAA (sf)    Senior          Floating          255.825
A-3      AAA (sf)    Senior          Fixed              87.280
B        AA (sf)     Subordinate     Fixed             138.990
C        A (sf)      Subordinate     Fixed             140.740
D        BBB+ (sf)   Subordinate     Fixed              69.490
E        BB+ (sf)    Subordinate     Fixed              60.150

(i) The interest rates and actual sizes of these tranches will be
     determined on the pricing date.


VITALITY RE V: S&P Assigns Prelim. 'BB+' Rating on Class B Notes
----------------------------------------------------------------
Standard & Poor's Ratings Services said that it has assigned its
preliminary ratings of 'BBB+(sf)' and 'BB+(sf)' to the Class A and
Class B notes, respectively, to be issued by Vitality Re V Ltd.
The notes will cover claims payments of Health Re Inc., and
ultimately, Aetna Life Insurance Co. (ALIC), relating to the
covered insurance business to the extent the medical benefits
ratio (MBR) exceeds 102% for the Class A notes and 96% for the
Class B notes. The MBR will be calculated on an
annual aggregate basis.

The ratings are based on the lowest of the following: the MBR risk
factor on the ceded risk ('BBB+' for the Class A notes and 'BB+'
for the Class B notes); the rating on ALIC, the underlying ceding
insurer; and the rating on the permitted investments ('AAAm') that
will be held in the collateral account (there is a separate
account for each class of notes).

The MBR risk factors are currently the lowest of the three inputs.
However, if S&P lowered the rating on ALIC to less than the MBR
risk factor, it would lower the rating on the notes accordingly.

This is the fifth such issuance rated by Standard & Poor's.  The
first two issues -- Vitality Re I and Vitality Re II -- matured on
Jan. 7, 2014.

RATINGS LIST

New Ratings
Vitality Re V Ltd.
$140mil var rate principal-at-risk
ser 2014 Class A notes due 2019         BBB+(sf) (prelim)

$60mil var rate principal-at-risk
ser 2014 Class B notes due 2019         BB+(sf) (prelim)


WACHOVIA BANK 2006-C25: Fitch Cuts Class G Certs Rating to 'Csf'
----------------------------------------------------------------
Fitch Ratings has downgraded one class and affirmed 20 classes of
Wachovia Bank Commercial Mortgage Trust 2006-C25 (WBCMT 2006-C25)
commercial mortgage pass-through certificates.

Key Rating Drivers

Fitch modeled losses of 10.7% of the remaining pool; expected
losses on the original pool balance total 10.9%, including $61.5
million (2.2% of the original pool balance) in realized losses to
date. Fitch has designated 36 loans (38.9%) as Fitch Loans of
Concern, which includes 11 specially serviced assets (13.1%).

As of the November 2013 distribution date, the pool's aggregate
principal balance has been reduced by 18.6% to $2.33 billion from
$2.86 billion at issuance. Per the servicer reports, two loans
(1.8% of the pool) are defeased. Interest shortfalls are currently
affecting classes F through S and total $15.5 million.

The largest contributor to expected losses is real estate owned
(REO) Central Parke Portfolio (3.5% of the pool), which consists
of 10 office and flex properties and one retail property located
in Cincinnati, OH. The assets transferred to special servicing in
July 2011 due to imminent monetary default. A deed-in-lieu of
foreclosure transaction closed in June 2012. Recent occupancies at
the properties ranged between 24% and 96% with one office property
expected to become vacant in Jan. 2014. Per the special servicer,
the properties are being marketed for sale.

The next largest contributor to losses is the specially serviced
Independent Square loan, which is secured by a 650,000 square foot
(sf) office property located in Jacksonville, FL (3.6%). The loan
was previously modified by the special servicer in August 2011
after the largest tenant vacated the property. A replacement
tenant has since taken occupancy of the space and the property was
88% occupied, as of October 2013. The loan was bifurcated into an
A/B structure, and the borrower contributed new equity to fund the
related leasing costs. The B-note is subordinate to the new
borrower equity. The loan recently transferred back to special
servicing to facilitate a sale of the property.

The third largest contributor to expected losses is the Piedmont
Center Buildings 9-12 loan (2.8%), which is secured by an office
property located in the Buckhead sub-market of Atlanta, GA. Cash
flow has declined over the last year and the servicer-reported YTD
June 2013 DSCR was 0.96x. As of September 2013, occupancy at the
property was reported at 78% with approximately 15% lease rollover
expected through 2014. Recent historical sub-market performance
remains weak. The property is considered overleveraged with a high
Fitch LTV of 157%.

Rating Sensitivity

Rating Outlooks on classes A-1A through A-J remain Stable due to
increasing credit enhancement and continued paydown. Rating
Outlooks on classes B through C are Negative due to potential for
further negative credit migration of the underlying collateral
including continued transfers to special servicing or performance
declines of current loans.

Distressed classes (those rated below 'B') may be subject to
further downgrades as additional losses are realized.

Fitch downgrades the following class as indicated:

-- $32.2 million class G to 'Csf' from 'CCsf', RE 0%.

Fitch affirms the following class and assigns or revises REs as
indicated:

-- $32.2 million class D at 'CCCsf', RE 50%.

Fitch affirms the following classes as indicated:

-- $8.9 million class A-PB2 at 'AAAsf', Outlook Stable;
-- $723.7 million class A-4 at 'AAAsf', Outlook Stable;
-- $500 million class A-5 at 'AAAsf', Outlook Stable;
-- $299.7 million class A-1A at 'AAAsf', Outlook Stable;
-- $286.2 million class A-M at 'AAAsf', Outlook Stable;
-- $218.3 million class A-J at 'BBsf', Outlook Stable;
-- $10.7 million class B at 'BBsf', Outlook Negative;
-- $35.8 million class C at 'Bsf', Outlook Negative;
-- $17.9 million class E at 'CCCsf', RE 0%;
-- $32.2 million class F at 'CCsf', RE 0%;
-- $32.2 million class H at 'Csf', RE 0%;
-- $32.2 million class J at 'Csf', RE 0%;
-- $32.2 million class K at 'Csf', RE 0%;
-- $10.7 million class L at 'Csf', RE 0%;
-- $10.7 million class M at 'Csf', RE 0%;
-- $10.7 million class N at 'Csf', RE 0%;
-- $2.9 million class O at 'Dsf', RE 0%;
-- $0 class P at 'Dsf', RE 0%;
-- $0 class Q at 'Dsf', RE 0%.

The class A-1, A-2, A-3 and A-PB1 certificates have paid in full.
Fitch does not rate the class S certificates. Fitch previously
withdrew the rating on the interest-only class IO certificates.


WAVE SPC 2007-1: Moody's Affirms 'Ca' Ratings on 5 Classes
----------------------------------------------------------
Moody's Investors Service announced that it has downgraded the
ratings of the following notes issued by Wave SPC 2007-1, Ltd.:

   -- U.S. $1,666,666.66 Swap Transaction, Downgraded to Baa1
      (sf); previously on Feb 25, 2013 Downgraded to A1 (sf);

   -- U.S. $2,542,766.67 Swap Transaction, Downgraded to Baa1
      (sf); previously on Feb 25, 2013 Downgraded to A1 (sf)

   -- U.S. $2,690,833.33 Swap Transaction, Downgraded to Baa1
      (sf); previously on Feb 25, 2013 Downgraded to A1 (sf)

   -- U.S. $7,819,225 Swap Transaction, Downgraded to Baa1 (sf);
      previously on Feb 25, 2013 Downgraded to A1 (sf)

   -- U.S. $516,666.67 Swap Transaction, Downgraded to Baa1 (sf);
      previously on Feb 25, 2013 Downgraded to A1 (sf)

   -- U.S. $595,591.66 Swap Transaction, Downgraded to Baa1 (sf);
      previously on Feb 25, 2013 Downgraded to A1 (sf)

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

   -- Cl. A-1, Affirmed Ca (sf); previously on Feb 25, 2013
      Downgraded to Ca (sf);

   -- Cl. A-2, Affirmed Ca (sf); previously on Feb 25, 2013
      Downgraded to Ca (sf);

   -- Cl. B, Affirmed Ca (sf); previously on Feb 25, 2013 Affirmed
      Ca (sf)

   -- Cl. C, Affirmed Ca (sf); previously on Feb 25, 2013
      Affirmed Ca (sf);

   -- Cl. D, Affirmed Ca (sf); previously on Feb 25, 2013 Affirmed
      Ca (sf)

                         RATINGS RATIONALE

The downgrades are due to an increase in the default risk of the
collateral asset pool and related potential for term default risk
of the upfront swaps as evidenced by the periodic cash-flow
margin, increase in the weighted average rating factor (WARF) and
a decrease in the weighted average recovery rate (WARR).  The
affirmations are due to key transaction metrics being commensurate
with existing ratings.  The downgrades and affirmations are the
result of Moody's on-going surveillance of commercial real estate
collateralized debt obligation (CRE CDO and Re-REMIC)
transactions.

Wave 2007-1 is a static cash transaction.  The transaction is
wholly backed by a portfolio of commercial mortgage backed
securities (CMBS).  As of the trustee's Dec. 20, 2013 report, the
aggregate note balance of the transaction has decreased to
$806.8 million from $2.0 billion at issuance.  The pro-rata
reduction in the note balances since transaction issuance is due
to in-kind redemptions in September 2011 and June 2013.  There
have been no paydowns or losses to the collateral pool.

On April 19, 2010, Moody's assigned ratings to six upfront swaps
(collectively the "Swaps") in the WAVE 2007-1 transaction.  Each
of the Swaps is dated as of June 18, 2007 and each is between SMBC
Capital Markets, Inc. (the "Swap Counterparty") and the Trust.
Moody's ratings address the risk posed to the Swap Counterparty on
an expected loss basis arising from the inability of the Trust to
honor its obligations under the Swaps.  The ratings take into
account the rating of the Swap Counterparty, the transactions'
legal structure and the characteristics of the collateral pool of
the trust.  The rating downgrade action today is the result of
realized and projected interest shortfalls on the underlying
collateral.  The diminished interest proceeds poses risks to the
funds available to pay the the future payment obligations under
the Swaps.

Moody's has identified the following as key indicators of the
expected loss within CRE CDO transactions: the weighted average
rating factor (WARF), the weighted average life (WAL), the
weighted average recovery rate (WARR), and Moody's asset
correlation (MAC).  Moody's typically models these 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 updated its assessments for the collateral it does not
rate.  The rating agency modeled a bottom-dollar WARF of 4508
compared to 3953 at last review.  The current ratings on the
Moody's-rated collateral and the assessments of the non-Moody's
rated collateral follow: Baa1-Baa3 (1.6% compared to 6.1% at last
review), Ba1-Ba3 (14.1% compared to 9.4% at last review), B1-B3
(36.2% compared to 46.5% at last review) and Caa1-Ca/C (48.1%
compared to 38.0% at last review).

Moody's modeled a WAL of 3.0 years, compared to 3.9 years at last
review.  The current WAL is based on assumptions about extensions
on the underlying collateral.

Moody's modeled a fixed WARR of 8.0% compared to 10.5% at last
review.

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

Methodology Underying the Rating Action:

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

Factors that would lead to an upgrade or downgrade of the rating
The performance of the notes is subject to uncertainty, because it
is sensitive to the performance of the underlying portfolio, which
in turn depends on economic and credit conditions that are subject
to change.  The servicing decisions of the master and special
servicer and surveillance by the operating advisor with respect to
the collateral interests and oversight of the transaction will
also affect the performance of the rated notes.

Moody's Parameter Sensitivities: Changes in any one or combination
of the key parameters could have rating implications for some of
the rated notes, although a change in one key parameter assumption
could be offset by a change in one or more of the other key
parameter assumptions.  The rated notes are particularly sensitive
to changes in recovery rates of the underlying collateral and
credit assessments.  However, in light of the performance
indicators noted above, Moody's believes that it is unlikely that
the ratings announced today are sensitive to any further changes.
The primary sources of uncertainty in Moody's assumptions are the
extent of growth in the current macroeconomic environment given
the weak recovery and commercial real estate property markets.
Commercial real estate property values continue to improve
modestly, 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, sustained growth will not be possible until investment
increases steadily for a significant period, non-performing
properties are cleared from the pipeline and fears of a euro area
recession abate.


WELLS FARGO 2011-C2: Fitch Affirms 'Bsf' Rating on Class F Notes
----------------------------------------------------------------
Fitch Ratings has affirmed 10 classes of Wells Fargo Bank, N.A.
(WFRBS) Commercial Mortgage Trust 2011-C2, commercial mortgage
pass-through certificates.

Key Rating Drivers

The affirmations are the result of stable performance of the
underlying collateral since issuance.  Fitch has designated one
loan (0.8%) as a Fitch Loan of Concern, which includes one
specially serviced loan (0.8%).

As of the December 2013 distribution date, the pool's aggregate
principal balance has been reduced by 3.4% to $1.26 billion from
$1.3 billion at issuance.  Per the servicer reporting, one loan
(0.5% of the pool) is defeased.  Interest shortfalls are currently
affecting class G due to special servicing fees.

The specially serviced loan (0.80% of the pool) is secured by two
office buildings with an aggregate 85,910 square feet (sf) of
space located in Reston, VA.  The property experienced significant
rollover in 2012 when three tenants comprising of 40.5% of the net
rentable area (NRA) vacated.  The special servicer reports the
occupancy was 55% as of September 2013, which declined from 84% as
of year-end 2011.  Additionally, the debt service coverage ratio
(DSCR) has declined to 0.85 times (x) as of second-quarter 2013
from 1.88x as of year-end 2011.  This loan remains current as of
the December 2013 remittance date and the borrower is in
discussion with the special servicer.

The largest loan (12.9% of the pool), Hollywood & Highland, is
secured by a 458,686 sf retail and entertainment center located
Los Angeles, CA. The property is anchored by Dolby Theater
(formerly known as the Kodak Theater) and includes a grand
ballroom, restaurants, night clubs and a bowling alley.  The
property's performance declined in 2012 after the Cirque du Soleil
show closed following its failure to generate significant cash
flows.  Although a 10-year lease agreement was signed in the fall
of 2011 with Cirque du Soleil, no termination fee was required to
close.  After Cirque du Soleil's last show in January 2013, the
borrower has reported booking over 85 replacement event dates at
the theater for 2013.  In addition, the borrower's goal is to book
over 220 rental days in the theater for 2014 and expects improved
performance going forward.  The servicer-reported occupancy and
DSCR as of June 2013 was 88.1% and 1.14x, respectively.

Rating Sensitivity

Rating Outlooks on classes A-1 through F remain Stable due to
stable performance. No rating actions are anticipated assuming the
current performance trends continue.  Initial Key Rating Drivers
and Rating Sensitivity are further described in the New Issue
report 'WF-RBS Commercial Mortgage Trust 2011-C2' published on
Feb. 8, 2011.

Fitch affirms the following classes:

-- $33.5 million class A-1 at 'AAAsf'; Outlook Stable;
-- $383.4 million class A-2 at 'AAAsf'; Outlook Stable;
-- $122.4 million class A-3 at 'AAAsf'; Outlook Stable;
-- $493.2 million class A-4 at 'AAAsf'; Outlook Stable;
-- $39 million class B at 'AAsf'; Outlook Stable;
-- $43.9 million class C at 'Asf'; Outlook Stable;
-- $68.2 million class D at 'BBB-sf'; Outlook Stable;
-- $21.1 million class E at 'BBsf'; Outlook Stable;
-- $14.6 million class F at 'Bsf'; Outlook Stable
-- $1,032 billion* class X-A at 'AAA; Outlook Stable.

*Notional amount and interest-only.
Fitch does not rate the class G and X-B certificates.

Headquartered in San Francisco, California, Wells Fargo & Company
-- http://www.wellsfargo.com-- provides retail, commercial, and
corporate banking services.  The company's Community Banking
segment offers deposits, such as checking accounts, savings
deposits, market rate accounts, individual retirement accounts,
time deposits, and debit cards; and loan products, including lines
of credit, auto floor plan lines, equity lines and loans,
equipment and transportation loans, education loans, residential
mortgage loans, and credit cards.


* Fitch Cuts Ratings on 35 Bonds in 19 CMBS Transactions to 'D'
---------------------------------------------------------------
Fitch Ratings has taken various actions on already distressed
bonds. Fitch downgraded 35 bonds in 19 U.S. commercial mortgage-
backed securities (CMBS) transactions to 'D', as the bonds have
incurred a principal write-down. The bonds were all previously
rated 'CCC', 'CC', or 'C', which indicates a default was expected.

In addition, Fitch has affirmed 42 distressed bonds in 10
transactions; the highest rating in these transactions is 'Dsf'
and losses have occurred or are considered inevitable. Recovery
prospects are very low for the remaining bonds in these
transactions, with the exception of one transaction where recent
dispositions have resulted in only defeased collateral remaining
in the trust.

Fitch also withdraws four bonds in one transaction where the
remaining classes have been reduced to zero due to paydown and/or
realized losses. All four bonds are rated 'Dsf'.

Key Rating Drivers

The downgrades are limited to just the bonds with write-downs. Any
remaining bonds in these transactions have not been analyzed as
part of this review.

A spreadsheet detailing Fitch's rating actions on the affected
transactions is available at http://is.gd/YykxyH


* Fitch Lowers 181 Distressed Bonds in 108 RMBS Deals to 'Dsf'
--------------------------------------------------------------
Fitch Ratings has downgraded 181 distressed bonds in 108 U.S. RMBS
transactions to 'Dsf'. The downgrades indicate that the bonds have
incurred a principal write-down. Of the bonds downgraded to 'Dsf',
180 classes were previously rated 'Csf' and one class was 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 181 classes affected by these downgrades, 107 are Prime, 31
are Alt-A, and 39 are Subprime. The remaining transaction types
are other sectors. Approximately, 53% of the bonds have an RE of
50%-100%, which indicates that the bonds will recover 50%-100% of
the current outstanding balance, while 34% have an RE of 0%.

A spreadsheet detailing Fitch's rating actions can be found at
http://is.gd/kEFxRF

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.


* Moody's Takes Action on $496MM of Alt-A RMBS Issued 2005-2006
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings of 10
tranches and upgraded the ratings of four tranches backed by Alt-A
RMBS loans, issued by four RMBS transactions.

Complete rating actions are as follows:

Issuer: Banc of America Funding 2006-G Trust

Cl. 2-A-1, Upgraded to B2 (sf); previously on Aug 8, 2012 Upgraded
to B3 (sf)

Cl. 2-A-4, Upgraded to B1 (sf); previously on Aug 8, 2012 Upgraded
to Caa1 (sf)

Cl. 2-A-5, Upgraded to Caa2 (sf); previously on Nov 5, 2010
Downgraded to Ca (sf)

Issuer: CWALT, Inc. Mortgage Pass-Through Certificates, Series
2005-J9

Cl. 2-A-1, Downgraded to Caa1 (sf); previously on Feb 16, 2012
Downgraded to B1 (sf)

Cl. 2-A-2, Downgraded to Caa1 (sf); previously on Feb 16, 2012
Downgraded to B1 (sf)

Cl. 2-X, Downgraded to Caa1 (sf); previously on Feb 22, 2012
Downgraded to B3 (sf)

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

Cl. 1-A-2, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 1-A-4, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 1-A-5, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 1-A-6, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa2 (sf)

Cl. 1-X, Downgraded to Caa3 (sf); previously on Apr 12, 2010
Downgraded to Caa1 (sf)

Issuer: Nomura Asset Acceptance Corporation, Alternative Loan
Trust, Series 2005-AR4

Cl. III-A-1, Upgraded to B3 (sf); previously on Aug 16, 2012
Downgraded to Caa1 (sf)

Issuer: Deutsche Alt-A Securities, Inc. Mortgage Loan Trust Series
2006-AR1

Cl. I-A-2, Downgraded to Caa1 (sf); previously on Sep 8, 2010
Confirmed at B3 (sf)

RATINGS RATIONALE

The ratings downgraded are a result of deteriorating performance
and structural features resulting in higher expected losses for
the bonds than previously anticipated. The ratings upgraded are
due to an increase in the credit enhancement available to the
bonds.

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

Factors that would lead to an upgrade or downgrade of the rating

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment
rate. The unemployment rate fell to 7.0% in November 2013 from
7.8% in November 2012 . Moody's forecasts an unemployment central
range of 6.5% to 7.5% for the 2014 year. Deviations from this
central scenario could lead to rating actions in the sector.

House prices are another key driver of US RMBS performance.
Moody's expects house prices to continue to rise in 2014. Lower
increases than Moody's expects or decreases could lead to negative
rating actions.

Finally, 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 Raises Rating on $533 Million of RMBS Issued From 2005
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 10 tranches
from six transactions backed by subprime mortgage loans.

Complete rating actions are as follows:

Issuer: Ameriquest Mortgage Securities Inc., Series 2005-R8

Cl. M-2, Upgraded to B1 (sf); previously on Apr 14, 2010
Downgraded to Caa1 (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2005-17

Cl. 4-AV-3, Upgraded to Caa2 (sf); previously on Aug 5, 2013
Upgraded to Ca (sf)

Issuer: CWABS Asset-Backed Certificates Trust 2005-3

Cl. MV-3, Upgraded to Ba3 (sf); previously on Apr 14, 2010
Downgraded to B2 (sf)

Cl. MV-4, Upgraded to Caa1 (sf); previously on Apr 14, 2010
Downgraded to Caa3 (sf)

Issuer: First Franklin Mortgage Loan Trust 2005-FF11

Cl. M-1, Upgraded to Caa1 (sf); previously on Apr 6, 2010
Downgraded to Caa3 (sf)

Issuer: First Franklin Mortgage Loan Trust 2005-FF12

Cl. A-1, Upgraded to Baa2 (sf); previously on Jul 15, 2011
Downgraded to Ba2 (sf)

Cl. A-2B, Upgraded to Ba1 (sf); previously on Jul 15, 2011
Downgraded to B1 (sf)

Cl. A-2C, Upgraded to Ba3 (sf); previously on Jul 15, 2011
Downgraded to B3 (sf)

Cl. M-1, Upgraded to Caa1 (sf); previously on Apr 6, 2010
Downgraded to Caa3 (sf)

Issuer: GE-WMC Asset-Backed Pass-Through Certificates, Series
2005-1

Cl. M-1, Upgraded to Caa1 (sf); previously on Jul 15, 2013
Upgraded to Caa3 (sf)

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 upgrades are due to improved performance on the
underlying pools.

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

Factors that would lead to an upgrade or downgrade of the rating

Ratings in the US RMBS sector remain exposed to the high level of
macroeconomic uncertainty, and in particular the unemployment
rate. The unemployment rate fell to 7% in November 2013 from 7.8%
in November 2012 . Moody's forecasts an unemployment central range
of 6.5% to 7.5% for the 2014 year. Deviations from this central
scenario could lead to rating actions in the sector. House prices
are another key driver of US RMBS performance. Moody's expects
house prices to continue to rise in 2014. Lower increases than
Moody's expects or decreases could lead to negative rating
actions. Finally, 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 26 Classes from 12 CDO Transactions
--------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 26
classes of notes from five collateralized loan obligation (CLO)
transactions, four collateralized debt obligation (CDO)
transactions backed by commercial mortgage-backed securities
(CMBS), two cash flow CDO transactions backed primarily by CLO
tranches, and one CDO transaction backed by mezzanine structured
finance assets.

The withdrawals follow the complete paydown of the notes as
reflected in the most recent trustee-issued note payment reports.

The following transactions redeemed their classes in full after
providing S&P notice that the equity holders directed optional
redemptions:

   -- Ares X CLO Ltd.
   -- Battalion CLO II Ltd.
   -- NewStar Credit Opportunities Funding II Ltd.

The following transactions fully paid off their last rated notes:

   -- Diversified Global Securities Ltd. II.
   -- WhiteHorse II Ltd.

The remaining paid-off tranches have other rated tranches still
outstanding in their transaction's capital structure.

RATINGS WITHDRAWN

AMMC CLO IV Ltd.
                            Rating
Class               To                  From
A-2                 NR                  AAA (sf)

Anthracite CDO I Ltd.
                            Rating
Class               To                  From
D                   NR                  AA (sf)
D-FL                NR                  AA (sf)

Anthracite CDO II Ltd.
                            Rating
Class               To                  From
C                   NR                  A+ (sf)
C-FL                NR                  A+ (sf)

Anthracite CDO III Ltd.
                            Rating
Class               To                  From
Class A Notes       NR                  BBB- (sf)

Ares X CLO Ltd.
                            Rating
Class               To                  From
C-1                 NR                  AAA (sf)
C-2                 NR                  AAA (sf)
D-1                 NR                  BBB+ (sf)
D-2                 NR                  BBB+ (sf)

Ashford CDO I Ltd.
                            Rating
Class               To                  From
Class A-1LA         NR                  AA- (sf)

Battalion CLO II Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)
A-2                 NR                  AAA (sf)
B                   NR                  AA+ (sf)
C                   NR                  A+ (sf)
D                   NR                  BBB+ (sf)

C-Bass CBO V Ltd.
                            Rating
Class               To                  From
D-1                 NR                  B+ (sf)
D-2                 NR                  B+ (sf)

Crest Exeter Street Solar 2004-1 Ltd.
                            Rating
Class               To                  From
B-1                 NR                  BB+ (sf)
B-2                 NR                  BB+ (sf)

Diversified Global Securities Ltd. II
                            Rating
Class               To                  From
C                   NR                  CCC- (sf)

NewStar Credit Opportunities Funding II Ltd.
                            Rating
Class               To                  From
A-1T                NR                  AAA (sf)
A-2R                NR                  AA- (sf)
A-2T                NR                  AA- (sf)

WhiteHorse II Ltd.
                            Rating
Class               To                  From
A-3L                NR                  AA+ (sf)
B-1L                NR                   A+ (sf)

NR-Not rated.


* S&P Lowers Four Ratings from Three U.S. CMBS Transactions
-----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of commercial mortgage pass-through certificates from
three U.S. commercial mortgage-backed securities (CMBS)
transactions because of current and potential interest shortfalls.
Concurrently, S&P withdrew its ratings on two classes from the
same transactions following the full repayment of the class'
principal balances, as noted in each transaction's December 2013
trustee remittance report.

S&P lowered its ratings on three of these classes to 'D (sf)'
because it expects the accumulated interest shortfalls to remain
outstanding for the foreseeable future.  The three classes that
S&P downgraded to 'D (sf)' have had accumulated interest
shortfalls outstanding for seven to 11 months.  The recurring
interest shortfalls for the respective certificates are primarily
because of one or more of the following factors:

   -- Appraisal subordinate entitlement reduction (ASER) amounts
      are in effect for specially serviced assets;

   -- The lack of servicer advancing for loans that the servicer
      has declared nonrecoverable;

   -- Interest rate modifications related to corrected mortgage
      loans; and

   -- Special servicing fees.

In S&P's analysis, it primarily considered the ASER amounts based
on appraisal reduction amounts (ARAs), which were calculated using
recent Member of the Appraisal Institute (MAI) appraisals.  S&P
also considered servicer-nonrecoverable advance declarations and
special servicing fees that S&P believes is likely to cause
recurring interest shortfalls.

The servicer implements ARAs and the resulting ASER amounts
according to each respective transaction's terms.  Typically,
these terms call for the servicer to automatically implement an
ARA equal to 25% of the stated principal balance of a loan when a
loan is 60 days past due and an appraisal or other valuation is
not available within a specified timeframe.  When deciding which
classes from the affected transactions to downgrade to 'D (sf)',
S&P primarily considered the ASER amounts based on ARAs that were
calculated from MAI appraisals.  This is because ARAs based on a
principal balance haircut are highly subject to change, or even
reversal, once the special servicer obtains the MAI appraisals.

Servicer-nonrecoverable advance declarations can prompt shortfalls
because the servicer does not advance debt service, the recovery
of previously made advances are deemed nonrecoverable, or the
servicer fails to advance trust expenses when it determines what
advances are nonrecoverable.  Trust expenses may include, but are
not limited to, property operating expenses, property taxes,
insurance payments, and legal expenses.

Discussions of the individual transactions follow.

    BANK OF AMERICA N.A. - FIRST UNION NATIONAL BANK COMMERCIAL
                    MORTGAGE TRUST, SERIES 2001-3

S&P lowered its ratings on the class L and M certificates from
Bank of America N.A. - First Union National Bank Commercial
Mortgage Trust's series 2001-3.  S&P lowered its rating to 'D
(sf)' from 'CCC- (sf)' on the class M certificates to reflect
accumulated interest shortfalls outstanding for seven months and
S&P's expectation that the interest shortfalls will remain
outstanding for the foreseeable future.  S&P lowered its rating to
'CCC- (sf)' from 'B- (sf)' on the class L certificates to reflect
accumulated interest shortfalls outstanding for four months.  If
the class continues to experience interest shortfalls in the near
term, S&P may further lower its rating on the class to 'D (sf)'.
According to the Dec. 11, 2013, trustee remittance report, the net
interest shortfalls totaling $121,891 resulted primarily from:

   -- Reimbursement of prior advances related to the Shopko Plaza
      loan ($41,400);

   -- Interest rate modifications ($44,643);

   -- Interest not advanced ($32,748); and

   -- Special servicing and workout fees ($3,636).

The current reported interest shortfalls affected all classes
subordinate to and including class L.

CREDIT SUISSE FIRST BOSTON MORTGAGE SECURITIES CORP., SERIES
                             2003-C3

S&P lowered its rating on the class J certificates from Credit
Suisse First Boston Mortgage Securities Corp.'s series 2003-C3 to
'D (sf)' from 'CCC+ (sf)' to reflect accumulated interest
shortfalls outstanding for 10 months and S&P's expectation that
the accumulated interest shortfalls will remain outstanding for
the foreseeable future.  According to the Dec. 17, 2013, trustee
remittance report, the net interest shortfalls totaling $4,170
resulted from:

   -- Special servicing fees ($3,892);

   -- ASER ($257) related to the Red Springs Shopping Center asset
      ($2.0 million, 4.7%) that is currently with the special
      servicer, C-III Asset Management LLC; and

   -- Interest paid to servicer on advances ($22).

The current reported interest shortfalls affected all classes
subordinate to and including class K.  The trust collected $65,136
in deferred interest related to the Best Buy - Mishawaka, Ind.
loan (which has been repaid in full).  The deferred interest was
allocated to repaying the accumulated interest shortfalls
outstanding on the class H certificates.  While S&P do not
necessarily believe the class J certificates will incur additional
interest shortfalls, it is S&P's expectation that the accumulated
interest shortfalls will remain outstanding for the foreseeable
future.  For this reason, S&P is lowering the rating on the class
J certificates to 'D (sf)'.  As of the Dec. 17, 2013, trustee
remittance report, ARAs totaling $48,405 were in effect for the
Red Springs Shopping Center asset.

   J.P. MORGAN CHASE COMMERCIAL MORTGAGE SECURITIES CORP., SERIES
                            2003-LN1

S&P lowered its rating on the class L certificates from J.P.
Morgan Chase Commercial Mortgage Securities Corp.'s series 2003-
LN1 to 'D (sf)' from 'CCC- (sf)' to reflect accumulated interest
shortfalls outstanding for 11 months and S&P's expectation that
interest shortfalls will continue for the foreseeable future.
According to the Dec. 16, 2013, trustee remittance report, the net
interest shortfalls totaling $38,148 resulted primarily from:

   -- ASER amounts ($25,923) related to two assets ($11.6 million,
      20.3%) that are currently with the special servicer,
      Centerline Capital Group;

   -- Liquidation fees ($9,678); and

   -- Special servicing and workout fees ($2,546).

The current reported interest shortfalls affected all classes
subordinate to and including class M. As of the Dec. 16, 2013,
trustee remittance report, ARAs totaling $6.2 million were in
effect for two of the specially serviced assets.

RATINGS LOWERED

Bank of America N.A.-First Union National Bank Commercial Mortgage
Trust
Commercial mortgage pass-through certificates series 2001-3

                                                      Reported
         Rating                   Credit   interest shortfalls
Class  To        From     enhancement(%)  Current  Accumulated
L      CCC- (sf) B- (sf)          49.32    29,122      152,462
M      D (sf)    CCC- (sf)        25.71    44,404      262,668

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2003-C3
                                                      Reported
         Rating                   Credit   interest shortfalls
Class  To        From     enhancement(%)  Current  Accumulated
J      D (sf)    CCC+ (sf)         14.81   65,277      160,697

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2003-LN1
                                                      Reported
         Rating                   Credit   interest shortfalls
Class  To        From     enhancement(%)  Current  Accumulated
L      D (sf)    CCC- (sf)          5.99   25,689      196,034

RATINGS WITHDRAWN
Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2003-C3
Class  To        From
G      NR        BBB+ (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2003-LN1
Class  To        From
F      NR        BBB- (sf)

NR-Not rated.


* S&P Lowers 6 Ratings on 4 U.S. CMBS Transactions to Dsf
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D (sf)'
on six classes of commercial mortgage pass-through certificates
from four U.S. commercial mortgage-backed securities (CMBS)
transactions due to current interest shortfalls.

S&P lowered its ratings on these six classes to 'D (sf)' because
they have accumulated interest shortfalls outstanding between five
and 12 months and S&P expects them to remain outstanding for the
foreseeable future.  The recurring interest shortfalls for the
respective certificates are primarily due to one or more of the
following factors:

   -- Appraisal subordinate entitlement reduction (ASER) amounts
      in effect for specially serviced assets;

   -- The lack of servicer advancing for loans where the servicer
      has made nonrecoverable advance declarations;

   -- Interest rate modifications or deferrals related to
      corrected mortgage loans; and

   -- Special servicing fees.

S&P's analysis primarily considered the ASER amounts based on
appraisal reduction amounts (ARAs) calculated using recent Member
of the Appraisal Institute (MAI) appraisals.  S&P also considered
servicer-nonrecoverable advance declarations and special servicing
fees that S&P believes will likely cause recurring interest
shortfalls.

The servicer implements ARAs and resulting ASER amounts according
to each respective transaction's terms.  Typically, these terms
call for an ARA equal to 25% of the stated principal balance of a
loan to be implemented automatically when a loan is 60 days past
due and an appraisal or other valuation is not available within a
specified time frame.  S&P primarily considered ASER amounts based
on ARAs calculated from MAI appraisals when deciding which classes
from the affected transactions to downgrade to 'D (sf)'.  This is
because ARAs based on a principal balance haircut are highly
subject to change, or even reversal, once the special servicer
obtains the MAI appraisals.

Servicer-nonrecoverable advance declarations can prompt shortfalls
from a lack of debt-service advancing, the recovery of previously
made advances being deemed nonrecoverable, or the failure to
advance trust expenses when nonrecoverable declarations have been
determined.  Trust expenses may include, but are not limited to,
property operating expenses, property taxes, insurance payments,
and legal expenses.

Discussions of the individual transactions follow.

            CITIGROUP COMMERCIAL MORTGAGE TRUST 2007-C6

S&P lowered its ratings to 'D (sf)' on the class G and H
commercial mortgage pass-through certificates from Citigroup
Commercial Mortgage Trust 2007-C6 to reflect accumulated interest
shortfalls outstanding for five and 12 consecutive months,
respectively.  Based on S&P's analysis, it expects interest
shortfalls to continue in the near term.  According to the
Dec. 12, 2013, trustee remittance report, the current monthly
interest shortfalls totaled $1.4 million and resulted primarily
from:

   -- ASER amounts totaling $1.2 million related to ARAs totaling
      $267.6 million on 31 ($434.3 million, 10.7%) of the 40
      assets ($560.8 million, 13.8%) that are currently with the
      special servicer, CWCapital Asset Management LLC
      (CWCapital).  The current ASER amounts were partially offset
      this period by ASER recoveries of $181,033 related to three
      specially serviced assets ($48.8 million, 1.2%);

   -- Interest rate reductions totaling $193,275 from the
      modifications of the 50 West Corporate Center loan
      ($56.0 million, 1.4%), Quality Inn & Suites--Dulles, Va.
      loan ($10.3 million, 0.3%), Nob Hill Apartments real estate
      owned (REO) asset ($9.2 million, 0.2%), and Serino's Italian
      Foods loan ($1.9 million, 0.05%);

   -- Interest not advanced of $22,177 on the specially serviced
      Pomona Center REO asset ($4.6 million, 0.1%);

   -- Special servicing fees totaling $116,003; and

   -- Workout fees totaling $7,809.

The current reported interest shortfalls have affected all classes
subordinate to and including class G.

     GMAC COMMERCIAL MORTGAGE SECURITIES INC. (SERIES 2001-C2)

S&P lowered its rating to 'D (sf)' on the class F certificates
from GMAC Commercial Mortgage Securities Inc.'s series 2001-C2 to
reflect accumulated interest shortfalls outstanding for eight
consecutive months.  Based on S&P's analysis, it expects interest
shortfalls to continue in the near term.  According to the
Dec. 16, 2013, trustee remittance report, the current monthly
interest shortfalls from the underlying collateral totaled
$344,607.  However, $309,916 was reported as interest shortfalls
to certificates and the remainder was reported as principal
losses.  Interest shortfalls were primarily from:

   -- Interest not advanced totaling $351,264 for three of the
      specially serviced assets: the Corporate Woods Office
      Building II and III REO asset ($27.2 million, 45.7%), the
      Princeton Park Corporate Center REO asset ($17.4 million,
      29.2%), and Lichtenstein Florida Portfolio REO asset
     ($9.9 million, 16.7%); offset by Net special servicing fees
      recovered of $5,119 due to the $3.0 million Otranto Plaza
      loan's liquidation.

The current reported interest shortfalls have affected all classes
subordinate to and including class F.

             LB-UBS COMMERCIAL MORTGAGE TRUST 2006-C7

S&P lowered its ratings to 'D (sf)' on the class C and D
certificates from LB-UBS Commercial Mortgage Trust 2006-C7 to
reflect accumulated interest shortfalls outstanding for six and
eight consecutive months, respectively.  Based on S&P's analysis,
it expects interest shortfalls to continue in the near term.
According to the Dec. 17, 2013, trustee remittance report, the
interest shortfalls totaled $541,312 and were primarily from:

   -- Interest rate reductions or deferrals totaling $462,435 from
      modifications of the Colony Square loan ($116.0 million,
      5.0%) and Midtown Plaza loan ($65.0 million, 2.8%);

   -- ASER amounts totaling $50,856 related to ARAs totaling
      $9.7 million on four ($19.1 million, 0.8%) of the eight
      assets ($141.7 million, 6.1%) that are currently with the
      special servicer, LNR Partners LLC;

   -- Interest not advanced of $32,910 on the specially serviced
      Parker Square--Bldg 600 REO asset ($6.7 million, 0.3%);

   -- Special servicing fees totaling $29,541; and

   -- Workout fees totaling $5,845.

The current reported interest shortfalls have affected all classes
subordinate to and including class A-J.  If accumulated interest
shortfalls continue to be outstanding for an extended period of
time on classes A-J and B, S&P may lower the ratings on these
classes to 'D (sf)'.

             LB-UBS COMMERCIAL MORTGAGE TRUST 2008-C1

S&P lowered its rating to 'D (sf)' on the class E certificates
from LB-UBS Commercial Mortgage Trust 2008-C1 to reflect
accumulated interest shortfalls outstanding for seven consecutive
months.  Based on S&P's analysis, it expects interest shortfalls
to continue in the near term.  According to the Dec. 17, 2013,
trustee remittance report, the current monthly interest shortfalls
totaled $272,886 and resulted primarily from:

   -- Interest rate reductions or deferrals totaling $131,391 from
      the modifications of the Sutton Plaza loan ($26.6 million,
      3.0%), Best Western--Clearwater loan ($19.1 million, 2.1%),
      and West Point Shopping Center loan ($9.7 million, 1.1%);

   -- ASER amounts totaling $122,306 related to ARAs totaling
      $22.3 million on three ($43.7 million, 4.9%) of the five
      assets ($70.3 million, 7.9%) that are currently with the
      special servicer, CWCapital;

   -- Special servicing fees totaling $15,841; and

   -- Workout fees totaling $3,222;

The current reported interest shortfalls have affected all classes
subordinate to and including class D. If class D continues to
experience interest shortfalls for an extended period of time, S&P
may lower the rating on the class to 'D (sf)'.

RATINGS LOWERED

Citigroup Commercial Mortgage Trust 2007-C6
Commercial mortgage pass-through certificates

                                                Reported
         Rating                  Credit    interest shortfalls
Class  To       From     enhancement(%)  Current   Accumulated
G      D (sf)   CCC- (sf)         5.96   226,109     1,049,858
H      D (sf)   CCC- (sf)         4.64   254,377     2,745,653


GMAC Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2001-C2

                                                Reported
         Rating                  Credit    interest shortfalls
Class  To       From     enhancement(%)  Current   Accumulated
F      D (sf)   CCC- (sf)         66.78   82,415       244,382


LB-UBS Commercial Mortgage Trust 2006-C7
Commercial mortgage pass-through certificates
                                                Reported
         Rating                  Credit    interest shortfalls
Class  To       From     enhancement(%)  Current   Accumulated
C      D (sf)   CCC- (sf)          2.61  137,824       826,945
D      D (sf)   CCC- (sf)           1.30   138,302      899,262


LB-UBS Commercial Mortgage Trust 2008-C1
Commercial mortgage pass-through certificates

                                                Reported
         Rating                  Credit    interest shortfalls
Class  To       From     enhancement(%)  Current   Accumulated
E      D (sf)   CCC- (sf)          4.91   45,174       257,614


                             *********

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 by e-mail.

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 the nation's bankruptcy courts.  The
list includes links to freely downloadable of these small-dollar
petitions in Acrobat PDF documents.

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.

                           *********

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, 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 2014.  All rights reserved.  ISSN: 1520-9474.

This material is copyrighted and any commercial use, resale or
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re-mailing and photocopying) is strictly prohibited without prior
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herein is obtained from sources believed to be reliable, but is
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The TCR subscription rate is $975 for 6 months delivered via
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are $25 each.  For subscription information, contact Peter A.
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                  *** End of Transmission ***