TCR_Public/140727.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, July 27, 2014, Vol. 18, No. 207

                            Headlines

ALESCO PREFERRED IV: Moody's Confirms Caa1 Rating on $5MM Notes
ALLEGRO CLO I: S&P Affirms 'BB' Rating on Class D Notes
ARES XXXI: Fitch Expects to Assign 'BBsf' Rating to Class D Notes
BANC OF AMERICA 2005-4: Fitch Affirms Dsf Rating on Cl. K Notes
BUSINESS LOAN 2003-A: S&P Raises Rating on Class B Notes to B+

CARLYLE GLOBAL 2012-2: S&P Assigns BB Rating on Class E-R Notes
CNL FUNDING 99-1: Moody's Raises Rating on 2 Note Classes
COMM MORTGAGE 2006-C8: Fitch Affirms CC Rating on Cl. B Certs
COMM 2010-C1: Fitch Affirms 'BB' Rating on Class F Notes
GLENEAGLES CLO: Moody's Affirms 'Ba3' Rating on Class D Notes

GLENEAGLES CLO: S&P Raises Rating on Class D Notes to 'B+'
GOLUB CAPITAL 10: S&P Affirms 'BB' Rating on Class E Notes
GSC GROUP VIII: Moody's Hikes Rating on $13MM Cl. D Notes to Ba3
ICG US CLO 2014-2: Moody's Assigns (P)B3 Rating on $8.5MM Notes
IMSCI COMMERCIAL 2014-5: Fitch Assigns BB Rating on Class F Notes

JP MORGAN 2005-LDP5: Fitch Affirms Csf Ratings on 4 Cert. Classes
JP MORGAN 2013-C14: Fitch Affirms 'Bsf' Rating on Class G Certs
JP MORGAN 2014-C21: Fitch Assigns 'BB' Rating on Class E Notes
MADISON PARK VIII: S&P Affirms 'BB' Rating on Class E Notes
MIDOCEAN CREDIT II: S&P Affirms 'BB' Rating on Class E Notes

MIDOCEAN CREDIT III: S&P Assigns 'BB' Rating on Class E Notes
MLMS 2005-ACR1: S&P Lowers Rating on 2 Note Classes to CCC
MORGAN STANLEY 2007-IQ13: Fitch Affirms Dsf Rating on Cl. H Certs
MORGAN STANLEY 2007-XLC1: Fitch Withdraws CC Rating on F Notes
MOUNTAIN CAPITAL V: Moody's Hikes Rating on B-2L Notes to Ba2

NYLIM FLATIRON 2006-1: Moody's Hikes Rating on Cl. D Notes to Ba2
OCTAGON INVESTMENT XI: Moody's Affirms Ba3 Rating on Cl. D Notes
ONEMAIN FINANCIAL 2014-2: S&P Assigns Prelim. BB Rating on C Notes
PORTOLA CLO: S&P Affirms 'B-' Rating on Class E Notes
PREFERRED TERM XVII: Moody's Hikes Rating on Cl. B Notes to B3

ROCKWALL CDO: Moody's Hikes Rating on Cl. B-2L Notes to B1
SOLARCITY LMC III: S&P Assigns Prelim. BB Rating on Class B Notes
UNITED AUTO 2014-1: S&P Assigns Prelim. BB Rating on Class E Notes
VALHALLA CLO: S&P Raises Rating on 2 Note Classes to 'B-'
VENTURE V CDO: S&P Affirms 'B+' Rating on Class D Notes

WACHOVIA BANK 2004-C15: S&P Lowers Rating on Class K Certs to D
WFRBS COMMERCIAL 2013-C15: Fitch Affirms BB Rating on Cl. E Notes

* Moody's Takes Action on $277MM of RMBS by Various Trusts
* Moody's Takes Action on $265-Mil. of RMBS by Various Issuers
* Moody's Takes Action on $71MM Subprime RMBS Issued 2001 to 2004
* Moody's Lowers Ratings on $32MM of RMBS by Bayview & RAMP


                             *********

ALESCO PREFERRED IV: Moody's Confirms Caa1 Rating on $5MM Notes
---------------------------------------------------------------
Moody's Investors Service has confirmed the ratings on the
following notes issued by Alesco Preferred Funding IV, Ltd.:

  $195,000,000 Class A-1 First Priority Senior Secured Floating
  Rate Notes Due 2034 (current balance of $114,849,469.33),
  Confirmed at Aa2 (sf); previously on June 26, 2014 Aa2 (sf)
  Placed Under Review for Possible Upgrade

  $63,000,000 Class A-2 Second Priority Senior Secured Floating
  Rate Notes Due 2034, Confirmed at A2 (sf); previously on June
  26, 2014 A2 (sf) Placed Under Review for Possible Upgrade

  $7,000,000 Class A-3 Second Priority Senior Secured
  Fixed/Floating Rate Notes Due 2034, Confirmed at A2 (sf);
  previously on June 26, 2014 A2 (sf) Placed Under Review for
  Possible Upgrade

  $5,000,000 Series I Combination Notes Due 2034 (current rated
  balance of $2,539,613.54), Confirmed at Caa1 (sf); previously
  on June 26, 2014 Caa1 (sf) Placed Under Review for Possible
  Upgrade

Alesco Preferred Funding IV, Ltd., issued in May 2004, is a
collateralized debt obligation backed by a portfolio of bank trust
preferred securities.

Ratings Rationale

Moody's confirmed the ratings on the Class A-1, Class A-2, Class
A-3 and Series Combination I notes due to the transaction's stable
performance. As such, the expected losses on the Class A-1, Class
A-2, Class A-3 and Series Combination I notes are still
commensurate with their current rating levels.

Moody's assumed defaulted amount decreased slightly to $10.5
million (4.1% of the current portfolio) from $15.5 million, and
the Class A-1 notes' par coverage, by Moody's calculations, has
increased slightly to 214.28%, from 209.30% since February 2014.
Based on the trustee's April 2014 report, the over-
collateralization ratio of the senior Class A notes was 127.6%
(limit 125.00%), versus 130.4% in February 2014, and that of the
Class B notes, 75.38% (limit 101.8%), versus 77.0% in February
2014.

The transaction was analyzed using the updates to Moody's TruPS
CDOs methodology described in "Moody's Approach to Rating TruPS
CDOs" published in June 2014. These updates include: (1) removing
the current 25% macro default probability stress for bank and
insurance TruPS; (2) expanding the default timing profiles from
one to six probability-weighted scenarios; (3) incorporating a
redemption profile for bank and insurance TruPS; (4) using a loss
distribution generated by Moody's CDOROM for deals that do not
permit reinvestment; (5) giving full par credit to deferring bank
TruPS that meet certain criteria; and (6) raising the assumed
recovery rate for insurance TruPS.

In taking the foregoing actions, Moody's also announced that it
had concluded its review of its ratings on the issuer's Class A-1
Notes, A-2 Notes, Class A-3 Notes and Series I Combination Notes
announced on June 26, 2014. At that time, Moody's had placed the
ratings on review for upgrade as a result of the aforementioned
methodology updates.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, and weighted average recovery
rate, are based on its methodology and could differ from the
trustee's reported numbers. In its base case, Moody's analyzed the
underlying collateral pool has having a performing par of $246.1
million, defaulted/deferring par of $10.5 million, a weighted
average default probability of 7.69% (implying a WARF of 769), and
a weighted average recovery rate upon default of 10%. In addition
to the quantitative factors Moody's explicitly models, qualitative
factors are part of rating committee considerations. Moody's
considers the structural protections in the transaction, the risk
of an event of default, recent deal performance under current
market conditions, the legal environment and specific
documentation features. All information available to rating
committees, including macroeconomic forecasts, inputs from other
Moody's analytical groups, market factors, and judgments regarding
the nature and severity of credit stress on the transactions, can
influence the final rating decision.

Methodology Underlying the Rating Action

The principal methodology used in this rating was "Moody's
Approach to Rating TruPS CDOs," published in June 2014.

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:

1) Macroeconomic uncertainty: TruPS CDOs performance could be
negatively affected by uncertainty about credit conditions in the
general economy. Moody's has a stable outlook on the US banking
sector.

2) Portfolio credit risk: Credit performance of the assets
collateralizing the transaction that is better than Moody's
current expectations could have a positive impact on the
transaction's performance. Conversely, asset credit performance
weaker than Moody's current expectations could have adverse
consequences on the transaction's performance.

3) Deleveraging: One source of uncertainty in this transaction is
whether deleveraging from unscheduled principal proceeds and
excess interest proceeds will continue and at what pace. Note
repayments that are faster than Moody's current expectations could
have a positive impact on the notes' ratings, beginning with the
notes with the highest payment priority.

4) Resumption of interest payments by deferring assets: A number
of banks have resumed making interest payments on their TruPS. The
timing and amount of deferral cures could have significant
positive impact on the transaction's over-collateralization ratios
and the ratings on the notes.

5) Exposure to non-publicly rated assets: The deal contains a
large number of securities whose default probability Moody's
assesses through credit scores derived using RiskCalc or credit
estimates. Because these are not public ratings, they are subject
to additional estimation uncertainty.

Loss and Cash Flow Analysis:

Moody's applied a Monte Carlo simulation framework in Moody's
CDOROM(TM) v.2.13.1 to model the loss distribution for TruPS CDOs.
The simulated defaults and recoveries for each of the Monte Carlo
scenarios defined the reference pool's loss distribution. Moody's
then used the loss distribution as an input in its CDOEdge(TM)
cash flow model. CDOROM(TM) v. 2.13.1 is available on
www.moodys.com under Products and Solutions -- Analytical models,
upon receipt of a signed free license agreement.

The portfolio of this CDO contains TruPS issued by small to medium
sized U.S. community banks that Moody's does not rate publicly. To
evaluate the credit quality of bank TruPS that do not have public
ratings, Moody's uses RiskCalc(TM), an econometric model developed
by Moody's KMV, to derive credit scores. Moody's evaluation of the
credit risk of most of the bank obligors in the pool relies on
FDIC Q1-2014 financial data.

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 relative to the base case
modeling results, which may be different from the current public
ratings of the 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):

Assuming a two-notch upgrade to assets with below-investment grade
ratings or rating estimates (WARF of 500)

Class A-1: +1

Class A-2: +2

Class A-3: +2

Class B-1: 0

Class B-2: 0

Class B-3: 0

Assuming a two-notch downgrade to assets with below-investment
grade ratings or rating estimates (WARF of 1131)

Class A-1: -2

Class A-2: -1

Class A-3: -1

Class B-1: 0

Class B-2: 0

Class B-3: 0


ALLEGRO CLO I: S&P Affirms 'BB' Rating on Class D Notes
-------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on Allegro
CLO I Ltd./Allegro CLO I LLC 's $324.10 million floating-rate
notes following the transaction's effective date as of May 27,
2014.

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 S&P's criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to S&P by the
collateral manager, and may also reflect its assumptions about the
transaction's investment guidelines.  This is because not all
assets in the portfolio have been purchased.

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

"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 S&P deems
necessary.

RATINGS AFFIRMED

Allegro CLO I Ltd./Allegro CLO I LLC

Class                      Rating               Amount
                                               (mil. $)
A-1                        AAA (sf)             213.80
A-2                        AA (sf)               45.70
B                          A (sf)                28.50
C                          BBB (sf)              19.10
D                          BB (sf)               17.00


ARES XXXI: Fitch Expects to Assign 'BBsf' Rating to Class D Notes
-----------------------------------------------------------------
Fitch Ratings expects to assign the following ratings and Rating
Outlooks to Ares XXXI CLO Ltd./LLC:

-- $759,900,000 class A-1 notes 'AAAsf'; Outlook Stable;
-- $136,900,000 class A-2 notes 'AAsf'; Outlook Stable;
-- $75,700,000 class B notes 'Asf'; Outlook Stable;
-- $46,250,000 class C notes 'BBBsf'; Outlook Stable;
-- $57,500,000 class D notes 'BBsf'; Outlook Stable.

Fitch does not expect to rate the subordinated notes.

Transaction Summary

Ares XXXI CLO Ltd. and Ares XXXI CLO LLC (together, Ares XXXI, or
the issuer) comprise an arbitrage cash flow collateralized loan
obligation (CLO) that will be managed by Ares CLO Management XXXI,
L.P., a wholly owned subsidiary of Ares Management LLC (Ares
Management). Net proceeds from the issuance of the secured and
subordinated notes will be used to purchase a portfolio of
approximately $1.25 billion of primarily senior-secured leveraged
loans. The CLO will have a four-year reinvestment period and a
two-year non-call period.

Key Rating Drivers

Sufficient Credit Enhancement: Credit enhancement (CE) available
to the notes, in addition to excess spread, is sufficient to
protect against portfolio default and recovery rate projections in
the respective rating stress scenarios. The level of CE for each
class of notes is above the average CE for notes in the same
respective rating categories in recent CLO issuances.
'B' Asset Quality: The average credit quality of the indicative
portfolio is approximately 'B', which is comparable to recent
CLOs. Issuers rated in the 'B' rating category denote relatively
weak credit quality; however, in Fitch Ratings' opinion, each
class of rated notes is projected to perform with sufficient
robustness against default rates commensurate with its applicable
rating stress.

Strong Recovery Expectations: The indicative portfolio consists of
96.1% first-lien senior-secured loans. Approximately 89.1% of the
indicative portfolio has either strong recovery prospects or a
Fitch-assigned recovery rating of 'RR2' or higher, resulting in a
base case recovery assumption of 76.3%. In determining the notes'
ratings, Fitch stressed the indicative portfolio by assuming a
higher portfolio concentration of assets with lower recovery
prospects and further reduced recovery assumptions for higher
rating stress assumptions. For example, the analysis of the class
A-1 notes assumed a 36.9% recovery rate in Fitch's 'AAAsf'
scenario.

Consistent Portfolio Parameters: The concentration limitations and
collateral quality test levels are within the range of limits set
in the majority of recent CLOs. Fitch addressed the impact of the
most prominent risk-presenting concentration allowances in the
Fitch stressed portfolio analysis.

Rating Sensitivities

Fitch evaluated the structure's sensitivity to the potential
variability of key model assumptions, including decreases in
recovery rates and increases in default rates or correlation.
Fitch expects the class A-1 and class A-2 notes to remain
investment grade, while classes B, C, and D are generally expected
to remain within two rating categories, even under the most
extreme sensitivity scenarios. Results under these sensitivity
scenarios ranged between 'AA-sf' and 'AAAsf' for the class A-1
notes, between 'BBBsf' and 'AAAsf' for the class A-2 notes,
between 'BBsf' and 'AA+sf' for the class B notes, between 'B-sf'
and 'AA-sf' for the class C notes, and between a level below
'CCCsf' and 'BBB+sf' for the class D notes. The results of these
scenarios remain consistent with the assigned ratings.
The expected ratings are based on information provided to Fitch as
of July 24, 2014. Sources of information used to assess these
ratings were provided by the arranger, J.P. Morgan Securities LLC,
and the public domain.


BANC OF AMERICA 2005-4: Fitch Affirms Dsf Rating on Cl. K Notes
---------------------------------------------------------------
Fitch Ratings has affirmed 19 classes of Banc of America
Commercial Mortgage Inc. (BACM) commercial mortgage pass-through
certificates series 2005-4.

Key Rating Drivers

The affirmations reflect sufficient credit enhancement and
continued stable performance of the pool since Fitch's last rating
action. Fitch modeled losses of 10.3% of the remaining pool;
expected losses on the original pool balance total 10.1%,
including $53 million (3.3% of the original pool balance) in
realized losses to date. Fitch has designated 39 loans (33.8%) as
Fitch Loans of Concern, which includes 16 specially serviced
assets (10%). Of the remaining pool, 79% matures in 2015, most of
which (52%) matures between May and July 2015.

The largest contributor to expected losses is the Capistrano I
Office Buildings loan (2.6% of the pool), which is secured by an
188,040 square foot (sf) office building located in San Juan
Capistrano, CA. The largest three tenants are Los Golondrinas Mex.
Food/Arturo Galindo Jr. (4%) lease expiration January 2019; Semi
Conductor Technology Associates Inc. (3%) expiration December
2017; and The Effect (3%) expiration December 2014. No other
tenant represents more than 2% of the total net rentable area
(NRA) at the property. Per the borrower, property performance has
been affected by on-going freeway and bridge construction in the
area in addition to lower occupancy and declining base rents. The
borrower continues to actively market the vacancies; however, per
the borrower, there are no firm prospects. The year-end (YE) 2013
net operating income (NOI) declined 8% from YE 2012 and 44% since
issuance. There is approximately 21% lease rollover in 2014 and
23% in 2015. Although property occupancy has improved slightly to
70% compared to 66% at Fitch's last review, average rent declined
to $14 sf from $16 sf at last review; occupancy and rents remain
below market. Per REIS as of 1Q 2014, the Southern Orange County
submarket vacancy is 17.8% with asking rent $28.65sf. The loan
remains current.

The next largest contributor to expected losses is the specially-
serviced Prairie Stone Commons loan (1.2%), which is secured by a
101,615 sf office property located in Hoffman Estates, IL, built
in 1992. The loan transferred to special servicing in 2009 due to
a payment default. As of May 2014, the property is 38% occupied. A
summary judgment was received at the June 2014 hearing and a sale
date has been set for July 31st. The special servicer was
scheduled to attend a mandatory court ordered settlement
conference in the Guaranty lawsuit.

The third largest contributor to expected losses is the specially-
serviced Friar's Branch Crossing (0.9%), which is a 110,027 SF
office/retail property located in Chattanooga, TN. The asset was
acquired via foreclosure in September 2011 and is currently real
estate owned (REO). As of June 2014, the property is 58% occupied.
The leasing broker is NAI Charter Real Estate Corporation. Per the
special servicer, the asset is currently being marketed by a loan
sale advisor with several other loan and REO assets.

Rating Sensitivity

Rating Outlooks on classes A-5A through A-1A and B remain Stable
due to sufficient credit enhancement and continued paydown of the
classes. The revision of class A-J to Positive from Stable
reflects the expected increases in credit enhancement due to
additional defeasance, expected paydown and upcoming loan
maturities in 2015. With continued stable pool performance and
loss expectations, and upgrade to class A-J is likely.

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

-- $97.1 million class A-J at 'BBBsf', Outlook to Positive from
    Stable;

-- $15.9 million class C at 'Bsf', Outlook to Stable from
    Negative;

-- $29.7 million class D at 'CCCsf', RE 60%.

Fitch affirms the following classes:

-- $485.9 million class A-5A at 'AAAsf', Outlook Stable;
-- $125.7 million class A3 and A4 at 'AAAsf', Outlook Stable;
-- $7.3 million class A-SB at 'AAAsf', Outlook Stable;
-- $69.4 million class A-5B at 'AAAsf', Outlook Stable;
-- $80.5 million class A-1A at 'AAAsf', Outlook Stable;
-- $31.7 million class B at 'BBsf', Outlook Stable;
-- $17.8 million class E at 'CCsf', RE 0%;
-- $19.8 million class F at 'CCsf', RE 0%;
-- $17.8 million class G at 'Csf', RE 0%;
-- $23.8 million class H at 'Csf', RE 0%;
-- $7.9 million class J at 'Csf', RE 0%;
-- $2.6 million class K at 'Dsf', RE 0%;
-- $0 class L at 'Dsf', RE 0%;
-- $0 class M at 'Dsf', RE 0%;
-- $0 class N at 'Dsf', RE 0%;
-- $0 class O at 'Dsf', RE 0%.

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


BUSINESS LOAN 2003-A: S&P Raises Rating on Class B Notes to B+
--------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B notes from Business Loan Express (BLX) Business Loan Trust 2003-
A and the class A, B, and C notes from series 2006-A.  At the same
time, S&P affirmed its ratings on the class A notes from BLX
Business Loan Trust 2003-A and the class A, B, C, and D notes from
series 2007-A.

These transactions are asset-backed securitizations backed by
payments from small business loans primarily collateralized by
first liens on commercial real estate.

The upgrades reflect credit enhancement buildup and the notes'
ability to withstand S&P's stress tests at a higher rating level
after applying its new small business loan-backed securitization
criteria that was released on March 28, 2014.  These transactions
have paid down to the notes since S&P's last rating actions.  The
credit quality of the underlying loans has improved as the
delinquency rates have stalled.  Moreover, the transactions
received additional proceeds from the liquidation of the charged
off loans (delinquent loans that were written off after being past
due for a certain number of days per the governing trust
documents) in the pool.  After applying S&P's new criteria, it
upgraded some of the classes from two transactions to reflect
higher recoveries, improved loan performance, and collateral
seasoning.

The affirmations reflect the adequate credit support available to
the notes at their current rating levels.

BUSINESS LOAN EXPRESS BUSINESS LOAN TRUST 2003-A

Since S&P's January 2013 rating actions, the series 2003-A
transaction has paid down to approximately 5.0% of its original
balance.  According to the May 2014 servicer report, there were 11
loans left in the pool.  The five-largest obligors represented
64.6% of the pool and the 10-largest obligors represented 93.3%.
The transaction also has four charged-off loans.  According to the
May 2014 servicer report, the charged-off loans were approximately
$4.0 million, or 29.3% of the underlying collateral pool.  The
credit quality of the pool has improved and currently the pool has
no delinquent loans compared with 13.3% in January 2013.

BUSINESS LOAN EXPRESS BUSINESS LOAN TRUST 2006-A

The series 2006-A transaction has paid down to approximately 25%
of its original outstanding balance since S&P's March 2013
affirmations.  According to the May 2014 servicer report, there
were 175 loans left in the pool.  The five-largest obligors made
up 13.3% of the pool, and the 10-largest obligors represented
23.3% of the pool.  The charged-off loans were approximately $13.2
million, or 15.0% of the underlying collateral pool.  Delinquent
and defaulted loans were 7.0% in May 2014, down from 13.4% in
January 2013.  Since January 2013, the transaction has caught up
on all scheduled principal payments to the notes and has now
funded the reserve account to $9.7 million, which meets the
current requisite amount.

BUSINESS LOAN EXPRESS BUSINESS LOAN TRUST 2007-A

The series 2007-A class A notes has paid down to approximately
28.0% of its original outstanding balance since S&P's March 2013
rating actions.  Currently, the class B, C, and D notes are not
receiving any scheduled principal.  There were 103 loans left in
the pool, according to the May 2014 servicer report.  The five-
largest obligors represented 12.2% of the pool, and the 10-largest
represented 23.1% of the pool.  Delinquent and defaulted loans
were 2.4% of the pool in May 2014, down from 15.9% in March 2013.
The transaction consists of a large amount of charged-off loans
totaling to approximately $67.8 million, or 44.6% of the
underlying collateral pool, and the reserve account's current
balance is $0.0, which does not meet the $14.7 million current
requisite amount.

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

RATINGS RAISED

Business Loan Express Business Loan Trust 2003-A

           Rating        Rating
Class      To            From
B          B+ (sf)       CCC+ (sf)

Business Loan Express Business Loan Trust 2006-A

           Rating        Rating
Class      To            From
A          BBB+ (sf)     CCC+ (sf)
B          BBB (sf)      CCC (sf)
C          BBB- (sf)     CCC- (sf)

RATINGS AFFIRMED

Business Loan Express Business Loan Trust 2003-A
Class      Rating
A          BB- (sf)

Business Loan Express Business Loan Trust 2007-A
Class      Rating
A          CCC (sf)
B          CCC- (sf)
C          CC (sf)
D          CC (sf)


CARLYLE GLOBAL 2012-2: S&P Assigns BB Rating on Class E-R Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on the
class A-1, A-2, B-1, B-2, C-1, C-2, D, and E notes from Carlyle
Global Market Strategies CLO 2012-2 Ltd., a collateralized loan
obligation (CLO) transaction managed by Carlyle Investment
Management LLC, after the notes were redeemed in full.  At the
same time, S&P assigned ratings to the new class A-1-R, B-1-R, C-
1-R, D-R, and E-R notes.

The replacement notes were issued via a supplemental indenture.
The issuer used all of the proceeds from the replacement classes
of notes to redeem the original classes of notes, as outlined by
provisions in the transaction documents.  The replacement notes
issued all have a floating interest rate with a notional balance
equal to the originally issued floating-rate note balance (plus
fixed-rate note balance, where applicable).  The replacement notes
were issued at a lower spread over LIBOR than the original
floating-rate notes.

The transaction is still in its reinvestment period, and none of
the notes have delevered.

S&P's full cash flow analysis resulted in mostly higher cushions
for the senior notes after the refinancing compared with that at
the spread prior to refinancing.

CASH FLOW ANALYSIS RESULTS
Current date before refinancing
Class      Amount    Interest         BDR      SDR     Cushion
         (Mil. $)    rate(%)          (%)      (%)         (%)
A-1        310.00    LIBOR + 1.47    67.20    61.50       5.70
A-2         13.00    2.62            67.20    61.50       5.70
B-1         35.00    LIBOR + 3.00    63.52    53.76       9.76
B-2         20.00    4.37            63.52    53.76       9.76
C-2         30.00    LIBOR + 3.00    55.04    47.71       7.33
C-1          7.50    4.71            55.04    47.71       7.33
D           24.00    LIBOR + 4.70    49.04    41.86       7.18
E           23.00    LIBOR + 6.25    40.88    35.13       5.75

Current date after refinancing
A-1-R      323.00    LIBOR + 1.30    65.85    61.50       4.35
B-1-R       55.00    LIBOR + 2.10    64.56    53.76      10.80
C-1-R       37.50    LIBOR + 2.90    55.50    47.71       7.79
D-R         24.00    LIBOR + 3.90    50.22    41.86       8.36
E-R         23.00    LIBOR + 6.10    42.14    35.13       7.01

Effective date
A-1        310.00    LIBOR + 1.47    65.38    63.40       1.98
A-2         13.00    2.62            65.38    63.40       1.98
B-1         35.00    LIBOR + 3.00    61.39    55.36       6.03
B-2         20.00    4.37            61.39    55.36       6.03
C-2         30.00    LIBOR + 3.00    52.62    49.30       3.32
C-1          7.50    4.71            52.62    49.30       3.32
D           24.00    LIBOR + 4.70    45.99    43.13       2.86
E           23.00    LIBOR + 6.25    37.34    36.16       1.18

BDR-Break-even scenario.
SDR-Scenario default rate.

The supplemental indenture did not make any other substantive
changes to the transaction.

RATINGS WITHDRAWN

Carlyle Global Market Strategies CLO 2012-2 Ltd.
                        Rating
Class              To           From
A-1                NR           AAA (sf)
A-2                NR           AAA (sf)
B-1                NR           AA (sf)
B-2                NR           AA (sf)
C-1                NR           A (sf)
C-2                NR           A (sf)
D                  NR           BBB (sf)
E                  NR           BB (sf)

RATINGS ASSIGNED

Carlyle Global Market Strategies CLO 2012-2 Ltd.
Class              Rating
A-1-R              AAA (sf)
B-1-R              AA (sf)
C-1-R              A (sf)
D-R                BBB (sf)
E-R                BB (sf)

TRANSACTION INFORMATION

Issuer: Carlyle Global Market Strategies CLO 2012-2 Ltd.
Coissuer: Carlyle Global Market Strategies CLO 2012-2 LLC
Collateral manager: Carlyle Investment Management LLC
Refinancing arranger: Citigroup Global Markets Inc.
Trustee: The Bank Of New York Mellon Trust Co. N.A.
Transaction type: Cash flow CL


CNL FUNDING 99-1: Moody's Raises Rating on 2 Note Classes
---------------------------------------------------------
Moody's Investors Service has upgraded two classes of securities
issued by CNL Funding 99-1, LP. The securities are backed by
franchise loans made to fast-food and casual dining restaurants.

Issuer: CNL Funding 99-1, LP

Class E, Upgraded to B1 (sf); previously on Feb 11, 2011
Downgraded to B3 (sf)

Class F, Upgraded to B3 (sf); previously on Jun 30, 2009
Downgraded to Caa1 (sf)

Ratings Rationale

The upgrade results from high levels of credit enhancement
available to protect noteholders from potential future collateral
writedowns. As the deal amortizes, the sequential payment
waterfall allows for subordination as a percentage of the pool
balance to increase over time. The rating actions also reflect the
underlying concentrations and default risks in the transaction as
well as Moody's view on future performance of the collateral
properties.

As of the June 2014 payment date, the Classes E and F notes had
89% and 66% total credit enhancement, respectively, from 45 loans
to 9 obligors. The collateral pool is highly concentrated, with
66% exposure to two obligors with KFC and Applebee's restaurants.

The principal methodology used in this rating was "Moody's Global
Approach to Rating SME Balance Sheet Securitizations" published in
January 2014.

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

An increase or decrease in delinquencies or losses that differs
from recent performance, or further large changes in credit
enhancement available to the notes.


COMM MORTGAGE 2006-C8: Fitch Affirms CC Rating on Cl. B Certs
-------------------------------------------------------------
Fitch Ratings has affirmed all classes of COMM Mortgage Trust
series 2006-C8 commercial mortgage pass-through certificates and
revised the Outlook on Class A-M to Stable from Negative.

Key Rating Drivers

The affirmations are the result of stable overall pool performance
since Fitch's last review. Fitch modeled losses of 10.9% for the
remaining pool; expected losses on the original pool balance total
12.3%, including $187.5 million (7.4% of the original pool
balance) in realized losses to date. Fitch has designated 30 loans
(27.8%) as Fitch Loans of Concern, which includes 18 specially
serviced assets (12.6%).

As of the July 2014 distribution date, the pool's aggregate
principal balance has been reduced by 32.4% to $2.55 billion from
$3.78 billion at issuance. Nine loans (7.9%) are defeased.
Interest shortfalls totaling $40.1 million are currently affecting
classes E through S.

Rating Sensitivities

All investment rated classes are expected to remain stable and no
near-term rating actions are anticipated. In addition, the
distressed classes (rated below 'B') may be subject to further
rating actions as losses are realized.

The largest contributor to expected losses is a loan secured by
405,000 square feet (sf) of a 689,601 sf regional mall located in
Clovis, CA (3% of the pool). Loan was transferred to the special
servicing in September 2013 due to payment default. The servicer
is working with the borrower for a possible loan modification.
Occupancy as of April 2014 was 73.5%, compared to 74% at year-end
(YE) 2012 and 87.9% at issuance.

The second largest contributor to expected losses is a portfolio
of seven (12 at issuance) recreational vehicle resort communities
located in five different states (2.2%). All properties became
real estate owned assets (REO) as of May 2013. Based on servicer
provided asset valuations, significant losses are expected upon
liquidation of these assets.

The third largest contributor to expected losses is an
office/medical office building located in the West Central
submarket of Las Vegas, Nevada totaling 130,268 SF. The property
became REO as of June 2012 via foreclosure sale. The asset is on a
ground lease with approximately 11 years remaining. Occupancy as
of June 2014 was 66%.

Fitch affirms the following classes and revises Outlook as
indicated:

-- $12.2 million class A-AB at 'AAAsf'; Outlook Stable;
-- $1.1 billion class A-4 at 'AAAsf'; Outlook Stable;
-- $481.8 million class A-1A at 'AAAsf'; Outlook Stable;
-- $377.6 million class A-M at 'AAsf'; Outlook to Stable from
    Negative;
-- $302.1 million class A-J at 'CCCsf'; RE 90%;
-- $28.3 million class B at 'CCsf'; RE 0%;
-- $42.5 million class C at 'CCsf'; RE 0%;
-- $37.8 million class D at 'CCsf'; RE 0%;
-- $23.6 million class E at 'Csf'; RE 0%;
-- $28.3 million class F at 'Csf'; RE 0%;
-- $51.9 million class G at 'Csf'; RE 0%;
-- $37.8 million class H at 'Csf'; RE 0%;
-- $15.4 million class J at 'Dsf'; RE 0%;
-- $0 class K at 'Dsf'; RE 0%;
-- $0 class L at 'Dsf'; RE 0%;
-- $0 class M at 'Dsf'; RE 0%;
-- $0 class N at 'Dsf'; RE 0%;
-- $0 class O at 'Dsf'; RE 0%.

The classes A-1, A-2A, A-2B and A-3 have paid in full. Fitch does
not rate the class P, Q and S certificates. Fitch previously
withdrew the ratings on the interest-only class X-P and X-S
certificates.


COMM 2010-C1: Fitch Affirms 'BB' Rating on Class F Notes
--------------------------------------------------------
Fitch Ratings has affirmed 13 classes of Deutsche Bank Securities
COMM 2010-C1 commercial mortgage pass-through certificates.

KEY RATING DRIVERS

The affirmations of the Deutsche Bank Securities COMM 2010-C1 are
based on the overall stable performance of the underlying
collateral pool.

As of the July 2013 remittance, the pool's aggregate principal
balance has been paid down by 6.5% to $801 million from $857
million at issuance.  The top 15 loans reported full year 2013
financials.  Based on full year financial statements, the pool's
overall net operating income (NOI) improved 5.0% since issuance.
Almost half of the pool (48.6%) is comprised of five year loans
that mature in 2015.

There are no delinquent or specially serviced loans.  Four loans
(8.1%) are on the master servicer's watch list of which two (5.7%)
are considered Fitch Loans of Concern and are in the transaction's
largest 15 loans.

The largest Fitch Loan of Concern is Central Plaza (3.6% of the
pool) secured by a 405,693 square foot, 20 story office tower,
three two story office buildings, and a nine-level parking garage.
The property is located in commercial zone that is approximately
one mile north of downtown Phoenix, AZ.  Occupancy at the subject
has modestly improved during the last year to 61% as of March 2014
from a low of 56% during the 2012 calendar year.  The sponsor
continues to market the vacant space in an effort to further
backfill the campus vacancy.  Per Reis, the Uptown submarket of
Phoenix has a class A vacancy rate of 29.5% and rental rate of
$21.50 per square foot (psf) as of first quarter 2014.  The
submarket vacancy rate is expected to continue to fall over the
next three years as the region's economic activity continues to
expand and the new development is limited in the area.  The loan
matures in Oct. 2015.

The second Fitch loan of concern, is a loan secured by a 195,326
sf office complex, 400 Skokie Boulevard (2.1%), located in
Northbrook, IL, approximately 20 miles north of Chicago.  The
subject was built in 1984 and renovated in 2006.  The property's
occupancy was 81% as of Dec. 2013 which is a slight improvement
from 79% at year-end 2012.  The sponsor continues to work in a
challenging submarket environment to increase occupancy while
renewing a number of tenant leases schedule to expire in 2015.
Per Reis, Chicago's north suburban office market vacancy rate is
currently 25%.  The loan matures in Sep. 2015.

RATINGS SENSITIVITY

All classes maintain a Stable Outlook.  Due to the recent issuance
of the transaction and stable performance, Fitch does foresee
negative ratings migration until a material economic or asset
level event changes the transaction's overall portfolio-level
metrics.  If the Fitch Loans of Concern default and/or transfer to
the special servicer, negative rating outlooks or negative rating
actions on the junior classes are possible.  However, given the
significant expected paydown due to the high percentage of
maturing loans in 2015, the expected increase in credit
enhancement may mitigate an increase in expected losses.

Fitch has affirmed the following classes:

   -- $362.8 million class A-1 at 'AAAsf'; Outlook Stable;
   -- $35.1 million class A-1D at 'AAAsf'; Outlook Stable;
   -- $75.1 million class A-2 at 'AAAsf'; Outlook Stable;
   -- $179.5 million class A-3 at 'AAAsf'; Outlook Stable;
   -- $262.5 million class XP-A at 'AAAsf'; Outlook Stable;
   -- $326.2 million class XS-A at 'AAAsf'; Outlook Stable;
   -- $326.2 million class XW-A at 'AAAsf'; Outlook Stable;
   -- $24.6 million class B at 'AAsf'; Outlook Stable;
   -- $28.9 million class C at 'Asf'; Outlook Stable;
   -- $45 million class D at 'BBB-sf'; Outlook Stable;
   -- $7.5 million class E at 'BBB-sf'; Outlook Stable;
   -- $12.8 million class F at 'BBsf'; Outlook Stable;
   -- $12.9 million class G at 'B-sf'; Outlook Stable.

Fitch does not rate the interest-only class XW-B or the $17.1
million class H.


GLENEAGLES CLO: Moody's Affirms 'Ba3' Rating on Class D Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Gleneagles CLO, Ltd:

$51,000,000 Class C Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due November 1, 2017, Upgraded to Baa1
(sf); previously on March 18, 2014 Upgraded to Baa2 (sf)

$5,000,000 Class 1 Extendable Combination Notes Due November 1,
2017 (current rated balance of $3,086,482), Upgraded to A1 (sf);
previously on March 18, 2014 Upgraded to A2 (sf)

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

$620,000,000 Class A-1 Floating Rate Senior Secured Extendable
Notes Due November 1, 2017 (current outstanding balance of
$140,097,199.74),Affirmed Aaa (sf); previously on March 18, 2014
Affirmed Aaa (sf)

$28,000,000 Class A-2 Floating Rate Senior Secured Extendable
Notes Due November 1, 2017, Affirmed Aaa (sf); previously on March
18, 2014 Affirmed Aaa (sf)

$60,500,000 Class B Floating Rate Senior Secured Extendable Notes
Due November 1, 2017, Affirmed Aaa (sf); previously on March 18,
2014 Upgraded to Aaa (sf)

$49,500,000 Class D Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due November 1, 2017 (current
outstanding balance of $28,816,366), Affirmed Ba3 (sf); previously
on March 18, 2014 Affirmed Ba3 (sf)

Gleneagles CLO, Ltd., issued in October 2005, is a collateralized
loan obligation (CLO) backed primarily by a portfolio of senior
secured loans with material exposure to structured finance and
legacy defaulted assets. The transaction's reinvestment period
ended in November 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 date in
March 2014. The Class A-1 notes have been paid down by
approximately 11% or $68.3 million since the last rating action.
Based on the trustee's May 2014 report, the over-collateralization
(OC) ratios for the Class A/B, Class C, and Class D notes are
reported at 143.7%, 117.5%, and 106.5%, respectively, versus March
2014 levels of 135.1%, 115.3%, and 106.5%, respectively.

The portfolio includes a number of investments in securities that
mature after the notes do. Based on the trustee's May 2014 report,
securities that mature after the notes do currently make up
approximately $44.4 million or 12.46% of the portfolio. These
investments, which include some mezzanine and junior CLO notes,
could expose the notes to market risk in the event of liquidation
when the notes mature. Additionally, Moody's also notes that
current portfolio has $70.4 million of defaulted assets, $42.4
million of which have been defaulted for more than 3 years.
Moody's affirmed the rating on the Class D notes (lowest priority
rated debt in the capital structure) owing to the market risk
stemming from the exposure to these long-dated assets as well as
the uncertainty in amount and timing of the recoveries from the
legacy defaulted assets.

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
February 2014.

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.
Additionally, in light of the deal's sizable exposure to legacy
defaulted assets, which increases its sensitivity to the recovery
rate assumptions in the rating analysis, Moody's ran scenarios
using a range of recovery rate assumptions. Realization of higher
or lower than assumed recoveries would have a positive or negative
impact, respectively, on the CLO notes.

6) Long-dated assets: The presence of assets that mature after the
CLO's legal maturity date exposes the deal to liquidation risk on
those assets. This risk is borne first by investors with the
lowest priority in the capital structure. Moody's assumes that the
terminal value of an asset upon liquidation at maturity will 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) or the asset's current market value. In light of the
deal's sizable exposure to long-dated assets, which increases its
sensitivity to the liquidation assumptions in the rating analysis,
Moody's ran scenarios using a range of liquidation value
assumptions. However, actual long-dated asset exposures and
prevailing market prices and conditions at the CLO's maturity will
drive the deal's actual losses, if any, from long-dated assets.

7) 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 relative to the base case
modeling results, which may be different from the current public
ratings of the 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% (2244)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C: +2

Class D: +1

Class 1 Extendable Combination Notes: +2

Moody's Adjusted WARF + 20% (3366)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C: -1

Class D: -1

Class 1 Extendable Combination Notes: -3

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 February 2014.

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 $315.7 million, defaulted
par of $73.1 million, a weighted average default probability of
14.71% (implying a WARF of 2805), a weighted average recovery rate
upon default of 50.13%, a diversity score of 24 and a weighted
average spread of 3.25%.

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. Moody's generally applies
recovery rates for CLO securities as published in "Moody's
Approach to Rating SF CDOs". In some cases, alternative recovery
assumptions may be considered based on the specifics of the
analysis of the CLO transaction. 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 3.2% of the collateral
pool. Additionally, for each credit estimates whose related
exposure constitutes more than 3% of the collateral pool, Moody's
applied a two-notch equivalent assumed downgrade to approximately
3.9% of the pool.


GLENEAGLES CLO: S&P Raises Rating on Class D Notes to 'B+'
----------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, and D notes from Gleneagles CLO Ltd., and removed them from
CreditWatch with positive implications.  S&P also affirmed its
ratings on the class A-1 and A-2 notes from the same transaction.
Gleneagles CLO Ltd. is a U.S. collateralized loan obligation (CLO)
transaction that closed in October 2005 and is managed by Highland
Capital Management L.P.

The transaction ended its reinvestment period in November 2012.
The upgrades reflect the increased credit support following
paydowns of $220.69 million to the class A-1 notes.  These
paydowns have left the class A-1 notes at 22.60% of their original
balances.

According to the May 2014 trustee report, the transaction has
$70.46 million in defaulted obligations, up from the $64.02
million noted in the April 2013 trustee report, which S&P used for
its June 2013 rating actions.

The amount of 'CCC' rated collateral held in the transaction's
asset portfolio dropped since S&P's last rating actions.
According to the May 2014 trustee report, the transaction held
$22.38 million in assets rated in the 'CCC' range, down from the
$33.78 million noted in the April 2013 trustee report.

In addition, the upgrades also reflect an improvement in the
overcollateralization (O/C) available to support all of the notes,
primarily due to the aforementioned paydowns.  The trustee
reported the following O/C ratios in the May 2014 monthly report:

   -- The class B O/C ratio was 143.66%, up from 118.25% in April
      2013.

   -- The class C O/C ratio was 117.46%, up from 108.89% in April
      2013.

   -- The class D O/C ratio was 106.48%, up from 104.23% in April
      2013.

S&P's rating on the class C and D notes are driven by its largest
obligor default test, which intends to address the potential
concentration of exposure to obligors in the transaction's
portfolio.  Based on S&P's review, the top five assets constitute
almost 21% of the total performing portfolio.

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

CASH FLOW RESULTS AND SENSITIVITY ANALYSIS

Gleneagles CLO Ltd.

                              Cash flow
         Previous             implied     Cash flow    Final
Class    rating               rating      cushion(i)   rating
A-1      AAA (sf)             AAA (sf)    33.65%       AAA (sf)
A-2      AAA (sf)             AAA (sf)    33.65%       AAA (sf)
B        AA (sf)/Watch Pos    AAA (sf)    14.06%       AAA (sf)
C        BBB (sf)/Watch Pos   AA- (sf)    1.61%        BBB+ (sf)
D        B- (sf)/Watch Pos    BBB+ (sf)   1.21%        B+ (sf)

(i) The cash flow cushion is the excess of the tranche break-even
     default rate above the scenario default rate at the cash flow
     implied rating for a given class of rated notes.

RECOVERY RATE AND CORRELATION SENSITIVITY

In addition to S&P's base-case analysis, it generated additional
scenarios in which it made negative adjustments of 10% to the
current collateral pool's recovery rates relative to each
tranche's weighted average recovery rate

S&P also generated other scenarios by adjusting the intra- and
inter-industry correlations to assess the current portfolio's
sensitivity to different correlation assumptions assuming the
correlation scenarios outlined below.

RATINGS LIST

Gleneagles CLO Ltd.

                     Rating      Rating
Class   Identifier   To          From
A-1     378663AA6    AAA (sf)    AAA (sf)
A-2     378663AC2    AAA (sf)    AAA (sf)
B       378663AE8    AAA (sf)    AA (sf)/Watch Pos
C       378663AG3    BBB+ (sf)   BBB (sf)/Watch Pos
D       378663AJ7    B+ (sf)     B- (sf)/Watch Pos


GOLUB CAPITAL 10: S&P Affirms 'BB' Rating on Class E Notes
----------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on the
class A, B, C, and D notes from Golub Capital Partners CLO 10
Ltd., a collateralized loan obligation transaction managed by GCI
Operations LLC, after the notes were redeemed in full.  At the
same time, S&P assigned its ratings on the replacement class A-R,
B-R, C-R, and D-R notes.

In addition, S&P affirmed its ratings on the class E and F notes,
which were not refinanced.

The replacement notes were issued via a supplemental indenture.
All of the proceeds from the replacement notes were used to redeem
the original notes as outlined by provisions in the transaction
documents.  The replacement notes were issued at a lower spread
over LIBOR than the originals.

S&P's full cash flow analysis resulted in positive cushions at the
effective date rating for the refinanced notes.

Table 1

Current date after refinancing
Class       Amount  Interest           BDR      SDR   Cushion
          (mil. $)  rate(%)            (%)      (%)       (%)
A-R        197.00   LIBOR plus 1.20   69.55    65.71     3.82
B-R         12.50   LIBOR plus 1.75   73.41    57.70    15.71
C-R         31.75   LIBOR plus 2.95   57.86    51.39     6.46
D-R         16.00   LIBOR plus 3.85   51.31    45.48     5.83
E           15.00   LIBOR plus 5.20   44.34    38.28     6.06
F            9.00   LIBOR plus 5.20   38.67    31.99     6.68

BDR-Break-even default rate.
SDR-Scenario default rate.

Table 2

Effective date
Class       Amount  Interest           BDR      SDR   Cushion
          (mil. $)  rate(%)            (%)      (%)       (%)
A          197.00   LIBOR plus 1.41   69.10    64.99     4.11
B           12.50   LIBOR plus 2.75   74.87    56.76    18.11
C           31.75   LIBOR plus 4.05   59.58    50.41     9.16
D           16.00   LIBOR plus 4.20   53.68    43.98     9.70
E           15.00   LIBOR plus 5.20   46.43    36.55     9.89
F            9.00   LIBOR plus 5.20   43.63    30.19    13.44

BDR-Break-even default rate.
SDR-Scenario default rate.

The supplemental indenture did not make any other substantive
changes to the transaction.

RATINGS WITHDRAWN

Golub Capital Partners CLO 10 Ltd.
Original notes

                        Rating
Class              To           From
A                  NR           AAA (sf)
B                  NR           AA (sf)
C                  NR           A (sf)
D                  NR           BBB (sf)

RATINGS ASSIGNED

Golub Capital Partners CLO 10 Ltd.
Replacement notes

Class              Rating
A-R                AAA (sf)
B-R                AA (sf)
C-R                A (sf)
D-R                BBB (sf)

RATINGS AFFIRMED

Golub Capital Partners CLO 10 Ltd.

Class              Rating
E                  BB (sf)
F                  B (sf)

TRANSACTION INFORMATION

Issuer:               Golub Capital Partners CLO 10 Ltd.
Co-issuer:            Golub Capital Partners CLO 10 LLC
Collateral manager:   GCI Operations LLC
Refinancing arranger: JPMorgan
Trustee:              The Bank of New York Mellon Trust Co.
                      N.A.
Transaction type:     Cash flow CLO


GSC GROUP VIII: Moody's Hikes Rating on $13MM Cl. D Notes to Ba3
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by GSC Group CDO Fund VIII, Limited:

  $267,000,000 Class A-1 Floating Rate Senior Notes Due April 17,
2021 (current outstanding balance of $73,210,955), Upgraded to Aaa
(sf); previously on October 26, 2011 Confirmed at Aa1 (sf)

$14,000,000 Class A-2 Floating Rate Senior Notes Due April 17,
2021, Upgraded to Aaa (sf); previously on October 26, 2011
Upgraded to A1 (sf)

$19,400,000 Class B Deferrable Floating Rate Notes Due April 17,
2021, Upgraded to Aa1 (sf); previously on October 26, 2011
Upgraded to Baa1 (sf)

$17,000,000 Class C Deferrable Floating Rate Notes Due April 17,
2021, Upgraded to Baa3 (sf); previously on October 26, 2011
Upgraded to Ba2 (sf)

$13,000,000 Class D Deferrable Floating Rate Notes Due April 17,
2021 (current outstanding balance of $9,152,596), Upgraded to Ba3
(sf); previously on October 26, 2011 Upgraded to B1 (sf)

GSC Group CDO Fund VIII, Limited, issued in March 2007, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans. The transaction's reinvestment
period ended in April 2014.

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 January 2014. Moody's notes that
during the last two payment dates, the Class A-1 notes have paid
down by approximately 71% or $179.6 million. Based on the
trustee's July 2014 report, the over-collateralization (OC) ratios
for the Class A, Class B, Class C and Class D notes are reported
at 142.00%, 124.58%, 112.49% and 106.91%, respectively, versus
January 2014 levels of 122.09%, 113.82%, 107.44% and 104.29%,
respectively. The July 2014 OC ratios do not reflect the $51.6
million payment made to the Class A-1 notes on the July 17th
payment date.

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
February 2014.

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. Moody's also ran stress scenarios to assess the
collateral pool's concentration risk because loans to obligors it
assesses with credit estimates constitute more than 3% of the
collateral pool.

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 relative to the base case
modeling results, which may be different from the current public
ratings of the 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% (2658)

Class A-1: 0

Class A-2: 0

Class B: +1

Class C: +2

Class D: +1

Moody's Adjusted WARF + 20% (3986)

Class A-1: 0

Class A-2: 0

Class B: -2

Class C: -1

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 February 2014.

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 $138.6 million, defaulted
par of $12.2 million, a weighted average default probability of
18.97% (implying a WARF of 3322), a weighted average recovery rate
upon default of 49.76%, a diversity score of 27 and a weighted
average spread of 4.65%.

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. Moody's generally applies
recovery rates for CLO securities as published in "Moody's
Approach to Rating SF CDOs". In some cases, alternative recovery
assumptions may be considered based on the specifics of the
analysis of the CLO transaction. 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 4.6% of the collateral
pool. Additionally, for each credit estimates whose related
exposure constitutes more than 3% of the collateral pool, Moody's
applied a two-notch equivalent assumed downgrade to approximately
3.6% of the pool.


ICG US CLO 2014-2: Moody's Assigns (P)B3 Rating on $8.5MM Notes
---------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to
eight classes of notes to be issued by ICG US CLO 2014-2, Ltd.:

  $3,000,000 Class X Senior Term Notes due 2026 (the "Class X
  Notes"), Assigned (P)Aaa (sf)

  $247,000,000 Class A Senior Term Notes due 2026 (the "Class A
  Notes"), Assigned (P)Aaa (sf)

  $51,000,000 Class B Senior Term Notes due 2026 (the "Class B
  Notes"), Assigned (P)Aa2 (sf)

  $24,000,000 Class C Deferrable Mezzanine Term Notes due 2026
  (the "Class C Notes"), Assigned (P)A2 (sf)

  $19,000,000 Class D-1 Deferrable Mezzanine Term Notes due 2026
  (the "Class D-1 Notes"), Assigned (P)Baa3 (sf)

  $5,000,000 Class D-2 Deferrable Mezzanine Term Notes due 2026
  (the "Class D-2 Notes"), Assigned (P)Baa3 (sf)

  $22,000,000 Class E Deferrable Junior Term Notes due 2026 (the
  "Class E Notes"), Assigned (P)Ba3 (sf)

  $8,500,000 Class F Deferrable Junior Term Notes due 2026 (the
  "Class F Notes"), Assigned (P)B3 (sf)

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

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

Ratings Rationale

Moody's provisional ratings of the Rated Notes address the
expected losses posed to noteholders. The provisional 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.

ICG US CLO 2014-2 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 second lien loans
and unsecured loans. We expect the portfolio to be approximately
80% ramped as of the closing date.

ICG Debt Advisors 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 will issue 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 February 2014.

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

Par amount: $400,000,000

Diversity Score: 60

Weighted Average Rating Factor (WARF): 2850

Weighted Average Spread (WAS): 3.70%

Weighted Average Coupon (WAC): 7.00%

Weighted Average Recovery Rate (WARR): 47.0%

Weighted Average Life (WAL): 8.1 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
February 2014.

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 2850 to 3278)

Rating Impact in Rating Notches

Class X Notes: 0

Class A Notes: 0

Class B Notes: -2

Class C Notes: -2

Class D-1 Notes: -1

Class D-2 Notes: -1

Class E Notes: 0

Class F Notes: -1

Percentage Change in WARF -- increase of 30% (from 2850 to 3705)

Rating Impact in Rating Notches

Class X Notes: 0

Class A Notes: -1

Class B Notes: -3

Class C Notes: -4

Class D-1 Notes: -2

Class D-2 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.

Moody's has assessed the "Experience of, Arrangements Among and
Oversight of Transaction Parties," a sub-component of Governance
in the V Score analysis, as Medium for this transaction, instead
of Low/Medium for the benchmark CLO. The score of Medium reflects
the fact that this transaction will be the Manager's second U.S.
CLO transaction and that the Manager is a newly-established and
relatively untested manager, although its senior team includes
individuals that have experience in managing CLO transactions.
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.


IMSCI COMMERCIAL 2014-5: Fitch Assigns BB Rating on Class F Notes
-----------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to Institutional Mortgage Securities Canada Inc.'s
(IMSCI) commercial mortgage pass-through certificates, series
2014-5:

   -- $152,282,000 class A-1 'AAAsf'; Outlook Stable;
   -- $119,001,000 class A-2 'AAAsf'; Outlook Stable;
   -- $6,236,000 class B 'AAsf'; Outlook Stable;
   -- $9,355,000 class C 'Asf'; Outlook Stable;
   -- $8,185,000 class D 'BBBsf'; Outlook Stable;
   -- $4,677,000 class E 'BBB-sf'; Outlook Stable;
   -- $3,118,000 class F 'BBsf'; Outlook Stable;
   -- $3,118,000 class G 'Bsf'; Outlook Stable.

All currencies are in Canadian dollars (CAD).

Fitch does not rate the $311,819,832 (notional balance) interest-
only class X or the non-offered $5,847,832 class H certificate.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 41 loans secured by 55 commercial
properties having an aggregate principal balance of approximately
$311.8 million as of the cutoff date.  The loans were originated
or acquired by Institutional Mortgage Capital, LP.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 70.2% of the properties
by balance, cash flow analysis of 100%, and asset summary reviews
on 100% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.16x, a Fitch stressed loan-to-value (LTV) of 98.2%,
and a Fitch debt yield of 9.6%.  Fitch's aggregate net cash flow
represents a variance of 4.2% to issuer cash flows.

KEY RATING DRIVERS

Canadian Loan Attributes and Historical Performance: The ratings
reflect strong historical Canadian commercial real estate loan
performance, including a low delinquency rate and low historical
losses of less than 0.1%, as well as positive loan attributes,
including short amortization schedules and recourse to the
borrower and additional guarantors.

Fitch Leverage: The pool has a Fitch DSCR and LTV of 1.16x and
98.2%, respectively, which represents slightly lower leverage than
the IMSCI 2013-4 deal, which had a Fitch DSCR and LTV of 1.16x and
100.2%, respectively.  The leverage is also slightly lower than
the first quarter 2014 average for U.S. CMBS, which was an LTV of
104.7%.

Amortization: The pool has a weighted average amortization term of
24 years, which represents faster amortization than U.S. conduit
loans.  There are no partial or full interest-only loans.  The
pool's maturity balance represents a paydown of 13.4% of the
closing balance and 16.3% from the original loan balance.

Seasoning and Loan Term: The pool incudes 11 seasoned loans, with
seasoning ranging from 12 to 80 months.  The pool has a weighted
average loan term of 5.3 years, significantly shorter than U.S.
fixed-rate transactions.  Two of the top 10 loans have scheduled
maturity dates within the next two years.

RATING SENSITIVITIES

Fitch performed two model-based break-even analyses to determine
the level of cash flow and value deterioration the pool could
withstand prior to $1 of loss being experienced by the 'BBB-sf'
and 'AAAsf' rated classes.  Fitch found that the IMSCI 2014-5 pool
could withstand a 46.9% decline in value (based on appraised
values at issuance) and an approximately 13% decrease to the most
recent actual cash flow prior to experiencing a $1 of loss to the
'BBB-sf' rated class.  Additionally, Fitch found that the pool
could withstand a 52% decline in value and an approximately 21.3%
decrease in the most recent actual cash flow prior to experiencing
$1 of loss to any 'AAAsf' rated class.

Key Rating Drivers and Rating Sensitivities are further described
in the accompanying transaction report.

The master and special servicer is Midland Loan Services, a
Division of PNC Bank, National Association, rated 'CMS1' and
'CSS1', respectively, by Fitch.


JP MORGAN 2005-LDP5: Fitch Affirms Csf Ratings on 4 Cert. Classes
-----------------------------------------------------------------
Fitch Ratings has affirmed J.P. Morgan Chase Commercial Mortgage
Series Corp. commercial mortgage pass-through certificates series
2005-LDP5.

Key Rating Drivers

The affirmations are the result of stable overall pool performance
since Fitch's last review. Fitch modeled losses of 9.7% for the
remaining pool; expected losses on the original pool balance total
7.6%, including $23 million (0.5% of the original pool balance) in
realized losses to date. Fitch has designated 32 loans (18.5%) as
Fitch Loans of Concern, which includes four specially serviced
assets (6.6%).

As of the July 2014 distribution date, the pool's aggregate
principal balance has been reduced by 27.5% to $3.14 billion from
$4.33 billion at issuance. Thirteen loans (5.2%) are defeased.
Interest shortfalls totaling $16.1 million are currently affecting
classes L through NR.

Rating Sensitivities

Ratings on all investment grade classes are expected to remain
stable and no near-term rating actions are anticipated. Future
downgrades to class G are likely if pool performance deteriorates.
In addition, the distressed classes (rated below 'B') may be
subject to further rating actions as losses are realized.

The largest contributor to expected losses is a loan secured by a
526,245 square foot (sf) Class A corporate headquarters campus
complex located in Las Colinas, Texas (3.1% of the pool). The loan
was transferred to special servicing in March 2012 due to covenant
default as a result of reserve funding shortfalls in the amount of
$1.5 million. The borrower has submitted a loan modification
proposal which is under review by the special servicer. The
property is 100% leased to NEC Corporation of America until March
2016, who in turn subleases the space to various tenants.

The next largest contributor to expected losses is a 706,684 sf
regional enclosed mall located in Hanover, MA (2.7%). The property
became a real estate owned asset (REO) in February 2010 through
foreclosure. Anchor tenants include WalMart, JC Penney and Dick's
Sporting Goods. The servicer reported property occupancy was 97%
as of first quarter (1Q) 2014.

The third largest contributor to expected losses is the Atlantic
Development Portfolio loan (2.7%), which is secured by five office
complexes and two industrial properties located in Somerset and
Warren, NJ. The properties have suffered from reduced revenue due
to lower occupancy as a result of tenants vacating upon or prior
to lease expirations. The servicer reported occupancy as of 1Q
2014 was 73%, compared to 97% at issuance. Servicer reported
second quarter 2013 debt service coverage ratio (DSCR) was 1.0x,
compared to 0.8x at YE2012 and 0.81x at YE2011.

Fitch affirms the following classes as indicated:

-- $97.1 million class A-3 at 'AAAsf'; Outlook Stable;
-- $1.4 billion class A-4 at 'AAAsf'; Outlook Stable;
-- $22.7 million class A-SB at 'AAAsf'; Outlook Stable;
-- $257.3 million class A-1A at 'AAAsf'; Outlook Stable;
-- $419.7 million class A-M at 'AAAsf'; Outlook Stable;
-- $299 million class A-J at 'AAsf'; Outlook to Stable from
    Negative;
-- $26.2 million class B at 'Asf'; Outlook Stable;
-- $73.4 million class C at 'BBBsf'; Outlook Stable;
-- $42 million class D at 'BBB-sf'; Outlook Stable;
-- $21 million class E at 'BBsf'; Outlook Stable;
-- $52.5 million class F at 'Bsf'; Outlook Stable;
-- $36.7 million class G at 'B-sf'; Outlook Negative;
-- $52.5 million class H at 'CCCsf'; RE 95%.
-- $42 million class J at 'CCCsf'; RE 0%;
-- $63 million class K at 'CCsf'; RE 0%.
-- $26.2 million class L at 'CCsf'; RE 0%;
-- $15.7 million class M at 'CCsf'; RE 0%;
-- $15.7 million class N at 'Csf'; RE 0%;
-- $5.2 million class O at 'Csf'; RE 0%;
-- $5.2 million class P at 'Csf'; RE 0%;
-- $10.5 million class Q at 'Csf'; RE 0%.

The class A-1, A-2FL and A-2 certificates have paid in full.

Fitch does not rate the class NR, HG-1, HG-2, HG-3, HG-4 and HG-5
certificates. Fitch previously withdrew the ratings on the
interest-only class X-1 and X-2 certificates.


JP MORGAN 2013-C14: Fitch Affirms 'Bsf' Rating on Class G Certs
---------------------------------------------------------------
Fitch Ratings has affirmed 13 classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust (JPMBB) commercial mortgage
pass-through certificates series 2013-C14.

Key Rating Drivers

The affirmations are the result of stable performance of the
underlying pool since issuance. As of the July 2014 distribution
date, the pool's aggregate principal balance has been reduced by
1.1% to $1.14 billion from $1.15 billion at issuance.  There are
currently no delinquent or specially serviced loans.  Thirty-one
(85% of the pool balance) out of the 45 loans in the pool reported
year end (YE), trailing 12-month (TTM), or partial year 2013 or
2014 financials.

The largest loan in the pool is secured by 308,190 square feet
(sf) of in-line space within the Meadows Mall, a 945,043 sf
regional mall located in Las Vegas NV. The four anchors -
Dillard's, Macy's, J.C. Penney, and Sears - own their
improvements. The largest collateral tenants are Forever 21 (5.5%
of the net rentable area [NRA]), Victoria Secret (3.9% NRA), and
Hollister (2.4% NRA). As of YE December 2013 occupancy reported at
98.7%, and in-line tenant sales reported at $306 per square foot
(psf) compared to $392 psf at YE 2012. The net operating income
(NOI) debt service coverage ratio (DSCR) reported at 1.59x for YE
2013, compared to 1.55x at issuance. The subject A-1 note is parri
passu with a $53.2 million A-2 note that is included in the JPMBB
2014-C18 transaction.

The second largest loan in the pool is secured by the Spirit
Portfolio, which is composed of 26 properties (22 retail, two
office, and two industrial) totaling 1.6 million sf. The
properties are located across 13 states and contain 19 different
tenants. The largest property is the 573,000 sf J. Jill
Distribution Center (36.8% portfolio NRA) located in Tilton, NH.
The portfolio occupancy remains unchanged from issuance at 100%.
The third largest loan in the pool is secured by 589 Fifth Avenue,
a 169,486 sf office building located in midtown Manhattan, NY. The
servicer reported occupancy at 90% as of June 2014, compared to
96.7% at issuance. The office tenants consist entirely of diamond
dealers, while the entire 57,000 sf retail portion of the property
is leased to H&M (33.6% NRA) through July 2033. The YE 2013 NOI
DSCR reported at 1.29x, which only reflects partial year rental
revenue from H&M. H&M's starting rent of approximately $12.7
million per year commenced on July 1, 2013, and increases by
approximately 3% every three years. The subject A-2 note is
interest only, and is parri passu with an identical $87.5 million
A-1 note that is included in the JPMBB 2013-C13 transaction.

Rating Sensitivity

All classes maintain Stable Outlooks. Due to the recent issuance
of the transaction and stable performance, Fitch does not foresee
positive or negative ratings migration until a material economic
or asset level event changes the transaction's portfolio-level
metrics. Additional information on rating sensitivity is available
in the report 'J.P. Morgan Chase Commercial Mortgage Securities
Trust 2013-C14' (May 2, 2014.

Fitch affirms the following classes as indicated:

-- $67.8 million class A-1 at 'AAAsf'; Outlook Stable;
-- $278.3 million class A-2 at 'AAAsf'; Outlook Stable;
-- $75 million class A-3 at 'AAAsf'; Outlook Stable;
-- $288.5 million class A-4 at 'AAAsf'; Outlook Stable;
-- $81.8 million class A-SB at 'AAAsf'; Outlook Stable;
-- $80.4 million class A-S at 'AAAsf'; Outlook Stable;
-- $871.9 million * class X-A at 'AAAsf'; Outlook Stable;
-- $76.1 million class B at 'AA-sf'; Outlook Stable;
-- $45.9 million class C at 'A-sf'; Outlook Stable;
-- $53.1 million class D at 'BBB-sf'; Outlook Stable;
-- $11.5 million class E at 'BBB-sf'; Outlook Stable;
-- $12.9 million class F at 'BB+sf'; Outlook Stable;
-- $23 million class G at 'Bsf'; Outlook Stable.

* Notional amount and interest-only.

Fitch does not rate the class NR or class X-C certificates. The
class X-B certificate was withdrawn from the transaction prior to
closing.


JP MORGAN 2014-C21: Fitch Assigns 'BB' Rating on Class E Notes
--------------------------------------------------------------
Fitch Ratings has assigned the following ratings and Rating
Outlooks to the J.P. Morgan Chase Commercial Mortgage Securities
Trust, Series 2014-C21 commercial mortgage pass-through
certificates.

   -- $35,720,000 class A-1 'AAAsf'; Outlook Stable;
   -- $25,518,000 class A-2 'AAAsf'; Outlook Stable;
   -- $59,360,000 class A-3 'AAAsf'; Outlook Stable;
   -- $325,000,000 class A-4 'AAAsf'; Outlook Stable;
   -- $357,185,000 class A-5 'AAAsf'; Outlook Stable;
   -- $82,529,000 class A-SB 'AAAsf'; Outlook Stable;
   -- $954,872,000a class X-A 'AAAsf'; Outlook Stable;
   -- $90,112,000a class X-B 'AA-sf'; Outlook Stable;
   -- $69,560,000b class A-S 'AAAsf'; Outlook Stable;
   -- $90,112,000b class B 'AA-sf'; Outlook Stable;
   -- $45,846,000b class C 'A-sf'; Outlook Stable;
   -- $205,518,000b class EC 'A-sf'; Outlook Stable;
   -- $25,295,000ac class X-C 'BBsf'; Outlook Stable;
   -- $74,303,000c class D 'BBB-sf'; Outlook Stable;
   -- $25,295,000c class E 'BBsf'; Outlook Stable;
   -- $17,390,000c class F 'Bsf'; Outlook Stable.

(a) Notional amount and interest only.
(b) Class A-S, class B, and class C certificates may be exchanged
    for a related amount of class EC certificates, and class EC
    certificates may be exchanged for class A-S, class B, and
    class C certificates.
(c) Privately placed pursuant to Rule 144A.

Fitch does not rate the $56,912,885 non-rated class, and the
$74,302,885 interest-only class X-D.

The certificates represent the beneficial ownership in the trust,
primary assets of which are 73 loans secured by 84 commercial
properties having an aggregate principal balance of approximately
$1.26 billion as of the cutoff date.  The loans were contributed
to the trust by JPMorgan Chase Bank, National Association;
Barclays Bank PLC; MC-Five Mile Commercial Mortgage Finance LLC;
Starwood Mortgage Funding II LLC; and RAIT Funding, LLC.

Fitch reviewed a comprehensive sample of the transaction's
collateral, including site inspections on 73.6% of the properties
by balance, cash flow analysis on 74.4%, and asset summary reviews
on 74.4% of the pool.

The transaction has a Fitch stressed debt service coverage ratio
(DSCR) of 1.13x, a Fitch stressed loan-to-value (LTV) of 108.5%,
and a Fitch debt yield of 9.47%.  Fitch's aggregate net cash flow
represents a variance of 7.3% to issuer cash flows.

KEY RATING DRIVERS

Fitch Leverage: This transaction has higher leverage than other
recent Fitch-rated fixed-rate deals.  The pool's Fitch LTV of
108.5% is higher than the 2013 average of 101.6%.  Excluding the
credit opinion loan, the pool's Fitch LTV is 110.3%.  The pool's
Fitch DSCR of 1.13x is below the 2013 average of 1.29x, although
reflective of higher average mortgage rates.

Pool Concentration: The pool is diverse by loan size and sponsor
as compared to average transactions from 2013, as evidenced by a
loan concentration index (LCI) of 305 and sponsor concentration
index (SCI) of 391.  Also, the 10 largest loans represent 45.5% of
the total pool balance, which is lower than the average 2013 top
10 concentration of 54.5%.

Below-Average Amortization: Three of the top 10 loans are full-
term interest-only.  As such, the pool has a significantly above-
average proportion of interest-only loans (24.3% of the pool
balance versus the 2013 average of 17.1%) and above-average
concentration of partial interest loans (48.1% versus the 2013
average of 34%).  The pool is scheduled to amortize 9.81% prior to
maturity.

Credit Opinion Loan: The third largest loan in the pool, Miami
International Mall (4.7%), has a Fitch credit opinion 'BBB-sf' on
a stand-alone basis.  The loan is collateralized by a super-
regional mall in Miami, FL.  This loan participation is a $60
million, non-controlling pari passu portion of a $160 million
loan.

RATING SENSITIVITIES

For this transaction, Fitch's net cash flow (NCF) was 6.6% below
the most recent NOI (for properties that a recent 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 JPMBB 2014-C21 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 'A-
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 'BBBsf' could result.

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

Criteria Application

Fitch property-level cash flow analysis, modeling assumptions, and
application of Fitch mortgage constants and cap rates were
generally consistent with Fitch Research on Updates to the
published criteria were applied as:

   -- For non-pari passu full-term IO conduit loans in this
      transaction, the FC-DSCR is weighted 33.3% FT-DSCR and 66.7%
      FK-DSCR. In addition, amortization credit has been increased
      for all amortizing loans. This criteria update is based on
      recent regression testing which demonstrated a more
      significant difference in the performance of amortizing
      versus interest-only loans.

   -- The confidence interval for the 'AAAsf' rating category has
      been increased from 99.990% to 99.995% and the confidence
      interval for the 'AAsf' rating category has been decreased
      from 99.920% to 99.880%.  This criteria update is based on
      an examination of tranche thickness and implied loss
      coverage multiples as they compare to other structured
      finance sectors.


MADISON PARK VIII: S&P Affirms 'BB' Rating on Class E Notes
-----------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on the
class A, B, C, and D notes from Madison Park Funding VIII Ltd., a
collateralized loan obligation transaction managed by Credit
Suisse Asset Management LLC, after the notes were redeemed in
full.  At the same time, S&P assigned ratings to the replacement
class A-R, B-R, C-R, and D-R notes.  In addition, S&P affirmed its
rating on the class E, which the issuer didn't refinance.

The transaction issued the replacement notes via a supplemental
indenture.  It used all of the proceeds to redeem the original
notes as per the provisions in the transaction documents.  The
replacement notes were issued at a lower spread over LIBOR than
the original notes.

S&P's full cash flow analysis resulted in positive cushions at the
effective date rating for the refinanced notes.

Table 1

Current Date After Refinancing
Class       Amount  Interest          BDR      SDR    Cushion
          (Mil. $)  rate(%)           (%)      (%)        (%)
A-R        252.50   LIBOR plus 1.25   67.15    62.67    4.48
B-R         48.50   LIBOR plus 2.20   64.28    55.05    9.23
C-R         27.50   LIBOR plus 2.80   56.58    49.11    7.47
D-R         20.25   LIBOR plus 3.85   50.25    43.29    6.96
E           19.00   LIBOR plus 5.35   40.43    36.47    3.96

Table 2

Effective Date
Class       Amount  Interest          BDR      SDR    Cushion
          (Mil. $)  rate(%)           (%)      (%)        (%)
A          252.50   LIBOR plus 1.42   67.64    63.85    3.79
B           48.50   LIBOR plus 2.70   64.59    56.12    8.47
C           27.50   LIBOR plus 3.50   56.38    50.13    6.25
D           20.25   LIBOR plus 4.35   50.62    44.22    6.39
E           19.00   LIBOR plus 5.35   43.86    37.33    6.54

BDR-Break-even default rate.
SDR-Scenario default rate.

The supplemental indenture did not make any other substantive
changes to the transaction.

RATINGS WITHDRAWN

Madison Park Funding VIII Ltd.

                   Rating       Rating
Class              To           From
A                  NR           AAA (sf)
B                  NR           AA (sf)
C                  NR           A (sf)
D                  NR           BBB (sf)

RATINGS ASSIGNED

Madison Park Funding VIII Ltd.

Class              Rating
A-R                AAA (sf)
B-R                AA (sf)
C-R                A (sf)
D-R                BBB (sf)

RATING AFFIRMED

Madison Park Funding VIII Ltd.

Class              Rating
E                  BB (sf)

TRANSACTION INFORMATION

Issuer:               Madison Park Funding VIII Ltd.
Co-issuer:            Madison Park Funding VIII LLC
Collateral manager:   Credit Suisse Asset Management LLC
Refinancing arranger: Citigroup Global Markets Inc.
Trustee:              Wells Fargo Bank N.A.
Transaction type:     Cash flow CLO


MIDOCEAN CREDIT II: S&P Affirms 'BB' Rating on Class E Notes
------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
MidOcean Credit CLO II/MidOcean Credit CLO II LLC's $372.00
million floating-rate notes following the transaction's effective
date as of June 11, 2014.

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 S&P's criteria to a combination of
purchased collateral, collateral committed to be purchased, and
the indicative portfolio of assets provided to S&P by the
collateral manager, and may also reflect its assumptions about the
transaction's investment guidelines.  This is because not all
assets in the portfolio have been purchased.

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

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

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

RATINGS LIST

MidOcean Credit CLO II/MidOcean Credit CLO II LLC

                           Rating
Class      Identifier      To            From
A          59863KAA5       AAA (sf)      AAA (sf)
B          59863KAC1       AA (sf)       AA (sf)
C          59863KAE7       A (sf)        A (sf)
D          59863KAG2       BBB (sf)      BBB (sf)
E          59802TAA0       BB (sf)       BB (sf)


MIDOCEAN CREDIT III: S&P Assigns 'BB' Rating on Class E Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
MidOcean Credit CLO III/MidOcean Credit CLO III LLC's $473.75
million floating-rate notes.

The note issuance is 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
      income 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.

   -- The transaction's ability to make 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
      0.2272%-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 50% of the excess
      interest proceeds that are available before paying uncapped
      administrative expenses and fees, collateral manager
      subordinated and incentive fees, and income note payments as
      principal proceeds for the purchase of additional collateral
      assets during the reinvestment period.

RATINGS ASSIGNED

MidOcean Credit CLO III/MidOcean Credit CLO III LLC

Class                     Rating                   Amount
A                         AAA (sf)                 312.50
B                         AA (sf)                   62.50
C (deferrable)            A (sf)                    36.25
D (deferrable)            BBB (sf)                  27.50
E (deferrable)            BB (sf)                   23.75
F (deferrable)            B (sf)                    11.25
Income notes              NR                        44.25

NR-Not rated.


MLMS 2005-ACR1: S&P Lowers Rating on 2 Note Classes to CCC
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes from two U.S. residential mortgage-backed securities
(RMBS) resecuritized real estate mortgage investment conduit (re-
REMIC) transactions.  At the same time, Standard & Poor's raised
its rating on one class from another such transaction.  In
addition, Standard & Poor's affirmed its ratings on 25 other
classes from these transactions.

"The three transactions we reviewed were issued between 2004 and
2009 and are supported by underlying RMBS backed by an assortment
of different collateral types, including prime, Alt-A, and
subprime mortgage loans.  Subordination, overcollateralization
(when available), and applicable excess interest generally provide
credit support for the underlying securities of the re-REMIC
transactions. In addition, there is usually subordination within
the capital structures of the re-REMICs themselves," S&P said.

The downgrades were generally due to a deterioration -- including
increased delinquencies -- in the performance of the mortgage pool
supporting the underlying classes.  This increased the projected
loss to the pool and the underlying class.

S&P raised its rating on class 7-A-1 from CSMC Series 2009-2R.
The upgrade reflects S&P's opinion that the projected credit
support for the class will be more than sufficient to cover the
revised projected losses at the higher rating.

"Our ratings on re-REMIC classes consider the timely payment of
interest and ultimate payment of principal.  We reviewed the
interest and principal amounts due on the underlying securities,
which are then passed through to the applicable re-REMIC classes.
We applied our loss projections to the underlying collateral to
identify the magnitude of losses that we believe the underlying
securities could pass through to the applicable re-REMIC classes.
In addition, we stressed our loss projections at various rating
categories to assess whether the re-REMIC classes could continue
to pay the interest and principal due if they were to experience
such losses," S&P added.

The affirmations of the ratings above 'CCC (sf)' reflect S&P's
assessment that these re-REMIC classes will likely receive timely
interest and the ultimate payment of principal under the
applicable stressed assumptions.  The affirmed ratings in the 'CCC
(sf)' and 'CC (sf)' categories reflect S&P's belief that the
projected credit support for these classes will remain
insufficient to cover the base-case projected losses allocable to
the underlying classes, which will then flow to these re-REMIC
classes.

ECONOMIC OUTLOOK

When determining a U.S. RMBS collateral pool's relative credit
quality, S&P's loss expectations stem, to a certain extent, from
its view of how the loans will behave under various economic
conditions.  Standard & Poor's baseline macroeconomic outlook
assumptions for variables that S&P believes could affect
residential mortgage performance are as follows:

   -- A 6.5% unemployment rate for 2014, decreasing to 6.0% for
      2015;

   -- Home prices will increase 6% in 2014, using the 20-city
      Standard & Poor's/Case-Shiller Home Price Index;

   -- Real GDP growth will be 2.3% in 2014 and 3.1% in 2015;

   -- The 30-year mortgage rate will average 4.4% for 2014 and
      increase to 5.0% in 2015; and

   -- The inflation rate will be 1.9% in 2014 and 2.0% in 2015.

S&P's outlook for RMBS is stable.  Although S&P views overall
housing fundamentals positively, it believes RMBS fundamentals
still hinge on additional factors, such as the ultimate fate of
modified loans, the propensity of servicers to advance on
delinquent loans, and liquidation timelines.

Under S&P's baseline economic assumptions, it expects RMBS
collateral quality to improve.  However, if the U.S. economy were
to become stressed in line with Standard & Poor's downside
forecast, it believes that U.S. RMBS credit quality would weaken.
S&P's downside scenario reflects the following key assumptions:

   -- Total unemployment rises to 7.0% in 2014 and then 7.2% in
      2015;

   -- Downward pressure causes a 1.1% GDP growth in 2014, rising
      slightly to 1.2% in 2015;

   -- Home price momentum slows as potential buyers are not able
      to purchase property; and

   -- The 30-year fixed mortgage rate falls slightly to 4.3% in
      2014, but limited access to credit and pressure on home
      prices largely prevents consumers from capitalizing on such
      lower rates.

RATING RAISED

CSMC Series 2009-2R
Series 2009-2R
                               Rating
Class      CUSIP       To                   From
7-A-1      22944FCW7   AA+ (sf)             AA (sf)

RATINGS LOWERED

MLMS 2005-ACR1 Ltd.
Series 2005-ACR1
                               Rating
Class      CUSIP       To                   From
M-1        55311XAA3   BBB+ (sf)            A (sf)
M-2        55311XAB1   CCC (sf)             BBB (sf)
M-3        55311XAC9   CCC (sf)             BB (sf)

Residential Asset Securitization Trust 2004-R1
Series 2004-R1
                               Rating
Class      CUSIP       To                   From
A-4        45660NZA6   BB+ (sf)             BBB+ (sf)

RATINGS AFFIRMED

CSMC Series 2009-2R
Series 2009-2R
Class      CUSIP       Rating
1-A-9      22944FAS8   AAA (sf)
1-A-17     22944FBJ7   AAA (sf)
1-A-10     22944FAU3   AA+ (sf)
1-A-5      22944FAJ8   AAA (sf)
1-A-11     22944FAW9   AAA (sf)
4-A-2      22944FCL1   BBB-p (sf)
1-A-4      22944FAG4   AAA (sf)
1-A-16     22944FBG3   AA+ (sf)
1-A-7      22944FAN9   AAA (sf)
1-A-13     22944FBA6   AAA (sf)
1-A-8      22944FAQ2   AAA (sf)
1-A-3      22944FAE9   AAA (sf)
1-A-2      22944FAC3   AAA (sf)
7-A-2      22944FCY3   CCCp (sf)
1-A-6      22944FAL3   AAA (sf)
4-A-1      22944FCJ6   AAA (sf)
1-A-18     22944FBL2   AA+ (sf)
1-A-15     22944FBE8   AAA (sf)
1-A-12     22944FAY5   AAA (sf)
5-A-1      22944FCN7   AAA (sf)
1-A-14     22944FBC2   AA+ (sf)

MLMS 2005-ACR1 Ltd.
Series 2005-ACR1
Class      CUSIP       Rating
M-4        55311XAD7   CCC (sf)
M-5        55311XAE5   CCC (sf)
M-6        55311XAF2   CC (sf)

Residential Asset Securitization Trust 2004-R1
Series 2004-R1
Class      CUSIP       Rating
A-3        45660NYZ2   BBB+ (sf)


MORGAN STANLEY 2007-IQ13: Fitch Affirms Dsf Rating on Cl. H Certs
-----------------------------------------------------------------
Fitch Ratings has affirmed 18 classes of Morgan Stanley Capital I
Trust (MSC 2007-IQ13) commercial mortgage pass-through
certificates series 2007-IQ13.

Key Rating Drivers

The affirmations reflect sufficient credit enhancement of the
remaining classes relative to Fitch's expected losses. Fitch
modeled losses of 13.6% of the remaining pool; expected losses on
the original pool balance total 14%, including $60 million (3.7%
of the original pool balance) in realized losses to date. Fitch
has designated 36 loans (35.8%) as Fitch Loans of Concern, which
includes 13 specially serviced assets (11.5%).

As of the July 2014 distribution date, the pool's aggregate
principal balance has been reduced by 23.6% to $1.25 billion from
$1.64 billion at issuance. Per the servicer reporting, four loans
(5.1% of the pool) are defeased.

The largest contributor to expected losses is the 75-101 Federal
Street loan (16.8% of the pool), which is secured by two
interconnected, class A office buildings composed of 811,687
square feet (sf) in Boston's financial district. The second
largest tenant EnerNOC (4.7% of NRA) vacated and relocated its
corporate headquarters to the Innovation District in June 2013. As
of June 2014, occupancy for the building was 77%. Due to the
decline in occupancy, cash flow has been insufficient to service
the debt with servicer reported debt service coverage ratio (DSCR)
as of March 2014 at 0.74x. As of May 2014, Reis reported the
Central Business District submarket of Boston vacancy rate at
10.7% and asking rents of $53.18 psf compared to in-place rents of
approximately $38 psf. Although losses were modeled for the loan,
refinance and default risk is mitigated by strong loan structural
features, institutional sponsorship and a central CBD location. As
of July 2014, the loan is current and approximately $1.6 million
remains in tenant reserves.

The next largest contributor to expected losses is a specially-
serviced 1.2 million-sf, outlet mall (6.2%) in Hazelwood, MO, a
suburb of St. Louis. The loan transferred to special servicing in
October 2011 due to the borrower's inability to secure financing
by the loan's maturity date. A deed-in-lieu of foreclosure was
signed in August 2012. As of June 2014, servicer reported
occupancy for the property was 78%. The servicer has made leasing
progress by securing a new lease with Ross Dress for Less in
addition to renewing Books-A-Million and Burlington Coat Factory;
however, the mall continues to face challenges in tenant retention
due to increased competition from two new outlet malls in nearby
Chesterfield, MO. Recent tenants vacating the mall include
Marshall's and Nascar Speedpark representing 9.1% of the NRA
collectively. Approximately 25.9% of leases are scheduled to
expire through the end of 2015.

The third largest contributor to expected losses is a specially
serviced asset (1.6%), secured by a 119,898 sf retail property
located in Ontario, CA. The loan transferred to special servicing
in July 2010 for non-monetary default due to a change in property
management and transfer of ownership without lender consent. The
loan was scheduled for a foreclosure sale prior to the borrower
filing for bankruptcy protection in July 2013. As of January 2014,
occupancy for the property was 87%. The largest tenant, Platt
College, occupies 35% of the property and has a lease expiring in
July 2021, while the second largest tenant, West Coast Ultrasound,
occupies 25% with lease expiration in May 2019.

Rating Sensitivity

Rating Outlooks on classes A-1A through A-4 remain Stable due to
increasing credit enhancement and continued paydown of the
classes. Class A-M, rated 'AAsf', continues to have a Stable
Outlook. Fitch applied additional stresses to the REO ST. Louis
Mills asset given the high concentration of lease expirations
coupled with increased competition in the area. Should property
performance deteriorate, a Negative Rating Outlook or rating
action is possible. The distressed classes (those rated below 'B-
sf') are subject to further downgrades as losses are realized.

Fitch affirms the following classes as indicated:

-- $267.6 million class A-1A at 'AAAsf', Outlook Stable;
-- $41.3 million class A-2 at 'AAAsf', Outlook Stable;
-- $64 million class A-3 at 'AAAsf', Outlook Stable;
-- $448.8 million class A-4 at 'AAAsf', Outlook Stable;
-- $163.9 million class A-M at 'AAsf', Outlook Stable;
-- $149.6 million class A-J at 'CCCsf', RE 70%;
-- $32.8 million class B at 'CCCsf', RE 0%;
-- $16.4 million class C at 'CCsf', RE 0%;
-- $16.4 million class D at 'Csf', RE 0%;
-- $14.3 million class E at 'Csf', RE 0%;
-- $18.4 million class F at 'Csf', RE 0%;
-- $14.3 million class G at 'Csf', RE 0%;
-- $5.6 million 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 O and P certificates. Class A-1 is
paid in full. Fitch previously withdrew the ratings on the
interest-only class X and X-Y certificates.


MORGAN STANLEY 2007-XLC1: Fitch Withdraws CC Rating on F Notes
--------------------------------------------------------------
Fitch Ratings has affirmed two classes of Morgan Stanley 2007-
XLC1, Ltd./Morgan Stanley 2007-XLC1, LLC, (Morgan Stanley 2007-
XLC1).  Fitch also withdraws all ratings due to a lack of investor
interest.

KEY RATING DRIVERS

The CDO has only one asset remaining in the portfolio -- a pari
passu A-note interest, which is considered defaulted by the
trustee.  The loan is secured by approximately 60 acres of land
located in Las Vegas, NV.  The property, which is in the process
of being master planned and rezoned for development, is currently
comprised of improved land with 457 apartments and 615,000 sf of
office/industrial space, and 20 acres of vacant land.  A
substantial loss is modeled on this loan in the base case
scenario.

Since the last rating action, total pay down to the liabilities
has been approximately $103 million primarily from the full
repayment of principal and accrued interest from the Crowne Plaza
Times Square mezzanine loan and the discounted sale of the Kaihuna
Land asset.  Classes B through E have paid in full with a partial
repayment to the now senior class F.

The affirmations at 'CCsf' and 'Csf' for classes F and G,
respectively, are based on a deterministic analysis that considers
Fitch's base case loss expectation for the remaining loan as well
as anticipated recoveries relative to each classes credit
enhancement.

RATING SENSITIVITIES

Morgan Stanley 2007-XLC1 is a static CRE CDO originated in 2007.
Principal proceeds were applied pro-rata to the liabilities until
sequential pay was triggered in November 2008.  The portfolio is
specially serviced by CT Investment Management Co., LLC, an
affiliate of The Blackstone Group.

In July 2014, Fitch was notified that affiliates of the special
servicer now hold all the outstanding notes.  The ratings are
withdrawn as they are no longer considered to be relevant to
Fitch's coverage due to a lack of investor interest.

Fitch affirms and withdraws the following classes as indicated:

   -- $15.9 million class F at 'CCsf'; RE 95%;
   -- $14.3 million class G at 'C'; RE 0%.

Classes A-1 through E have paid in full.


MOUNTAIN CAPITAL V: Moody's Hikes Rating on B-2L Notes to Ba2
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Mountain Capital CLO V, Ltd.:

$19,000,000 Class A-3L Floating Rate Notes Due September 2018,
Upgraded to Aaa (sf); previously on October 9, 2013 Upgraded to
Aa1 (sf);

$11,000,000 Class B-1L Floating Rate Notes Due September 2018,
Upgraded to A1 (sf); previously on October 9, 2013 Upgraded to
Baa1 (sf);

$10,500,000 Class B-2L Floating Rate Notes Due September 2018
(current balance $9,718,389.47), Upgraded to Ba2 (sf); previously
on October 9, 2013 Affirmed Ba3 (sf).

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

$191,000,000 Class A-1L Floating Rate Notes Due September 2018
(current outstanding balance of $23,870,333.06), Affirmed Aaa
(sf); previously on October 9, 2013 Affirmed Aaa (sf);

$30,000,000 Class A-1LA Floating Rate Notes Due September 2018
(current outstanding balance of $1,124,193.67), Affirmed Aaa (sf);
previously on October 9, 2013 Affirmed Aaa (sf);

$3,000,000 Class A-1LB Floating Rate Notes Due September 2018,
Affirmed Aaa (sf); previously on October 9, 2013 Affirmed Aaa
(sf);

$15,000,000 Class A-2L Floating Rate Notes Due September 2018,
Affirmed Aaa (sf); previously on October 9, 2013 Affirmed Aaa
(sf).

Mountain Capital CLO V, Ltd., issued in June 2006, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans. The transaction's reinvestment
period ended in September 2012.

Ratings Rationale

The rating actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's over-
collateralization ratios since September 2013.

The Class A notes have been paid down by approximately 74% or
$72.9 million since September 2013 Based on the trustee's July
2014 report, the over-collateralization (OC) ratios for the senior
Class A, Class A, ClassB-1L, and Class B-2L notes are reported at
212.77% (test limit of 112.0%), 147.56% (limit 106.0%), 125.32%
(limit 105.5%) , and 110.59% (limit 102.25%), respectively, versus
September 2013 levels of 142.24%, 122.21%, 113.00%, and 105.95%,
respectively.

The portfolio includes a number of investments in securities that
mature after the notes do. Based on the trustee's July 2014
report, securities that mature after the notes do currently make
up approximately $4.52 million or 5.51% of the portfolio, compared
to $5.55 million or 3.73% as of August 2013. These investments
could expose the notes to market risk in the event of liquidation
when the notes mature.

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
February 2014.

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) Long-dated assets: The presence of assets that mature after the
CLO's legal maturity date exposes the deal to liquidation risk on
those assets. This risk is borne first by investors with the
lowest priority in the capital structure. Moody's assumes that the
terminal value of an asset upon liquidation at maturity will 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) or the asset's current market value. The deal's
increased exposure owing to amendments to loan agreements
extending maturities continues. Actual long-dated asset exposures
and prevailing market prices and conditions at the CLO's maturity
will drive the deal's actual losses, if any, from long-dated
assets.

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 relative to the base case
modeling results, which may be different from the current public
ratings of the 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% (2076)

Class A-1L: 0

Class A-1LA: 0

Class A-1LB: 0

Class A-2L: 0

Class A-3L: 0

Class B-1L: 2

Class B-2L: 1

Moody's Adjusted WARF + 20% (3114)

Class A-1L: 0

Class A-1LA: 0

Class A-1LB: 0

Class A-2L: 0

Class A-3L: 0

Class B-1L: -2

Class B-2L: -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 February 2014.

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 $87.43 million, defaulted
par of $4.03 million, a weighted average default probability of
15.08% (implying a WARF of 2596), a weighted average recovery rate
upon default of 53.60%, a diversity score of 28 and a weighted
average spread of 2.99%.

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.


NYLIM FLATIRON 2006-1: Moody's Hikes Rating on Cl. D Notes to Ba2
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by NYLIM Flatiron CLO 2006-1, Ltd.:

$19,500,000 Class A-3 Floating Rate Senior Notes Due August 8,
2020, Upgraded to Aaa (sf); previously on July 2, 2013 Upgraded to
Aa1 (sf)

$28,500,000 Class B Deferrable Floating Rate Senior Notes Due
August 8, 2020, Upgraded to Aa1 (sf); previously on July 2, 2013
Upgraded to A1 (sf)

$36,500,000 Class C Deferrable Floating Rate Senior Subordinate
Notes Due August 8, 2020, Upgraded to Baa1 (sf); previously on
July 2, 2013 Affirmed Ba1 (sf)

$17,500,000 Class D Deferrable Floating Rate Subordinate Notes
Due August 8, 2020, Upgraded to Ba2 (sf); previously on July 2,
2013 Affirmed B1 (sf)

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

$301,000,000 Class A-1 Floating Rate Senior Notes Due August 8,
2020 (current outstanding balance of $208,917,951), Affirmed Aaa
(sf); previously on July 2, 2013 Affirmed Aaa (sf)

$150,000,000 Class A-2A Floating Rate Senior Notes Due August 8,
2020 (current outstanding balance of $99,523,129), Affirmed Aaa
(sf); previously on July 2, 2013 Affirmed Aaa (sf)

$15,000,000 Class A-2B Floating Rate Senior Notes Due August 8,
2020, Affirmed Aaa (sf); previously on July 2, 2013 Upgraded to
Aaa (sf)

NYLIM Flatiron CLO 2006-1, Ltd., issued in July 2006, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans. The transaction's reinvestment
period ended in August 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 December 2013. The Class A-1 and A-
2A notes have been paid down by approximately 23.0% or $92.1
million since that time. Based on the trustee's July 2014 report,
the over-collateralization (OC) ratios for the Class A, Class B,
Class C and Class D notes are reported at 131.94%, 121.82%,
110.92% and 106.36%, respectively, versus December 2013 levels of
124.91%, 117.23%, 108.67% and 104.99%, respectively. The credit
quality of the collateral has been stable since December 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
February 2014.

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.

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 relative to the base case
modeling results, which may be different from the current public
ratings of the 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% (1912)

Class A-1: 0

Class A-2A: 0

Class A-2B: 0

Class A-3: 0

Class B: +1

Class C: +2

Class D: +2

Moody's Adjusted WARF + 20% (2868)

Class A-1: 0

Class A-2A: 0

Class A-2B: 0

Class A-3: 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 February 2014.

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 $452.5 million, no defaulted
par, a weighted average default probability of 15.13% (implying a
WARF of 2390), a weighted average recovery rate upon default of
52.41%, a diversity score of 51 and a weighted average spread of
2.89%.

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.


OCTAGON INVESTMENT XI: Moody's Affirms Ba3 Rating on Cl. D Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Octagon Investment Partners XI, Ltd.:

$344,500,000 Class A-1A Senior Secured Floating Rate Notes Due
2021, Upgraded to Aaa (sf); previously on September 20, 2011
Confirmed at Aa1 (sf);

$37,500,000 and EUR 0 Class A-1B Redenominatable Senior Secured
Floating Rate Notes Due 2021 (current outstanding balance of
$38,069,700), Upgraded to Aaa (sf); previously on September 20,
2011 Confirmed at Aa1 (sf);

$22,000,000 Class A-2 Senior Secured Floating Rate Notes Due
2021, Upgraded to Aa1 (sf); previously on September 20, 2011
Confirmed at Aa3 (sf).

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

$31,000,000 Class B Senior Secured Deferrable Floating Rate Notes
Due 2021, Affirmed Baa1 (sf); previously on September 20, 2011
Upgraded to Baa1 (sf);

$19,000,000 Class C Secured Deferrable Floating Rate Notes Due
2021, Affirmed Ba1 (sf); previously on September 20, 2011 Upgraded
to Ba1 (sf);

$16,000,000 Class D Secured Deferrable Floating Rate Notes Due
2021, Affirmed Ba3 (sf); previously on September 20, 2011 Upgraded
to Ba3 (sf).

Octagon Investment Partners XI, Ltd., issued in July 26, 2007, is
a collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans. The transaction's reinvestment
period will end on August 25, 2014.

Ratings Rationale

These rating actions reflect the benefit of the short period of
time remaining before the end of the deal's reinvestment period on
August 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 weighted
average rating factor (WARF) and higher weighted average spread
(WAS) compared to their covenant levels. 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
February 2014.

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.

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 relative to the base case
modeling results, which may be different from the current public
ratings of the 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% (2022)

Class A-1A: 0

Class A-1B: 0

Class A-2: 0

Class B: +3

Class C: +1

Class D: +1

Moody's Adjusted WARF + 20% (3034)

Class A-1A: -1

Class A-1B: -1

Class A-2: -3

Class B: -2

Class C: -1

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 February 2014.

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 $497.1 million, defaulted
par of $1.7 million, a weighted average default probability of
17.2% (implying a WARF of 2528), a weighted average recovery rate
upon default of 46.8%, a diversity score of 60 and a weighted
average spread of 3.4%.

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. Moody's generally applies
recovery rates for CLO securities as published in "Moody's
Approach to Rating SF CDOs." In some cases, alternative recovery
assumptions may be considered based on the specifics of the
analysis of the CLO transaction. In each case, historical and
market performance and the collateral manager's latitude for
trading the collateral are also factors.


ONEMAIN FINANCIAL 2014-2: S&P Assigns Prelim. BB Rating on C Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to OneMain Financial Issuance Trust 2014-2's $1.184
billion asset-backed notes series 2014-2.

The note issuance is an asset-backed securities transaction backed
by personal consumer loan receivables.

The preliminary ratings are based on information as of July 21,
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 54.3%, 46.9%, 41.7%, and
      34.2% credit support to the class A, B, C, and D notes,
      respectively, in the form of subordination,
      overcollateralization, a reserve account, and excess spread.

   -- These credit support levels are sufficient to withstand
      stresses commensurate with the preliminary ratings on the
      notes based on S&P's stressed cash flow scenarios.

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

   -- The timely interest and full principal payments expected to
      be made under stressed cash flow modeling scenarios
      appropriate to the assigned preliminary ratings.

   -- The characteristics of the pool being securitized.

   -- The operational risks associated with OneMain Financial
      Inc.'s decentralized business model.

   -- The transaction's payment and legal structures.

PRELIMINARY RATINGS ASSIGNED

OneMain Financial Issuance Trust 2014-2

Class     Rating       Type            Interest         Amount
                                       rate        (mil. $)(i)
A         A (sf)       Senior          Fixed           875.000
B         BBB (sf)     Subordinate     Fixed           118.430
C         BB (sf)      Subordinate     Fixed            69.080
D         B (sf)       Subordinate     Fixed           121.710

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


PORTOLA CLO: S&P Affirms 'B-' Rating on Class E Notes
-----------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B-1, B-2, C, and D notes from Portola CLO Ltd. and affirmed its
rating on the class E notes.  At the same time, S&P removed the
ratings on the class A, B-1, B-2, C, and D notes from CreditWatch
where it had placed them with positive implications on April 9,
2014.  Portola CLO Ltd. is a collateralized loan obligation
transaction that closed in December 2007 and is managed by Pacific
Investment Management Co. LLC.

The transaction's reinvestment period ended in November 2013.
Since then, the class A notes have paid down nearly $104 million
to reduce their remaining balance to less than 66% of their
original balance.  The upgrades reflect these paydowns to the
class A notes, which provided additional support for the class
B-1, B-2, C, and D notes.  The improvements are also evident in
the increased class A/B, C, D, and E overcollateralization ratios
since S&P's June 2013 rating actions.  The rating on the class C
notes was driven by S&P's largest-obligor default test.  S&P
applied the largest-obligor test to address event and model risks
that might be present in rated transactions.

The affirmation on the class E notes reflects S&P's opinion that
there remains sufficient credit support available to the notes at
the current rating level.

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

CASH FLOW RESULTS AND SENSITIVITY ANALYSIS

Portola CLO Ltd.

                                Cash flow
         Previous               implied     Cash flow   Final
                                            cushion
Class    rating                 rating      (%)(i)      rating
A        AA+(sf)/Watch Pos      AAA (sf)     15.04      AAA (sf)
B-1      AA (sf)/Watch Pos      AA+ (sf)     10.74      AA+ (sf)
B-2      AA (sf)/Watch Pos      AA+ (sf)     10.74      AA+ (sf)
C        A (sf)/Watch Pos       AA- (sf)     1.61       A+ (sf)
D        BBB- (sf)/Watch Pos    BBB+ (sf)    1.62       BBB+ (sf)
E        B- (sf)                CCC+ (sf)    1.43       B- (sf)

(i) The cash flow cushion is the excess of the tranche break-even
     default rate above the scenario default rate at the cash flow
     implied rating for a given class of rated notes.

RECOVERY RATE AND CORRELATION SENSITIVITY

In addition to S&P's base-case analysis, it generated additional
scenarios in which it made negative adjustments of 10% to the
current collateral pool's recovery rates relative to each
tranche's weighted average recovery rate.

S&P also generated other scenarios by adjusting the intra- and
inter-industry correlations to assess the current portfolio's
sensitivity to different correlation assumptions assuming the
correlation scenarios outlined.

RATINGS LIST

Portola CLO Ltd.
                     Rating      Rating
Class   Identifier   To          From
A       73689AAA0    AAA (sf)    AA+ (sf)/Watch Pos
B-1     73689AAC6    AA+ (sf)    AA (sf)/Watch Pos
B-2     73689AAE2    AA+ (sf)    AA (sf)/Watch Pos
C       73689AAG7    A+ (sf)     A (sf)/Watch Pos
D       73689AAJ1    BBB+ (sf)   BBB- (sf)/Watch Pos
E       73689CAA6    B- (sf)     B- (sf)


PREFERRED TERM XVII: Moody's Hikes Rating on Cl. B Notes to B3
--------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of the following notes issued by Preferred Term Securities
XVII:

$58,400,000 Floating Rate Class B Mezzanine Notes due June 23,
2035 (current balance of $61,624,335.24, including interest
shortfall), Upgraded to B3 (sf); previously on October 17, 2013
Affirmed Ca (sf)

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

$62,000,000 Floating Rate Class A-2 Senior Notes due June 23,
2035, Affirmed Baa3 (sf); previously on October 17, 2013 Upgraded
to Baa3 (sf)

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

$270,800,000 Floating Rate Class A-1 Senior Notes due June 23,
2035 (current balance of $189,333,204.98), Confirmed at A3 (sf);
previously on June 26, 2014 A3 (sf) Placed Under Review for
Possible Upgrade

Ratings Rationale

The rating actions are primarily a result of the updates to
Moody's TruPS CDOs methodology described in "Moody's Approach to
Rating TruPS CDOs" published in June 2014, the deleveraging of the
Class A-1 notes, an increase in the transaction's over-
collateralization ratios and resumption of interest payments of
previously deferring assets.

The transaction has benefited from the updates to Moody's TruPS
CDOs methodology described in "Moody's Approach to Rating TruPS
CDOs" published in June 2014. These updates include: (1) removing
the current 25% macro default probability stress for bank and
insurance TruPS; (2) expanding the default timing profiles from
one to six probability-weighted scenarios; (3) incorporating a
redemption profile for bank and insurance TruPS; (4) using a loss
distribution generated by Moody's CDOROM(TM) for deals that do not
permit reinvestment; (5) giving full par credit to deferring bank
TruPS that meet certain criteria; and (6) raising the assumed
recovery rate for insurance TruPS.

In addition, the Class A-1 notes have paid down by approximately
3.1% or $6.1 million since September 2013, using the diversion of
excess interest proceeds. The Class A-1 notes' par coverage has
thus improved to 174.14% from 154.93% since September 2013, by
Moody's calculations. Based on the trustee's June 2014 report, the
over-collateralization ratio of the Class A notes was 128.0%
(limit 128.0%), versus 115.5% on September 2013, the Class B
notes, 103.4% (limit 115.0%), versus 94.6% in September 2013 and
the Class C notes, 84.4% (limit 107.0%), versus 78.2% in September
2013. The Class A-1 notes will continue to benefit from diversion
of excess interest due to the failure of the Mezzanine Principal
Coverage Test. They will also benefit from redemptions proceeds of
any assets in the collateral pool.

Moody's also observed that the Class B will resume receiving its
interest payments due to Class A principal coverage test cure as
of the June 2014 report. The notes will continue to receive their
periodic interest and deferred interest until it is paid in full
unless as long as the Class A principal coverage test is not
failing.

The total par amount that Moody's treated as having defaulted or
deferring declined to $123.0 million from $149.9 million in
September 2013. Since September 2013, two previously deferring
banks with a total par of $18.9 million have resumed making
interest payments on their TruPS.

In taking the foregoing actions, Moody's also announced that it
had concluded its review of its ratings on the issuer's Class A-1
Notes announced on June 26, 2014. At that time, Moody's had placed
the ratings on review for upgrade as a result of the
aforementioned methodology updates.

The key model inputs Moody's used in its analysis, such as par,
weighted average rating factor, and weighted average recovery
rate, are based on its methodology and could differ from the
trustee's reported numbers. In its base case, Moody's analyzed the
underlying collateral pool has having a performing par balance of
$326.8 million, defaulted/deferring par of $123.0 million, a
weighted average default probability of 12.01% (implying a WARF of
1201), and a weighted average recovery rate upon default of 10%.
In addition to the quantitative factors Moody's explicitly models,
qualitative factors are part of rating committee considerations.
Moody's considers the structural protections in the transaction,
the risk of an event of default, recent deal performance under
current market conditions, the legal environment and specific
documentation features. All information available to rating
committees, including macroeconomic forecasts, inputs from other
Moody's analytical groups, market factors, and judgments regarding
the nature and severity of credit stress on the transactions, can
influence the final rating decision.

Methodology Underlying the Rating Action

The principal methodology used in this rating was "Moody's
Approach to Rating TruPS CDOs," published in June 2014.

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:

1) Macroeconomic uncertainty: TruPS CDOs performance could be
negatively affected by uncertainty about credit conditions in the
general economy. Moody's has a stable outlook on the US banking
sectorMoody's maintains its stable outlook on the US insurance
sector.

2) Portfolio credit risk: Credit performance of the assets
collateralizing the transaction that is better than Moody's
current expectations could have a positive impact on the
transaction's performance. Conversely, asset credit performance
weaker than Moody's current expectations could have adverse
consequences on the transaction's performance.

3) Deleveraging: One source of uncertainty in this transaction is
whether deleveraging from unscheduled principal proceeds and
excess interest proceeds will continue and at what pace. Note
repayments that are faster than Moody's current expectations could
have a positive impact on the notes' ratings, beginning with the
notes with the highest payment priority.

4) Resumption of interest payments by deferring assets: A number
of banks have resumed making interest payments on their TruPS. The
timing and amount of deferral cures could have significant
positive impact on the transaction's over-collateralization ratios
and the ratings on the notes.

5) Exposure to non-publicly rated assets: The deal contains a
large number of securities whose default probability Moody's
assesses through credit scores derived using RiskCalc(TM) or
credit estimates. Because these are not public ratings, they are
subject to additional estimation uncertainty.

Loss and Cash Flow Analysis:

Moody's applied a Monte Carlo simulation framework in Moody's
CDOROM(TM) v.2.13.1 to model the loss distribution for TruPS CDOs.
The simulated defaults and recoveries for each of the Monte Carlo
scenarios defined the reference pool's loss distribution. Moody's
then used the loss distribution as an input in its CDOEdge(TM)
cash flow model. CDOROM v. 2.13.1 is available on www.moodys.com
under Products and Solutions -- Analytical models, upon receipt of
a signed free license agreement.

The portfolio of this CDO contains TruPS issued by small to medium
sized U.S. community banks and insurance companies that Moody's
does not rate publicly. To evaluate the credit quality of bank
TruPS that do not have public ratings, Moody's uses RiskCalc, an
econometric model developed by Moody's KMV, to derive credit
scores. Moody's evaluation of the credit risk of most of the bank
obligors in the pool relies on FDIC Q1-2014 financial data. For
insurance TruPS that do not have public ratings, Moody's relies on
the assessment of its Insurance team, based on the credit analysis
of the underlying insurance firms' annual statutory financial
reports.

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 relative to the base case
modeling results, which may be different from the current public
ratings of the 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):

Assuming a two-notch upgrade to assets with below-investment grade
ratings or rating estimates (WARF of 752)

Class A-1: +1

Class A-2: +3

Class B: +2

Class C: 0

Assuming a two-notch downgrade to assets with below-investment
grade ratings or rating estimates (WARF of 1718)

Class A-1: -2

Class A-2: 0

Class B: -2

Class C: 0


ROCKWALL CDO: Moody's Hikes Rating on Cl. B-2L Notes to B1
----------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of the following notes issued by Rockwall CDO Ltd.:

$115,000,000 Class A-1LB Floating Rate Extendable Notes Due 2024
Notes, Upgraded to Aa2 (sf); previously on January 17, 2014
Upgraded to Aa3 (sf);

$76,000,000 Class A-2L Floating Rate Extendable Notes Due 2024
Notes, Upgraded to A3 (sf); previously on January 17, 2014
Upgraded to Baa2 (sf);

$48,000,000 Class A-3L Floating Rate Extendable Notes Due 2024
Notes, Upgraded to Ba1 (sf); previously on January 17, 2014
Upgraded to Ba2 (sf);

$36,000,000 Class B-1L Floating Rate Extendable Notes Due 2024
Notes (current outstanding balance of $28,510,000), Upgraded to
Ba3 (sf); previously on January 17, 2014 Affirmed B1 (sf);

$26,000,000 Class B-2L Floating Rate Extendable Notes Due 2024
Notes (current outstanding balance of $16,838,370.67), Upgraded to
B1 (sf); previously on January 17, 2014 Affirmed B3 (sf);

$10,000,000 Combination Notes due August 2024 Notes (current
rated balance of $7,923,165), Upgraded to Ba3 (sf); previously on
January 17, 2014 Affirmed B1 (sf).

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

$635,000,000 Class A-1LA Floating Rate Extendable Notes Due 2024
Notes (current outstanding balance of $569,614,896.01), Affirmed
Aaa (sf); previously on January 17, 2014 Upgraded to Aaa (sf).

Rockwall CDO II Ltd., issued in May 2007, is a collateralized loan
obligation (CLO) backed primarily by a portfolio of senior secured
loans with significant exposure to CLO tranches. CLO tranches
currently represent 36.1% of the portfolio. The transaction's
reinvestment period will end in August 2014.

Ratings Rationale

These rating actions are primarily a result of an improvement in
the credit quality of the portfolio since January 2014. Based on
Moody's calculation the weighted average rating factor (WARF) is
currently at 2036 compared to 2449 in January 2014. Furthermore,
the transaction's overcollateralization ratios have been
relatively stable since January 2014.

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
February 2014.

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 structured finance assets: The deal has a
significant investment in securities from CLO issuers. The
performance and characteristic of these investments can be notably
different from corporate debt, and may introduce additional risk.
Currently, 36.1% of the deal's portfolio is composed of CLO
tranches.

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 relative to the base case
modeling results, which may be different from the current public
ratings of the 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% (1629)

Class A-1LA: 0

Class A-1LB: +1

Class A-2L: +2

Class A-3L: +2

Class B-1L: +1

Class B-2L: +2

Combination Notes: +1

Moody's Adjusted WARF + 20% (2443)

Class A-1LA: 0

Class A-1LB: -2

Class A-2L: -3

Class A-3L: -2

Class B-1L: -2

Class B-2L: -1

Combination Notes: -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 February 2014.

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 $897.1 million, defaulted
par of $51.4 million, a weighted average default probability of
14.33% (implying a WARF of 2036), a weighted average recovery rate
upon default of 34.73%, a diversity score of 51 and a weighted
average spread of 3.11%.

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. Moody's generally applies
recovery rates for CLO securities as published in "Moody's
Approach to Rating SF CDOs." In some cases, alternative recovery
assumptions may be considered based on the specifics of the
analysis of the CLO transaction. In each case, historical and
market performance and the collateral manager's latitude for
trading the collateral are also factors.


SOLARCITY LMC III: S&P Assigns Prelim. BB Rating on Class B Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to SolarCity LMC Series III LLC's $201.5 million solar
asset-backed series 2014-2 notes.

The note issuance is an asset-backed securities transaction backed
by all rights, title, and interest of the issuer in and to a
portfolio of solar PV systems.

The preliminary ratings are based on information as of July 22,
2014.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

   -- The credit enhancement available in the form of
      overcollateralization and subordination (for the class A
      notes);

   -- The manager's operational and management abilities;

   -- The customer base's initial credit quality underlying the
      master lease;

   -- The projected cash flows supporting the notes; and

   -- The transaction's structure.

PRELIMINARY RATINGS ASSIGNED

SolarCity LMC Series III LLC Series 2014-2

Class       Rating          Amount
                           (mil. $)
A           BBB+ (sf)        160.0
B           BB (sf)           41.5


UNITED AUTO 2014-1: S&P Assigns Prelim. BB Rating on Class E Notes
------------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to United Auto Credit Securitization Trust 2014-1's
$175.66 million notes Series 2014-1.

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

The preliminary ratings are based on information as of July 21,
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 54.7%, 46.9%, 38.4%,
      32.5%, and 24.7% credit support for the class A, B, C, D,
      and E notes, respectively, based on stressed break-even cash
      flow scenarios (including excess spread).

   -- These credit support levels provide coverage of more than
      3.20x, 2.70x, 2.15x, 1.65x, and 1.35x S&P's expected net
      loss range of 16.75%-17.25% for the class A, B, C, D, and E
      notes, respectively.

   -- The likelihood of timely interest and principal payments by
      the assumed legal final maturity dates under stressed cash-
      flow modeling scenarios that are appropriate for the
      assigned preliminary ratings.

   -- S&P's expectation that under a moderate ('BBB') stress
      scenario, the ratings on the class A, B, C, and D notes
      would not decline by more than one rating category.  Under
      this scenario, the preliminary 'BB (sf)' rated class E notes
      would not decline by more than one rating category in the
      first year but would ultimately not pay off in a 'BBB'
      stress scenario, as expected.  These potential rating
      movements are consistent with S&P's credit stability
      criteria, which outline the outer bound of credit
      deterioration as a one-category downgrade within the first
      year for 'AAA' and 'AA' rated securities and a two-category
      downgrade within the first year for 'A' through 'BB' rated
      securities under moderate stress conditions.

   -- The credit enhancement in the form of subordination,
      overcollateralization, a reserve account, and excess spread
      as well as a performance trigger to build
      overcollateralization if net losses exceed designated
      levels.

   -- The collateral characteristics of the subprime pool being
      securitized: It is approximately five months seasoned, with
      a weighted average remaining term of about 35 months.
      Approximately 8.5% of the loans have an original term of 49
      to 60 months, and as a result, S&P expects the pool will pay
      down more quickly than many other subprime pools with longer
      loan terms.

   -- S&P's analysis of five years of static pool data following
      the credit crisis and after United Auto Credit Corp. (UACC)
      centralized its operations and shifted toward shorter loan
      terms.  S&P also reviewed the performance of UACC's two
      outstanding securitizations as well as its seven
      securitizations from 2004 to 2007.

   -- UACC's 18-plus-year history of originating, underwriting,
      and servicing subprime auto loans.

   -- The transaction's payment and legal structures.

PRELIMINARY RATINGS ASSIGNED

United Auto Credit Securitization Trust 2014-1

        Preliminary                Interest       Preliminary
Class   rating       Type          rate       amount (Mil. $) (i)
A-1     A-1+ (sf)    Senior        Fixed               52.300
A-2     AAA (sf)     Senior        Fixed               40.700
B       AA (sf)      Subordinate   Fixed               25.000
C       A (sf)       Subordinate   Fixed               24.000
D       BBB (sf)     Subordinate   Fixed               14.660
E       BB (sf)      Subordinate   Fixed               19.000

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


VALHALLA CLO: S&P Raises Rating on 2 Note Classes to 'B-'
---------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, C-1, and C-2 notes from Valhalla CLO Ltd., and removed its
rating on the class A-2 notes from CreditWatch with positive
implications.  Valhalla CLO Ltd. is a U.S. hybrid collateralized
loan obligation (CLO) transaction managed by Highland Capital
Management L.P. Hybrid CLOs are corporate collateralized debt
obligation (CDO)transactions that combine elements of both cash
flow and synthetic CDOs.

The transaction's portfolio modification period ended in August
2011.  Since then, the reference obligations began to amortize,
reducing the entire $648.0 million retained calculation amount.
Following the complete reduction of the retained amount, the notes
began paying down.  The class A-1 notes previously paid off their
outstanding balance by using interest that was diverted to pay
down the notes to cure previously failing overcollateralization
ratios.  Since S&P's September 2012 rating actions, the class A-2
notes paid down $16.2 million to reduce their outstanding balance
to less than 66% of the original outstanding balance.  The
upgrades reflect improvements in the overcollateralization level
available to the tranches as a result of the amortization of the
reference obligations and note paydowns.

The rating actions on the class B, C-1, and C-2 notes were driven
by the application of the largest obligor test.  S&P applied the
largest-obligor test to address event and model risks that might
be present in rated transactions.  The class C-1 and C-2 notes
failed the largest-obligor default test at the 'B'rating level
category, but the current ratings account for cash flow results
that suggested higher ratings than the previous ones.

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

RATINGS LIST

Valhalla CLO Ltd.
                     Rating
Class   Identifier   To          From
A-2     91914RAB0    AA+ (sf)    A- (sf)/Watch Pos
B       91914RAC8    BBB+ (sf)   BB+ (sf)
C-1     91914RAE4    B- (sf)     CCC- (sf)
C-2     91914RAF1    B- (sf)     CCC- (sf)


VENTURE V CDO: S&P Affirms 'B+' Rating on Class D Notes
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-2, B, and C notes and affirmed its ratings on the class A-1 and
D notes from Venture V CDO Ltd., a collateralized loan obligation
transaction that closed in December 2005 and is managed by MJX
Asset Management LLC.  At the same time, S&P removed the rating on
the class A-2 notes from CreditWatch, where it was placed with
positive implications on April 9, 2014.

The transaction's reinvestment period ended in May 2012.  Since
the Sept. 2013 upgrades to the class A-1, A-2, and B notes
reflecting the class A-1 notes' paydowns, the notes have paid down
an additional $72.8 million and are reduced to less than 17% of
their original balance.  The upgrades reflect these paydowns,
which helped create additional support for the class A-2, B, and C
notes.  The improvements are also evident in the increased class
A, B, C and D par value ratios since S&P's September 2013 rating
actions.

As of the June 10, 2014, trustee report, Venture V CDO Ltd. has
roughly $13.9 million in loans maturing after the transaction's
November 2018 legal final maturity.  Exposure to these long-dated
assets subjects the transaction to potential market value risk, as
the manager may have to liquidate these securities when the
transaction matures in order to pay down the notes on their final
maturity date.  The affirmation of the D notes reflects this
negative risk.

The class D notes were also affected by S&P's largest-obligor
default test, which it applies to address event and model risks
that might be present in rated transactions.  The class D notes
failed the largest-obligor default test at the 'B' rating
category, but the final rating takes into account the cash flow
results that suggested a higher rating.

The affirmation of the class A-1 notes reflects S&P's opinion that
there is still sufficient credit support available to the notes at
the current rating level.

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

RATINGS LIST

Venture V CDO Ltd.

                     Rating      Rating
Class   Identifier   To          From
A-1     92328BAA5    AAA (sf)    AAA (sf)
A-2     92328BAB3    AAA (sf)    AA+ (sf)/Watch Pos
B       92328BAC1    AA+ (sf)    A+ (sf)
C       92328BAD9    BBB+ (sf)   BBB- (sf)
D       92328BAE7    B+ (sf)     B+ (sf)


WACHOVIA BANK 2004-C15: S&P Lowers Rating on Class K Certs to D
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
K commercial mortgage pass-through certificates from Wachovia Bank
Commercial Mortgage Trust's series 2004-C15, a U.S. commercial
mortgage-backed securities (CMBS) transaction, to 'D (sf)' from
'CCC- (sf)'.

"We lowered our rating to 'D (sf)' on the class K certificates
following principal losses detailed in the July 17, 2014, trustee
remittance report.  The principal losses totaling $12.8 million
primarily resulted from the liquidation of the Penn's Purchase II
real estate-owned (REO) asset, which was with the special
servicer, Torchlight Investors LLC.  According to the July 2014
trustee remittance report, the asset liquidated at a loss severity
of 99.9% ($12.79 million in principal losses) of its beginning
trust balance of $12.80 million.  Consequently, class K
experienced a 75.6% loss of its $4.3 million original principal
balance, while subordinate classes L, M, and N lost 100% of their
respective opening balances.  We previously lowered our ratings
on these subordinate classes to 'D (sf)'," S&P said.


WFRBS COMMERCIAL 2013-C15: Fitch Affirms BB Rating on Cl. E Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed 13 classes of WFRBS Commercial Mortgage
Trust (WFRBS) commercial mortgage pass-through certificates series
2013-C15.

KEY RATING DRIVERS

The affirmations are based on the stable performance of the
underlying collateral pool.  The pool has experienced no realized
losses to date.  Fitch has designated one loan (1.8%) as a Fitch
Loan of Concern; this loan transferred to the special servicer in
March of 2014 due to monetary default.

As of the July 2014 distribution date, the pool's aggregate
principal balance has been reduced by 0.7% to $1.1 billion.  No
loans are defeased.  Interest shortfalls are currently affecting
the non- rated class G.

The largest loan of the pool (10.0%) is secured by interest in a
1.1 million square foot (sf) regional mall located in Augusta, GA.
The mall's anchors include Dillard's, Macy's, JC Penney and Sears,
all of which are excluded from the collateral.  As of year-end
(YE) 2013, the servicer-reported collateral occupancy and debt
service coverage ratio (DSCR) was 92.9% and 2.29x, respectively.

The second largest loan (9.4%) is secured by two properties
located in Long Beach, CA and Columbus, OH.  Both properties are
100% leased to Molina Healthcare (lease expires April 2038).
Consolidated DSCR was a reported 2.34x as of YE 2013.

The specially serviced loan is secured by a 612-unit cooperative
residential building located in Astoria, NY.  The asset was
transferred to special servicing in March 2014 due to monetary
default and remains delinquent.  Per the special servicer, legal
counsel has been engaged.  In addition there is on-going
litigation in federal court claiming fraud and breach of fiduciary
duty, among other allegations, on the part of the board of
directors of the cooperative.  The loan is being dual tracked for
payoff or foreclosure.  In its analysis of the transaction, Fitch
considered the loan's low leverage and will continue to monitor
the status.

RATING SENSITIVITY

The Rating Outlook for all classes remains Stable.  Due to the
recent issuance of the transaction and stable performance, Fitch
does not foresee positive or negative ratings migration until a
material economic or asset- level event changes the transaction's
portfolio-level metrics.

Fitch affirms the following classes as indicated:

   -- $52.6 million class A-1 at 'AAAsf', Outlook Stable;
   -- $48.1 million class A-2 at 'AAAsf', Outlook Stable;
   -- $260 million class A-3 at 'AAAsf', Outlook Stable;
   -- $301.8 million class A-4 at 'AAAsf', Outlook Stable;
   -- $104.8 million class A-SB at 'AAAsf', Outlook Stable;
   -- $80.3 million class A-S*at 'AAAsf', Outlook Stable;
   -- $846.8 million class X-A** at 'AAAsf', Outlook Stable;
   -- $74.7 million class B* at 'AA-sf', Outlook Stable;
   -- $42.9 million class C* at 'A-sf', Outlook Stable;
   -- $62.3 million class D at 'BBB-sf', Outlook Stable;
   -- $22.1 million class E at 'BBsf', Outlook Stable;
   -- $11.1 million class F at 'Bsf', Outlook Stable.
   -- $197.9 million class PEX* at 'A-sf', Outlook Stable.

* The class A-S, class B and class C certificates may be
    exchanged for class PEX certificates, and class PEX
    certificates may be exchanged for the class A-S, class B and
    class C certificates.
** Notional amount and interest only.

Fitch does not rate the class G certificates.


* Moody's Takes Action on $277MM of RMBS by Various Trusts
----------------------------------------------------------
Moody's Investors Service, on July 21, 2014, upgraded the ratings
of 10 tranches from seven transactions and downgraded the ratings
of one tranche from one transactions backed by Subprime mortgage
loans.

Complete rating actions are as follows:

Issuer: ACE Securities Corp. Home Equity Loan Trust, Series 2005-
HE1

Cl. M-5, Upgraded to Caa3 (sf); previously on Mar 6, 2013 Affirmed
C (sf)

Issuer: Citigroup Mortgage Loan Trust 2006-NC1

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

Issuer: Fremont Home Loan Trust 2006-1

Cl. I-A-1, Upgraded to Ba2 (sf); previously on Apr 29, 2010
Downgraded to B1 (sf)

Issuer: HSI Asset Securitization Corporation Trust 2006-NC1

Cl. I-A, Upgraded to B2 (sf); previously on Aug 13, 2010
Downgraded to B3 (sf)

Issuer: HSI Asset Securitization Corporation Trust 2007-HE2

Cl. II-A-1, Downgraded to Caa2 (sf); previously on Aug 13, 2010
Downgraded to B3 (sf)

Issuer: IndyMac Home Equity Mortgage Loan Asset-Backed Trust,
INABS 2006-C

Cl. 1A, Upgraded to Caa1 (sf); previously on Sep 15, 2010
Downgraded to Caa3 (sf)

Cl. 2A, Upgraded to Caa2 (sf); previously on Sep 15, 2010
Downgraded to Caa3 (sf)

Issuer: People's Choice Home Loan Securities Trust 2005-2

Cl. M3, Upgraded to B1 (sf); previously on Sep 26, 2013 Upgraded
to B3 (sf)

Cl. M4, Upgraded to Ca (sf); previously on Mar 4, 2013 Affirmed C
(sf)

Issuer: Popular ABS Mortgage Pass-Through Trust 2005-D

Cl. A-4, Upgraded to Baa3 (sf); previously on Oct 12, 2012
Downgraded to Ba1 (sf)

Cl. A-5, Upgraded to Ba3 (sf); previously on Jul 21, 2010
Downgraded to B2 (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 a result of improving performance of
the related pools and/or faster pay-down of the bonds due to high
prepayments/faster liquidations. The downgrades are a result of
deteriorating performance and/or structural features resulting in
higher expected losses for the bonds than previously anticipated.

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 6.1% in June 2014 from 7.5% in
June 2013. 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 Takes Action on $265-Mil. of RMBS by Various Issuers
--------------------------------------------------------------
Moody's Investors Service, on July 21, 2014, upgraded the ratings
of 14 tranches from 11 transactions and downgraded the ratings of
8 tranches from 3 transactions issued by various issuers, backed
by Subprime mortgage loans.

Complete rating actions are as follows:

Issuer: ABFS Mortgage Loan Trust 2001-1

Cl. A-1, Underlying Rating: Downgraded to Ca (sf); previously on
Sep 12, 2013 Confirmed at Caa3 (sf)

Financial Guarantor: MBIA Insurance Corporation (Upgraded to B2,
Outlook Stable on May 21, 2014)

Issuer: ABFS Mortgage Loan Trust 2001-4, Mortgage-Backed Notes,
Series 2001-4

Cl. A, Underlying Rating: Downgraded to Ca (sf); previously on Sep
12, 2013 Confirmed at Caa3 (sf)

Financial Guarantor: MBIA Insurance Corporation (Upgraded to B2,
Outlook Stable on May 21, 2014)

Issuer: Bear Stearns ABS Trust Certificates, Series 2001-3

Cl. M-1, Upgraded to B1 (sf); previously on Mar 11, 2011
Downgraded to B3 (sf)

Issuer: Bear Stearns Asset Backed Securities I Trust 2004-HE11

Cl. M-2, Upgraded to Ba3 (sf); previously on Mar 5, 2013 Affirmed
B1 (sf)

Issuer: Bear Stearns Asset Backed Securities, Inc., Series 2000-2

Cl. B, Upgraded to Caa1 (sf); previously on Apr 9, 2012 Downgraded
to Caa3 (sf)

Issuer: C-BASS 2003-CB6 Trust

Cl. M-1, Upgraded to Ba2 (sf); previously on Mar 10, 2011
Downgraded to Ba3 (sf)

Issuer: RAMP Series 2003-RZ3 Trust

Cl. M-2, Upgraded to Caa1 (sf); previously on Mar 30, 2011
Downgraded to Caa3 (sf)

Issuer: RAMP Series 2004-RS11 Trust

Cl. M-2, Upgraded to Ba2 (sf); previously on Sep 3, 2013 Upgraded
to B2 (sf)

Cl. M-3, Upgraded to Caa1 (sf); previously on Mar 30, 2011
Downgraded to Ca (sf)

Issuer: RAMP Series 2004-RS9 Trust

Cl. M-II-1, Upgraded to Ba1 (sf); previously on Sep 3, 2013
Upgraded to Ba2 (sf)

Issuer: RASC Series 2003-KS6 Trust

Cl. A-I, Upgraded to B2 (sf); previously on Apr 9, 2012 Confirmed
at Caa1 (sf)

Cl. A-II, Upgraded to B2 (sf); previously on Apr 9, 2012 Confirmed
at Caa1 (sf)

Issuer: RASC Series 2004-KS10 Trust

Cl. M-1, Upgraded to Ba3 (sf); previously on Apr 9, 2012 Upgraded
to B3 (sf)

Cl. M-2, Upgraded to Caa2 (sf); previously on Apr 9, 2012
Downgraded to C (sf)

Issuer: C-BASS Mortgage Loan Asset-Backed Certificates, Series
2004-CB6

Cl. AF-3, Downgraded to A1 (sf); previously on May 4, 2012
Downgraded to Aa2 (sf)

Underlying Rating: Downgraded to A1 (sf); previously on May 4,
2012 Downgraded to Aa2 (sf)

Financial Guarantor: Syncora Guarantee Inc. (Insured Rating
Withdrawn Nov 08, 2012)

Cl. AF-4, Downgraded to Aa3 (sf); previously on Mar 10, 2011
Downgraded to Aa1 (sf)

Cl. B-2, Downgraded to C (sf); previously on Mar 10, 2011
Downgraded to Ca (sf)

Cl. B-3, Downgraded to C (sf); previously on Mar 10, 2011
Downgraded to Ca (sf)

Cl. B-4, Downgraded to C (sf); previously on Mar 10, 2011
Downgraded to Ca (sf)

Issuer: RASC Series 2004-KS8 Trust

Cl. M-II-1, Upgraded to Caa1 (sf); previously on Mar 30, 2011
Downgraded to Caa3 (sf)

Issuer: Structured Asset Securities Corp 2003-BC2

Cl. M-3, Upgraded to B2 (sf); previously on Dec 4, 2012 Upgraded
to Caa1 (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 a result of improving performance of
the related pools and/or faster pay-down of the bonds due to high
prepayments/faster liquidations.  The downgrades are a result of
structural features resulting in higher expected losses for the
bonds than previously anticipated. For the transaction C-BASS
Mortgage Loan Asset-Backed Certificates, Series 2004-CB6, the
downgrades on Cl. AF-3 and Cl. AF-4 are prompted by a decline in
the credit enhancement available to these bonds as the deal
continues to pass performance triggers.

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 6.1% in June 2014 from 7.5% in
June 2013. 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 Takes Action on $71MM Subprime RMBS Issued 2001 to 2004
-----------------------------------------------------------------
Moody's Investors Service, on July 22, 2014, upgraded the ratings
of seven tranches and downgraded the rating of one tranche from
five subprime RMBS transactions backed by Subprime mortgage loans.

Complete rating action is as follows:

Issuer: Argent Securities Inc., Series 2004-W9

Cl. M-2, Upgraded to B3 (sf); previously on Mar 18, 2011
Downgraded to Caa2 (sf)

Cl. M-3, Upgraded to Caa3 (sf); previously on Apr 13, 2012
Downgraded to C (sf)

Issuer: CWABS, Inc. Asset-Backed Certificates, Series 2001-BC3

Cl. M-2, Downgraded to C (sf); previously on Mar 17, 2011
Confirmed at Ca (sf)

Issuer: First Franklin Mortgage Loan Trust 2004-FF2

Cl. M-2, Upgraded to B1 (sf); previously on Dec 4, 2012 Upgraded
to B3 (sf)

Cl. M-3, Upgraded to Caa1 (sf); previously on Dec 4, 2012 Upgraded
to Caa3 (sf)

Cl. M-4, Upgraded to Caa3 (sf); previously on Mar 15, 2011
Downgraded to C (sf)

Issuer: First Franklin Mortgage Loan Trust 2004-FF3

Cl. M-1, Upgraded to B1 (sf); previously on Mar 15, 2011
Downgraded to B3 (sf)

Issuer: Ameriquest Mortgage Securities Inc., Series 2002-AR1

Cl. M-1, Upgraded to B2 (sf); previously on May 4, 2012 Confirmed
at Caa1 (sf)

Ratings Rationale

The rating actions reflect recent performance of the underlying
pools and Moody's updated loss expectations on the pools. The
upgrade actions are a result of improving performance of the
related pools and/or improving credit enhancement on the bonds due
to continued availability of spread and failure of performance
triggers. The downgrade action reflect the updated loss
projections.

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 6.1% in June 2014 from 7.5% in
June 2013. 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 Lowers Ratings on $32MM of RMBS by Bayview & RAMP
-----------------------------------------------------------
Moody's Investors Service has downgraded the ratings of five
tranches issued by two RMBS transactions. The collateral backing
these deals primarily consists of first lien, fixed and adjustable
rate "scratch and dent" residential mortgages.

Complete rating actions are as follows:

Issuer: Bayview Financial Mortgage Pass-Through Trust 2006-C

Cl. 1-A2, Downgraded to Ba1 (sf); previously on Sep 23, 2013
Downgraded to Baa2 (sf)

Cl. 1-A3, Downgraded to Caa2 (sf); previously on Sep 23, 2013
Downgraded to B3 (sf)

Issuer: RAMP Series 2004-SL1 Trust

Cl. M-I-3, Downgraded to Ba1 (sf); previously on Jul 17, 2012
Downgraded to Baa3 (sf)

Cl. M-I-4, Downgraded to Ba3 (sf); previously on Jul 17, 2012
Downgraded to Ba1 (sf)

Cl. M-I-5, Downgraded to B2 (sf); previously on Jul 17, 2012
Downgraded to B1 (sf)

Ratings Rationale

The ratings are a result of the recent performance of the
underlying pools and reflect Moody's updated loss expectations on
the pools. In Bayview Financial Mortgage Pass-Through Trust 2006-
C, the ratings were downgraded as a result of the expected credit
support depletion, where interest shortfall can occur due to the
under-collateralization of the senior bonds. In RAMP Series 2004-
SL1 Trust, the ratings were downgraded as a result of the level of
credit enhancement available to the bonds relative to the loss
expectation.

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 6.1% in June 2014 from 7.5% in
June 2013. 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.


                             *********

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
publication in any form (including e-mail forwarding, electronic
re-mailing and photocopying) is strictly prohibited without prior
written permission of the publishers.  Information contained
herein is obtained from sources believed to be reliable, but is
not guaranteed.

The TCR subscription rate is $975 for 6 months delivered via
e-mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Peter A.
Chapman at 215-945-7000 or Nina Novak at 202-241-8200.


                  *** End of Transmission ***