TCR_Public/141026.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, October 26, 2014, Vol. 18, No. 298

                            Headlines

A10 TERM ASSET: DBRS Confirms 'B(sf)' Rating on Class F Certs
ABACUS 2006-10: S&P Lowers Rating on 3 Note Classes to D
ADVANTA BUSINESS 2006-C1: S&P Lowers Class C Notes Rating to Dsf
ANTHRACITE CDO III: S&P Lowers Rating on 5 Notes Classes to D
APIDOS CLO XIX: Moody's Assigns (P)B3 Rating on Class F Notes

ATLAS SENIOR V: S&P Affirms 'BB-' Rating on Class E Notes
BATTALION CLO VI: Moody's Assigns B3 Rating on $3.9MM Cl. E Notes
CAMBER MASTER: S&P Raises Rating on Series 7 & 8 Notes to BB-
CARLYLE MCLAREN: S&P Raises Rating on Class B-2L Notes to B-
COMM 2014-CCRE20: DBRS Rates Class E Certificates '(P)BB'

CREDIT SUISSE 2004-CF2: S&P Raises Rating on II-M-1 Notes to BB-
CREDIT SUISSE 2007-TFL2: Moody's Cuts Rating on 2 Notes to C
EMPORIA PREFERRED III: Moody's Affirms B1 Rating on Cl. E Notes
EXETER AUTOMOBILE 2014-3: DBRS Finalizes BB Rating on Cl. D Debt
FLAGSHIP CREDIT 2014-2: S&P Assigns BB- Rating on Class E Notes

GOLDEN KNIGHT II: S&P Affirms B+ Rating on Class E Notes
HALCYON LOAN II: S&P Affirms BB Rating on Class D Notes
HARBOURVIEW CLO VII: Moody's Rates $22.5MM Class E Notes '(P)Ba3'
HARCH CLO II: Moody's Raises Rating on $10MM Cl. E Notes to Caa1
HARCH CLO III: Moody's Affirms Ba3 Rating on $15MM Class E Notes

HULL STREET: S&P Assigns Preliminary B Rating on Class F Notes
INWOOD PARK: Moody's Affirms Ba2 Rating on $50MM Class E Notes
KVK CLO 2014-2: S&P Affirms 'BB' Rating on Class E Notes
JP MORGAN 1997-C5: Moody's Affirms Caa3 Rating on Class X Notes
MADISON AVENUE 2013-650M: DBRS Confirms 'BB' Rating on Cl. E Certs

MOMENTUM CAPITAL: Moody's Hikes Rating on Class E Notes to Ba2
MORGAN STANLEY 2004-TOP15: S&P Lowers Class K Certs' Rating to D
MSBAM 2013-C12: Moody's Affirms B1 Rating on Class F Certificate
N-STAR REL CDO IV: S&P Raises Rating on Class C Notes to BB-
NANTUCKET CLO I: Moody's Raises Rating on $12.6MM Notes to Ba2

NAVIGATOR CDO 2006: Moody's Hikes $12.5MM D Notes Rating to Ba1
NCF DEALER 2014-1: DBRS Rates Class D Notes '(P)BB'
RAIT 2014-FL3: DBRS Rates Class X-1 Notes '(P)BB'
WACHOVIA BANK 2003-C7: Moody's Affirms C Rating on Cl. H Certs
WATERFRONT CLO 2007-1: Moody's Rates $11.5MM Cl. C Notes 'Ba1'

WFRBS COMMERCIAL 2013-C17: Fitch Affirms 'BBsf' Rating on E Notes

* Moody's Hikes Rating on $84MM of RMBS Issued 2003-2004
* Moody's Takes Action on $848MM Alt-A RMBS Issued 2005-2007
* S&P Takes Actions on 11 BlackRock Fund Exchange-Traded Funds


                             *********

A10 TERM ASSET: DBRS Confirms 'B(sf)' Rating on Class F Certs
-------------------------------------------------------------
DBRS Inc. has confirmed the following Commercial Mortgage Pass-
Through Certificates, Series 2013-2 issued by A10 Term Asset
Financing 2013-2, LLC.  The trends are Stable.

-- Class A at AAA (sf)
-- Class B at A (sf)
-- Class C at BBB (sf)
-- Class D at BBB (low) (sf)
-- Class E at BB (sf)
-- Class F at B (sf)

The ratings confirmations reflect the continued performance of the
pool since issuance in November 2013.  The current pool consists
of 23 loans secured by traditional commercial real estate assets,
including office, multifamily, retail and industrial properties.
According to the September 2014 remittance, there has been
collateral reduction of less than 1.0%.  The loans benefit from
low leverage on a per-unit basis, with the weighted-average debt
yield based on the most recently reported net operating income and
outstanding trust balance at 11.2%, which is relatively strong,
given the pool consists of stabilizing assets.

All of the collateral loans were originated by A10 Capital, LLC
(A10).  A10 specializes in mini-perm loans, which typically have
two- to five-year terms and are used to finance properties until
they are fully stabilized.  The borrowers are typically new equity
sponsors of fairly well-positioned assets within their respective
markets.  A10's initial advance is the senior debt component
typically used for the purchase of a real estate-owned acquisition
or discounted payoff loans.  Most loans are structured with three-
year terms and include built-in extensions and future funding
facilities meant to aid in property stabilization, both of which
are at the lender's sole discretion.  Five loans, totaling $6.2
million, have repaid since issuance, with proceeds being used to
fund the reserve account, which may be used to provide future
funding to individual borrowers.  The reserve account has a
current balance of $13.5 million against total potential future
funding obligations of $27.3 million.  Once the reserve account
reaches 75% of the outstanding future funding obligation total,
loan repayment proceeds will be used to pay down the outstanding
bonds sequentially.  According to the most recent reporting, a
majority of the collateral assets in the subject pool have not yet
reached stabilization.

The transaction is concentrated, as the largest loan, which
consists of a portfolio of 19 cross-collateralized properties,
represents 25.2% of the current pool balance based on the
individual properties' fully funded loan amounts.  The largest
five and ten loans represent 53.5% and 73.5% of the current pool
balance based on their fully funded loan amounts, respectively.
None of the loans in the pool has an initial maturity date prior
to April 1, 2016, and one loan, representing 3.6% of the current
pool balance, has completely drawn down its future funding
facility.  An additional three loans, representing 4.7% of the
fully funded pool balance, did not receive future funding
components with their respective financings.

The ratings assigned by DBRS contemplate timely payments of
distributable interest and, in the case of the Offered Notes other
than the Class A Notes, ultimate recovery of Deferred
Collateralized Note Interest Amounts (inclusive of interest
payable thereon at the applicable rate, to the extent permitted by
law).  The transaction is a standard sequential pay waterfall.


ABACUS 2006-10: S&P Lowers Rating on 3 Note Classes to D
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D (sf)'
on three classes from Abacus 2006-10 Ltd., a U.S. synthetic
collateralized debt obligation (CDO) transaction backed by
commercial mortgage-backed securities (CMBS).  At the same time,
S&P withdrew its ratings on three classes from  Claris Ltd.'s
series 92-2007, series 93-2007, and series 94-2007, all of which
are synthetic CDO of CMBS transactions.

The lowered ratings follow principal losses incurred on the notes
according to the note valuation reports.

The withdrawals follow notices that all the remaining notes in the
transactions have been terminated and redeemed.

RATINGS LOWERED

Abacus 2006-10 Ltd.
                Rating
Class       To          From
J           D (sf)      CC (sf)
K           D (sf)      CC (sf)
L           D (sf)      CC (sf)

RATINGS WITHDRAWN

Claris Ltd.
US$2.5 bil Sonoma Valley 2007-1 Synthetic CDO of CMBS Variable
Notes due 2049
series 92/2007
                  Rating
Class        To           From
Trnch 1      NR           B+ (sf)

Claris Ltd.
US$2.5 bil Sonoma Valley 2007-1Synthetic CDO of CMBS Variable
Notes due 2049
series 93/2007
                  Rating
Class        To           From
Trnch 1      NR           B+ (sf)

Claris Ltd.
US$2.5 bil Sonoma Valley 2007-1 Synthetic CDO of CMBS Variable
Notes due 2049
series 94/2007
                  Rating
Class        To           From
Trnch 1      NR           B+ (sf)

NR--Not rated.



ADVANTA BUSINESS 2006-C1: S&P Lowers Class C Notes Rating to Dsf
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
C (2006-C1) notes from Advanta Business Card Master Trust to 'D
(sf)' from 'CC (sf)'.

The downgrade reflects the nonpayment of full principal to the
investors of the class C(2006-C1) notes on the Oct. 20, 2014,
legal final maturity date.  This left the full initial principal
amount of $140,000,000 outstanding or unpaid on that date.


ANTHRACITE CDO III: S&P Lowers Rating on 5 Notes Classes to D
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on seven
classes from Anthracite CDO III Ltd. and three classes from Sorin
Real Estate CDO I Ltd.; both transactions are U.S. cash flow
collateralized debt obligations backed by commercial mortgage-
backed securities.

S&P downgraded these tranches because they continue to defer
interest as a result of failing overcollateralization tests and
have little prospect of receiving their full principal payment.

RATINGS LOWERED

Anthracite CDO III Ltd.
                Rating
Class       To          From
DFL         CC (sf)     CCC- (sf)
DFX         CC (sf)     CCC- (sf)
EFL         D (sf)      CC (sf)
EFX         D (sf)      CC (sf)
F           D (sf)      CC (sf)
G           D (sf)      CC (sf)
H           D (sf)      CC (sf)

Sorin Real Estate CDO I Ltd.
                Rating
Class       To          From
D           D (sf)      CC (sf)
E           D (sf)      CC (sf)
F           D (sf)      CC (sf)


APIDOS CLO XIX: Moody's Assigns (P)B3 Rating on Class F Notes
-------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to
seven classes of notes to be issued by Apidos CLO XIX (the
"Issuer" or "Apidos XIX").

Moody's rating action is as follows:

$270,000,000 Class A-1 Senior Secured Floating Rate Notes due
2026 (the "Class A-1 Notes"), Assigned (P)Aaa (sf)

$50,000,000 Class A-2 Senior Secured Floating Rate Notes due 2026
(the "Class A-2 Notes"), Assigned (P)Aaa (sf)

$53,250,000 Class B Senior Secured Floating Rate Notes due 2026
(the "Class B Notes"), Assigned (P)Aa2 (sf)

$33,000,000 Class C Mezzanine Deferrable Floating Rate Notes due
2026 (the "Class C Notes"), Assigned (P)A2 (sf)

$29,500,000 Class D Mezzanine Deferrable Floating Rate Notes due
2026 (the "Class D Notes"), Assigned (P)Baa3 (sf)

$25,500,000 Class E Junior Deferrable Floating Rate Notes due
2026 (the "Class E Notes"), Assigned (P)Ba3 (sf)

$7,500,000 Class F Junior Deferrable Floating Rate Notes due 2026
(the "Class F Notes"), Assigned (P)B3 (sf)

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

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.

Apidos XIX 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. Moody's expect the portfolio to be
approximately 85% ramped as of the closing date.

CVC Credit Partners, 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: $500,000,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2701

Weighted Average Spread (WAS): 3.65%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 46.9%

Weighted Average Life (WAL): 8 years

Methodology Underlying the Rating Action

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
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 2701 to 3106)

Rating Impact in Rating Notches

Class A-1 Notes: 0

Class A-2 Notes: 0

Class B Notes: -1

Class C Notes: -2

Class D Notes: -1

Class E Notes: -1

Class F Notes: -1

Percentage Change in WARF -- increase of 30% (from 2701 to 3511)

Rating Impact in Rating Notches

Class A-1 Notes: -1

Class A-2 Notes: -1

Class B Notes: -3

Class C Notes: -4

Class D Notes: -2

Class E Notes: -1

Class F Notes: -4

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 V Score provides 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. The V Score applies to the entire
transaction, rather than individual tranches.


ATLAS SENIOR V: S&P Affirms 'BB-' Rating on Class E Notes
---------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on Atlas
Senior Loan Fund V Ltd./Atlas Senior Loan Fund V LLC's $511.00
million floating-rate notes following the transaction's effective
date as of Aug. 21, 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 S&P's opinion that
the portfolio collateral purchased by the issuer, as reported to
S&P by the trustee and collateral manager, in combination with the
transaction's structure, provides sufficient credit support to
maintain the ratings that S&P assigned on the transaction's
closing date.  The effective date reports provide a summary of
certain information that S&P used in its analysis and the results
of S&P's review based on the information presented to S&P.

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

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

Atlas Senior Loan Fund V Ltd./Atlas Senior Loan Fund V LLC

Class                      Rating                       Amount
                                                      (mil. $)
A                          AAA (sf)                     310.50
B                          AA (sf)                       52.50
C (deferrable)             A (sf)                        42.50
D (deferrable)             BBB (sf)                      27.30
E (deferrable)             BB- (sf)                      26.70


BATTALION CLO VI: Moody's Assigns B3 Rating on $3.9MM Cl. E Notes
-----------------------------------------------------------------
Moody's Investors Service has assigned ratings to six classes of
notes issued by Battalion CLO VI Ltd.

Moody's rating action is as follows:

$290,800,000 Class A-1 Senior Secured Floating Rate Notes due
2026 (the "Class A-1 Notes"), Assigned Aaa (sf)

$44,000,000 Class A-2 Senior Secured Floating Rate Notes due 2026
(the "Class A-2 Notes"), Assigned Aa2 (sf)

$24,200,000 Class B Senior Secured Deferrable Floating Rate Notes
due 2026 (the "Class B Notes"), Assigned A2 (sf)

$27,200,000 Class C Senior Secured Deferrable Floating Rate Notes
due 2026 (the "Class C Notes"), Assigned Baa3 (sf)

$29,250,000 Class D Secured Deferrable Floating Rate Notes due
2026 (the "Class D Notes"), Assigned Ba3 (sf)

$3,900,000 Class E Secured Deferrable Floating Rate Notes due
2026 (the "Class E Notes"), Assigned B3 (sf)

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

Ratings Rationale

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

Battalion VI is a managed cash flow CLO. The issued notes will be
collateralized primarily by broadly syndicated first lien senior
secured corporate loans. At least 95% of the portfolio must
consist of senior secured loans and eligible investments, and up
to 5% of the portfolio may consist of second lien loans and
unsecured loans. The Issuer's documents require the portfolio to
be at least 87% ramped as of the closing date.

Brigade Capital Management, LP (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 has issued preferred
shares. 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: $450,000,000

Diversity Score: 48

Weighted Average Rating Factor (WARF): 2800

Weighted Average Spread (WAS): 3.75%

Weighted Average Coupon (WAC): 7.50%

Weighted Average Recovery Rate (WARR): 46.0%

Weighted Average Life (WAL): 8 years.

Methodology Underlying the Rating Action:

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
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 2800 to 3220)

Rating Impact in Rating Notches

Class A-1 Notes: -1

Class A-2 Notes: -2

Class B Notes: -2

Class C Notes: -1

Class D Notes: 0

Class E Notes: 0

Percentage Change in WARF -- increase of 30% (from 2800 to 3640)

Rating Impact in Rating Notches

Class A-1 Notes: -1

Class A-2 Notes: -3

Class B Notes: -3

Class C Notes: -2

Class D Notes: -1

Class E Notes: -2

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 V Score provides 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. The V Score applies to the entire
transaction, rather than individual tranches.


CAMBER MASTER: S&P Raises Rating on Series 7 & 8 Notes to BB-
-------------------------------------------------------------
Standard & Poor's Ratings Services took the following rating
actions on 13 tranches from 13 synthetic collateralized debt
obligation (CDO) transactions:

   -- S&P raised its rating on one tranche from one investment-
      grade corporate-backed U.S. synthetic CDO transaction and
      removed it from CreditWatch, where S&P placed it with
      positive implications.

   -- S&P also raised its ratings on two tranches from two
      synthetic CDO transactions that are weak-linked to one
      investment-grade corporate-backed U.S. synthetic CDO, and
      removed them from CreditWatch positive.

   -- S&P placed its ratings on six tranches from six investment-
      grade corporate-backed U.S. synthetic CDO transactions on
      CreditWatch positive.

   -- S&P also placed its ratings on four tranches from four
      synthetic CDO transactions that are weak-linked to one
      investment grade corporate-backed U.S. synthetic CDO on
      CreditWatch positive.

The rating and CreditWatch actions follow S&P's monthly review of
synthetic CDO transactions and reflect the transactions'
seasoning, the rating stability of the obligors in the underlying
reference portfolios over the past few months, and the increased
synthetic-rated overcollateralization ratios, which are above 100%
at the next-highest rating level.

RATINGS RAISED AND REMOVED FROM CREDITWATCH POSITIVE

Camber Master Trust Series 7
Series 7
                            Rating
Class               To                  From
Notes               BB- (sf)            B+ (sf)/Watch Pos

Camber Master Trust Series 8
Series 8
                            Rating
Class               To                  From
Notes               BB- (sf)            B+ (sf)/Watch Pos

REVE SPC
Series 26
                          Rating
Class               To                  From
B                   BB (sf)             BB- (sf)/Watch Pos

RATINGS PLACED ON CREDITWATCH POSITIVE

Athenee CDO PLC
Series 2007-5
                            Rating
Class               To                  From
                    BB (sf)/Watch Pos   BB (sf)

Galena CDO II (Ireland) PLC
Series A-1U10-B
                            Rating
Class               To                  From
A-1U10-B            BB (sf)/Watch Pos   BB (sf)

PARCS Master Trust
Series 2007-10
                            Rating
Class               To                  From
Trust Unit          A- (sf)/Watch Pos   A- (sf)

Pivot Master Trust
Series 5
                            Rating
Class               To                  From
Notes               B (sf)/Watch Pos    B (sf)

Pivot Master Trust
Series 6
                            Rating
Class               To                  From
Notes               B (sf)/Watch Pos    B (sf)

Pivot Master Trust
Series 7
                            Rating
Class               To                  From
Notes               B (sf)/Watch Pos    B (sf)

Pivot Master Trust
Series 8
                            Rating
Class               To                  From
Notes               B (sf)/Watch Pos    B (sf)

Rutland Rated Investments
Series DRYDEN06-2
                            Rating
Class               To                  From
A1-$LS              A (sf)/Watch Pos    A (sf)

STARTS (Cayman) Ltd.
Series 2007-9
                            Rating
Class               To                  From
Notes               BBB (sf)/Watch Pos  BBB (sf)

STARTS (Ireland) PLC
Series 2007-31
                            Rating
Class               To                  From
A2-D2               A- (sf)/Watch Pos   A- (sf)


CARLYLE MCLAREN: S&P Raises Rating on Class B-2L Notes to B-
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1, A-1LV, A-2L, A-3L, B-1L, and B-2L notes from Carlyle McLaren
CLO Ltd. and removed them from CreditWatch, where they were placed
with positive implications on Aug. 29, 2014.  Carlyle McLaren CLO
Ltd is a collateralized loan obligation (CLO) transaction managed
by Carlyle Investment Management LLC that closed in July 2007.

The transaction's reinvestment period ended in August 2013.  Since
S&P's rating action in Nov. 2012, the class A-1L notes have paid
down a combined $92.3 million to reduce their remaining
outstanding balance to less than 76% of their original balance.
The upgrades reflect the paydowns to the class A-1L and A-1LV
notes, which helped create additional support for the subordinate
notes.  The improvements are also evident in the increased class A
and B-1L overcollateralization ratios.

Despite the class B-2L notes failing our largest-obligor default
test at the 'B' rating level, S&P upgraded the notes, taking into
account that the cash flow results suggested a higher rating, the
transaction's improved credit support since S&P's last rating
actions, and S&P's belief that the credit support available does
not reflect risk commensurate with the 'CCC' rating level.  The
largest-obligor default test is a supplemental test that addresses
event and model risks that might be present in rated transactions.

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.

CASH FLOW RESULTS AND SENSITIVITY ANALYSIS

Carlyle McLaren CLO, Ltd.

                             Cash flow    Cash flow
          Previous           implied      cushion      Final
Class      rating            rating       (i)          rating
A-1L   AA+ (sf)/Watch Pos    AAA (sf)     5.43%        AAA (sf)
A-1LV   AA+ (sf)/Watch Pos   AAA (sf)     5.43%        AAA (sf)
A-2L   AA (sf)/Watch Pos     AA+ (sf)     7.65%        AA+ (sf)
A-3L   A (sf)/Watch Pos      A+ (sf       7.41%        A+ (sf)
B-1L   BBB (sf)/Watch Pos    BBB+ (sf)    4.53%        BBB+ (sf)
B-2L   CCC+ (sf)/Watch Pos   BB+ (sf)     0.97%        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.

Correlation
Scenario              Within industry (%)   Between industries (%)
Below base case       15.0                  5.0
Base case             20.0                  7.5
Above base case       25.0                  10.0

                    Recovery    Corr.        Corr.
        Cash flow   decrease    increase     decrease
        implied     implied     implied      implied      Final
Class   rating      rating      rating       rating       rating
A-1L    AAA (sf)    AAA (sf)    AAA (sf)     AAA (sf)   AAA (sf)
A-1LV   AAA (sf)    AAA (sf)    AAA (sf)     AAA (sf)   AAA (sf)
A-2L    AA+ (sf)    AA+ (sf)    AA+ (sf)     AA+ (sf)   AA+ (sf)
A-3L    A+ (sf)     A+ (sf)     A+ (sf)      AA (sf)    A+ (sf)
B-1L    BBB+ (sf)   BBB- (sf)   BBB+ (sf)    A- (sf)    BBB+ (sf)
B-2L    BB+ (sf)    B+ (sf)     BB (sf)      BB+ (sf)   B- (sf)

Corr.--Correlation.

DEFAULT BIASING SENSITIVITY

To assess whether the current portfolio has sufficient diversity,
S&P biased defaults on the assets in the current collateral pool
with the highest spread and lowest base-case recoveries.

                       Spread          Recovery
           Cash flow   compression     compression
           implied     implied         implied         Final
Class      rating      rating          rating          rating
A-1L       AAA (sf)    AAA (sf)        AA+ (sf)        AAA (sf)
A-1LV      AAA (sf)    AAA (sf)        AA+ (sf)        AAA (sf)
A-2L       AA+ (sf)    AA+ (sf)        A+ (sf)         AA+ (sf)
A-3L       A+ (sf)     A+ (sf)         BBB+ (sf)       A+ (sf)
B-1L       BBB+ (sf)   BBB+ (sf)       BB- (sf)        BBB+ (sf)
B-2L       BB+ (sf)    BB- (sf)        CCC (sf)        B- (sf)

RATINGS LIST

Carlyle McLaren CLO Ltd.

                     Rating
Class   Identifier   To          From
A-1L    85430XAA6    AAA (sf)    AA+ (sf)/Watch Pos
A-1LV   85430XAB4    AAA (sf)    AA+ (sf)/Watch Pos
A-2L    85430XAC2    AA+ (sf)    AA (sf)/Watch Pos
A-3L    85430XAD0    A+ (sf)     A (sf)/Watch Pos
B-1L    85430XAE8    BBB+ (sf)   BBB (sf)/Watch Pos
B-2L    85430AAA6    B- (sf)     CCC+ (sf)/Watch Pos


COMM 2014-CCRE20: DBRS Rates Class E Certificates '(P)BB'
---------------------------------------------------------
DBRS Inc. has assigned provisional ratings to the following
classes of Commercial Mortgage Pass-Through Certificates, Series
2014-CCRE20, to be issued by COMM 2014-CCRE20 Commercial Mortgage
Trust.  The trends are Stable.

-- Class A-1 at AAA (sf)
-- Class A-2 at AAA (sf)
-- Class A-SB at AAA (sf)
-- Class A-3 at AAA (sf)
-- Class A-4 at AAA (sf)
-- Class X-A at AAA (sf)
-- Class X-B at AAA (sf)
-- Class X-C at AAA (sf)
-- Class X-D at AAA (sf)
-- Class X-E at AAA (sf)
-- Class X-F at AAA (sf)
-- Class X-G at AAA (sf)
-- Class A-M at AAA (sf)
-- Class B at AA (sf)
-- Class PEZ at A (low) (sf)
-- Class C at A (low) (sf)
-- Class D at BBB (low) (sf)
-- Class E at BB (low) (sf)
-- Class F at B (high) (sf)
-- Class G at B (low) (sf)

Classes X-B, X-C, X-D, X-E, X-F, X-G, D, E, F, G and H will be
privately placed pursuant to Rule 144A.  The Class X balances are
notional.  DBRS ratings on interest-only (IO) certificates address
the likelihood of receiving interest based on the notional amount
outstanding.  DBRS considers the IO certificates' position within
the transaction payment waterfall when determining the appropriate
rating.

Up to the full certificate, balance of the Class A-M, Class B and
Class C certificates may be exchanged for Class PEZ certificates.
Class PEZ certificates may be exchanged for up to the full
certificate balance of the Class A-M, Class B and Class C
certificates.

The collateral consists of 64 fixed-rate loans secured by 101
commercial and multifamily properties, with a transaction balance
of $1,182,593,628.  The pool exhibits a DBRS weighted-average term
debt service coverage ratio (DSCR) and debt yield of 1.62 times
(x) and 8.8%, respectively, based on the whole loan balances.  The
DBRS sample included 30 loans, representing 74.3% of the pool.
Properties representing 43.6% of the pool are located in urban
markets with increased liquidity, greater than transactions in the
recent past that typically have urban concentrations of 15% to
20%.

The pool is concentrated by loan size as the top ten loans
represent 53.9% of the overall pool balance.  The pool has a
concentration level similar to a pool of 24 equal-sized loans.
The combined partial IO and full-term IO concentration is 56.6%.
There are eight loans that are IO for the full term, representing
32.1% of the pool, including the two largest loans in the pool.
Overall, this results in a relatively low level of amortization
during the loan term of -13.5%.  Additionally, 29 loans,
representing 48.1% of the pool, have a DBRS-calculated Refi DSCR
of less than 1.00x.  However, these DSCRs are based on a weighted-
average stressed refinance constant of 9.7%, which implies an
interest rate of 9.1%, amortizing on a 30-year schedule.  This
represents a significant stress of nearly 4.6% over the weighted-
average contractual interest rate of the loans in the pool.


CREDIT SUISSE 2004-CF2: S&P Raises Rating on II-M-1 Notes to BB-
----------------------------------------------------------------
Standard & Poor's Ratings Services, on Oct. 17, 2014, corrected
its rating on class II-M-1 from Credit Suisse First Boston (CSFB)
Trust 2004-CF2 by lowering it to 'CCC (sf)' from 'BB- (sf)' and
removing it from CreditWatch with negative implications.  On
June 26, 2014, S&P inadvertently raised this rating to 'BB- (sf)'
from 'CCC (sf)' and placed it on CreditWatch negative.

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 it believes could affect
residential mortgage performance are:

   -- A 6.2% unemployment rate for 2014, decreasing to 5.7% 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 2.2% in 2014 and 3.0% in 2015;

   -- The 30-year mortgage rate will average 4.2% for 2014 and
      increase to 5.0% in 2015; and

   -- The inflation rate will be 1.8% in 2014, rising to 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 these key assumptions:

   -- Total unemployment rises to 6.4% in 2014 and then to 6.6% in
      2015;

   -- Downward pressure causes a 1.7% GDP growth in 2014, falling
      to 1.0% in 2015;

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

   -- The 30-year fixed mortgage rate remains at 4.2% in 2014, and
      rises slightly to 4.4% in 2015, but limited access to credit
      and pressure on home prices largely prevents consumers from
      capitalizing on these rates.

RATING CORRECTED

CSFB Trust 2004-CF2

                              Rating
Class  CUSIP     To         June 26, 2014        Pre-June 26, 2014
II-M-1 22541SE20 CCC (sf)   BB- (sf)/Watch Neg   CCC (sf)


CREDIT SUISSE 2007-TFL2: Moody's Cuts Rating on 2 Notes to C
------------------------------------------------------------
Moody's Investors Service upgraded the ratings of three classes,
downgraded the ratings of two interest-only IO classes and
affirmed the ratings of two classes of Credit Suisse First Boston
Mortgage Securities Corp. Commercial Mortgage Pass-Through
Certificates, Series 2007-TFL2 as follows:

Cl. A-3, Upgraded to Ba1 (sf); previously on Jan 30, 2014 Affirmed
B2 (sf)

Cl. B, Upgraded to B1 (sf); previously on Jan 30, 2014 Affirmed B3
(sf)

Cl. C, Upgraded to B2 (sf); previously on Jan 30, 2014 Affirmed
Caa1 (sf)

Cl. D, Affirmed Caa3 (sf); previously on Jan 30, 2014 Affirmed
Caa3 (sf)

Cl. E, Affirmed C (sf); previously on Jan 30, 2014 Affirmed C (sf)

Cl. A-X-1, Downgraded to C (sf); previously on Jan 30, 2014
Affirmed Caa1 (sf)

Cl. A-X-2, Downgraded to C (sf); previously on Jan 30, 2014
Affirmed B2 (sf)

Ratings Rationale

The upgrades of Class A-3, Class B and Class C are due primarily
to increased credit support resulting from the pay off of the
Planet Hollywood loan in June 2014. The downgrades of IO Classes
A-X-1 and A-X-2 are due to their not receiving interest payments
and the expectation that they will not receive interest payments
in the future. The ratings of Class D and Class E are consistent
with Moody's expected loss and thus are affirmed.

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

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

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

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

Methodology Underlying The Rating Action

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

Moody's review incorporated the use of the excel-based Large Loan
Model v8.7. The large loan model derives credit enhancement levels
based on an aggregation of adjusted loan-level proceeds derived
from Moody's loan-level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type and sponsorship. Moody's also further adjusts these
aggregated proceeds for any pooling benefits associated with loan
level diversity and other concentrations and correlations.

Deal Performance

As of the September 15, 2014 Payment Date, the transaction's
certificate balance decreased by approximately 81% to $285.8
million from $1.5 billion at securitization due to the liquidation
of four loans, the pay off of three loans, and a partial pay down
of the one remaining loan, the Seattle portfolio loan.

Pooled classes C through L have significant accumulated interest
shortfalls totaling $7.2 million as of the September 2014 Payment
Date. Moody's expects the interest shortfalls associated with the
liquidated Resorts Atlantic City loan and the Biscayne Landing
loan to remain permanent. Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions (ASERs) and
extraordinary trust expenses.

The trust has experienced $306.4 million in losses since
securitization due to the liquidation of both the Resorts Atlantic
City loan and the Biscayne Landing loan. Pooled Classes F, G, H,
J, K and L have experienced full losses.

The Seattle Portfolio loan ($285.8 million) is the one remaining
loan in the pool. It is collateralized by 11 office properties in
the Seattle, Washington metropolitan area. A restructure of the
loan closed in October 2013 that included a foreclosure of the
First Mezzanine loan by a Walton Street sponsored fund. Terms of
the restructure include an extension of the loan maturity date to
April 9, 2015, a new capital contribution in the amount of $37.5
million, a $3.8 million principal repayment, annual amortization
of the senior participation in the amount of $3.155 million, a
cash flow sweep to fund a Rollover Reserve and reimbursement of
all advances and special servicing fees. There is additional non-
trust subordinate mortgage debt with a current balance of $173.8
million. The portfolio was 70% leased as of June 30, 2014 compared
to 61% at last review. However, revenue and net cash flow
significantly decreased during 2013 and for the year-to-date
period ended June 30, 2014, compared to 2012. Moody's loan to
value (LTV) ratio is 97%, compared to 89% at last review.


EMPORIA PREFERRED III: Moody's Affirms B1 Rating on Cl. E Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Emporia Preferred Funding III, Ltd.:

$37,170,000 Class C Third Priority Subordinated Deferrable Notes
Due 2021, Upgraded to Aa2 (sf); previously on May 27, 2014
Upgraded to A1 (sf)

$20,650,000 Class D Fourth Priority Subordinated Deferrable Notes
Due 2021, Upgraded to Baa3 (sf); previously on May 27, 2014
Affirmed Ba1 (sf)

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

$100,000,000 Class A-1 First Priority Senior Notes Due 2021
(current outstanding balance of $33,131,571.56), Affirmed Aaa
(sf); previously on May 27, 2014 Affirmed Aaa (sf)

$40,000,000 Class A-2 First Priority Senior Revolving Notes Due
2021 (current outstanding balance of $13,252,628.62), Affirmed Aaa
(sf); previously on May 27, 2014 Affirmed Aaa (sf)

$132,580,000 Class A-3 First Priority Delayed Draw Senior Notes
Due 2021 (current outstanding balance of $43,925,837.57), Affirmed
Aaa (sf); previously on May 27, 2014 Affirmed Aaa (sf)

$26,845,000 Class B Second Priority Senior Notes Due 2021,
Affirmed Aaa (sf); previously on May 27, 2014 Upgraded to Aaa (sf)

$18,585,000 Class E Fifth Priority Subordinated Deferrable Notes
Due 2021, Affirmed B1 (sf); previously on May 27, 2014 Affirmed B1
(sf)

Emporia Preferred Funding III, Ltd., issued in March 2007, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans, with significant exposure to
middle market loans. The transaction's reinvestment period ended
in April 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 May 2014. The Class A notes have
been paid down by approximately 38% or $56.4 million since May
2014. Based on the trustee's September 2014 report, the over-
collateralization (OC) ratios for the Class A/B, Class C, Class D
and Class E notes are reported at 177.52%, 134.77%, 118.86% and
107.45%, respectively, versus May 2014 levels of 152.09%, 125.27%,
114.09% and 105.61%, respectively.

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.

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% (2769)

Class A-1: 0

Class A-2: 0

Class A-3: 0

Class B: 0

Class C: +3

Class D: +2

Class E: +1

Moody's Adjusted WARF + 20% (4154)

Class A-1: 0

Class A-2: 0

Class A-3: 0

Class B: 0

Class C: -1

Class D: -1

Class E: -2

Loss and Cash Flow Analysis:

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations," 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 $206.8 million, defaulted
par of $3.8 million, a weighted average default probability of
24.04% (implying a WARF of 3461), a weighted average recovery rate
upon default of 47.95%, a diversity score of 29 and a weighted
average spread of 3.87%.

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 3.98% 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
3.35% of the pool.


EXETER AUTOMOBILE 2014-3: DBRS Finalizes BB Rating on Cl. D Debt
----------------------------------------------------------------
DBRS Inc. has finalized its provisional ratings on the following
classes issued by Exeter Automobile Receivables Trust 2014-3:

-- Series 2014-3, Class A rated AAA (sf)
-- Series 2014-3, Class B rated A (sf)
-- Series 2014-3, Class C rated BBB (sf)
-- Series 2014-3, Class D rated BB (sf)


FLAGSHIP CREDIT 2014-2: S&P Assigns BB- Rating on Class E Notes
---------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
Flagship Credit Auto Trust 2014-2's $329.98 million auto
receivables-backed notes series 2014-2.

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

The ratings reflect S&P's view of:

   -- The availability of approximately 39.84%, 31.63%, 24.75%,
      21.12%, and 19.31% credit support (including excess spread)
      for the class A, B, C, D, and E notes, respectively, based
      on stressed cash flow scenarios.  These credit support
      levels provide coverage of approximately 3.00x, 2.30x,
      1.75x, 1.58x, and 1.35x S&P's 12.50%-13.00% expected
      cumulative net loss range for the class A, B, C, D, and E
      notes, respectively.

   -- The timely interest and principal payments made under
      stressed cash flow modeling scenarios that are appropriate
      to the assigned ratings.

   -- The expectation that under a moderate ('BBB') stress
      scenario, all else being equal, S&P's rating on the class A
      notes would remain within one rating category of S&P's 'AA
      (sf)' rating within the first year and S&P's ratings on the
      class B, C, D, and E notes would remain within two rating
      categories of S&P's 'A (sf)', 'BBB (sf)', 'BB (sf)', and
      'BB- (sf)' ratings, respectively, within the first year.
      This is within the one-category rating tolerance for 'AA'
      rated securities, and two-category rating tolerance for 'A',
      'BBB', 'BB', 'BB-' rated securities, as outlined in S&P's
      credit stability criteria.

   -- The credit enhancement in the form of subordination,
      overcollateralization, a reserve account, and excess spread.

   -- The characteristics of the collateral pool being
      securitized.

   -- The transaction's payment and legal structures.

RATINGS ASSIGNED

Flagship Credit Auto Trust 2014-2

Class       Rating       Type          Interest        Amount
                                       rate          (mil. $)
A           AA (sf)      Senior        Fixed           242.04
B           A (sf)       Subordinate   Fixed            38.53
C           BBB (sf)     Subordinate   Fixed            31.83
D           BB (sf)      Subordinate   Fixed            12.56
E           BB- (sf)     Subordinate   Fixed             5.02


GOLDEN KNIGHT II: S&P Affirms B+ Rating on Class E Notes
--------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
B, C, and D notes from Golden Knight II CLO Ltd., a collateralized
loan obligation (CLO) transaction managed by Lord Abbett & Co.  In
addition, S&P removed its ratings on these three classes from
CreditWatch, where it placed them with positive implications on
Aug. 29, 2014.  Simultaneously, S&P affirmed its ratings on the
class A and E notes from the same transaction.

The upgrades on the class B, C, and D notes reflect the increased
credit support following the continued paydowns to the class A
notes.  The transaction is in its amortization phase and is
scheduled to pay down the notes sequentially.

The class A notes have 35.01% of their original balance remaining,
down from 63.68% in Jan. 2014, when S&P upgraded the class A, B,
and C notes.  The resulting lower balance of the senior notes
increased the credit support, as reflected in the higher
overcollateralization (O/C) ratios in the Sept. 2014 report:

   -- The class A/B O/C ratio was 144.51%, up from 125.39% in
      Jan. 2014.

   -- The class C O/C ratio was 128.09%, up from 116.90% in
      Jan. 2014.

   -- The class D O/C ratio was 117.82%, up from 111.13% in
      Jan. 2014.

   -- The class E O/C ratio was 109.66%, up from 106.26% in
      Jan. 2014.

In addition, the transaction continues to have a low level of
defaults -- $3.95 million per the Sept. 2014 report.  This balance
has not changed since S&P's Jan. 2014 rating actions.  Moreover,
the amount of collateral rated in the 'CCC' range held in the
transaction's asset portfolio decreased to $15.59 million in
Sept. 2014 from $19.51 million in Jan. 2014, which, increased the
credit cushion available to the notes.

The transaction held $34.95 million of long-dated assets that
mature after the transaction's stated maturity date.  S&P's
analysis accounted for the potential market value and/or
settlement-related risk arising from the potential liquidation of
those remaining securities on the transaction's legal final
maturity date.  This affected the class D and E notes, so their
final ratings are lower than those implied by their respective
cash flows.

S&P's affirmations on the class A and E notes reflect the
availability of adequate credit support at their current rating
levels.

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

Golden Knight II CLO Ltd.

                            Cash flow
       Previous             implied    Cash flow   Final
Class  rating               rating     cushion(i)  rating
A      AAA                  AAA (sf)   38.62%      AAA (sf)
B      AA+ (sf)/Watch Pos   AAA (sf)   12.83%      AAA (sf)
C      A (sf)/Watch Pos     AA+ (sf)   10.41%      AA+ (sf)
D      BBB (sf)/Watch Pos   A+ (sf)    6.33%       A- (sf)
E      B+                   BB+ (sf)   8.35%       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.

Correlation
Scenario        Within industry (%)  Between industries (%)
Below base case                15.0                     5.0
Base case                      20.0                     7.5
Above base case                25.0                    10.0

                  Recovery   Correlation  Correlation
       Cash flow  decrease   increase     decrease
       implied    implied    implied      implied    Final
Class  rating     rating     rating       rating     rating
A      AAA (sf)   AAA (sf)   AAA (sf)     AAA (sf)   AAA (sf)
B      AAA (sf)   AAA (sf)   AAA (sf)     AAA (sf)   AAA (sf)
C      AA+ (sf)   AA+ (sf)   AA+ (sf)     AAA (sf)   AA+ (sf)
D      A+ (sf)    A+ (sf)    A+ (sf)      AA- (sf)   A- (sf)
E      BB+ (sf)   BB+ (sf)   BB+ (sf)     BBB- (sf)  B+ (sf)

DEFAULT BIASING SENSITIVITY

To assess whether the current portfolio has sufficient diversity,
S&P biased defaults on the assets in the current collateral pool
with the highest spread and lowest base-case recoveries.

                    Spread        Recovery
       Cash flow    compression   compression
       implied      implied       implied      Final
Class  rating       rating        rating       rating
A      AAA (sf)     AAA (sf)      AAA (sf)     AAA (sf)
B      AAA (sf)     AAA (sf)      AAA (sf)     AAA (sf)
C      AA+ (sf)     AA+ (sf)      AA- (sf)     AA+ (sf)
D      A+ (sf)      A+ (sf)       BBB+ (sf)    A- (sf)
E      BB+ (sf)     BB+ (sf)      B+ (sf)      B+ (sf)

RATINGS RAISED AND REMOVED FROM CREDITWATCH
Golden Knight II CLO Ltd.

                   Rating
Class        To              From
B            AAA (sf)        AA+ (sf)/Watch Pos
C            AA+ (sf)        A (sf)/Watch Pos
D            A- (sf)         BBB (sf)/Watch Pos

RATINGS AFFIRMED

Golden Knight II CLO Ltd.

Class        Rating
A            AAA (sf)
E            B+ (sf)


HALCYON LOAN II: S&P Affirms BB Rating on Class D Notes
-------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A-1-J, A-2, B, and C notes and affirmed its ratings on the class
A-1-S and D notes from Halcyon Loan Investors CLO II Ltd., a U.S.
collateralized loan obligation (CLO) transaction managed by
Halcyon Loan Investors L.P.  At the same time, S&P removed its
ratings on classes A-1-J, A-2, B, and C from CreditWatch, where
S&P had placed them with positive implications on Aug. 29, 2014.

The upgrades reflect principal amortization paydowns to the class
A-1-S notes after the reinvestment period.  Since S&P's Dec. 2012
rating actions, the class A-1-S notes were paid down by $36.13
million in total to 83.52% of their original balance, increasing
credit support for the subordinate notes.

As of the Sept. 2014 trustee report, there are no longer any
defaulted assets since the $3.48 million (0.88%) reported in Oct.
2012.  Assets from obligors in the 'CCC' rating category increased
slightly over this period, to $4.69 million (1.31%) from $4.33
million (1.10%) in October 2012.

While the cash flow results indicate support for the class D notes
at the 'BB-' rating level, we affirmed the 'BB (sf)' rating based
on the paydowns to the class A-1-S notes, the increased
overcollateralization ratios, and the fact that the transaction
currently has no defaulted assets.

The affirmations on classes A-1-S and D reflect the adequate
credit support available at their current ratings.

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

S&P will continue to review its ratings on the notes and assess
whether they 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

Halcyon Loan Investors CLO II Ltd.

                           Cash flow
       Previous            implied    Cash flow   Final
Class  rating              rating     cushion(i)  rating
A-1-S  AAA (sf)            AAA (sf)       17.67%  AAA (sf)
A-1-J  AA+ (sf)/Watch Pos  AAA (sf)        7.45%  AAA (sf)
A-2    AA (sf)/Watch Pos   AA+ (sf)       12.63%  AA+ (sf)
B      A (sf)/Watch Pos    AA+ (sf)        0.95%  AA (sf)
C      BBB (sf)/Watch Pos  BBB+ (sf)       7.18%  BBB+ (sf)
D      BB (sf)             BB- (sf)        1.21%  BB (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.

Correlation
Scenario        Within industry (%)  Between industries (%)
Below base case                15.0                     5.0
Base case                      20.0                     7.5
Above base case                25.0                    10.0

                  Recovery   Correlation  Correlation
       Cash flow  decrease   increase     decrease
       implied    implied    implied      implied    Final
Class  rating     rating     rating       rating     rating
A-1-S  AAA (sf)   AAA (sf)   AAA (sf)     AAA (sf)   AAA (sf)
A-1-J  AAA (sf)   AAA (sf)   AAA (sf)     AAA (sf)   AAA (sf)
A-2    AA+ (sf)   AA+ (sf)   AA+ (sf)     AAA (sf)   AA+ (sf)
B      AA+ (sf)   AA- (sf)   AA- (sf)     AA+ (sf)   AA (sf)
C      BBB+ (sf)  BBB+ (sf)  BBB+ (sf)    A (sf)     BBB+ (sf)
D      BB- (sf)   B+ (sf)    BB- (sf)     BB (sf)    BB (sf)

DEFAULT BIASING SENSITIVITY

To assess whether the current portfolio has sufficient diversity,
S&P biased defaults on the assets in the current collateral pool
with the highest spread and lowest base-case recoveries.

                    Spread        Recovery
       Cash flow    compression   compression
       implied      implied       implied      Final
Class  rating       rating        rating       rating
A-1-S  AAA (sf)     AAA (sf)      AAA (sf)     AAA (sf)
A-1-J  AAA (sf)     AAA (sf)      AA+ (sf)     AAA (sf)
A-2    AA+ (sf)     AA+ (sf)      AA+ (sf)     AA+ (sf)
B      AA+ (sf)     AA (sf)       A+ (sf)      AA (sf)
C      BBB+ (sf)    BBB+ (sf)     BB+ (sf)     BBB+ (sf)
D      BB- (sf)     B+ (sf)       B- (sf)      BB (sf)

RATING AND CREDITWATCH ACTIONS

Halcyon Loan Investors CLO II Ltd.

                  Rating
Class         To          From
A-1-S         AAA (sf)    AAA (sf)
A-1-J         AAA (sf)    AA+ (sf)/Watch Pos
A-2           AA+ (sf)    AA (sf)/Watch Pos
B             AA (sf)     A (sf)/Watch Pos
C             BBB+ (sf)   BBB (sf)/Watch Pos
D             BB (sf)     BB (sf)


HARBOURVIEW CLO VII: Moody's Rates $22.5MM Class E Notes '(P)Ba3'
-----------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings to
eight classes of notes to be issued by HarbourView CLO VII, Ltd.

Moody's rating action is as follows:

$5,000,000 Class A-X Senior Secured Floating Rate Notes due 2026
(the "Class A-X Notes"), Assigned (P)Aaa (sf)

$228,000,000 Class A-1 Senior Secured Floating Rate Notes due
2026 (the "Class A-1 Notes"), Assigned (P)Aaa (sf)

$30,000,000 Class A-F Senior Secured Fixed Rate Notes due 2026
(the "Class A-F Notes"), Assigned (P)Aaa (sf)

$33,000,000 Class B-1 Senior Secured Floating Rate Notes due 2026
(the "Class B-1 Notes"), Assigned (P)Aa2 (sf)

$10,000,000 Class B-F Senior Secured Fixed Rate Notes due 2026
(the "Class B-F Notes"), Assigned (P)Aa2 (sf)

$24,000,000 Class C Secured Deferrable Fixed Rate Notes due 2026
(the "Class C Notes"), Assigned (P)A2 (sf)

$24,000,000 Class D Secured Deferrable Floating Rate Notes due
2026 (the "Class D Notes"), Assigned (P)Baa3 (sf)

$22,000,000 Class E Secured Deferrable Floating Rate Notes due
2026 (the "Class E Notes"), Assigned (P)Ba3 (sf)

The Class A-X Notes, Class A-1 Notes, Class A-F Notes, Class B-1
Notes, Class B-F Notes, Class C Notes, Class D Notes and Class E
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.

HarbourView VII 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. The portfolio is expected to be at least 60%
ramped as of the closing date.

HarbourView Asset Management Corporation (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: $403,500,000

Diversity Score: 65

Weighted Average Rating Factor (WARF): 2625

Weighted Average Spread (WAS): 3.80%

Weighted Average Coupon (WAC): 6.50%

Weighted Average Recovery Rate (WARR): 45.0%

Weighted Average Life (WAL): 8 years

Methodology Underlying the Rating Action

The principal methodology used in this rating was "Moody's Global
Approach to Rating Collateralized Loan Obligations" published in
February 2014.

Factors That Would Lead to an Upgrade or a 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 2625 to 3019)

Rating Impact in Rating Notches

Class A-X Notes: 0

Class A-1 Notes: 0

Class A-F Notes: 0

Class B-1 Notes: -2

Class B-F Notes: -2

Class C Notes: -2

Class D Notes: -1

Class E Notes: -1

Percentage Change in WARF -- increase of 30% (from 2625 to 3413)

Rating Impact in Rating Notches

Class A-X Notes: 0

Class A-1 Notes: -1

Class A-F Notes: -1

Class B-1 Notes: -3

Class B-F Notes: -3

Class C Notes: -3

Class D Notes: -2

Class E Notes: -1

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 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.


HARCH CLO II: Moody's Raises Rating on $10MM Cl. E Notes to Caa1
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Harch CLO II Limited:

$26,000,000 Class D Deferrable Floating Rate Notes Due 2017,
Upgraded to A1 (sf); previously on July 2, 2014 Affirmed Baa3
(sf)

$10,000,000 Class E Deferrable Floating Rate Notes Due 2017
(current outstanding balance of $7,060,554.53), Upgraded to Caa1
(sf); previously on July 2, 2014 Downgraded to Caa2 (sf)

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

$14,000,000 Class C Deferrable Floating Rate Notes Due 2017
(current outstanding balance of $4,035,140.26), Affirmed Aaa
(sf); previously on July 2, 2014 Affirmed Aaa (sf)

Harch CLO II Limited, issued in November 2005, is a collateralized
loan obligation (CLO) backed primarily by a portfolio of senior
secured loans. The transaction's reinvestment period ended in
October 2010.

Ratings Rationale

These rating actions are primarily a result of an increase in the
transaction's over-collateralization ratios since July 2014. The
Class C notes have been paid down by approximately 61.9% or $6.5
million since July 2014. The improvement in the transaction's
over-collateralization ratios is partially due to higher than
expected realized recoveries on defaulted assets and additional
proceeds from sales of equity holdings which were not accounted
for in the last rating action. Based on the trustee's September
2014 report, the over-collateralization (OC) ratios for the Class
C, Class D and Class E notes are reported at 970.41%, 130.37% and
105.56%, respectively, versus July 2014 levels of 415.20.%,
120.13% and 100.70%, respectively.

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.

7) Lack of portfolio granularity: The performance of the portfolio
depends to a large extent on the credit conditions of a few large
obligors Moody's rates non-investment-grade, especially if they
jump to default.

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% (2024)

Class C: 0

Class D: +2

Class E: +1

Moody's Adjusted WARF + 20% (3035)

Class C: 0

Class D: -1

Class E: -2

Loss and Cash Flow Analysis:

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations," 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 $39 million, defaulted par
of $2.3 million, a weighted average default probability of 11.76%
(implying a WARF of 2529), a weighted average recovery rate upon
default of 47.87%, a diversity score of 14 and a weighted average
spread of 3.24%.

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.


HARCH CLO III: Moody's Affirms Ba3 Rating on $15MM Class E Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the rating on the following
notes issued by Harch CLO III Limited:

$19,000,000 Class D Deferrable Floating Rate Notes due 2020,
Upgraded to A1 (sf); previously on May 23, 2014 Upgraded to Baa2
(sf)

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

$43,500,000 Class A-2 Floating Rate Notes due 2020 (current
outstanding balance of $37,763,600), Affirmed Aaa (sf); previously
on May 23, 2014 Affirmed Aaa (sf)

$26,000,000 Class B Floating Rate Notes due 2020, Affirmed Aaa
(sf); previously on May 23, 2014 Affirmed Aaa (sf)

$20,000,000 Class C Deferrable Floating Rate Notes due 2020,
Affirmed Aaa (sf); previously on May 23, 2014 Upgraded to Aaa (sf)

$15,000,000 Class E Deferrable Floating Rate Notes due 2020,
Affirmed Ba3 (sf); previously on May 23, 2014 Affirmed Ba3 (sf)

Harch CLO III Limited, issued in April 2007, is a collateralized
loan obligation (CLO) backed primarily by a portfolio of senior
secured loans. The transaction's reinvestment period ended in
April 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 (OC) ratios since May 2014. Since then, Class A-
1 notes has been paid off completely, and the Class A-2 notes have
been paid down by approximately 13.2% or $5.7 million. Based on
the trustee's August 2014 report, the OC ratios for the Class A/B,
Class C, Class D and Class E notes are reported at 196.7%, 149.7%,
122.0% and 106.5%, respectively, versus April 2014 levels of
160.8%, 133.4%, 114.8% and 103.4%, respectively.

The deal has benefited from an improvement in the credit quality
of the portfolio since May 2014. Based on Moody's calculation, the
weighted average rating factor (WARF) is currently 2397 compared
to 2597 in May 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.

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% (1918)

Class A-2: 0

Class B: 0

Class C: 0

Class D: +3

Class E: +1

Moody's Adjusted WARF + 20% (2876)

Class A-2: 0

Class B: 0

Class C: 0

Class D: -1

Class E: -1

Loss and Cash Flow Analysis:

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations,"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 $122.9 million, defaulted
par of $2.5 million, a weighted average default probability of
13.3% (implying a WARF of 2397), a weighted average recovery rate
upon default of 48.8%, a diversity score of 29 and a weighted
average spread of 3.3%.

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.


HULL STREET: S&P Assigns Preliminary B Rating on Class F Notes
--------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Hull Street CLO Ltd./Hull Street CLO LLC's $470.00
million floating-rate notes.

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

The preliminary ratings are based on information as of Oct. 17,
2014.  Subsequent information may result in the assignment of
final ratings that differ from the preliminary ratings.

The preliminary ratings reflect:

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

   -- The transaction's credit enhancement, which is sufficient to
      withstand the defaults applicable for the supplemental tests
      (excluding excess spread), and cash flow structure, which
      can withstand the default rate projected by Standard &
      Poor's 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 S&P expects to be
      bankruptcy remote.

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

   -- The collateral manager's experienced management team.

   -- The transaction's ability to make timely interest and
      ultimate principal payments on the preliminary rated notes,
      which S&P assessed using its cash flow analysis and
      assumptions commensurate with the assigned preliminary
      ratings under various interest-rate scenarios, including
      LIBOR ranging from 0.2316%-12.7531%.

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

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

PRELIMINARY RATINGS ASSIGNED

Hull Street CLO Ltd./Hull Street CLO LLC

Class                   Rating     Amount (mil. $)
A                       AAA (sf)            316.00
B                       AA (sf)              60.00
C (deferrable)          A (sf)               38.00
D (deferrable)          BBB (sf)             25.25
E (deferrable)          BB (sf)              20.75
F (deferrable)          B (sf)               10.00
Subordinated notes      NR                   45.00

NR--Not rated.


INWOOD PARK: Moody's Affirms Ba2 Rating on $50MM Class E Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Inwood Park CDO Ltd.:

$68,750,000 Class C Floating Rate Deferrable Notes Due 2021,
Upgraded to Aa2 (sf); previously on December 9, 2013 Upgraded to
A1 (sf);

$50,000,000 Class D Floating Rate Deferrable Notes Due 2021,
Upgraded to Baa1 (sf); previously on December 9, 2013 Upgraded to
Baa3 (sf).

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

$565,500,000 Class A-1-A Floating Rate Notes Due 2021 (current
outstanding balance of $186,164,082.42) Affirmed Aaa (sf);
previously on December 9, 2013 Affirmed Aaa (sf);

$141,375,000 Class A-1-B Floating Rate Notes Due 2021, Affirmed
Aaa (sf); previously on December 9, 2013 Affirmed Aaa (sf);

$177,500,000 Class A-2 Floating Rate Notes Due 2021 (current
outstanding balance of $82,246,772.24), Affirmed Aaa (sf);
previously on December 9, 2013 Affirmed Aaa (sf);

$90,625,000 Class B Floating Rate Notes Due 2021, Affirmed Aaa
(sf); previously on December 9, 2013 Upgraded to Aaa (sf);

$50,000,000 Class E Floating Rate Deferrable Notes Due 2021,
Affirmed Ba2 (sf); previously on December 9, 2013 Affirmed Ba2
(sf).

Inwood Park CDO Ltd., issued in January 2007, is a collateralized
loan obligation (CLO) backed primarily by a portfolio of senior
secured loans. The transaction's reinvestment period ended in
January 2013.

Ratings Rationale

These rating actions are primarily a result of deleveraging of the
senior notes and an increase in the transaction's over-
collateralization ratios since January 2014. The Class A-1 and A-2
notes have been paid down each by approximately 37.4% or $126.2
million since that time. Based on the trustee's September 2014
report, the over-collateralization (OC) ratios for the Class A/B,
Class C, Class D and Class E notes are reported at 143.50%,
126.16%, 115.98% and 107.31%, respectively, versus January 2014
levels of 135.28%, 121.91%, 113.73% and 106.58%, respectively.

The deal has also benefited from an improvement in the credit
quality of the portfolio since January 2014. Based on the
trustee's September 2014 report, the weighted average rating
factor is currently 2473 compared to 2533 in 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) 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.

7) Post-Reinvestment Period Trading: Subject to certain
requirements, the deal can reinvest certain proceeds after the end
of the reinvestment period, and as such the manager has the
ability to erode some of the collateral quality metrics to the
covenant levels. Such reinvestment could affect the transaction
either positively or negatively.

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% (2045)

Class A-1-A: 0

Class A-1-B: 0

Class A-2: 0

Class B: 0

Class C: +2

Class D: +2

Class E: +1

Moody's Adjusted WARF + 20% (3067)

Class A-1-A: 0

Class A-1-B: 0

Class A-2: 0

Class B: 0

Class C: -2

Class D: -2

Class E: -1

Loss and Cash Flow Analysis:

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations," published in 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 $715.5 million, defaulted
par of $2.8 million, a weighted average default probability of
17.42% (implying a WARF of 2557), a weighted average recovery rate
upon default of 48.91%, a diversity score of 59 and a weighted
average spread of 3.04%.

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.


KVK CLO 2014-2: S&P Affirms 'BB' Rating on Class E Notes
--------------------------------------------------------
Standard & Poor's Ratings Services affirmed its rating on KVK CLO
2014-2 Ltd./KVK CLO 2014-2 LLC's $559.50 million floating rate
notes following the transaction's effective date as of July 22,
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 noted.

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

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

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

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

On an ongoing basis after S&P issues an effective date ratings
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

KVK CLO 2014-2 Ltd./KVK CLO 2014-2 LLC

Class                      Rating                       Amount
                                                       (mil. $)

X                          AAA (sf)                       4.00
A                          AAA (sf)                     378.00
B                          AA (sf)                       67.50
C (deferrable)             A (sf)                        50.00
D (deferrable)             BBB (sf)                      32.00
E (deferrable)             BB (sf)                       28.00


JP MORGAN 1997-C5: Moody's Affirms Caa3 Rating on Class X Notes
---------------------------------------------------------------
Moody's Investors Service has affirmed the rating of one class of
J.P. Morgan Commercial Mortgage Finance Corp 1997-C5 as follows:

Cl. X, Affirmed Caa3 (sf); previously on Dec 5, 2013 Affirmed Caa3
(sf)

Ratings Rationale

The rating of the IO class, Class X, was affirmed based on the
credit performance (or the weighted average rating factor or WARF)
of its referenced classes. The IO class is the only outstanding
Moody's-rated class in this transaction.

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

The rating of an IO class is based on the credit performance of
its referenced classes. An IO class may be upgraded based on a
lower weighted average rating factor or WARF due to an overall
improvement in the credit quality of its reference classes. An IO
class may be downgraded based on a higher WARF due to a decline in
the credit quality of its reference classes, paydowns of higher
quality reference classes or non-payment of interest. Classes that
have paid off through loan paydowns or amortization are not
included in the WARF calculation. Classes that have experienced
losses are grossed up for losses and included in the WARF
calculation, even if Moody's has withdrawn the rating.

Methodology Underlying The Rating Action

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

Description of Models Used

Moody's review incorporated the use of the excel-based Large Loan
Model v 8.7. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

Deal Performance

As of the September 15, 2014 distribution date, the transaction's
aggregate certificate balance has decreased by 98% to $20.3
million from $1.0 billion at securitization. The Certificates are
collateralized by seven mortgage loans ranging in size from less
than 2% to 82% of the pool.

One loan, representing 4% of the pool, is on the master servicer's
watchlist. The watchlist includes loans which meet certain
portfolio review guidelines established as part of the CRE Finance
Council (CREFC) monthly reporting package. As part of Moody's
ongoing monitoring of a transaction, Moody's reviews the watchlist
to assess which loans have material issues that could impact
performance.

Twenty loans have been liquidated from the pool, resulting in an
aggregate realized loss of $25.5 million (47.4% loss severity on
average). No loans are currently in special servicing.

Moody's was provided with full year 2013 operating results for
100% of the pool. Moody's weighted average conduit LTV is 30%
compared to 31% at Moody's prior review. Moody's conduit component
excludes loans with credit assessments, defeased and CTL loans and
specially serviced and troubled loans. Moody's net cash flow (NCF)
reflects a weighted average haircut of 11.7% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 10%.

Moody's actual and stressed conduit DSCRs are 1.97X and 3.72X,
respectively, compared to 2.01X and 3.53X at prior review. Moody's
actual DSCR is based on Moody's NCF and the loan's actual debt
service. Moody's stressed DSCR is based on Moody's NCF and a 9.25%
stressed rate applied to the loan balance.

The top three conduit loans represent 92% of the pool balance. The
largest loan is the Spectrum at Reston Town Center ($16.6 million
-- 82.0% of the pool), which is secured by an anchored retail
property, approximately 20 miles outside of Washington, DC. The
year-end 2013 occupancy was 100%, the same as at prior review.
Moody's LTV and stressed DSCR are 31% and 3.54X, respectively,
compared to 32% and 3.42X at prior review.

The second largest loan is the Whitehall Apartments Loan ($1.1
million --5.6% of the pool), which is secured by a 68 unit
multifamily complex located in Clarksville, TN, approximately 45
miles northwest of Nashville. The property is located near Fort
Campbell and military personnel occupy a majority of the units.
Moody's LTV and stressed DSCR are 41% and 2.53X, respectively,
compared to 34% and 3.00X at prior review.

The third largest loan is the Clopper II Research & Development
Loan ($0.78 million -- 3.8% of the pool), which is secured by a
79,000 square foot industrial property located in Gaithersburg,
MD, which is approximately 20 miles outside of Washington, DC. As
of the March 2013 rent roll, the property was 86% leased, the same
as at prior review. Moody's LTV and stressed DSCR are 14% and
>4.00X, respectively, compared to 19% and 5.70X at prior review.


MADISON AVENUE 2013-650M: DBRS Confirms 'BB' Rating on Cl. E Certs
------------------------------------------------------------------
DBRS Inc. has confirmed the ratings for the following classes of
Commercial Mortgage Pass-Through Certificates Series 2013-650M
issued by Madison Avenue Trust 2013-650M.  The trends are Stable.

-- Class A at AAA (sf)
-- Class X-A at AAA (sf)
-- Class B at AA (low) (sf)
-- Class C at A (low) (sf)
-- Class D at BBB (low) (sf)
-- Class E at BB (low) (sf)

The confirmations reflect the property's stable performance, which
is considered in line with expectations.  The collateral consists
of a $675 million fixed-rate loan secured by 650 Madison Avenue, a
595,348 square foot (sf), 27-story, Class A office and retail
tower built in 1957.  It is considered one of the premier office
towers in the Plaza District submarket because of its unobstructed
views of Central Park starting at the 15th floor and its 200 feet
of ground-floor retail frontage along Madison Avenue.  At
issuance, DBRS was aware of one tenant's intent to vacate.  The
third-largest office tenant, Reservoir Capital, vacated the space
upon the lease expiration date of June 30, 2014.  Reservoir
Capital occupied floors 22 through 26, represented 9.7% of the net
rental area (NRA).  A letter of intent for 7,456 sf of Reservoir
Capital's space had been submitted at the time the loan closed,
and a lease was executed for this space on July 1, 2014, to
Lakewood Capital Management LP through December 2020.

The office portion of the collateral is 89.5% occupied by nine
tenants and the retail is 100% occupied by three tenants.
Together, the subject property is currently 90.7% occupied.  Polo
Ralph Lauren is the larget tenant at the subject, comprising 46.4%
of the NRA and 43.4% of the net rental income, and is on a long-
term lease that extends more than four years beyond the loan term.
The year-to-date June 2014 annualized debt service coverage ratio
(DSCR) was reported to be 2.19 times (x), which reflects a 7.6%
net cash flow change over the DBRS underwriting.

With a 2.05x DBRS Term DSCR, there is minimal term default risk,
and with 63.3% of the NRA leased to long-term investment-grade
tenants, refinance risk is considered minimal.


MOMENTUM CAPITAL: Moody's Hikes Rating on Class E Notes to Ba2
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Momentum Capital Fund, Ltd.:

$22,500,000 Class B Floating Rate Notes Due 2021, Upgraded to Aaa
(sf); previously on September 30, 2013 Affirmed Aa3 (sf)

$15,950,000 Class C Deferrable Floating Rate Notes Due 2021,
Upgraded to Aa2 (sf); previously on September 30, 2013 Affirmed A3
(sf)

$11,250,000 Class D Deferrable Floating Rate Notes Due 2021,
Upgraded to A3 (sf); previously on September 30, 2013 Affirmed Ba1
(sf)

$9,150,000 Class E Deferrable Floating Rate Notes Due 2021,
Upgraded to Ba2 (sf); previously on September 30, 2013 Affirmed
Ba3 (sf)

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

$209,750,000 Class A-1 Floating Rate Notes Due 2021 (current
outstanding balance of $61,306,900), Affirmed Aaa (sf); previously
on September 30, 2013 Affirmed Aaa (sf)

$52,400,000 Class A-2 Floating Rate Notes Due 2021, Affirmed Aaa
(sf); previously on September 30, 2013 Affirmed Aaa (sf)

Momentum Capital Fund, Ltd., issued in September 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans. The transaction's reinvestment period ended
in October 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 (OC) ratios since January 2014.The Class A-1
notes have been paid down by approximately 70% or $140 million
since that time. Based on the trustee's September 2014 report, the
OC ratios for the Class A/B, Class C, Class D and Class E notes
are reported at 137.43%, 123.02%, 114.55% and 108.48%,
respectively, versus January 2014 levels of 118.72 %, 112.25 %,
108.08 % and 104.92%, respectively.

The deal has benefited from an improvement in the credit quality
of the portfolio since January 2014. Based on the trustee's
September 2014 report, the weighted average rating factor is
currently 2446 compared to 2692 in 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.

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% (2047)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C: +2

Class D: +3

Class E: +2

Moody's Adjusted WARF + 20% (3070)

Class A-1: 0

Class A-2: 0

Class B: 0

Class C: -2

Class D: -2

Class E: 0

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 $186.9 million, defaulted
par of $0.7 million, a weighted average default probability of
15.73% (implying a WARF of 2558), a weighted average recovery rate
upon default of 51.78%, a diversity score of 35 and a weighted
average spread of 3.08%.

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.


MORGAN STANLEY 2004-TOP15: S&P Lowers Class K Certs' Rating to D
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
K commercial mortgage pass-through certificates from Morgan
Stanley Capital I Trust 2004-TOP15, a U.S. commercial mortgage-
backed securities (CMBS) transaction, to 'D (sf)' from 'B (sf)'.

The downgrade reflects principal losses detailed in the Oct. 14,
2014, trustee remittance report.  The reported principal losses
totaled $2.0 million, which primarily resulted from the
liquidation of the Sunset Park real estate owned (REO) asset that
was with the special servicer, C-III Asset Management LLC.
According to the report, the asset liquidated at a loss severity
of 28.6% of its beginning scheduled trust balance at the time of
liquidation of $6.9 million.  Consequently, class K experienced a
$1.4 million, or 61.0%, loss of its $2.2 million original
principal balance, and the subordinate class L, the rating on
which we previously lowered to 'D (sf)', lost 100.0% of its
$626,461 beginning principal balance.


MSBAM 2013-C12: Moody's Affirms B1 Rating on Class F Certificate
----------------------------------------------------------------
Moody's Investors Service has affirmed the ratings on 13 classes
in Morgan Stanley Bank of America Merrill Lynch Trust 2013-C12
Commercial Mortgage Pass-Through Certificates as follows:

Cl. A-1, Affirmed Aaa (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Aaa (sf)

Cl. A-2, Affirmed Aaa (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Aaa (sf)

Cl. A-3, Affirmed Aaa (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Aaa (sf)

Cl. A-4, Affirmed Aaa (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Aaa (sf)

Cl. A-S, Affirmed Aaa (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Aaa (sf)

Cl. A-SB, Affirmed Aaa (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed Aa3 (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Aa3 (sf)

Cl. C, Affirmed A3 (sf); previously on Oct 29, 2013 Definitive
Rating Assigned A3 (sf)

Cl. PST, Affirmed A1 (sf); previously on Oct 29, 2013 Definitive
Rating Assigned A1 (sf)

Cl. D, Affirmed Baa3 (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Baa3 (sf)

Cl. E, Affirmed Ba2 (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Ba2 (sf)

Cl. F, Affirmed B1 (sf); previously on Oct 29, 2013 Definitive
Rating Assigned B1 (sf)

Cl. X-A, Affirmed Aaa (sf); previously on Oct 29, 2013 Definitive
Rating Assigned Aaa (sf)

Ratings Rationale

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

The rating on the exchangeable class PST was affirmed due to the
weighted average rating factor of its referenced classes.

The ratings on the IO class was affirmed due to the weighted
average rating factor of its referenced classes.

Moody's rating action reflects a base expected loss of 2.9% of the
current balance.

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

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

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

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

Methodology Underlying The Rating Action

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

On October 9, 2014, Moody's issued a "Request for Comment" asking
for market feedback on proposed changes to the methodology it uses
to rate conduit and fusion CMBS transactions. If Moody's adopts
the new methodology as proposed, the changes could affect the
ratings of MSBAM 2013-C12.

Description Of Models Used

Moody's review used the excel-based CMBS Conduit Model v 2.64,
which it uses for both conduit and fusion transactions. Conduit
model results at the Aa2 (sf) level are driven by property type,
Moody's actual and stressed DSCR, and Moody's property quality
grade (which reflects the capitalization rate Moody's uses to
estimate Moody's value). Conduit model results at the B2 (sf)
level are based on a paydown analysis using the individual loan-
level Moody's LTV ratio. Moody's may consider other concentrations
and correlations in its analysis. Based on the model pooled credit
enhancement levels of Aa2 (sf) and B2 (sf), the required credit
enhancement on the remaining conduit classes are either
interpolated between these two data points or determined based on
a multiple or ratio of either of these two data points. For fusion
deals, Moody's merges the credit enhancement for loans with
investment-grade Structured Credit Assessments with the conduit
model credit enhancement for an overall model result. Moody's
incorporates negative pooling (adding credit enhancement at the
Structured Credit Assessment level) for loans with similar
Structured Credit Assessments in the same transaction.

Moody's uses a variation of Herf to measure the diversity of loan
sizes, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including the risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 28, compared to 29 at securitization.

Deal Performance

As of the September 17, 2014 distribution date, the transaction's
aggregate certificate balance has decreased by 1% to $1.26 billion
from $1.27 billion at securitization. The certificates are
collateralized by 72 mortgage loans ranging in size from less than
1% to 10% of the pool, with the top ten loans constituting 49% of
the pool.

Three loans, constituting 1% of the pool, are on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews
the watchlist to assess which loans have material issues that
could affect performance.

There are currently no loans in special servicing.

Moody's received full year 2013 operating results for 95% of the
pool and partial year 2014 for 91% of the pool. Moody's weighted
average conduit LTV is 100% compared to 102% at securitization.
Moody's conduit component excludes loans with Structured Credit
Assessments, defeased and CTL loans, and specially serviced and
troubled loans. Moody's net cash flow (NCF) reflects a weighted
average haircut of 7% to the most recently available net operating
income (NOI). Moody's value reflects a weighted average
capitalization rate of 9.5%.

Moody's actual and stressed conduit DSCRs are 1.56X and 1.05X,
respectively, compared to 1.52X and 1.01X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 24% of the pool balance. The
largest loan is The Merrimack Premium Outlets Loan ($130.0 million
-- 10.3% of the pool), which is secured by a 408,996 square foot
(SF) outlet center located in Merrimack, New Hampshire. The outlet
center is situated immediately off the Everett Turnpike within the
Southern New Hampshire section of the greater Boston market area,
approximately ten miles north of the Massachusetts/New Hampshire
border. The property was recently developed by Simon Property
Group, L.P. and opened for business in June 2012. The loan is
interest-only for the first 24 months of the loan term. As of
March 2014 the property was 99% leased compared to 100% at
securitization. Moody's LTV and stressed DSCR are 103% and 0.95X,
respectively, compared to 103% and 0.94X at securitization.

The second largest loan is the 15 Metro Tech Center Loan ($88.3
million -- 7.0% of the pool), which is secured by a 19-story,
Class A office building containing 649,492 SF of net rentable area
located in Brooklyn, New York. The loan is a pari-passu interest
in a $166.7 million loan. It is one of seven Class A buildings
situated within the MetroTech Center, all of which are owned by
the Sponsor. The property was built in 2003, and contains a two-
level below-grade parking garage offering 113 spaces. The property
is well located approximately five minutes from downtown
Manhattan, and is accessible via twelve subway lines and the Long
Island Rail Road. As of June 2014 the building was 100% leased by
three credit tenants who signed leases prior to the building's
completion. One of the tenants, WellPoint Inc. currently subleases
92% of their space to seven subtenants. The WellPoint Inc. lease
represents 64% of the building's net rentable area (NRA) is
scheduled to expire on June 30, 2020. Moody's LTV and stressed
DSCR are 90% and 1.08X, respectively, compared to 91% and 1.06X at
securitization.

The third largest loan is The City Creek Center Loan ($83.5
million -- 6.6% of the pool), which is secured by 348,537 SF of
net rentable area contained within a 628,934 SF regional mall
located in Salt Lake City, Utah. City Creek Center opened in March
2012 as part of a $1.5 billion mixed-used redevelopment of
downtown Salt Lake City that was started in 2006. In addition to
the subject property, the development contains 2.1 million SF of
office space, 800 multi-family units and a 4,000-space
subterranean garage. The center is anchored by Macy's and
Nordstrom. Both anchor units are owned by their respective tenants
and are not contributed as collateral for the loan. The Borrower
owns a leasehold interest in the majority of the collateral, and a
fee interest in three restaurants (27,685 SF).The ground-lease is
with the Church of Latter Day Saints with an initial term of 30
years, and four additional 10-year options. Moody's LTV and
stressed DSCR are 79% and 1.17X, respectively, compared to 80% and
1.15X at securitization.


N-STAR REL CDO IV: S&P Raises Rating on Class C Notes to BB-
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A, B, and C notes from N-Star REL CDO IV Ltd., a commercial real
estate collateralized debt obligation (CRE CDO) transaction.
Concurrently, S&P affirmed its ratings on four other classes from
the same transaction.

The rating actions reflect S&P's analysis of the transaction's
liability structure and the underlying collateral's credit
characteristics using S&P's global CDOs of pooled structured
finance assets criteria, S&P's U.S. and Canadian commercial
mortgage-backed securities (CMBS) rating methodology and
assumptions, and S&P's CMBS global property evaluation methodology
criteria.  The upgrades also reflect the transaction's
amortization. Class A had a current outstanding balance of $10.5
million as of the Sept. 29, 2014, note valuation report, down from
$178.9 million at issuance.

According to the Sept. 29, 2014, note valuation report, the
transaction's collateral totaled $261.8 million, while the
transaction's liabilities totaled $208.0 million, down from $376.5
million in liabilities at issuance.  The transaction's current
asset pool includes these:

   -- Ten whole loans ($130.9 million, 49.9%);

   -- Four mezzanine loans ($58.2 million, 22.3%);

   -- Two junior participation loans ($25.6 million, 9.8%);

   -- One CMBS resecuritized real estate mortgage investment
      conduit (re-REMIC) security ($15.0 million, 5.7%);

   -- Two CDO securities ($13.3 million, 5.1%);

   -- Two CMBS tranches ($8.4 million, 3.2%);

   -- One REIT debt security ($7.5 million, 2.9%); and

   -- One CMBS rake bond ($2.9 million, 1.1%).

The trustee report noted seven defaulted assets: one CMBS re-REMIC
security, two CDO securities, two CMBS tranches, one mezzanine
loan ($7.2 million, 2.8%), and one CMBS rake bond.  The defaulted
loan is the Castleton Office Park mezzanine loan ($7.2 million,
2.8%), for which S&P estimated no recovery.

Using loan performance information provided by the collateral
manager, S&P applied asset-specific recovery rates in its analysis
of the performing loans ($207.5 million, 79.3%) using its U.S. and
Canadian CMBS criteria and its CMBS global property evaluation
methodology.  S&P did not apply asset-specific recovery rates to
the Mercer Greene loan, the Reader's Digest loan, the Adaptec
loan, the Edenvale loan, and the Admiral Crew Lodging loan.

S&P also considered in its analysis qualitative factors, such as
the loans' near-term maturities, refinancing prospects, and
modifications.

According to the Sept. 29, 2014, trustee report, the deal passed
all of its overcollateralization and interest coverage tests.

RATINGS LIST

N-Star REL CDO IV Ltd.
Collateralized debt obligations series 2005-1
                       Rating
Class    Identifier    To           From
A        62939WAA3     A+ (sf)      BB- (sf)
B        62939WAB1     BBB- (sf)    B- (sf)
C        62939WAC9     BB- (sf)     CCC+ (sf)
D        62939WAD7     CCC+ (sf)    CCC+ (sf)
E        62939WAE5     CCC+ (sf)    CCC+ (sf)
F        62939XAA1     CCC (sf)     CCC (sf)
G        62939XAB9     CCC- (sf)    CCC- (sf)


NANTUCKET CLO I: Moody's Raises Rating on $12.6MM Notes to Ba2
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Nantucket CLO I Ltd.:

$18,000,000 Class C Senior Secured Deferrable Floating Rate Notes
due November 24, 2020, Upgraded to Aaa (sf); previously on August
16, 2013 Upgraded to Aa2 (sf);

$15,600,000 Class D Secured Deferrable Floating Rate Notes due
November 24, 2020, Upgraded to A3 (sf); previously on August 16,
2013 Upgraded to Baa2 (sf);

$12,600,000 Class E Secured Deferrable Floating Rate Notes due
November 24, 2020, Upgraded to Ba2 (sf); previously on August 16,
2013 Affirmed Ba3 (sf).

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

$215,700,000 Class A Senior Secured Floating Rate Notes due
November 24, 2020 (current outstanding balance of $93,268,702.98),
Affirmed Aaa (sf); previously on August 16, 2013 Affirmed Aaa
(sf);

$15,000,000 Class B Senior Secured Floating Rate Notes due
November 24, 2020, Affirmed Aaa (sf); previously on August 16,
2013 Affirmed Aaa (sf).

Nantucket CLO I Ltd., issued in November 2006, is a collateralized
loan obligation (CLO) backed primarily by a portfolio of senior
secured loans. 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
overcollateralization (OC) ratios since February 2014. The Class A
notes have been paid down by approximately 29.0% or $38.1 million
since February 2014. Based on the trustee's October 2014 report,
the Class A/B, Class C, Class D, and Class E OC ratios are
reported at 149.84%, 128.48%, 114.35%, 105.02%, respectively,
versus February 2014 levels of 135.57%, 121.79%, 111.94%, and
105.07%, respectively.

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.

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% (1909)

Class A: 0

Class B: 0

Class C: +1

Class D: +2

Class E: +1

Moody's Adjusted WARF + 20% (2863)

Class A: 0

Class B: 0

Class C: -2

Class D: -2

Class E: -1

Loss and Cash Flow Analysis

Moody's modeled the transaction using a cash flow model based on
the Binomial Expansion Technique, as described in Section 2.3 of
the "Moody's Global Approach to Rating Collateralized Loan
Obligations," published in 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 $164.3 million, no defaulted
par, a weighted average default probability of 15.5% (implying a
WARF of 2386), a weighted average recovery rate upon default of
50.84%, a diversity score of 35 and a weighted average spread of
2.90%.

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.


NAVIGATOR CDO 2006: Moody's Hikes $12.5MM D Notes Rating to Ba1
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Navigator CDO 2006, Ltd.:

$26,000,000 Class B-1 Floating Rate Secured Deferrable Term Notes
Due 2020, Upgraded to Aa1 (sf); previously on May 29, 2014
Upgraded to Aa3 (sf)

$7,000,000 Class B-2 Fixed Rate Secured Deferrable Term Notes Due
2020, Upgraded to Aa1 (sf); previously on May 29, 2014 Upgraded to
Aa3 (sf)

$15,500,000 Class C Floating Rate Secured Deferrable Term Notes
Due 2020, Upgraded to A2 (sf); previously on May 29, 2014 Upgraded
to Baa2 (sf)

$12,500,000 Class D Floating Rate Secured Deferrable Term Notes
Due 2020 (current outstanding balance of $10,437,972), Upgraded to
Ba1 (sf); previously on May 29, 2014 Affirmed Ba3 (sf)

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

$40,000,000 Class A Floating Rate Senior Secured Revolving Notes
Due 2020 (current outstanding balance of $6,781,507), Affirmed Aaa
(sf); previously on May 29, 2014 Affirmed Aaa (sf)

$265,000,000 Class A Floating Rate Senior Secured Term Notes Due
2020 (current outstanding balance of $44,927,485), Affirmed Aaa
(sf); previously on May 29, 2014 Affirmed Aaa (sf)

$10,000,000 Class 1 Combination Notes Due 2020 (current rated
balance of $3,726,126), Affirmed Aaa (sf); previously on May 29,
2014 Upgraded to Aaa (sf)

Navigator CDO 2006, Ltd., issued in September 2006, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans. The transaction's reinvestment
period ended in September 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 May 2014. The Class A notes have
been paid down by approximately 64.8% or $95.3 million since that
time . Based on the trustee's September 2014 report, the over-
collateralization (OC) ratios for the Class A, Class B, Class C
and Class D notes are reported at 186.4%, 133.1%, 117.3% and
108.6%, respectively, versus May 2014 levels of 147.7%, 120.6%,
111.1% and 105.4%, respectively. The September 2014 trustee
reported overcollateralization ratios do not include the September
2014 payment distribution when $30.6 million of principal proceeds
were used to pay down the Class A notes.

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.

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% (2224)

Class A Revolving: 0

Class A Term: 0

Class B-1: +1

Class B-2: +1

Class C: +3

Class D: +2

Class 1 Combination Notes: 0

Moody's Adjusted WARF + 20% (3336)

Class A Revolving: 0

Class A Term: 0

Class B-1: -2

Class B-2: -2

Class C: -2

Class D: -1

Class 1 Combination Notes: 0

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 of $122.8 million, no defaulted par, a weighted average
default probability of 16.99% (implying a WARF of 2780), a
weighted average recovery rate upon default of 51.72%, a diversity
score of 40 and a weighted average spread of 3.07%.

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.


NCF DEALER 2014-1: DBRS Rates Class D Notes '(P)BB'
---------------------------------------------------
DBRS Inc. has assigned provisional ratings to the following notes
issued by NCF Dealer Floorplan Master Trust, Series 2014-1:

Series 2014-1 Notes, Class A rated AA (sf)
Series 2014-1 Notes, Class B rated A (sf)
Series 2014-1 Notes, Class C rated BBB (sf)
Series 2014-1 Notes, Class D rated BB (sf)


RAIT 2014-FL3: DBRS Rates Class X-1 Notes '(P)BB'
-------------------------------------------------
DBRS Inc. has assigned provisional ratings to the following
classes of secured floating-rate notes to be issued by RAIT 2014-
FL3 Trust.  All trends are Stable.

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

All classes have been privately placed pursuant to Rule 144A.

The collateral for the transaction consists of newly originated
floating-rate mortgages (20 loans, $202.8 million) secured by 21
transitional commercial real estate properties (the Initial Loans)
and two additional mortgages, with a total of $16.6 million to be
contributed in the 90 days post-closing (the Delayed Closing
Mortgage loans) to combine for a total of $219.4 million and 22
loans.  The loans are secured by current cash flowing assets, most
of which are in a period of transition with plans to stabilize and
improve the asset value.  The floating-rate mortgages were
analyzed to determine the probability of loan default over the
term of the loan and its refinance risk at maturity, based on a
fully extended loan term.  Due to the floating-rate nature of the
loans, the index (one-month LIBOR) was modeled at the lower of a
DBRS stressed index that corresponded to the remaining fully
extended term of the loans and the strike price of the interest
rate cap, with the respective contractual loan spread added to
determine a stressed interest rate over the loan term.  When the
cutoff balances were measured against the DBRS in-place net cash
flow (NCF) and their respective stressed constants, there were 17
loans, representing 70.7% of the pool, with term debt service
coverage ratios (DSCRs) below 1.15 times (x), a threshold
indicative of a higher likelihood of term default.  Additionally,
to assess refinance risk, DBRS applied its refinance constants to
the balloon amounts, resulting in 14 loans, or 77.2% of the loans
having refinance DSCRs below 1.00x relative to the DBRS stabilized
NCF.  The properties are often transitioning, with potential
upside in the cash flow; however, DBRS does not give full credit
to the stabilization if there are no holdbacks or other loan
structural features in place were insufficient to support such
treatment.

The transaction is a sequential-pay structure.


WACHOVIA BANK 2003-C7: Moody's Affirms C Rating on Cl. H Certs
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of two classes
and affirmed the ratings on three classes of Wachovia Bank
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2003-C7 as follows:


Cl. E, Upgraded to Aa2 (sf); previously on Jul 10, 2014 Affirmed
A3 (sf)

Cl. F, Upgraded to A3 (sf); previously on Jul 10, 2014 Affirmed
Ba1 (sf)

Cl. G, Affirmed Caa2 (sf); previously on Jul 10, 2014 Downgraded
to Caa2 (sf)

Cl. H, Affirmed C (sf); previously on Jul 10, 2014 Downgraded to C
(sf)

Cl. X-C, Affirmed Caa3 (sf); previously on Jul 10, 2014 Downgraded
to Caa3 (sf)

Ratings Rationale

The ratings on P&I classes E and F were upgraded based primarily
on an increase in credit support resulting from loan paydowns and
amortization. The deal has paid down 41% since Moody's last
review.

The ratings on P&I classes G and H were affirmed because the
ratings are consistent with Moody's expected loss.

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

Moody's rating action reflects a base expected loss of 3.7% of the
current balance compared to 36.5% at Moody's last review. Moody's
base expected loss plus realized losses is now 6.4% of the
original pooled balance compared to 7.3% at the last review.

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

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

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

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

Methodology Underlying The Rating Action

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

On October 9, 2014, Moody's issued a "Request for Comment" asking
for market feedback on proposed changes to the methodology it uses
to rate conduit and fusion CMBS transactions. If Moody's adopts
the new methodology as proposed, the changes could affect the
ratings of WBCMT 2003-C7.

Description Of Models Used

Moody's review used the excel-based CMBS Conduit Model v 2.64,
which it uses for both conduit and fusion transactions. Conduit
model results at the Aa2 (sf) level are driven by property type,
Moody's actual and stressed DSCR, and Moody's property quality
grade (which reflects the capitalization rate Moody's uses to
estimate Moody's value). Conduit model results at the B2 (sf)
level are based on a paydown analysis using the individual loan-
level Moody's LTV ratio. Moody's may consider other concentrations
and correlations in its analysis. Based on the model pooled credit
enhancement levels of Aa2 (sf) and B2 (sf), the required credit
enhancement on the remaining conduit classes are either
interpolated between these two data points or determined based on
a multiple or ratio of either of these two data points. For fusion
deals, Moody's merges the credit enhancement for loans with
investment-grade structured credit assessments with the conduit
model credit enhancement for an overall model result. Moody's
incorporates negative pooling (adding credit enhancement at the
structured credit assessment level) for loans with similar
structured credit assessments in the same transaction.

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

When the Herf falls below 20, Moody's uses the excel-based Large
Loan Model v 8.7 and then reconciles and weights the results from
the conduit and large loan models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan-level proceeds
derived from Moody's loan-level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type and sponsorship. Moody's also further adjusts these
aggregated proceeds for any pooling benefits associated with loan
level diversity and other concentrations and correlations.

Deal Performance

As of the September 15, 2014 distribution date, the transaction's
aggregate certificate balance has decreased by 96% to $45.5
million from $1.012 billion at securitization. The certificates
are collateralized by 16 mortgage loans ranging in size from less
than 2% to 19% of the pool, with the top ten loans constituting
90% of the pool. Two loans, constituting 4% of the pool, have
defeased and are secured by US government securities.

One loan, constituting 19% of the pool, is on the master
servicer's watchlist. The watchlist includes loans that meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, the agency reviews
the watchlist to assess which loans have material issues that
could affect performance.

Five loans have been liquidated from the pool, resulting in an
aggregate realized loss of $63 million (for an average loss
severity of 71.9%). No loans are currently in special servicing.

Moody's has assumed a high default probability for one poorly
performing loan, constituting 19% of the pool and has recognized
an expected loss for this loan.

Moody's received full year 2013 operating results for 100% of the
pool and full or partial year 2014 operating results for 86% of
the pool. Moody's weighted average conduit LTV is 69%, compared to
70% at Moody's last review. Moody's conduit component excludes
loans with structured credit assessments, defeased and CTL loans,
and specially serviced and troubled loans. Moody's net cash flow
(NCF) reflects a weighted average haircut of 11.6% to the most
recently available net operating income (NOI). Moody's value
reflects a weighted average capitalization rate of 9.2%.

Moody's actual and stressed conduit DSCRs are 1.23X and 1.53X,
respectively, compared to 1.21X and 1.52X at the last review.
Moody's actual DSCR is based on Moody's NCF and the loan's actual
debt service. Moody's stressed DSCR is based on Moody's NCF and a
9.25% stress rate the agency applied to the loan balance.

The top three conduit loans represent 57% of the pool balance. The
largest loan is the Sea Breeze Village Loan ($8.7 million -- 19.2%
of the pool), which is secured by a shadow-anchored retail
property in Las Vegas, Nevada. The shadow anchors are CVS and
Albertsons grocery store. At year-end 2013, The property was 90%
leased. Moody's LTV and stressed DSCR are 85% and 1.17X,
respectively, compared to 86% and 1.17X at the last review.

The second largest loan is the Plaza de Laredo Loan ($8.6 million
-- 19.0% of the pool), which is secured by a retail property
located in Laredo, Texas, approximately 2.5 hours south of San
Antonio. The top three tenants are Home Depot, Academy Sports &
Outdoors, and Office Depot. As of March 2014, the property was
100% leased. Moody's LTV and stressed DSCR are 68% and 1.47X,
respectively, compared to 69% and 1.46X at the last review.

The third largest loan is the Acacia Court Loan ($8.6 million --
18.9% of the pool), which is secured by a retail property located
in Tempe, Arizona. As of June 2014, the property was 78% leased.
The loan is on the Watchlist due to low DSCR and occupancy.
Moody's has identified this loan as a troubled loan due to its
poor performance and approaching maturity. Moody's LTV and
stressed DSCR are 155% and 0.73X, respectively, the same as at
last review.


WATERFRONT CLO 2007-1: Moody's Rates $11.5MM Cl. C Notes 'Ba1'
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the
following notes issued by Waterfront CLO 2007-1, Ltd.:

$32,000,000 Class A-2 Floating Rate Notes Due 2020, Upgraded to
Aaa (sf); previously on September 11, 2013 Affirmed Aa1 (sf)

$9,500,000 Class A-3 Floating Rate Notes Due 2020, Upgraded to
Aaa (sf); previously on September 11, 2013 Affirmed Aa3 (sf)

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

$195,000,000 Class A-1 Floating Rate Notes Due 2020 (current
outstanding balance of $104,486,540), Affirmed Aaa (sf);
previously on September 11, 2013 Affirmed Aaa (sf)

$19,000,000 Class B Deferrable Floating Rate Notes Due 2020,
Affirmed A3 (sf); previously on September 11, 2013 Upgraded to A3
(sf)

$11,500,000 Class C Deferrable Floating Rate Notes Due 2020,
Affirmed Ba1 (sf); previously on September 11, 2013 Affirmed Ba1
(sf)

$10,500,000 Class D Deferrable Floating Rate Notes Due 2020,
Affirmed Ba3 (sf); previously on September 11, 2013 Affirmed Ba3
(sf)

Waterfront CLO 2007-1, Ltd., issued in August 2007, is a
collateralized loan obligation (CLO) backed primarily by a
portfolio of senior secured loans. The transaction's reinvestment
period ended in October 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 January 2014. The Class A-1 Notes
have been paid down by $88.8 million, or 45.9% since then. Based
on the trustee's 3 October 2014 report, which does not reflect
principal payments of $12.7 million to the Class A-1 notes on the
15 October payment date, the over-collateralization ratios for the
Class A, B, C and D Notes are reported at 135.7%, 121.2%, 113.9%
and 107.9%, respectively, versus January 2014 levels of 124.2%,
114.9%, 109.9% and 105.7%, respectively.

The portfolio includes a number of investments in securities that
mature after the notes do. Based on the trustee's October 2014
report, securities that mature after the notes do currently make
up approximately 9.5% of the portfolio. 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.

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% (2118)

Class A-1: 0

Class A-2: 0

Class A-3: +1

Class B: +3

Class C: +2

Class D: +1

Moody's Adjusted WARF + 20% (3176)

Class A-1: 0

Class A-2: 0

Class A-3: -1

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 $202.1 million, defaulted
par of $2.5 million, a weighted average default probability of
17.89% (implying a WARF of 2647), a weighted average recovery rate
upon default of 44.69%, a diversity score of 45 and a weighted
average spread of 4.21%.

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.


WFRBS COMMERCIAL 2013-C17: Fitch Affirms 'BBsf' Rating on E Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed 13 classes of WFRBS commercial mortgage
Trust 2013-C17 pass-through certificates.

KEY RATING DRIVERS

The affirmations are due to the overall stable performance of the
underlying collateral pool.  Fitch reviewed the most recently
available financial performance data for the pool, as well as
updated rent rolls for the top 15 loans, which represent 54.4% of
the transaction.  Of the loans in the pool, 82.6% reported 2013
year-end financials.

As of the September 2014 distribution date, the pool's aggregate
principal balance has been reduced by 0.7% to $987.9 million from
$904.4 million at issuance.  Currently there are no specially
serviced or defeased loans.  Fitch has designated five loans
(10.1%) as Fitch Loans of Concern (LOC), three of which are also
reported on the servicer Watchlist.  The Fitch LOCs, though
underperforming expectations at issuance, continue to perform and
Fitch does not anticipate imminent default at this time.

The servicer reported a significant drop in occupancy at The
Barlow, a 174,901 square foot (SF) mixed-use retail and industrial
property located in Sebastopol, CA.  The property collateralizes
the 8th largest loan in the transaction, representing 2.7% of the
pool.  As of first quarter 2014 (1Q'14), the property occupancy
was reported at 78%, compared to 90% at year-end (YE) 2013 and
95.3% at issuance.  The debt service coverage ratio (DSCR) has
declined to 1.25x, compared to 1.3x at YE2013 and 1.59x at
issuance.  In reviewing the servicer provided rent roll, it
appears that a portion of the development that is not part of the
loan collateral was included in the tenant roster.  Fitch has
asked for clarification, but given that reported cash flow has
declined, Fitch will continue to monitor the loan's performance.

The largest loan in the pool, Hilton Sandestin Beach Resort & Spa
(8.4%), is a 10-year interest-only (IO) loan secured by a 598-room
full-service beachfront hotel located within the 2,400-acre
Sandestin Resort in Destin, Florida.  The loan is performing in
line with underwriting expectations.  Per the August 2014 STAR
report, trailing 12-month (TTM) occupancy, average daily rate
(ADR) and revenue per available room (RevPar) were 62.5%, $227.04,
and $141.91, respectively, compared to 67.4%, $209.59, and $141.26
at issuance.  The servicer reported 2Q'14 DSCR was 4.62x, compared
to 3.91x at issuance.

The second largest loan, Matrix Portfolio (7.3%), is a five-year
partial IO loan (i.e. interest-only for the initial 12 months)
secured by a portfolio of 11 cross-collateralized and cross-
defaulted manufactured housing communities located in Michigan (10
properties) and Alabama (one property) totaling 5,347 pads,
including 840 park-owned homes.  The portfolio consists of seven
all-age and four age-restricted properties.  The loan has a
companion $69.5 million pari-passu note which is part of the GS
2013-J16 transaction.  The loan is performing in line with issuer
underwriting expectations.  The servicer reported 2Q14 portfolio
DSCR and occupancy rate were 1.66x and 68%, compared to 1.51x and
68.7% at issuance.

The third largest loan (6.1%) is secured by 997,549 sf of the 1.6
million sf Westfield Mission Valley Mall in San Diego, CA.  The
property is well-located just north of San Diego, immediately off
of Interstate 8.  The Westfield Mission Valley Mall has 115 stores
and is anchored by Macy's (non-collateral), Target, Bed Bath &
Beyond and Nordstrom Rack.  The loan has a companion $100 million
pari-passu note which is part of the WFRBS 2013-C16 transaction.
The collateral is performing in line with underwritten
expectations.  As of July 2014, the property was 98.3% occupied,
the same level since issuance.  Servicer reported 1Q'13 DSCR was
3.0x, compared to 3.23x at issuance.

RATING SENSITIVITIES

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 these classes as indicated:

   -- $42 million class A-1 at 'AAAsf', Outlook Stable;
   -- $166.9 million class A-2 at 'AAAsf', Outlook Stable;
   -- $125 million class A-3 at 'AAAsf', Outlook Stable;
   -- $236.9 million class A-4 at 'AAAsf', Outlook Stable;
   -- $55.8 million class A-SB at 'AAAsf', Outlook Stable;
   -- $73.5 million class A-S at 'AAAsf', Outlook Stable;
   -- $58.8 million class B at 'AA-sf', Outlook Stable;
   -- $31.6 million class C at 'A-sf', Outlook Stable;
   -- $47.5 million class D at 'BBB-sf', Outlook Stable;
   -- $15.8 million class E at 'BBsf', Outlook Stable;
   -- $9 million class F at 'Bsf', Outlook Stable;
   -- Interest - Only class X-A at 'AAAsf'; Outlook Stable;
   -- Interest - Only class X-B at 'AA-sf'; Outlook Stable.

Fitch does not rate the class G or class X-C certificates.



* Moody's Hikes Rating on $84MM of RMBS Issued 2003-2004
--------------------------------------------------------
Moody's Investors Service has upgraded the ratings of nine
tranches from six 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: Bear Stearns Asset Backed Securities I Trust 2004-BO1

Cl. M-6, Upgraded to Ba1 (sf); previously on Jan 24, 2014 Upgraded
to Ba3 (sf)

Cl. M-7, Upgraded to B3 (sf); previously on Jan 24, 2014 Upgraded
to Caa2 (sf)

Cl. M-8, Upgraded to Ca (sf); previously on Feb 4, 2013 Affirmed C
(sf)

Issuer: Credit Suisse Mortgage Capital Trust 2006-CF1

Cl. B-1, Upgraded to Caa1 (sf); previously on Feb 4, 2013 Affirmed
Caa3 (sf)

Issuer: GSAMP Trust 2005-SD2

Cl. M-3, Upgraded to B1 (sf); previously on Feb 4, 2013 Affirmed
B3 (sf)

Issuer: GSRPM Mortgage Loan Trust 2003-1

Cl. B-1, Upgraded to Baa3 (sf); previously on Feb 4, 2013 Affirmed
Ba1 (sf)

Issuer: Soundview Home Loan Trust 2003-1

Cl. M-4, Upgraded to B1 (sf); previously on Feb 4, 2013 Downgraded
to B3 (sf)

Issuer: Truman Capital Mortgage Loan Trust 2004-1

Cl. M-2, Upgraded to Ba3 (sf); previously on Jan 24, 2014 Upgraded
to B2 (sf)

Cl. M-3, Upgraded to Ca (sf); previously on Feb 4, 2013 Affirmed C
(sf)

Ratings Rationale

The rating actions are a result of the recent performance of the
underlying pools and reflect Moody's updated loss expectations on
the pools. The ratings upgraded are primarily due to the build-up
in credit enhancement due to sequential pay structure, non-
amortizing subordinate bonds, and availability of excess spread.
Performance has remained generally stable from Moody's last
review.

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 5.9% in September 2014 from
7.2% in September 2013. Moody's forecasts an unemployment central
range of 6% to 7% 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 $848MM Alt-A RMBS Issued 2005-2007
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 22 tranches
and downgraded the ratings of seven tranches from 13 transactions
issued by miscellaneous issuers. The tranches are backed by Alt-A
RMBS loans issued from 2005 to 2007.

Complete rating actions are as follows:

Issuer: Banc of America Funding 2005-C Trust

Cl. A-1, Upgraded to B1 (sf); previously on Jul 8, 2010 Downgraded
to B3 (sf)

Cl. A-2, Upgraded to Ba3 (sf); previously on Aug 8, 2012 Upgraded
to B2 (sf)

Issuer: Banc of America Funding 2006-G Trust

Cl. 2-A-1, Upgraded to Ba3 (sf); previously on Jan 9, 2014
Upgraded to B2 (sf)

Cl. 2-A-4, Upgraded to Ba3 (sf); previously on Jan 9, 2014
Upgraded to B1 (sf)

Cl. 2-A-5, Upgraded to B3 (sf); previously on Jan 9, 2014 Upgraded
to Caa2 (sf)

Issuer: Banc of America Funding 2007-4 Trust

Cl. 2-A-3, Downgraded to Caa2 (sf); previously on Aug 8, 2012
Downgraded to Caa1 (sf)

Cl. 2-A-4, Downgraded to Caa2 (sf); previously on Aug 8, 2012
Downgraded to Caa1 (sf)

Cl. 6-A-1, Downgraded to Ba3 (sf); previously on Apr 10, 2013
Downgraded to Ba1 (sf)

Cl. 7-A-1, Downgraded to Caa1 (sf); previously on Apr 10, 2013
Affirmed B2 (sf)

Issuer: Citigroup Mortgage Loan Trust, Series 2005-WF1

Cl. A-4, Upgraded to Ba2 (sf); previously on Nov 19, 2010
Downgraded to B1 (sf)

Issuer: Citigroup Mortgage Loan Trust, Series 2005-WF2

Cl. MV-2, Upgraded to Baa3 (sf); previously on Jan 21, 2014
Upgraded to Ba1 (sf)

Cl. MV-3, Upgraded to B3 (sf); previously on Jan 21, 2014 Upgraded
to Caa2 (sf)

Issuer: CWALT, Inc. Mortgage Pass-Through Certificates, Series
2005-J4

Cl. M-1, Upgraded to Baa1 (sf); previously on Jul 26, 2013
Upgraded to Baa3 (sf)

Issuer: GSAA Home Equity Trust 2005-11

Cl. 3A4, Upgraded to Ba3 (sf); previously on Mar 11, 2011
Downgraded to B3 (sf)

Issuer: GSAA Home Equity Trust 2005-3

Cl. M-2, Upgraded to Ba2 (sf); previously on Jan 15, 2014 Upgraded
to B2 (sf)

Cl. B-1, Upgraded to Ca (sf); previously on Aug 29, 2012
Downgraded to C (sf)

Issuer: GSAA Home Equity Trust 2005-9

Cl. 2A3, Upgraded to Baa1 (sf); previously on Jul 24, 2013
Upgraded to Baa3 (sf)

Cl. 2A4, Upgraded to Ba2 (sf); previously on Jul 24, 2013 Upgraded
to B1 (sf)

Cl. M-1, Upgraded to B3 (sf); previously on Aug 16, 2012 Upgraded
to Caa2 (sf)

Cl. M-2, Upgraded to Ca (sf); previously on May 11, 2010
Downgraded to C (sf)

Issuer: GSAA Home Equity Trust 2005-MTR1

Cl. A-4, Upgraded to Ba1 (sf); previously on Jan 15, 2014 Upgraded
to Ba3 (sf)

Cl. A-5, Upgraded to Caa1 (sf); previously on Jan 15, 2014
Upgraded to Caa3 (sf)

Issuer: Morgan Stanley Mortgage Loan Trust 2005-5AR

Cl. 1-A-4, Upgraded to Baa1 (sf); previously on Apr 26, 2013
Upgraded to Baa3 (sf)

Cl. 1-M-1, Upgraded to Ba1 (sf); previously on Jan 22, 2014
Upgraded to Ba3 (sf)

Cl. 1-M-2, Upgraded to B3 (sf); previously on Apr 26, 2013
Upgraded to Caa2 (sf)

Cl. 1-M-3, Upgraded to Caa2 (sf); previously on Apr 26, 2013
Upgraded to Ca (sf)

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

Cl. V-A-1, Downgraded to A1 (sf); previously on Jul 12, 2010
Confirmed at Aa1 (sf)

Issuer: Opteum Mortgage Acceptance Corporation Asset Backed Pass-
Through Certificates 2006-1

Cl. II-A2, Downgraded to C (sf); previously on Jun 20, 2013
Downgraded to Caa3 (sf)

Cl. II-APT, Downgraded to Caa2 (sf); previously on Jun 20, 2013
Downgraded to Caa1 (sf)

Ratings Rationale

The rating actions are a result of performance on the underlying
pools and reflect Moody's updated loss expectations on the pools.
The rating upgrades are due to stable pool performance and build
up of credit enhancement from excess spread. The rating downgrades
are due to the weak performance of the underlying collateral.

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 5.9% in September 2014 from
7.2% in September 2013 . Moody's forecasts an unemployment central
range of 6% to 7% for the 2014 year. Deviations from this central
scenario could lead to rating actions in the sector.

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

Finally, performance of RMBS continues to remain highly dependent
on servicer procedures. Any change resulting from servicing
transfers or other policy or regulatory change can impact the
performance of these transactions.


* S&P Takes Actions on 11 BlackRock Fund Exchange-Traded Funds
--------------------------------------------------------------
Standard & Poor's Ratings Services, on Oct. 17, 2014, said it
raised its fund credit quality ratings on nine BlackRock Fund
Advisors (BFA) funds and lowered its fund credit quality ratings
on two other funds.  In addition, S&P raised its fund volatility
ratings on two BFA funds.

"We raised the ratings on the iShares Emerging Markets Corporate
Bond ETF because of the fund's decreased aggregate exposures to
'CCC/CC' rated issues.  We raised the fund credit quality rating
on the iShares Emerging Markets Local Currency Bond ETF as a
result of lower rated countries falling out of the eligible
investment list for the fund.  We raised the fund credit quality
rating on the iShares Global High Yield Corporate Bond ETF because
the fund has continued to represent the high-yield market trend of
somewhat higher ratings and less 'CC' exposure.  We raised our
fund credit quality ratings on five BFA municipal funds because of
a change in the funds' eligible investment list.  The funds
represent the change in the underlying municipal indices, which
exclude U.S. territories and which had exposed the funds to lower
rated securities.  Each BFA fund seeks investment results that
correspond generally to the price and yield performance, before
fees and expenses, of its corresponding index.  The indices
represent the respective asset classes, and the current credit
quality of those asset classes has been generally higher than in
the past," S&P said.

"We lowered our credit quality ratings on the iShares Baa - Ba
Rated Corporate Bond ETF because of the fund's aggregate exposure
to issues that have come under stress in the economy.  The Global
Inflation-Linked fund is exposed to international countries that
have undergone recent downgrades.  Each fund seeks investment
results that correspond generally to the price and yield
performance, before fees and expenses, of its underlying index
that represents the corresponding market.  The current credit
quality of the indices is generally lower than in the past," S&P
added.

S&P raised the fund volatility rating on the iShares iBonds Sep
2015 AMT-Free Muni Bond ETF to 'S1' and the iShares iBonds Sep
2018 AMT-Free Muni Bond ETF to 'S2' because the funds will wind
down and terminate on Aug. 31, 2015, and Aug. 31, 2018,
respectively.  As a result, the volatility of monthly returns of
the ETFs have continued to decrease as the bonds near maturity.
Each fund seeks investment results that correspond generally to
the price and yield performance, before fees and expenses, of the
S&P AMT-Free Municipal Series Index of its corresponding year,
which measures the performance of investment-grade, noncallable
U.S. municipal bonds maturing in that year.

BFA, the funds' investment adviser, is a subsidiary of BlackRock
Inc.  As of Sept. 30, 2014, BlackRock Inc. and its affiliates
provided investment advisory services for assets estimated to
exceed $4.525 trillion.  State Street Bank & Trust Co. is the
administrator, custodian, and transfer agent for the fund.
BlackRock Investments LLC, a subsidiary of BlackRock Inc., is the
fund's distributor.

S&P's credit quality and volatility ratings are based on its
analysis of a fund's eligible portfolio investments and strategy,
historical return volatility, and management.  The fund credit
quality rating scale ranges from 'AAAf' (highest level of
protection) to 'CCCf' (least protection).  The ratings from 'AAf'
to 'CCCf' may be modified by the addition of a plus (+) or minus
(-) sign to show relative standing within the major rating
categories.

Volatility ratings range from lowest volatility ('S1', with
certain funds designated a plus sign [+] to indicate the fund's
extremely low sensitivity to changing market conditions) to
highest volatility ('S6').  The ratings are based on S&P's
analysis of a fund's investment strategy and portfolio risk,
including interest rate risk, credit quality, liquidity,
concentration, call and option risk, and currency risk.  S&P also
factors into the ratings the effects of various portfolio
strategies, such as the use of leverage, hedging, and derivative
instruments.

RATINGS LIST

Upgraded; Affirmed
                                                  To         From
iShares(R) iBonds(R) Sep 2016 AMT-Free Muni Bond ETF
iShares(R) iBonds(R) Sep 2017 AMT-Free Muni Bond ETF
iShares Short-Term National AMT-Free Muni Bond ETF
Fund Credit Quality Rating/Fund Volatility Rating
                                                AAf/S2     AA-f/S2

iShares(R) iBonds(R) Sep 2019 AMT-Free Muni Bond ETF
Fund Credit Quality Rating/Fund Volatility Rating
                                                 AAf/S3     A+f/S3

iShares Emerging Markets Corporate Bond ETF
Fund Credit Quality Rating/Fund Volatility Rating
                                                 BBf/S4    BB-f/S4

iShares Emerging Markets Local Currency Bond ETF
Fund Credit Quality Rating/Fund Volatility Rating
                                                BBB-f/S4   BB+f/S4

iShares Global High Yield Corporate Bond
Fund Credit Quality Rating/Fund Volatility Rating
                                                 Bf/S4      B-f/S4

Upgraded
                                                   To         From
iShares(R) iBonds(R) Sep 2015 AMT-Free Muni Bond ETF
Fund Credit Quality Rating/Fund Volatility Rating
                                                AAf/S1     AA-f/S2

iShares(R) iBonds(R) Sep 2018 AMT-Free Muni Bond ETF
Fund Credit Quality Rating/Fund Volatility Rating
                                                AAf/S2     AA-f/S3

Downgraded; Affirmed
                                                   To         From
iShares Baa - Ba Rated Corporate Bond ETF
Fund Credit Quality Rating/Fund Volatility Rating
                                               BB+f/S3    BBB-f/S3

iShares Global Inflation-Linked Bond ETF
Fund Credit Quality Rating/Fund Volatility Rating
                                                  A-f/S4     Af/S4



                             *********

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
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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
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Sheryl Joy P. Olano, Psyche A. Castillon, Ivy B. Magdadaro, Carlo
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Copyright 2014.  All rights reserved.  ISSN: 1520-9474.

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