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         T R O U B L E D   C O M P A N Y   R E P O R T E R

             Sunday, August 14, 2011, Vol. 15, No. 224

                            Headlines

ACAS BUSINESS: Fitch Affirms Junk Rating on $50 Mil. Class D Notes
ACAS BUSINESS: Fitch Affirms Rating on Four Note Classes
ACAS BUSINESS: Fitch Ups Rating on $90MM Cl. D Notes to 'Bsf'
ACAS BUSINESS: Good Notes Performance Cues Fitch to Hold Ratings
ACAS BUSINESS: S&P Affirms 'CCC-' Rating on Class D Notes

ACAS BUSINESS: Stable Performance Cues Fitch to Affirm Ratings
ALPINE SECURITIZATION: DBRS Assigns B Rating on $41.6MM Tranche
AMMC CLO: Moody's Upgrades Ratings of Four Classes of CLO Notes
APIDOS CDO: Moody's Upgrades Ratings of Five Classes of CLO Notes
ARES IIR/IVR: Moody's Upgrades Ratings of 6 Classes of CLO Notes

ARES XII: Moody's Upgrades Ratings of Five Classes of CLO Notes
ASHFORD CDO: Moody's Upgrades Ratings of Floating Rate Notes
AVENUE CLO: Moody's Upgrades Ratings of Five Classes of Notes
BABSON CLO: Moody's Upgrades Ratings of 7 Classes of Notes
BABSON LOAN: Moody's Upgrades Ratings of Five Classes of Notes

BALLYROCK CLO: Moody's Upgrades Ratings of 5 Classes of CLO Notes
BANC OF AMERICA: Fitch Affirms Junk Rating on Two Class Certs.
BANC OF AMERICA: Moody's Affirms Ratings of 23 CMBS Classes
BANKUNITED TRUST: S&P Raises Rating on RMBS Class I-A-2 to 'BB'
BEAR STEARNS: Losses Across the Pool Cues Fitch to Lower Ratings

BEAR STEARNS: Moody's Affirms Ratings of Eight CMBS Classes
BEAR STEARNS: Moody's Affirms Ratings of Five CMBS Classes
BEAR STEARNS: Moody's Upgrades Ratings of Eight CMBS Classes
BECKMAN COULTER: Fitch Holds 'BB-' Rating on $97 Mil. Class Notes
BLUEMOUNTAIN CLO: S&P Gives 'BB' Rating on Class E Notes

BRIDGEPORT CLO: Moody's Upgrades Ratings of 4 Classes of CLO Notes
BRIDGEPORT CLO: Moody's Upgrades Ratings of Floating Rate Notes
CALLIDUS DEBT: Moody's Upgrades Ratings of 5 Classes of Notes
CASHEL ROCK: S&P Withdraws 'B+' Rating on Class B Notes
CIT MARINE: S&P Affirms Rating on Certificate at 'B'

CITIGROUP COMMERCIAL: S&P Cuts Rating on Class HTT-2 to 'CCC+'
COLUMBUS PARK: Moody's Upgrades Ratings of 3 Classes of CLO Notes
COLUMBUSNOVA CLO: Moody's Raises Ratings of Five Classes of Notes
COLUMBUSNOVA CLO: Moody's Upgrades Ratings of CLO Notes
COMM 2004-LNB4: Moody's Downgrades Ratings of Seven CMBS Classes

COMM 2004-RS1: S&P Lowers Ratings on 3 Classes of Certs. to 'CCC-'
COMMERCIAL MORTGAGE: Moody's Affirms Ratings of 11 CMBS Classes
COMMERCIAL MORTGAGE: Moody's Affirms Ratings of Seven CMBS Classes
CREDIT SUISSE: Fitch Affirms Ratings of 14 Classes
DAVIS SQUARE: S&P Lowers Ratings on 5 Classes of Notes to 'D'

DLJ COMMERCIAL: Fitch Downgrades Rating on Class B-5 to 'Dsf/RR6'
DRYDEN VII-LEVERAGED: Moody's Upgrades Ratings of CLO Notes
DUNSMUIR CITY: Moody's Lowers Certificates Rating To Ba2 From Ba1
EATON VANCE: Moody's Upgrades Ratings of Six Classes of CLO Notes
FMC REAL ESTATE: Moody's Upgrades Ratings of Four CRE CDO Classes

FOUR CORNERS: Moody's Upgrades Ratings of 5 classes of CLO Notes
FRANKLIN CLO: Moody's Upgrades Ratings of 3 Classes of CLO Notes
GALAXY IV CLO: Moody's Upgrades Ratings of 7 Classes of CLO Notes
GE CAPITAL: Fitch Downgrades GECC Series 2001-1 Ratings
GE COMMERCIAL: Stable Performance Cues Fitch to Affirm Ratings

GMAC COMMERCIAL: S&P Lowers Ratings on 3 Classes of Certs. to 'D'
GOLDMAN SACHS: Moody's Upgrades Ratings of 6 Classes of CLO Notes
GRAMERCY REAL: Fitch Affirms Ratings of All Classes
GRANITE VENTURES: Moody's Upgrades Ratings of CLO Notes
GRAYSON CLO: Moody's Upgrades Ratings of 7 Classes of CLO Notes

GREENWICH CAPITAL: Fitch Affirms Ratings of All Classes
GS MORTGAGE: S&P Lowers Ratings on 3 Classes of Notes to 'D'
GUGGENHEIM 2006-3: Fitch Affirms Junk Rating on 3 Class Notes
GUGGENHEIM 2006-4: Fitch Affirms Junk Rating on Six Class Notes
GULF STREAM: Moody's Upgrades Ratings of 7 Classes of CLO Notes

HALCYON STRUCTURED: Moody's Raises Ratings of of CLO Notes
ING INVESTMENT: Moody's Upgrades Ratings of 6 Classes of CLO Notes
JEFFERIES RESECURITIZATION: S&P Affirms 'CC' Ratings on 2 Classes
JERSEY STREET: Moody's Upgrades Ratings of Four Classes of Notes
JP MORGAN: Losses Across the Pool Cues Fitch to Lower Ratings

JP MORGAN: Stable Performance Prompts Fitch to Affirm Ratings
JPMORGAN: Fitch Downgrades JPMorgan Series 2000-C10 Ratings
KATONAH 2007-1: Moody's Upgrades Ratings of Floating Rate Notes
LANDMARK VI: Moody's Upgrades Ratings of 5 Classes of CLO Notes
LB-UBS COMMERCIAL: Expected Losses Cue Fitch to Downgrade Ratings

LB-UBS COMMERCIAL: Moody's Affirms Ratings of 13 CMBS Classes
LB-UBS COMMERCIAL: Moody's Affirms Ratings of 19 CMBS Classes
LCM II: Moody's Upgrades Ratings of Six Classes of CLO Notes
LIGHTPOINT CLO: Moody's Upgrades Ratings of 5 Classes of Notes
MARKET SQUARE: Moody's Upgrades Ratings of Four Classes of Notes

MORGAN STANLEY: Fitch Takes Action on MSCI 2004-Top13 Ratings
MORGAN STANLEY: Fitch Takes Various Rating Actions
MORGAN STANLEY: Moody's Downgrades Ratings of 3 CRE CDO Classes
MOSELLE CLO: S&P Raises Ratings on 2 Classes of Notes From 'BB+'
MOUNTAIN CAPITAL: Moody's Upgrades Ratings of CLO Notes

NYLIM FLATIRON: Moody's Upgrades Ratings of Six Classes of Notes
OLYMPIC CLO: Moody's Upgrades Ratings of 4 Classes of CLO Notes
PORTOLA CLO: Moody's Upgrades Ratings of Six Classes of Notes
PREFERRED TERM: S&P Affirms Ratings on 2 Notes Classes at 'CCC-'
PRUDENTIAL SECURITIES: Moody's Raises Ratings of Two CMBS Classes

REPACS TRUST: Moody's Rates Repacs Trust Series Watto I Notes Caa1
RIVERSIDE PARK: S&P Gives 'BB' Rating on Class D Deferrable Notes
RYLAND MORTGAGE: Fitch Withdraws Rating on One Class
SECURITY NATIONAL: Moody's Downgrades Ratings of One Tranche
STRUCTURED ASSET: Moody's Confirms Ratings of Four Tranches

UBS COMMERCIAL: Fitch Upgrades Rating on Class B Loan to 'BB'
VENTURE IV: Moody's Upgrades Ratings of Seven Classes of CLO Notes
WACHOVIA BANK: Moody's Affirms Ratings of 27 CMBS Classes
WACHOVIA BANK: Fitch Affirms Ratings of Pooled Classes
WACHOVIA BANK: Moody's Reviews Nine CMBS Classes; Might Downgrade

WESTWOOD CDO: Moody's Upgrades Ratings of 6 Classes of CLO Notes
WIND RIVER: Moody's Upgrades Ratings of Six Classes of CLO Notes
ZAIS INVESTMENT: Moody's Upgrades Ratings of Four Classes of Notes
ZAIS INVESTMENT: Moody's Upgrades Ratings of Six Classes of Notes

* S&P Cuts Ratings on 10 Classes of Certs. to 'D' on Shortfalls
* S&P Cuts Ratings on 10 Classes of Pass-through Certs. to 'D'
* S&P Raises Ratings on 8 Ford-Related Transactions to 'BB-'



                            *********



ACAS BUSINESS: Fitch Affirms Junk Rating on $50 Mil. Class D Notes
------------------------------------------------------------------
Fitch Ratings has upgraded one class and affirmed one class of
notes issued by ACAS Business Loan Trust 2004-1 (ACAS BLT 2004-1):

  -- $30,943,219 class C notes upgraded to 'BBBsf'from 'BBsf';
     Outlook revised to Stable from Negative;

  -- $50,000,000 class D notes affirmed at 'CCCsf'; Recovery
     Rating revised to 'RR2' from 'RR4'.

The upgrade of the class C notes reflects the significant increase
of credit enhancement since the last rating action in August 2010.
The class C notes began to receive principal payments on the April
2011 payment date, driven by loan prepayments and excess spread
used to pay down the Additional Principal Amount (APA).  As of the
July 2011 payment date, 58% of the class C notes have paid down.
The notes are likely to perform under rating modeled stresses
above the 'BBBsf' category; however, a rating above 'BBBsf' would
not appropriately reflect the concentration of the portfolio's
exposure to 12 performing obligors.  Fitch expects the rating of
the class C notes to remain stable in the near term and has
revised the Outlook to Stable.

The affirmation on the class D notes are based on the improved
credit enhancement levels for the notes, tempered by the increased
concentration of the portfolio.  The improved credit enhancement
levels increased the recovery estimates on the class D notes, but
the notes continue to be exposed to default risk with only 12
performing obligors remaining.  The largest obligor is
approximately $14.9 million, or 13.7%, of the portfolio, and
second lien and subordinate loans, which have low recovery
prospects upon default, represent approximately 82.5% of the
performing portfolio.  The notes are likely to perform under
modeled stresses in the 'Bsf' category, but the ability of the
notes to be fully repaid relies upon the performance of a limited
number of companies with distressed ratings.

The notes of ACAS BLT 2004-1 have credit enhancement in the form
of collateral coverage, note subordination, and the application of
excess spread via the APA.  Upon the occurrence of a default in
the portfolio, the APA feature directs part or all of the excess
interest otherwise available to the equity to pay down the senior-
most notes in an amount equal to the aggregate balance of
defaulted assets in the portfolio.  Since Fitch's last rating
action the servicer has considered an additional $2.7 million of
loans as defaulted, while approximately $20.8 million of excess
spread has been used to pay principal to the senior notes.  The
APA was approximately $13.7 million on the July 2011 payment date,
compared to $31.7 million in July 2010.

The Recovery Rating (RR) on the class D notes was revised to 'RR2'
from 'RR4', as discounted cash flows yield a recovery projection
in a range between 70 - 90% in a base-case default scenario.
Recovery Ratings are designed to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities rated 'CCCsf' or below.  For further
details on Recovery Ratings, please see Fitch's reports 'Global
Rating Criteria for Corporate CDOs' and 'Criteria for Structured
Finance Recovery Ratings'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs' using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  As previously mentioned, both classes of notes passed
in modeled scenarios at rating levels above their current ratings.
However, Fitch's rating actions deviated from the modeling results
due to the concentration risks stated above.

ACAS BLT 2004-1 is a collateralized debt obligation (CDO) that
closed on Dec. 2, 2004, and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in Jan. 2007, and it is scheduled to mature in Oct.
2017.  ACAS BLT 2004-1 is secured by a portfolio of middle-market
loans.  The majority of these loans are not publicly rated, but
Fitch establishes model-based credit opinions for the performing
loans.  Information for the credit opinions was gathered from
financial statements provided to Fitch by ACAS.  The performing
loan portfolio consists of $108.6 million from 12 unique obligors,
with three of the largest obligors comprising approximately 40.2%
of the total portfolio.  Fitch considers approximately 57.7% of
the portfolio to be rated 'CCC', compared to 18.5% in the last
review, while none of the remaining obligors are rated above 'B+'.


ACAS BUSINESS: Fitch Affirms Rating on Four Note Classes
--------------------------------------------------------
Fitch Ratings has affirmed four classes of notes issued by ACAS
Business Loan Trust 2007-1 (ACAS BLT 2007-1):

  -- $72,197,050 class A notes at 'AAsf'; Outlook Stable;

  -- $36,095,289 class B notes at 'Asf'; Outlook revised to Stable
     from Negative;

  -- $64,971,520 class C notes at 'BBsf'; Outlook Negative;

  -- $36,095,289 class D notes at 'Bsf'; Outlook Negative.

The affirmation of the notes is based on the generally stable
performance of the transaction since Fitch's last rating action in
August 2010.  Since that time, each class of notes has benefited
from increased credit enhancement levels due to the significant
principal repayment of the class A notes.  However, the underlying
loan portfolio is becoming increasingly concentrated in low-rated
second lien and subordinated loans.

Through a combination of loan repayments and the diversion of
excess spread to pay principal on the notes, the class A notes
have received over $85 million of principal payments since Fitch's
last rating action.  Both the class A and B notes have a Stable
Rating Outlook reflecting the fact that they are well-positioned
to withstand future credit deterioration in the portfolio due to
their senior priorities and the degree of overcollateralization
available to these notes.  As of the May 15, 2011 servicer report
Fitch considers the performing portfolio balance to consist of
over $257 million of loans.

Fitch maintains Negative Rating Outlooks on the class C and D
notes due to the high degree of obligor concentration and the
increasingly risky characteristics of the underlying loans.  The
performing loan portfolio consists of 20 unique obligors, with
eight obligors each accounting for almost 7% of the total
portfolio. Fitch considers approximately 35% of the performing
portfolio to be rated 'CCC', compared to 17% at Fitch's last
rating action, while none of the remaining obligors are rated
above 'B+'.  Finally, over 90% of the performing portfolio
represents junior secured or unsecured loans, which indicates low
recovery prospects upon default.

The notes of ACAS BLT 2007-1 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the additional principal amount
(APA).  Upon the occurrence of a default in the portfolio, the APA
feature directs part or all of the excess interest otherwise
available to the equity to pay down the senior-most notes in an
amount equal to the aggregate balance of defaulted assets in the
portfolio.  Since Fitch's last rating action the servicer has
considered an additional $14.7 million of loans as defaulted,
while over $24.5 million of excess spread has been used to pay
principal to the class A notes. The APA stands at approximately
$36.3 million after the May 15, 2011 payment, compared to
$46.1 million in May 2010.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs' using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  Each class of notes passed the various stress scenarios
at rating levels in line with their current ratings.

ACAS BLT 2007-1 is a collateralized debt obligation (CDO) that
closed on April 24, 2007 and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in November 2007.  ACAS BLT 2007-1 is secured by a
portfolio of middle-market loans.  The majority of these loans are
not publicly rated; instead, Fitch establishes model-based credit
opinions for the performing loans.  Information for the credit
opinions was gathered from financial statements provided to Fitch
by ACAS.


ACAS BUSINESS: Fitch Ups Rating on $90MM Cl. D Notes to 'Bsf'
-------------------------------------------------------------
Fitch Ratings has upgraded two classes and affirmed three classes
of notes issued by ACAS Business Loan Trust 2005-1 (ACAS BLT 2005-
1):

   -- $63,285,411 class A-1 notes affirmed at 'AAAsf'; Outlook
      revised to Stable from Negative;

   -- $29,096,741 class A-2B notes affirmed at 'AAAsf'; Outlook
      revised to Stable from Negative;

   -- $50,000,000 class B notes upgraded to 'AAsf' from 'Asf';
      Outlook revised to Stable from Negative;

   -- $145,000,000 class C notes affirmed at 'BBsf'; Outlook
      revised to Stable from Negative;

   -- $90,000,000 class D notes upgraded to 'Bsf' from
      'CCCsf/RR4'; Outlook Stable.

The upgrades of the class B and class D notes are the result of
the increased credit enhancement levels and the improved
performance of the notes since Fitch's last review in August 2010.

As of the July 2011 payment date, the class A-2A notes were paid
in full and approximately 85.5% and 41.8% of the class A-1 and
class A-2B notes, respectfully, were paid down.  The amortization
of the class A notes was largely driven by loan prepayments and
excess spread used to pay the Additional Principal Amount (APA).

Excess spread plays a significant role in the transaction, as the
class B and class D notes are likely to perform under higher
rating stresses.  However, the underlying loan portfolio has
become more concentrated in low-rated second lien and subordinated
loans.  The current portfolio contains 28 performing obligors,
represented by 74.6% of second lien or subordinated loans, which
have low recovery prospects upon default.  The rating actions
reflect these concentration risks, which are expected to increase
over the longer term, and may limit the benefit of excess spread,
and subsequently, introduce more volatility to the notes'
performance.  The revised Outlooks indicate the notes' stable
performance under their current rating stresses and Fitch's
expectation that the ratings of the notes will remain stable for
the near term.  The Recovery Rating was also removed and a Stable
Outlook was assigned to the class D notes, as a result of the
upgrade.

Similarly, the affirmation and revised Outlook of the class C
notes is based on the improving performance of the notes, amid the
growing concentration risks of the portfolio.  As with the other
notes, the class C notes are likely to perform under modeled
stresses above their current rating category.  However, the
concentration risks and portfolio quality supporting these notes
is in line with a 'BBsf' rating.  Therefore, Fitch has affirmed
the class C notes at its current rating and revised the Outlook to
Stable.

The notes of ACAS BLT 2005-1 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the additional principal amount
(APA).  Upon the occurrence of a default, the APA feature directs
part or all of the excess interest otherwise available to the
equity to pay down the senior-most notes in an amount equal to the
aggregate balance of defaulted assets in the portfolio.  Since
Fitch's last rating action the servicer has considered an
additional $51.5 million of loans as defaulted, while
approximately $138.8 million of excess spread has been used to
pay principal to the class A notes.  The APA stands at
approximately $23.3 million after the July 2011 payment, compared
to $110.6 million in July 2010.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs.  As mentioned above, all classes of notes, with the
exception of the class A notes, passed in various stress scenarios
in rating categories above their current ratings.  However,
Fitch's rating actions deviated from these modeling results due to
the concentration risks stated above.

ACAS BLT 2005-1 is a collateralized debt obligation (CDO) that
closed on Oct. 4, 2005 and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in January 2009.  ACAS BLT 2005-1 is secured by a
portfolio of middle-market loans. The majority of these loans are
not publicly rated; instead, Fitch establishes model-based credit
opinions for the performing loans.  Information for the credit
opinions was gathered from financial statements provided to Fitch
by ACAS.  The performing loan portfolio consists of $456.2 million
from 28 unique obligors, with the three largest obligors
comprising approximately 22.4% of the total portfolio.  Fitch
considers approximately 37.9% of the portfolio to be rated 'CCC',
compared to 12.7% in the last review, while 4.0% is rated 'BB-'
and the remaining obligors are rated in the 'B' category.


ACAS BUSINESS: Good Notes Performance Cues Fitch to Hold Ratings
----------------------------------------------------------------
Fitch Ratings has affirmed the notes issued by ACAS Business Loan
Trust 2006-1 (ACAS BLT 2006-1):

  -- $94,239,641 class A notes at 'Asf'; Outlook revised to Stable
     from Negative;

  -- $37,000,000 class B notes at 'BBBsf'; Outlook revised to
     Stable from Negative;

  -- $72,500,000 class C notes at 'Bsf'; Outlook revised to Stable
     from Negative;

  -- $35,500,000 class D notes at 'CCCsf'; Recovery Rating revised
     to 'RR3' from 'RR5'.

The affirmations and revised Outlooks are based on the overall
improvement of the notes' performance, countered by the growing
concentration risks of the portfolio.  As of the May 2011 payment
date, approximately 67.6% of the class A notes have paid down,
driven by loan prepayments and the excess spread used to pay
down the Additional Payment Amount (APA).  However, the current
performing portfolio is concentrated in 23 obligors, and
approximately 85.4% of the performing portfolio is composed of
low-rated second lien loans or subordinated loans, which indicates
low recovery prospects upon default.  The rating actions reflect
these concentration risks, which are expected to increase over the
longer term, and subsequently introduce more volatility to the
notes' performance.  The revised Outlooks indicate the notes'
stable performance under their current rating stresses and Fitch's
expectation that the ratings of the notes will remain stable for
the near term.

The notes of ACAS BLT 2006-1 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the APA.  Upon the occurrence of
a default in the portfolio, the APA feature directs part or all of
the excess interest otherwise available to the equity to pay down
the senior-most notes in an amount equal to the aggregate balance
of defaulted assets in the portfolio.  Since Fitch's last rating
action the servicer has considered an additional $36.7 million of
loans as defaulted, while approximately $38.7 million of excess
spread has been used to pay principal to the class A notes.  The
APA stands at approximately $55.4 million after the May 2011
payment date, compared to $57.5 million in May 2010.

The Recovery Rating (RR) on the class D notes was revised to 'RR3'
from 'RR5', as discounted cash flows yield a recovery projection
in a range between 50 - 70% in a base-case default scenario.
Recovery Ratings are designed to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities rated 'CCCsf' or below. For further
details on Recovery Ratings.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  The class A and class B notes passed modeled scenarios
at rating levels above their current ratings.  However, the rating
actions deviated from the modeling results due to the
concentration risks stated above.  The class C and class D notes
passed stress scenarios at rating levels in line with their
current ratings categories.

ACAS BLT 2006-1 is a collateralized debt obligation (CDO) that
closed on July 28, 2006 and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in August 2009.  ACAS BLT 2006-1 is secured by a
portfolio of middle-market loans.  The majority of these loans are
not publicly rated, but Fitch establishes model-based credit
opinions for the performing loans.  Information for the credit
opinions was gathered from financial statements provided to Fitch
by ACAS.  The performing loan portfolio consists of $276.0 million
from 23 unique obligors, with the three largest obligors
comprising approximately 18.1% of the total portfolio.  Fitch
considers approximately 48.8% of the portfolio to be rated 'CCC',
compared to 30.8% in the last review, while none of the remaining
obligors are rated above 'B+'.


ACAS BUSINESS: S&P Affirms 'CCC-' Rating on Class D Notes
---------------------------------------------------------
Standard & Poor's Ratings Services raised its rating to 'BBB+
(sf)' from 'BBB- (sf)' on the class B notes from ACAS Business
Loan Trust 2006-1, a U.S. collateralized loan obligation (CLO)
transaction managed by American Capital Ltd. "At the same time, we
affirmed our ratings on the class A, C, and D notes and removed
ratings on the classes A, B, C, and D from CreditWatch, where we
placed them with positive implications on May 3, 2011," S&P
related.

Standard & Poor's last lowered its ratings on all of the rated
notes on March 31, 2010, which followed the application of our
September 2009 corporate collateralized debt obligation (CDO)
criteria. The March 2010 rating action used figures obtained from
the February 28, 2010, servicer report. Based on numbers from the
May 26, 2011, servicer report $69.032 million in defaults have
occurred in the underlying portfolio between first-quarter 2010
and second-quarter 2011. In addition, the transaction diverted
$44.399 million of excess interest proceeds to pay down the class
A notes due to failure of the additional principal amount. This
additional principal amount is an amount defined by the indenture,
which references the positive excess, in par, of the outstanding
balance of the notes over the outstanding balance of the
collateral in the portfolio.

Standard & Poor's believes the increase in defaults to be offset
by the excess interest diversion which, in combination with
principal paydown on the underlying securities, has resulted in a
$119.13 million paydown to the class A notes since its March 2010
rating action.

"The affirmation of the ratings on the class A, C, and D notes
reflect our belief that the credit support available is
commensurate with the current rating level," S&P said.

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

Rating And Creditwatch Actions

ACAS Business Loan Trust 2006-1
                        Rating
Class              To           From
A                  A+ (sf)      A+ (sf)/Watch Pos
B                  BBB+ (sf)    BBB- (sf)/Watch Pos
C                  CCC+ (sf)    CCC+ (sf)/Watch Pos
D                  CCC- (sf)    CCC- (sf)/Watch Pos


ACAS BUSINESS: Stable Performance Cues Fitch to Affirm Ratings
--------------------------------------------------------------
Fitch Ratings has affirmed five classes of notes issued by ACAS
Business Loan Trust 2007-2 (ACAS BLT 2007-2):

  -- $78,203,494 class A notes at 'AAsf'; Outlook Stable;
  -- $34,874,179 class B notes at 'Asf'; Outlook revised to Stable
     from Negative;
  -- $58,588,620 class C notes at 'BBsf'; Outlook Negative;
  -- $29,294,310 class D notes at 'Bsf'; Outlook Negative;
  -- $39,524,069 class E notes at 'CCCsf/RR6'.

The affirmation of the notes is based on the generally stable
performance of the transaction since Fitch's last rating action in
August 2010.  Since that time, each class of notes has benefited
from increased credit enhancement levels due to the significant
principal repayment of the class A notes.  However, the underlying
loan portfolio is becoming increasingly concentrated in low-rated
second lien and subordinated loans.

Through a combination of loan repayments and the diversion of
excess spread to pay principal on the notes, the class A notes
have received approximately $101.6 million of principal payments
since Fitch's last rating action.  Both the class A and B notes
have a Stable Rating Outlook reflecting the fact that they are
well-positioned to withstand future credit deterioration in the
portfolio due to their senior priorities and the degree of
overcollateralization available to these notes.  As of the May 15,
2011 servicer report Fitch considers the performing portfolio
balance to consist of approximately $227.2 million of loans.
Fitch maintains Negative Rating Outlooks on the class C and D
notes due to the high degree of obligor concentration and the
increasingly risky characteristics of the underlying loans.  The
performing loan portfolio consists of 20 unique obligors, with
each of the nine largest obligors accounting for 6.7% to 7.2% of
the total portfolio.  Fitch considers approximately 43.8% of the
performing portfolio to be rated 'CCC', compared to 19% at Fitch's
last rating action, while none of the remaining obligors are rated
above 'B+'.  Approximately 69.1% of the performing portfolio
represents junior secured or unsecured loans, which indicates low
recovery prospects upon default.  The remaining 30.9% of the
portfolio consists of senior secured loans.

The notes of ACAS BLT 2007-2 benefit from credit enhancement in
the form of collateral coverage, note subordination, and the
application of excess spread via the additional principal amount
(APA).  Upon the occurrence of a default in the portfolio, the APA
feature directs part or all of the excess interest otherwise
available to the equity to pay down the senior-most notes in an
amount equal to the aggregate balance of defaulted assets in the
portfolio.  Since Fitch's last rating action the servicer has
considered an additional $33.1 million of loans as defaulted,
while over $25.6 million of excess spread has been used to pay
principal to the class A notes.  The APA stands at approximately
$62.4 million after the May 15, 2011 payment, compared to
$54.9 million in May 2010.

The class E notes maintain their Recovery Rating (RR) of 'RR6', as
these notes are not projected to recover any proceeds in a base-
case default scenario.  Recovery Ratings are designed to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities rated 'CCCsf' or below.
For further details on Recovery Ratings, please see Fitch's
reports 'Global Rating Criteria for Corporate CDOs' and 'Criteria
for Structured Finance Recovery Ratings'.

This review was conducted under the framework described in the
report 'Global Rating Criteria for Corporate CDOs' using the
Portfolio Credit Model (PCM) for projecting future default and
recovery levels for the underlying portfolio.  These default and
recovery levels were then utilized in Fitch's cash flow model
under various default timing and interest rate stress scenarios,
as described in the report 'Global Criteria for Cash Flow Analysis
in CDOs'.  The class A and B notes passed the various stress
scenarios at rating levels in line with their current ratings.
The class C and D notes passed the majority of the stress
scenarios at their current ratings and had minimal model failures
in the remaining scenarios.  The class E notes have a minimal
degree of credit enhancement and are highly sensitive to the
future performance of each of the underlying loans, and their
rating is reflective of this substantial credit risk.

ACAS BLT 2007-2 is a collateralized debt obligation (CDO) that
closed on Aug. 7, 2007 and is managed and serviced by American
Capital Strategies, Ltd (ACAS).  The transaction's reinvestment
period ended in February 2008.  ACAS BLT 2007-2 is secured by a
portfolio of middle-market loans.  The majority of these loans are
not publicly rated; instead, Fitch establishes model-based credit
opinions for the performing loans. Information for the credit
opinions was gathered from financial statements provided to Fitch
by ACAS.


ALPINE SECURITIZATION: DBRS Assigns B Rating on $41.6MM Tranche
---------------------------------------------------------------
DBRS has confirmed the rating of R-1 (high) (sf) for the
Commercial Paper (CP) issued by Alpine Securitization Corp.
(Alpine), an asset-backed commercial paper (ABCP) vehicle
administered by Credit Suisse, New York branch.  In addition,
DBRS has confirmed the ratings and revised the tranche sizes of
the aggregate liquidity facilities (the Liquidity) provided to
Alpine by Credit Suisse.

The $8,092,687,343 aggregate liquidity facilities are tranched as:

  -- $7,722,819,161 rated AAA (sf)
  -- $82,260,548 rated AA (sf)
  -- $42,104,634 rated A (sf)
  -- $65,374,347 rated BBB (sf)
  -- $61,435,636 rated BB (sf)
  -- $41,646,506 rated B (sf)
  -- $77,046,511 unrated (sf)

The ratings are based on March 31, 2011 data.

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

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

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

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

The principal methodology is the Asset-Backed Commercial Paper
Criteria Report: U.S. & European ABCP Conduits, which can be found
on the website under Methodologies.


AMMC CLO: Moody's Upgrades Ratings of Four Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by AMMC CLO III, Limited.:

US$307,500,000 Class A Floating Rate Notes Due 2016 (current
balance of $260,354,575), Upgraded to Aaa (sf); previously on June
22, 2011 Aa2 (sf) Placed under review for possible upgrade;

US$22,500,000 Class B Floating Rate Deferrable Revolving Notes Due
2016 (current outstanding balance of $0), Upgraded to Aa2 (sf);
previously on June 22, 2011 Baa3 (sf) Placed under review for
possible upgrade;

US$26,250,000 Class C Floating Rate Notes Due 2016, Upgraded to A2
(sf); previously on June 22, 2011 Ba1 (sf) Placed under review for
possible upgrade;

US$18,750,000 Class D Floating Rate Notes Due 2016 (current
balance of $15,047,283), Upgraded to Ba1 (sf); previously on June
22, 2011 Caa2 (sf) Placed under review for possible upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in September
2009. Based on the July 2011 trustee report, the weighted average
rating factor is currently 2288 compared to 2617 in August 2009.
In addition, Moody's notes that the Class A Notes have been paid
down by approximately 15% or $47 million since the rating action
in September 2009. As a result of the delevering, the
overcollateralization ratios have increased since the last rating
action. Based on the July 2011 trustee report, the senior
overcollateralization ratio is reported at 117.87% versus the
August 2009 level of 111.28%.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $310.6 million,
defaulted par of $3 million, a weighted average default
probability of 13% (implying a WARF of 2240), a weighted average
recovery rate upon default of 49.5%, and a diversity score of 59.
Moody's notes that the Class B Notes are revolving notes whereby
they are drawn only to replenish net principal losses in excess of
available interest proceeds. A deal structural feature specifies
that net principal losses must be repaid from (i) first, excess
interest before payment of the Class D Notes' interest, and (ii)
second, draws on the Class B Revolving Notes. There are no net
principal losses currently reported, and as a result, the Class B
Notes are undrawn. The default and recovery properties of the
collateral pool are incorporated in cash flow model analysis where
they are subject to stresses as a function of the target rating of
each CLO liability being reviewed. The default probability is
derived from the credit quality of the collateral pool and Moody's
expectation of the remaining life of the collateral pool. The
average recovery rate to be realized on future defaults is based
primarily on the seniority of the assets in the collateral pool.
In each case, historical and market performance trends and
collateral manager latitude for trading the collateral are also
factors.

AMMC CLO III, Limited, issued in July 2004, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

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

3) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.


APIDOS CDO: Moody's Upgrades Ratings of Five Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Apidos CDO I:

US$265,000,000 Class A-1 Floating Rate Notes (current outstanding
balance of 264,008,434), Upgraded to Aaa (sf); previously on
June 22, 2011 Aa1 (sf) Placed Under Review for Possible Upgrade;

US$15,000,000 Class A-2 Floating Rate Notes, Upgraded to Aa1 (sf);
previously on June 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

US$20,500,000 Class B Floating Rate Notes, Upgraded to A2 (sf);
previously on June 22, 2011 Baa3 (sf) Placed Under Review for
Possible Upgrade;

US$13,000,000 Class C Floating Rate Notes, Upgraded to Ba1 (sf);
previously on June 22, 2011 B1 (sf) Placed Under Review for
Possible Upgrade;

US$8,000,000 Class D Floating Rate Notes, Upgraded to Ba3 (sf);
previously on June 22, 2011 Caa3 (sf) Placed Under Review for
Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios since the rating action
in September 2009Based on the latest trustee report dated July 14,
2011, the Class A, Class B, Class C, and Class D
overcollateralization ratios are reported at 122.01%, 113.69%,
108.97%, and 106.26%, a respectively, versus August 2009 levels of
117.63%, 109.6%, 105.06%, and 102.44%, respectively. Additinally,
Moody's took into consideration the distribution of approximately
$991,566 of principal proceeds made to the Class A-1 Notes on the
payment date in July.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $341 million,
defaulted par of $750,000, a weighted average default probability
of 16.90% (implying a WARF of 2630), a weighted average recovery
rate upon default of 50.27%, and a diversity score of 73. The
default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Apidos CDO I, issued in August 2005, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

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


ARES IIR/IVR: Moody's Upgrades Ratings of 6 Classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Ares IIIR/IVR CLO Ltd.:

US$50,000,000 Class A-1 Variable Funding Floating Rate Notes
(current balance of $48,949,093), Upgraded to Aaa(sf); previously
on June 22, 2011, Aa3(sf) Placed Under Review for Possible
Upgrade;

US$446,300,000 Class A-2 Senior Secured Floating Rate Notes
(current balance of $436,919,609), Upgraded to Aaa(sf); previously
on June 22, 2011, Aa3(sf) Placed Under Review for Possible
Upgrade;

US$42,000,000 Class B Senior Secured Floating Rate Notes, Upgraded
to Aa3(sf); previously on June 22, 2011, Baa1(sf) Placed Under
Review for Possible Upgrade;

US$42,000,000 Class C Senior Secured Deferrable Floating Rate
Notes, Upgraded to A3(sf); previously on June 22, 2011, Ba1(sf)
Placed Under Review for Possible Upgrade;

US$35,000,000 Class D Secured Deferrable Floating Rate Notes,
Upgraded to Ba1(sf); previously on June 22, 2011, B1(sf) Placed
Under Review for Possible Upgrade;

US$31,500,000 Class E Secured Deferrable Floating Rate Notes,
Upgraded to Ba3(sf); previously on June 22, 2011, Caa3(sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in August
2009. Based on the July 2011 trustee report, the weighted average
rating factor is currently 2454 compared to 2825 in July 2009. The
overcollateralization ratios of the rated notes have also improved
since the rating action in August 2009. The Class A/B, Class C,
Class D, and Class E overcollateralization ratios are reported at
124.74%, 115.55%, 108.86% and 103.47%, respectively, versus July
2009 levels of 119.83%, 111.09%, 104.72% and 99.59%, respectively,
and all related overcollateralization tests are currently in
compliance.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $660 million,
defaulted par of $1.5 million, a weighted average default
probability of 25.18% (implying a WARF of 3079), a weighted
average recovery rate upon default of 47.66%, and a diversity
score of 58. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Ares IIIR/IVR CLO Ltd., issued in March of 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans with a 12.5% High Yield Bond basket.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score.


ARES XII: Moody's Upgrades Ratings of Five Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Ares XII CLO Ltd.:

US$479,500,000 Class A Floating Rate Notes Due November 25, 2020,
Upgraded to Aaa (sf); previously on June 22, 2011 Aa2 (sf) Placed
Under Review for Possible Upgrade;

US$52,500,000 Class B Floating Rate Notes Due November 25, 2020,
Upgraded to A1 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$42,000,000 Class C Floating Rate Deferrable Notes Due November
25, 2020, Upgraded to Baa2 (sf); previously on June 22, 2011 Ba1
(sf) Placed Under Review for Possible Upgrade;

US$35,000,000 Class D Floating Rate Deferrable Notes Due November
25, 2020, Upgraded to Ba2 (sf); previously on June 22, 2011 B3
(sf) Placed Under Review for Possible Upgrade;

US$35,000,000 Class E Floating Rate Deferrable Notes Due November
25, 2020 (current outstanding balance of $26,270,832), Upgraded to
B1 (sf); previously on June 22, 2011 Caa3 (sf) Placed Under Review
for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in August
2009. Based on the July 2011 trustee report, the weighted average
rating factor is currently 2403 compared to 2764 in June 2009. The
overcollateralization ratios of the rated notes have also improved
since the rating action in August 2009. Based on the latest
trustee report dated July 18, 2011, the Class A/B, Class C, Class
D, and Class E overcollateralization ratios are reported at
125.64%, 116.45%, 109.76%, and 105.22%, respectively, versus June
2009 levels of 122.04%,113.11%,106.61%, and 101.36%, respectively,
and all related overcollateralization tests are currently in
compliance. In particular, the Class E overcollateralization ratio
has increased in part due to the diversion of excess interest to
delever the Class E notes in the event of a Class E
overcollateralization or interest coverage test failure. Since the
rating action in August 2009, $5.3 million of interest proceeds
have reduced the outstanding balance of the Class E Notes by
16.8%.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $667.7 million,
defaulted par of $6.3 million, a weighted average default
probability of 23.68% (implying a WARF of 2861), a weighted
average recovery rate upon default of 49.98%, and a diversity
score of 45. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Ares XII CLO Ltd., issued in October 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011. Please see the Credit Policy page on www.moodys.com for
a copy of this methodology.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average coupon, and diversity score.
   However, as part of the base case, Moody's considered spread
   levels higher than the covenant levels due to the large
   difference between the reported and covenant levels.


ASHFORD CDO: Moody's Upgrades Ratings of Floating Rate Notes
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of six classes
of notes issued by Ashford CDO II Ltd. The notes affected by the
rating action are:

US$5,000,000 Class X Floating Rate Notes Due August 2013 (current
outstanding balance of $1,666,666.72), Upgraded to Aa1 (sf);
previously on 6/24/2011 Ba1 (sf) Placed Under Review for Possible
Upgrade;

US$175,000,000 Class A-1LA Floating Rate Notes Due November 2041
(current outstanding balance of $150,391,487.62), Upgraded to Baa2
(sf) Under Review for Possible Upgrade; previously on 6/24/2011 B3
(sf) Placed Under Review for Possible Upgrade;

US$42,000,000 Class A-1LB Floating Rate Notes Due November,
Upgraded to Ba1 (sf) Under Review for Possible Upgrade; previously
on 6/24/2011 Caa2 (sf) Placed Under Review for Possible Upgrade;

US$51,000,000 Class A-2L Floating Rate Notes Due November 2041,
Upgraded to Ba3 (sf) Under Review for Possible Upgrade; previously
on 6/24/2011 Caa3 (sf) Placed Under Review for Possible Upgrade;

US$34,000,000 Class A-3L Floating Rate Notes Due November 2041,
Upgraded to Caa1 (sf) Under Review for Possible Upgrade;
previously on 6/24/2011 Ca (sf) Placed Under Review for Possible
Upgrade;

US$22,000,000 Class B-1L Floating Rate Notes Due November 2041
(current outstanding balance of $21,467,502.39), Upgraded to Ca
(sf) Under Review for Possible Upgrade; previously on 6/24/2011 C
(sf) Placed Under Review for Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes result
primarily from improvement in the credit quality of the portfolio.

Following an announcement by Moody's on June 22nd that nearly all
CLO tranches currently rated Aa1 (sf) and below were placed on
review for possible upgrade ("Moody's places 4,220 tranches from
611 U.S. and 171 European CLO transactions on review for
upgrade"), 98 tranches of U.S. and European Structured Finance
(SF) CDOs with material exposure to CLOs were also placed on
review for possible upgrade ("Moody's places 98 tranches from 19
U.S. and 3 European SF CDO transactions with exposure to CLOs on
review for upgrade"). The rating action on the notes reflects CLO
tranche upgrades that have taken place thus far, as well as a two
notch adjustment for CLO tranches which remain on review for
possible upgrade. According to Moody's, 23% of the collateral has
been upgraded since June 22nd, and 67% remains on review.

As of the latest trustee report in July 2011, the Class A
overcollateralization ratio improved and is reported at 111.68%
versus July 2009 levels of 85.3%. Currently the B-1L and B-2L OC
tests are failing resulting in the diversion of interest proceeds
to payment of the principal on the Class A notes and resulting in
deferred interest payments to the Classe B-1L and B-2L Notes.

Ashford CDO II Ltd. is a collateralized debt obligation backed
primarily by a portfolio of collateralized loan obligations
("CLOs"), of which a majority are from the 2005-2006 vintage.

The principal methodology used in this rating was "Moody's
Approach to Rating SF CDOs" published in November 2010.

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.8 to model the loss distribution for SF CDOs. Within this
framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference.
Specifically, correlated defaults are simulated using a normal (or
"Gaussian") copula model that applies the asset correlation
framework. Recovery rates for defaulted credits are generated by
applying within the simulation the distributional assumptions,
including correlation between recovery values. Together, the
simulated defaults and recoveries across each of the Monte Carlo
scenarios define the loss distribution for the reference pool.

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

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios, discussed below. Results are shown in terms
of the number of notches' difference versus the current model
output, where a positive difference corresponds to lower expected
loss, assuming that all other factors are held equal:

Moody's Watchlisted bucket notched up by 3 rating notches:

Class X: 0

Class A-1La: +2

Class A-1Lb: +1

Class A-2L: +2

Class A-3L: +3

Class B-1L: +2

Class B-2L: 0

Moody's Watchlisted bucket notched up by 1 rating notches:

Class X: 0

Class A-1La: -2

Class A-1Lb: -2

Class A-2L: -2

Class A-3L: -1

Class B-1L: -1

Class B-2L: 0


AVENUE CLO: Moody's Upgrades Ratings of Five Classes of Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Avenue CLO III Ltd.:

US$357,000,000 Class A-1L Floating Rate Notes Due July 2018
(current outstanding balance of $310,410,378), Upgraded to Aaa
(sf); previously on June 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

US$39,000,000 Class A-2L Floating Rate Notes Due July 2018,
Upgraded to A1 (sf); previously on June 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$24,000,000 Class A-3L Floating Rate Notes Due July 2018,
Upgraded to Baa2 (sf); previously on June 22, 2011 Caa1 (sf)
Placed Under Review for Possible Upgrade;

US$21,500,000 Class B-1L Floating Rate Notes Due July 2018,
Upgraded to Ba3 (sf); previously on June 22, 2011 Ca (sf) Placed
Under Review for Possible Upgrade;

US$22,000,000 Class B-2L Floating Rate Notes Due July 2018
(current outstanding balance of $24,902,472), Upgraded to Caa3
(sf); previously on June 22, 2011 C (sf) Placed Under Review for
Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in June 2009.
Based on the latest trustee report dated July 11, 2011, the
weighted average rating factor is currently 2393 compared to 2694
in June 2009. The overcollateralization ratios of the rated notes
have also improved since the rating action in June 2009. The
Senior Class A, Class A, Class B-1L and Class B-2L
overcollateralization ratios are reported at 117.56%, 110.07%,
104.13%, and 98.00%, respectively, versus June 2009 levels of
108.96%, 102.50%, 97.36%, and 91.73%, respectively. Moody's also
notes that the Class A-3L Notes and Class B-1L Notes are no longer
deferring interest, and that all previously deferred interest has
been paid in full.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $412 million,
defaulted par of $19.3 million, a weighted average default
probability of 17.26 % (implying a WARF of 2545), a weighted
average recovery rate upon default of 48.75%, and a diversity
score of 55. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

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

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score.


BABSON CLO: Moody's Upgrades Ratings of 7 Classes of Notes
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of the
following notes issued by Babson CLO Ltd. 2006-II:

US$200,000,000 Class A-1A Senior Notes Due 2020 (current
outstanding balance of $193,866,697), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$22,000,000 Class A-1B Senior Notes Due 2020, Upgraded to Aa1
(sf); previously on June 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

US$218,000,000 Class A-2 Senior Notes Due 2020 (current
outstanding balance of $211,977,207), Upgraded to Aa1 (sf);
previously on June 22, 2011 Aa3 (sf) Placed Under Review for
Possible Upgrade;

US$18,500,000 Class B Senior Notes Due 2020, Upgraded to Aa3 (sf);
previously on June 22, 2011 A3 (sf) Placed Under Review for
Possible Upgrade;

US$32,000,000 Class C Deferrable Mezzanine Notes Due 2020,
Upgraded to A3 (sf); previously on June 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$20,000,000 Class D Deferrable Mezzanine Notes Due 2020,
Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

US$10,000,000 Class E Deferrable Mezzanine Notes Due 2020,
Upgraded to Ba2 (sf); previously on June 22, 2011 Caa2 (sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an improvement in the
credit quality of the underlying portfolio and an increase in the
transaction's overcollateralization ratios since the rating action
in July 2009. The Class A/B, Class C, Class D, and Class E
overcollateralization ratios are reported at 122.08%, 113.91%,
109.34%, and 107.19%, respectively, versus June 2009 levels of
112.70%, 105.25%, 101.07%, and 99.08%, respectively, and all
related overcollateralization tests are currently in compliance.
Moody's also notes that the Class E Notes are no longer deferring
interest and that all previously deferred interest has been paid
in full. Based on the same trustee report, the weighted average
rating factor is currently 2618 compared to 3044 in the June 2009
report.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par balance, including principal proceeds, of $548
million, defaulted par of $1.9 million, a weighted average default
probability of 23.1% (implying a WARF of 2778), a weighted average
recovery rate upon default of 50.4%, and a diversity score of 80.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends, and collateral manager
latitude for trading the collateral are also factors.

Babson CLO Ltd. 2006-II, issued in October 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2016 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the managers'
investment strategies and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1. Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2. Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming worse
   of reported and covenanted values for the weighted average
   rating factor. As part of the base case, Moody's considered
   diversity and spread levels higher than the covenant levels due
   to the large difference between the reported and covenant
   levels.


BABSON LOAN: Moody's Upgrades Ratings of Five Classes of Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Babson Loan Opportunity CLO, Ltd.:

US$421,000,000 Class A Senior Notes Due 2018 (current outstanding
balance of $416,828,225), Upgraded to Aaa (sf); previously on
Jun 22, 2011 Aa2 (sf) Placed Under Review for Possible Upgrade;

US$24,500,000 Class B Senior Notes Due 2018, Upgraded to Aaa (sf);
previously on Jun 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

US$24,500,000 Class C Deferrable Mezzanine Notes Due 2018,
Upgraded to Aa2 (sf); previously on Jun 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$22,000,000 Class D Deferrable Mezzanine Notes Due 2018,
Upgraded to A2 (sf); previously on Jun 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

US$16,500,000 Class E Deferrable Junior Notes Due 2018, Upgraded
to Baa2 (sf); previously on Jun 22, 2011 Caa3 (sf) Placed Under
Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The actions reflect key
changes to the modeling assumptions, which incorporate (1) a
removal of the temporary 30% default probability macro stress
implemented in February 2009 as well as (2) increased BET
liability stress factors and increased recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in September
2009. Based on the June 2011 trustee report, the weighted average
rating factor is currently 2620 compared to 2956 in July 2009. The
Senior, Class C, Class D and Class E overcollateralization ratios
are reported at 130.7%, 123.8%, 118.2% and 114.3%, respectively,
versus July 2009 levels of 125.6%, 119%, 113.6% and 109.7%,
respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $577 million,
defaulted par of $0 million, a weighted average default
probability of 17.8% (implying a WARF of 2605), a weighted average
recovery rate upon default of 50.9%, and a diversity score of 70.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Babson Loan Opportunity CLO, Ltd., issued in March 2008, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011. Please see the Credit Policy page on www.moodys.com for
a copy of this methodology.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior, 2) divergence in legal
interpretation of CLO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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


BALLYROCK CLO: Moody's Upgrades Ratings of 5 Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Ballyrock CLO 2006-2 Ltd.:

US$446,900,000 Class A Floating Rate Notes, Due 2020, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$25,000,000 Class B Floating Rate Notes, Due 2020, Upgraded to
Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed Under Review
for Possible Upgrade;

US$30,000,000 Class C Deferrable Floating Rate Notes, Due 2020,
Upgraded to Baa1 (sf); previously on June 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$33,600,000 Class D Deferrable Floating Rate Notes, Due 2020,
Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

US$21,000,000 Class E Deferrable Floating Rate Notes, Due 2020
(current outstanding balance of $16,574,414), Upgraded to Ba3
(sf); previously on June 22, 2011 Caa3 (sf) Placed Under Review
for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in May 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2641 compared to 3124 in May 2009. The Class
A/B, Class C, Class D and Class E overcollateralization ratios are
reported at 125.5%, 118.0%, 110.6% and 107.3%, respectively,
versus May 2009 levels of 118.6%, 111.5%, 104.5% and 101.3%,
respectively, and all related overcollateralization tests are
currently in compliance.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $591 million,
defaulted par of $3 million, a weighted average default
probability of 21.93% (implying a WARF of 2807), a weighted
average recovery rate upon default of 48.49%, and a diversity
score of 60. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Ballyrock CLO 2006-2 Ltd., issued in December 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CLO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average coupon, and diversity score.
   However, as part of the base case, Moody's considered a spread
   level higher than the covenant level due to the large
   difference between the reported and covenant levels.


BANC OF AMERICA: Fitch Affirms Junk Rating on Two Class Certs.
--------------------------------------------------------------
Fitch Ratings has affirmed the pooled classes of Banc of America
Large Loan 2005-MIB1 commercial mortgage pass-through
certificates.  The affirmations reflect overall stable loss
expectations for the pooled classes as well as pay down since
Fitch's last review.  Fitch's performance expectation incorporates
prospective views regarding the outlook of the commercial real
estate market.

Fitch affirms these classes and revises Rating Outlooks as
indicated:

  -- $10.2 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $43 million class B at 'AAAsf'; Outlook Stable;
  -- $51.2 million class C at 'AAAsf'; Outlook Stable;
  -- $30.3 million class D at 'AA+sf'; Outlook Stable;
  -- $30.3 million class E at 'AAsf'; Outlook Stable;
  -- $30.3 million class F at 'AA-sf'; Outlook to Stable from
     Negative;
  -- $30.3 million class G at 'A-sf'; Outlook to Stable from
     Negative;
  -- $25.3 million class H at 'BBB+sf'; Outlook to Stable from
     Negative;
  -- $28.8 million class J at 'BBsf'; Outlook Negative;
  -- $30 million class L at 'CCsf/RR6'.

Fitch has also affirmed this class and revised the Recovery Rating
(RR) as indicated:

  -- $30.8 million class K to 'CCCsf/RR2' from 'CCC/RR1'.
     Class A-1 and interest-only classes X-1A and X-4 have paid in
     full.

All of the remaining loans have passed their final maturity or are
maturing over the next 12 months.  At issuance, the majority of
the loans had an average loan term of five years.  There is
uncertainty as to whether or not the loans will have issues
securing financing at final maturity or ultimate disposition.

Under Fitch's methodology, approximately 30% of the pooled balance
is modeled to default in the base case stress scenario, defined as
the 'B' stress.  In this scenario, the modeled average cash flow
decline is 6.1% and pooled expected losses are 9.3%. To determine
a sustainable Fitch cash flow and stressed value, Fitch analyzed
servicer-reported operating statements and STR reports, updated
property valuations, and recent sales comparisons.  Fitch
estimates that average recoveries will be approximately 68.9% in
the base case.

The transaction is collateralized by six loans, two of which are
secured by hotels (75.4%), two by retail (12.1%), one industrial
(9.6%) and one by multifamily (2.9%). Five of the six loans
(31.9%) are in special servicing.  The three largest pooled
contributors to losses (by unpaid principal balance) in the 'B'
stress scenario are: Radisson Resort Parkway (7.3%), The Shops at
Grand Avenue (6.8%) and The Pointe Apartments (2.9%).

The Radisson Resort Parkway is a 718 key full-service hotel
located in Kissimmee, FL. The property is adjacent to Walt
Disney's Celebration and is located 1.5 miles from Walt Disney
World.  The loan transferred to special servicing in July 2009.

Property performance has deteriorated with the property reporting
a negative year-end (YE) 2010 net cash flow.  As of May 2011, the
trailing 12 month (TTM) reported occupancy, average daily rate
(ADR) and revenue per available room (RevPAR) of 48.8%, $62 and
$30, respectively, compared to 78.5%, $76 and $60 at issuance.
The Shops at Grand Avenue is a 291,033 sf regional mall located in
Milwaukee, WI.  The collateral consists of 168,364 sf of in-line
space. The property is anchored by The Boston Store (not part of
the collateral) and includes major tenants such as TJ Maxx (lease
expiration in March 2014) and Office Max (lease expiration in
March 2016).  As of YE 2010, the servicer-reported NOI DSCR
declined 68.5% in the previous two years due to declining
occupancy at the property.  The loan transferred to special
servicing in September 2009.  One of the major tenants at
issuance, Linens N' Things, opened their store in 2005 and
subsequently vacated following a corporate bankruptcy filing.  As
of March 2011, the property reported an overall occupancy of 41%
and in-line occupancy of approximately 40%.  At issuance, the
property had an overall occupancy of 78.6% and in-line occupancy
of 62.7%.

The Pointe Apartments is a 360-unit multifamily property located
in Stone Mountain, GA, 16 miles northeast of Atlanta.  The loan
transferred to special servicing in August 2008 and is now real-
estate owned (REO).  At issuance, the property was 91.9% occupied.
As of a March 2011, the property was approximately 79% occupied,
an increase from 66% reported in 2009 when occupancy was affected
by tenant evictions.

Fitch previously withdrew the ratings of interest-only classes X-
1B, X-2, X-3 and X-5.


BANC OF AMERICA: Moody's Affirms Ratings of 23 CMBS Classes
-----------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 23
classes of Banc of America Commercial Mortgage Trust Commercial
Mortgage Pass-Through Certificates, Series 2007-1:

Cl. A-2, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Mar 8, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-MFX, Affirmed at Aa2 (sf); previously on Dec 9, 2010
Downgraded to Aa2 (sf)

Cl. A-MFL, Affirmed at Aa2 (sf); previously on Dec 9, 2010
Downgraded to Aa2 (sf)

Cl. A-J, Affirmed at Baa3 (sf); previously on Dec 9, 2010
Downgraded to Baa3 (sf)

Cl. B, Affirmed at Ba1 (sf); previously on Dec 9, 2010 Downgraded
to Ba1 (sf)

Cl. C, Affirmed at Ba3 (sf); previously on Dec 9, 2010 Downgraded
to Ba3 (sf)

Cl. D, Affirmed at B2 (sf); previously on Dec 9, 2010 Downgraded
to B2 (sf)

Cl. E, Affirmed at Caa1 (sf); previously on Dec 9, 2010 Downgraded
to Caa1 (sf)

Cl. F, Affirmed at Caa2 (sf); previously on Dec 9, 2010 Downgraded
to Caa2 (sf)

Cl. G, Affirmed at C (sf); previously on Dec 9, 2010 Downgraded to
C (sf)

Cl. H, Affirmed at C (sf); previously on Dec 9, 2010 Downgraded to
C (sf)

Cl. J, Affirmed at C (sf); previously on Dec 9, 2010 Downgraded to
C (sf)

Cl. K, Affirmed at C (sf); previously on Dec 9, 2010 Downgraded to
C (sf)

Cl. L, Affirmed at C (sf); previously on Dec 9, 2010 Downgraded to
C (sf)

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

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

Cl. O, Affirmed at C (sf); previously on Dec 9, 2010 Downgraded to
C (sf)

Cl. P, Affirmed at C (sf); previously on Dec 9, 2010 Downgraded to
C (sf)

Cl. XW, Affirmed at Aaa (sf); previously on Mar 8, 2007 Definitive
Rating Assigned Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
8.4% of the current balance compared to 8.6% at last review.
Moody's stressed scenario loss is 24.0% of the current balance.
Moody's provides a current list of base and stress scenario losses
for conduit and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. Due to the high level of credit subordination
and defeasance, it is unlikely that investment grade classes would
be downgraded even if losses are higher than Moody's expected
base.

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011. The
hotel and multifamily sectors are continuing to show signs of
recovery, while recovery in the office and retail sectors will be
tied to recovery of the broader economy. The availability of debt
capital continues to improve with terms returning toward market
norms. Moody's central global macroeconomic scenario reflects an
overall sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

The primary methodology used in this rating was CMBS "Moody's
Approach to Rating U.S. CMBS Conduit Transaction" published in
September 2000. Please see the Credit Policy page on
www.moodys.com for a copy of this methodology.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions and the CMBS Large Loan Model v 8.0. Conduit model
results at the Aa2 (sf) level are driven by property type, Moody's
actual and stressed DSCR, and Moody's property quality grade
(which reflects the capitalization rate used by Moody's to
estimate Moody's value). Conduit model results at the B2 (sf)
level are driven by a pay down analysis based on the individual
loan level Moody's LTV ratio. Moody's Herfindahl score (Herf), a
measure of loan level diversity, is a primary determinant of pool
level diversity and has a greater impact on senior certificates.
Other concentrations and correlations may be considered in Moody's
analysis. Based on the model pooled credit enhancement levels at
Aa2 (sf) and B2 (sf), the remaining conduit classes are either
interpolated between these two data points or determined based on
a multiple or ratio of either of these two data points. For fusion
deals, the credit enhancement for loans with investment-grade
underlying ratings is melded with the conduit model credit
enhancement into an overall model result. Fusion loan credit
enhancement is based on the credit estimate of the loan which
corresponds to a range of credit enhancement levels. Actual fusion
credit enhancement levels are selected based on loan level
diversity, pool leverage and other concentrations and correlations
within the pool. Negative pooling, or adding credit enhancement at
the underlying rating level, is incorporated for loans with
similar credit estimates in the same transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 25 compared to 26 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 9, 2010. Please see
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

DEAL PERFORMANCE

As of the July17, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 3% to $3.06 billion
from $3.15 billion at securitization. The Certificates are
collateralized by 157 mortgage loans ranging in size from less
than 1% to 9% of the pool, with the top ten loans representing 54%
of the pool. One loan, representing 3% of the pool, has defeased
and is collateralized with U.S. Government securities.

Moody's was provided with full year 2009 and full year 2010
operating results for 97% and 95% of the performing pool,
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 110%, the same as at last review.
Moody's net cash flow reflects a weighted average haircut of 10%
to the most recently available net operating income. Moody's value
reflects a weighted average capitalization rate of 8.75%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.3X and 0.89X, essentially the same at
last review. Moody's actual DSCR is based on Moody's net cash flow
(NCF) and the loan's actual debt service. Moody's stressed DSCR is
based on Moody's NCF and a 9.25% stressed rate applied to the loan
balance.

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

The pool has experienced an aggregate realized loss of
$13.2 million, stemming from loan liquidations, loan modifications
and a non-recoverable trust expense. Three loans have been
liquidated from the pool, resulting in a $4.8 million aggregate
loss (a 78% loss severity on average). Currently, there are 18
loans in special servicing, representing 18% of the pool. The
largest specially serviced loan is the Solana Loan ($220.0 million
-- 7.2% of the pool), which represents a 61% pari passu interest
in a $360.0 million first mortgage loan. The loan is secured by a
1.9 million square foot (SF) mixed use complex consisting of
office, retail and a 198-room full service hotel located in
Westlake, Texas. As of March 2011, the property was 81% leased.
The loan was transferred to special servicing in March 2009 for
imminent default but has remained current. The property's
performance has been impacted by declines in both the office and
hotel components. The Special Servicer has approved the loan
modification; however, negotiations with the Borrower to work out
the loan are still pending. The most recent appraisal (April 2011)
values the property at $216.0 million.

The second largest specially serviced loan is the 575 Lexington
Avenue Loan ($160.3 million - 5.2% of the pool), which represent a
50% pari passu interest in a $320.6 million first mortgage loan.
The loan is secured by a 35-story office building located on 51st
Street and Lexington Avenue in Manhattan, New York. The loan was
transferred to special servicing in March 2010 for imminent
default and is currently 90+ days delinquent. The special servicer
filed for foreclosure in January 2011. The most recent appraisal
(April 2010) values the property at $215.4 million.

The remaining 16 specially serviced loans are secured by a mix of
property types. The master servicer has recognized an aggregate
$85.1 million appraisal reduction for 16 of the specially serviced
loans. Moody's has estimated an aggregate $159.5 million loss (31%
expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for 18 poorly
performing loans representing 3.6% of the pool and has estimated a
$22.0 million loss (20% expected loss based on a 50% probability
default) from these troubled loans.

Based on the most recent remittance statement, Classes G through Q
have experienced cumulative interest shortfalls totaling $7.59
million. At last review, interest shortfalls totaled $4.1 million
and affected Classes J through Q. Moody's anticipates that the
pool will continue to experience interest shortfalls because of
the high exposure to specially serviced loans. Interest shortfalls
are caused by special servicing fees, including workout and
liquidation fees, appraisal entitlement reductions (ASERs) and
extraordinary trust expenses.

The top three performing conduit loans represent 21% of the pool
balance. The largest loan is the Skyline Portfolio Loan ($271.2
million -- 8.9% of the pool), which is secured by a portfolio of
eight cross-collateralized and cross-defaulted office buildings
located in Falls Church, Virginia. The loan represents a 40% pari-
passu interest in a $678 million first mortgage loan. As of
December 2010, the properties were 92% leased compared to 94% at
last review. The GSA leases approximately 55% of the net rentable
area (NRA) through 2015 and 2019. The loan sponsor is Vornado
Realty Trust. Moody's LTV and stressed DSCR are 119% and 0.80X,
essentially the same as at last review.

The second largest loan is the StratReal Industrial Portfolio I
Loan ($190.0 million -- 6.2% of the pool), which is secured by a
portfolio of 12 industrial properties, totaling 5.5 million SF,
located in Ohio (8), Tennessee (3) and California (1). Ford Motor
Co. (Moody's senior rating of rated Ba3, positive outlook)
occupies 14% of the gross leasable area through March 2012. As of
December 2010, the portfolio was 80% leased compared to 95% at
securitization; 40% of space is due to rollover within the next
year. Net operating income (NOI) has decreased by 9% since last
review. Moody's LTV and stressed DSCR are 132% and 0.72X,
respectively, compared to 126% and 0.75X, at last review.

The third largest loan is the Hirschfield Portfolio Loan ($167.0
million -- 5.5% of the pool), which is secured by four multifamily
complexes, totaling 1,841 units, located in three submarkets in
the Baltimore metropolitan area. Performance has been stable for
the last two years, but is still below the performance level at
securitization. Moody's LTV and stressed DSCR are 131% and 0.7X,
respectively, compared to 137% and 0.67X at last review.


BANKUNITED TRUST: S&P Raises Rating on RMBS Class I-A-2 to 'BB'
---------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on 21
classes from 11 U.S. residential mortgage-backed securities (RMBS)
transactions backed by Alternative-A (Alt-A) mortgage loans issued
from 2004 through 2006, and removed all of them from CreditWatch
positive. "At the same time, we lowered our ratings on 57 classes
from 25 transactions and removed 50 of them from CreditWatch
negative. In addition, we affirmed our ratings on 127 classes from
11 transactions with upgraded ratings, 21 transactions with
lowered ratings, and five additional transactions.  We removed
four of the affirmed ratings from CreditWatch positive and five
from CreditWatch negative," S&P related.

"On May 11,2011 we placed our ratings on 59 classes from 26 Alt-A
transactions within this review on CreditWatch negative and 25
classes from 13 transactions on CreditWatch positive," S&P said.
"We placed our ratings on these classes on CreditWatch with
negative and positive implications to reflect updated lifetime
loss projections following the revised classification of negative
amortization (or pay option) adjustable-rate mortgage (ARM)
transactions as outlined in 'Methodology And Assumptions: Revised
Lifetime Loss Projections For Prime, Subprime, And Alt-A U.S. RMBS
Issued In 2005-2007,' published March 25, 2011. Revised lifetime
loss projections for such transactions issued between 2005
and 2007 are listed in 'Transaction-Specific Lifetime Loss
Projections For Prime, Subprime, And Alternative-A U.S. RMBS
Issued In 2005-2007,' published June 27, 2011."

"The upgrades reflect our belief that the amount of projected
credit support available to the affected classes will be
sufficient to cover our revised lifetime projected losses at the
recommended rating level stresses. The downgrades reflect our
belief that projected credit support available to the affected
classes will be insufficient to cover the projected losses we
applied at the applicable rating stresses. The affirmations
reflect our belief that the amount of projected credit support
available for these classes is sufficient to cover projected
losses associated with the current rating levels. We withdrew our
ratings on four classes from four transactions in accordance with
our interest-only securities criteria," S&P related.

"To assess the creditworthiness of each class, we reviewed the
individual delinquencies and losses for each transaction to
project the classes' ability to withstand additional credit
deterioration. In order to maintain a 'B' rating on a class, we
assessed whether, in our view, a class could absorb the remaining
base-case loss assumptions we used in our analysis. In order to
maintain a rating higher than 'B', we assessed whether the class
could withstand losses exceeding our remaining base-case loss
assumptions at a percentage specific to each rating category (up
to 150% for a 'AAA' rating). For example, in general, we would
assess whether one class could withstand approximately 110% of our
remaining base-case loss assumptions to maintain a 'BB' rating.
However, to maintain a 'BBB' rating, we would assess whether a
different class could withstand approximately 120% of our
remaining base-case loss assumptions. Each class with an affirmed
'AAA' rating can, in our view, withstand approximately 150% of our
remaining base-case loss assumptions under our analysis," S&P
said.

Subordination, overcollateralization, and excess spread provide
credit support for the affected transactions. The underlying
collateral for these deals consists of fixed- and adjustable-rate
U.S. Alt-A mortgage loans secured by first-liens on one- to four-
family residential properties.

Rating Actions

BankUnited Trust 2005-1
Series 2005-1
                               Rating
Class      CUSIP       To                   From
I-A-1      06652DAA7   AAA (sf)             B- (sf)/Watch Pos
I-A-2      06652DAB5   BB (sf)              CCC (sf)/Watch Pos

Bear Stearns Mortgage Funding Trust 2006-AR4
Series 2006-AR4
                               Rating
Class      CUSIP       To                   From
A-1        07401JAA6   CCC (sf)             B- (sf)/Watch Neg

Bella Vista Mortgage Trust 2004-2
Series 2004-2
                               Rating
Class      CUSIP       To                   From
A-1        07820QAY1   CCC (sf)             BB+ (sf)/Watch Neg
A-2        07820QAZ8   B (sf)               AA+ (sf)/Watch Neg
A-3        07820QBJ3   CCC (sf)             BB+ (sf)/Watch Neg
X          07820QBA2   NR                   AA+ (sf)/Watch Neg

CHL Mortgage Pass-Through Trust 2004-20
Series 2004-20
                               Rating
Class      CUSIP       To                   From
1-A-1      12669F2G7   CC (sf)              B- (sf)/Watch Neg
2-A-1      12669F2H5   CC (sf)              B- (sf)/Watch Neg
2-A-2      12669F2X0   CC (sf)              B- (sf)/Watch Neg
3-A-1      12669F2J1   CC (sf)              B- (sf)/Watch Neg

CHL Mortgage Pass-Through Trust 2005-1
Series 2005-1
                               Rating
Class      CUSIP       To                   From
1-A-1      12669GRM5   CCC (sf)             BB (sf)/Watch Neg
2-A-1      12669GRQ6   CCC (sf)             B+ (sf)/Watch Neg

HarborView Mortgage Loan Trust 2004-10
Series 2004-10
                               Rating
Class      CUSIP       To                   From
B-1        41161PJT1   CCC (sf)             B- (sf)/Watch Neg

HarborView Mortgage Loan Trust 2005-12
Series 2005-12
                               Rating
Class      CUSIP       To                   From
2-A1A1     41161PVJ9   B- (sf)              BB- (sf)/Watch Neg
2-A1A2     41161PVK6   B- (sf)              BB- (sf)/Watch Neg

HarborView Mortgage Loan Trust 2005-9
Series 2005-9
                               Rating
Class      CUSIP       To                   From
3-X        41161PSQ7   AAA (sf)             AA+ (sf)/Watch Pos
3-PO       41161PST1   AAA (sf)             AA+ (sf)/Watch Pos
B-1        41161PSV6   A+ (sf)              AA+ (sf)/Watch Neg
B-2        41161PSW4   BB+ (sf)             AA+ (sf)/Watch Neg
B-3        41161PSX2   B (sf)               AA (sf)/Watch Neg
B-4        41161PSY0   B- (sf)              AA (sf)/Watch Neg
B-5        41161PSZ7   CCC (sf)             AA (sf)/Watch Neg
B-6        41161PTA1   CCC (sf)             BBB (sf)/Watch Neg
B-7        41161PTB9   CC (sf)              BB (sf)/Watch Neg

IndyMac INDX Mortgage Loan Trust 2004-AR1
Series 2004-AR1
                               Rating
Class      CUSIP       To                   From
1-A-1      45660NZX6   AA (sf)              AA+ (sf)/Watch Neg
2-A-1      45660NZY4   AA (sf)              AA+ (sf)/Watch Neg
A-X-2      45660NA21   AA (sf)              AA+ (sf)/Watch Neg

IndyMac INDX Mortgage Loan Trust 2004-AR12
Series 2004-AR12
                               Rating
Class      CUSIP       To                   From
A-1        45660N5H4   B- (sf)              B- (sf)/Watch Neg

IndyMac INDX Mortgage Loan Trust 2004-AR14
Series 2004-AR14
                               Rating
Class      CUSIP       To                   From
1-A-1A     45660LAA7   CCC (sf)             B- (sf)/Watch Neg
2-A-1A     45660LAC3   CCC (sf)             B- (sf)/Watch Neg
2-A-2A     45660LAE9   CCC (sf)             BB (sf)/Watch Neg

IndyMac INDX Mortgage Loan Trust 2004-AR2
Series 2004-AR2
                               Rating
Class      CUSIP       To                   From
1-A-1      45660NG66   BBB (sf)             AA- (sf)/Watch Neg
2-A-1      45660NG74   BBB (sf)             AA- (sf)/Watch Neg
A-X-2      45660NG90   NR                   AA- (sf)/Watch Neg

IndyMac INDX Mortgage Loan Trust 2004-AR3
Series 2004-AR3
                               Rating
Class      CUSIP       To                   From
B-1        45660NM36   BB (sf)              B (sf)/Watch Pos

IndyMac INDX Mortgage Loan Trust 2004-AR5
Series 2004-AR5
                               Rating
Class      CUSIP       To                   From
1-A-1      45660NS22   A (sf)               BBB (sf)/Watch Pos
2-A-1A     45660NS30   AAA (sf)             AA+ (sf)/Watch Pos
2-A-1B     45660NS48   AAA (sf)             AA+ (sf)/Watch Pos
2-A-2      45660NS55   A (sf)               BBB (sf)/Watch Pos
A-X-2      45660NS71   AAA (sf)             AA+ (sf)/Watch Pos

IndyMac INDX Mortgage Loan Trust 2004-AR7
Series 2004-AR7
                               Rating
Class      CUSIP       To                   From
A-1        45660NT88   B+ (sf)              B+ (sf)/Watch Neg
A-2        45660NT96   AA+ (sf)             BBB+ (sf)/Watch Pos
A-3        45660NU29   B+ (sf)              B+ (sf)/Watch Neg
A-5        45660NU45   B+ (sf)              B+ (sf)/Watch Neg

IndyMac INDX Mortgage Loan Trust 2004-AR8
Series 2004-AR8
                               Rating
Class      CUSIP       To                   From
2-A-2A     45660N2J3   A+ (sf)              BB (sf)/Watch Pos

IndyMac INDX Mortgage Loan Trust 2005-AR18
Series 2005-AR18
                               Rating
Class      CUSIP       To                   From
1-A-1      45660LVZ9   CCC (sf)             BB+ (sf)/Watch Neg
2-A-1A     45660LWD7   BBB (sf)             B- (sf)/Watch Pos
2-A-1B     45660LWE5   BBB (sf)             B- (sf)/Watch Pos

IndyMac INDX Mortgage Loan Trust 2005-AR2
Series 2005-AR2
                               Rating
Class      CUSIP       To                   From
1-A-1      45660LCK3   CCC (sf)             B- (sf)/Watch Neg
2-A-1A     45660LCL1   AAA (sf)             A (sf)/Watch Pos
2-A-2A     45660LCN7   CCC (sf)             B- (sf)

IndyMac INDX Mortgage Loan Trust 2005-AR4
Series 2005-AR4
                               Rating
Class      CUSIP       To                   From
2-A-1A     45660LEG0   AA+ (sf)             BB- (sf)/Watch Pos

IndyMac INDX Mortgage Loan Trust 2005-AR8
Series 2005-AR8
                               Rating
Class      CUSIP       To                   From
1-A-1      45660LJH3   CCC (sf)             B- (sf)/Watch Neg
2-A-1A     45660LJJ9   B- (sf)              B (sf)/Watch Neg

IndyMac INDX Mortgage Loan Trust 2006-AR9
Series 2006-AR9
                               Rating
Class      CUSIP       To                   From
3-A-1      45661EGG3   CCC (sf)             AAA (sf)/Watch Neg
3-A-2      45661EGH1   CCC (sf)             AAA (sf)/Watch Neg
3-X        45661EGJ7   NR                   AAA (sf)/Watch Neg
3-A-3      45661EGK4   CCC (sf)             AAA (sf)/Watch Neg

Lehman Mortgage Trust 2006-3
Series 2006-3
                               Rating
Class      CUSIP       To                   From
1-A-1      52520CAD7   CC (sf)              CC (sf)/Watch Pos
1-A10      52520CAN5   CC (sf)              CC (sf)/Watch Pos
1-A12      52520CAQ8   CC (sf)              CC (sf)/Watch Pos

Lehman XS Trust 2006-4N
Series      2006-4N
                               Rating
Class      CUSIP       To                   From
A-1B1      525221KK2   D (sf)               CC (sf)
A1-C1      525221KM8   D (sf)               CC (sf)
A1-D1      525221KP1   D (sf)               CC (sf)
A2-A       525221KR7   CC (sf)              CC (sf)/Watch Pos

Lehman XS Trust Series 2006-GP2
Series 2006-GP2
                               Rating
Class      CUSIP       To                   From
1-A5A      525227AH7   CCC (sf)             B- (sf)/Watch Neg
3-A1       525227AM6   CC (sf)              B- (sf)/Watch Neg

Lehman XS Trust Series 2006-GP4
Series 2006-GP4
                               Rating
Class      CUSIP       To                   From
2-A1       525161AC9   CC (sf)              B- (sf)/Watch Neg

MortgageIT Trust 2005-AR1
Series 2005-AR1
                               Rating
Class      CUSIP       To                   From
I-A-1      61915RBB1   BB (sf)              CCC (sf)/Watch Pos

RALI Series 2005-QA7 Trust
Series 2005-QA7
                               Rating
Class      CUSIP       To                   From
A-II-2     76110H7D5   CCC (sf)             BBB (sf)/Watch Neg

RALI Series 2005-QO1 Trust
Series 2005-QO1
                               Rating
Class      CUSIP       To                   From
A-1        761118EN4   B+ (sf)              BBB+ (sf)/Watch Neg
A-2        761118EP9   B+ (sf)              BBB+ (sf)/Watch Neg
A-3        761118EQ7   CCC (sf)             B- (sf)/Watch Neg

RALI Series 2005-QO2 Trust
Series 2005-QO2
                               Rating
Class      CUSIP       To                   From
A-1        761118HU5   B- (sf)              BB+ (sf)/Watch Neg

RALI Series 2005-QO3 Trust
Series 2005-QO3
                               Rating
Class      CUSIP       To                   From
A-1        761118KU1   CCC (sf)             B- (sf)/Watch Neg

Structured Adjustable Rate Mortgage Loan Trust Series 2005-16XS
Series 2005-16XS
                               Rating
Class      CUSIP       To                   From
A1         863579WR5   AAA (sf)             AA (sf)/Watch Pos
A2A        863579WS3   AAA (sf)             A+ (sf)/Watch Pos
A2B        863579WT1   AAA (sf)             A+ (sf)/Watch Pos
A3         863579WU8   AAA (sf)             A+ (sf)/Watch Pos

Structured Asset Mortgage Investments II Trust 2005-AR2
Series 2005-AR2
                               Rating
Class      CUSIP       To                   From
I-A-1      86359LHX0   CCC (sf)             B- (sf)/Watch Neg
II-A-1     86359LJA8   A (sf)               AAA (sf)/Watch Neg
II-X       86359LJD2   NR                   AAA (sf)/Watch Neg
II-A-2     86359LJB6   CCC (sf)             B- (sf)/Watch Neg

Structured Asset Mortgage Investments II Trust 2006-AR7
Series 2006-AR7
                               Rating
Class      CUSIP       To                   From
A-9        86361HAM6   B (sf)               B (sf)/Watch Neg
A-10       86361HAN4   CC (sf)              CCC (sf)
A-11       86361HAP9   CC (sf)              CCC (sf)

WaMu Mortgage Pass Through Certificates Series 2006-AR13 Trust
Series 2006-AR13
                               Rating
Class      CUSIP       To                   From
2A         93363RAB2   BB+ (sf)             AAA (sf)/Watch Neg
2A-1B      93363RAC0   CCC (sf)             B- (sf)/Watch Neg

WaMu Mortgage Pass-Through Certificates Series 2006-AR15 Trust
Series 2006-AR15
                               Rating
Class      CUSIP       To                   From
2A         93363QAC2   B (sf)               A+ (sf)/Watch Neg
2A-1B      93363QAD0   CC (sf)              CCC (sf)

Ratings Affirmed

BankUnited Trust 2005-1
Series 2005-1
Class      CUSIP       Rating
I-A-3      06652DAP4   CC (sf)
II-A-1     06652DAD1   CC (sf)

Bella Vista Mortgage Trust 2004-2
Series 2004-2
Class      CUSIP       Rating
A-4        07820QBK0   CC (sf)
M          07820QBB0   CC (sf)

CHL Mortgage Pass-Through Trust 2004-20
Series 2004-20
Class      CUSIP       Rating
M          12669F2S1   CC (sf)

CHL Mortgage Pass-Through Trust 2005-1
Series 2005-1
Class      CUSIP       Rating
1-A-2      12669GRN3   CC (sf)
2-A-2      12669GRR4   CC (sf)
2-A-3      12669GSN2   CC (sf)
M-1        12669GRU7   CC (sf)
M-2        12669GSP7   CC (sf)

HarborView Mortgage Loan Trust 2004-10
Series 2004-10
Class      CUSIP       Rating
1-A-1      41161PJH7   AAA (sf)
1-A-2A     41161PJJ3   AAA (sf)
1-A-2B     41161PJW4   AAA (sf)
2-A        41161PJK0   AAA (sf)
3-A-1A     41161PJL8   AAA (sf)
3-A-1B     41161PJM6   AAA (sf)
4-A        41161PJN4   AAA (sf)
X-1        41161PJP9   AAA (sf)
X-2        41161PJQ7   AAA (sf)
B-2        41161PJU8   CC (sf)

HarborView Mortgage Loan Trust 2005-12
Series 2005-12
Class      CUSIP       Rating
1-A1A      41161PVF7   CC (sf)
1-A1B      41161PVH3   CC (sf)
2-A1B      41161PVL4   CC (sf)
PO-1       41161PVP5   CC (sf)
PO-2A      41161PVV2   CC (sf)
PO-2B      41161PVW0   CC (sf)
PO-B       41161PVX8   CC (sf)

HarborView Mortgage Loan Trust 2005-9
Series 2005-9
Class      CUSIP       Rating
1-A        41161PSJ3   AAA (sf)
2-A-1A     41161PSK0   AAA (sf)
2-A-1B     41161PSL8   AAA (sf)
2-A-1C     41161PSM6   AAA (sf)
1-X        41161PSN4   AAA (sf)
2-X        41161PSP9   AAA (sf)
1-PO       41161PSR5   AAA (sf)
2-PO       41161PSS3   AAA (sf)
B-8        41161PTC7   CC (sf)
B-9        41161PTD5   CC (sf)
B-10       41161PTE3   CC (sf)
B-11       41161PTF0   CC (sf)

HarborView Mortgage Loan Trust 2006-1
Series 2006-1
Class      CUSIP       Rating
1-A1A      41161PA60   CCC (sf)
1-A1B      41161PA78   AA+ (sf)
2-A1A      41161PA86   CCC (sf)
2-A1B      41161PA94   CC (sf)
2-A1C      41161PB28   AA+ (sf)


HarborView Mortgage Loan Trust 2006-10
Series 2006-10
Class      CUSIP       Rating
1A-1A      41162CAA9   CC (sf)
1A-1B      41162CAB7   AA+ (sf)
2A-1A      41162CAC5   CCC (sf)
2A-1B      41162CAD3   CC (sf)
2A-1C      41162CAE1   AA+ (sf)

HarborView Mortgage Loan Trust 2006-4
Series 2006-4
Class      CUSIP       Rating
1-A1A      41161PL27   CCC (sf)
1-A2A      41161PP98   CC (sf)
2-A1A      41161PL43   CCC (sf)
2-A1B      41161PL50   CC (sf)
3-A1A      41161PL76   CCC (sf)
3-A1B      41161PP64   CC (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR1
Series 2004-AR1
Class      CUSIP       Rating
B-1        45660NA47   CC (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR12
Series 2004-AR12
Class      CUSIP       Rating
A-2        45660N5J0   CC (sf)
B-1        45660N5N1   CC (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR14
Series 2004-AR14
Class      CUSIP       Rating
1-A-1B     45660LAB5   CC (sf)
2-A-1B     45660LAD1   CC (sf)
2-A-2B     45660LAF6   CC (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR2
Series 2004-AR2
Class      CUSIP       Rating
B-1        45660NH32   CC (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR3
Series 2004-AR3
Class      CUSIP       Rating
A-1        45660NL78   AAA (sf)
A-X-2      45660NL94   AAA (sf)
B-2        45660NM44   CC (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR5
Series 2004-AR5
Class      CUSIP       Rating
B-1        45660NS97   CC (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR7
Series 2004-AR7
Class      CUSIP       Rating
B-1        45660NU52   CC (sf)

IndyMac INDX Mortgage Loan Trust 2004-AR8
Series 2004-AR8
Class      CUSIP       Rating
1-A-1      45660N2H7   CCC (sf)
2-A-1      45660N2L8   CCC (sf)
2-A-2B     45660N2K0   CCC (sf)

IndyMac INDX Mortgage Loan Trust 2005-AR18
Series 2005-AR18
Class      CUSIP       Rating
1-A-2      45660LWA3   CC (sf)
2-A-2A     45660LWV7   CC (sf)
2-A-2B     45660LWW5   CC (sf)
2-A-2C     45660LWF2   CC (sf)

IndyMac INDX Mortgage Loan Trust 2005-AR2
Series 2005-AR2
Class      CUSIP       Rating
2-A-1B     45660LCM9   CC (sf)
2-A-2B     45660LCP2   CC (sf)
2-A-3      45660LCQ0   CC (sf)
2-A-4      45660LCR8   CC (sf)

IndyMac INDX Mortgage Loan Trust 2005-AR4
Series 2005-AR4
Class      CUSIP       Rating
1-A-1      45660LEF2   CC (sf)
2-A-1B     45660LEH8   CC (sf)
2-A-2      45660LEJ4   CC (sf)

IndyMac INDX Mortgage Loan Trust 2005-AR8
Series 2005-AR8
Class      CUSIP       Rating
2-A-1B     45660LJK6   CC (sf)
2-A-2      45660LJL4   CC (sf)
A-PO       45660LJP5   CC (sf)

IndyMac INDX Mortgage Loan Trust 2006-AR9
Series 2006-AR9
Class      CUSIP       Rating
2-A-1      45661EGE8   CC (sf)

Lehman Mortgage Trust 2006-3
Series 2006-3
Class      CUSIP       Rating
3-A1       52520CAA3   CC (sf)
AP         52520CAU9   CC (sf)

MortgageIT Trust 2005-AR1
Series 2005-AR1
Class      CUSIP       Rating
I-A-2      61915RBC9   CC (sf)

RALI Series 2005-QA7 Trust
Series 2005-QA7
Class      CUSIP       Rating
A-I        76110H7A1   CC (sf)
A-II-1     76110H7B9   CC (sf)
A-II-3     76110H7E3   CC (sf)

RALI Series 2005-QO2 Trust
Series 2005-QO2
Class      CUSIP       Rating
A-2        761118HV3   CC (sf)

RALI Series 2005-QO3 Trust
Series 2005-QO3
Class      CUSIP       Rating
A-2        761118KV9   CC (sf)

Structured Adjustable Rate Mortgage Loan Trust Series 2005-16XS
Series 2005-16XS
Class      CUSIP       Rating
M1         863579WV6   CC (sf)
M2         863579WW4   CC (sf)

Structured Asset Mortgage Investments II Trust 2005-AR2
Series 2005-AR2
Class      CUSIP       Rating
I-A-2      86359LHY8   CC (sf)
II-A-3     86359LJC4   CC (sf)
III-A-1    86359LJE0   CCC (sf)
M-1        86359LJS9   CC (sf)
M-2        86359LJT7   CC (sf)
M-3        86359LJU4   CC (sf)
III-A-2    86359LJF7   CCC (sf)

Structured Asset Mortgage Investments II Trust 2006-AR7
Series 2006-AR7
Class      CUSIP       Rating
A-1A       86361HAA2   CCC (sf)
A-1B       86361HAB0   CCC (sf)
A-2A       86361HAC8   CC (sf)
A-2B       86361HAD6   CC (sf)
A-4        86361HAG9   CC (sf)
A-5        86361HAH7   CC (sf)
A-6        86361HAJ3   CC (sf)
A-12       86361HAQ7   CC (sf)
A-13A      86361HAR5   CC (sf)
A-13B      86361HAS3   CC (sf)
B-1        86361HAU8   CC (sf)

WaMu Mortgage Pass Through Certificates Series 2006-AR13 Trust
Series 2006-AR13
Class      CUSIP       Rating
1A         93363RAA4   CCC (sf)
CA-1C      93363RAD8   CC (sf)

WaMu Mortgage Pass-Through Certificates Series 2006-AR15 Trust
Series 2006-AR15
Class      CUSIP       Rating
1A         93363QAA6   CCC (sf)
1A-1B      93363QAB4   CC (sf)
CA-1C      93363QAE8   CC (sf)


BEAR STEARNS: Losses Across the Pool Cues Fitch to Lower Ratings
----------------------------------------------------------------
Fitch Ratings has downgraded two classes and upgraded one class of
Bear Stearns Commercial Mortgage Securities Inc.'s commercial
mortgage pass-through certificates, series 2002-PBW1.

Fitch downgrades these classes:

  -- $16.1 million class H to 'CCCsf/RR1' from 'B-sf'.
  -- $10.4 million class J to 'Csf/RR2' from 'CCCsf/RR2'.

Fitch upgrades this class:

  -- $13.8 million class F to 'BBBsf' from 'BBB-sf'; Outlook to
     Stable from Negative

In addition, Fitch affirms these classes and revises the Outlooks
as indicated:

  -- $384 million class A-2 at 'AAAsf'; Outlook Stable;
  -- $26.5 million class B at 'AAAsf'; Outlook Stable;
  -- $31.1 million class C at 'AAAsf'; Outlook Stable;
  -- $8.1 million class D at 'AAAsf'; Outlook Stable;
  -- $9.2 million class E at 'AAsf'; Outlook to Stable from
     Negative;
  -- $13.8 million class G at 'Bsf'; Outlook to Stable from
     Negative;
  -- $2.8 million class K at 'Dsf/RR6'
  -- Classes L through N at 'Dsf/RR6'

The downgrade reflects Fitch expected losses across the pool.
Fitch modeled losses of 3.55% of the remaining pool.  There are
currently five specially-serviced loans (2.72%) in the pool.

The upgrade reflects reductions to the pool's principal balance
resulting in increased credit enhancement to the senior classes.
As of the July 2011 distribution date, the pool's aggregate
principal balance has been reduced by 44% (including 3.4% of
realized losses) to $515.9 million from $921 million at issuance.
Twenty loans in the pool (34.42%) are currently defeased. Interest
shortfalls are affecting classes J through P.

The largest contributor to Fitch-modeled losses (0.99%) is secured
by secured by a 58,145 square foot (sf) vacant free-standing
retail building located in Toledo, OH.  The loan was transferred
to special servicing in September 2010 due to monetary default.
The special servicer is pursuing foreclosure.

The second largest contributor to Fitch-modeled losses (0.93%) is
secured by a manufactured housing community located in Belle
Vernon, PA.  Utility expenses have increased largely due to the
property switching to the city sewer plan. The 2010 DSCR was 0.44
times (x).

Class A-1 has repaid in full. Classes L through P has been reduced
to zero due to realized losses. Fitch does not rate class P.


BEAR STEARNS: Moody's Affirms Ratings of Eight CMBS Classes
-----------------------------------------------------------
Moody's Investors Service (Moody's) downgraded the ratings of
seven classes, confirmed three classes and affirmed eight classes
of Bear Stearns Commercial Mortgage Securities Trust, Commercial
Mortgage Pass Through Certificates, Series 2007-PWR15:

Cl. A-2, Affirmed at Aaa (sf); previously on Apr 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Apr 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Apr 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Confirmed at Aaa (sf); previously on Jul 29, 2011 Aaa
(sf) Placed Under Review for Possible Downgrade

Cl. A-4FL, Confirmed at Aaa (sf); previously on Jul 29, 2011 Aaa
(sf) Placed Under Review for Possible Downgrade

Cl. A-1A, Confirmed at Aaa (sf); previously on Jul 29, 2011 Aaa
(sf) Placed Under Review for Possible Downgrade

Cl. A-M, Downgraded to Baa1 (sf); previously on Jul 29, 2011 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-MFL, Downgraded to Baa1 (sf); previously on Jul 29, 2011 A1
(sf) Placed Under Review for Possible Downgrade

Cl. A-J, Downgraded to Caa1 (sf); previously on Jul 29, 2011 Ba2
(sf) Placed Under Review for Possible Downgrade

Cl. A-JFL, Downgraded to Caa1 (sf); previously on Jul 29, 2011 Ba2
(sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to Caa3 (sf); previously on Jul 29, 2011 B3 (sf)
Placed Under Review for Possible Downgrade

Cl. C, Downgraded to C (sf); previously on Jul 29, 2011 Caa2 (sf)
Placed Under Review for Possible Downgrade

Cl. D, Downgraded to C (sf); previously on Jul 29, 2011 Ca (sf)
Placed Under Review for Possible Downgrade

Cl. E, Affirmed at C (sf); previously on Feb 11, 2010 Downgraded
to C (sf)

Cl. F, Affirmed at C (sf); previously on Feb 11, 2010 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Feb 11, 2010 Downgraded
to C (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on Apr 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on Apr 9, 2007 Assigned
Aaa (sf)

RATINGS RATIONALE

The downgrades are due to larger than expected princial losses and
interest shortfalls resulting from the workout of the World Market
Center II Loan ($273.1 million - 10.9% of the pool). Moody's
currently anticipates total principal losses of $231.9 million on
the original balance of $345.0 million, as well as recurring
monthly interest shortfalls of $1.2 million. Terms of the
modification include an immediate principal write-down of
$65 million and a subsequent split of the loan into an $80 million
A-Note and a $200 million B-Note. The principal balance of the A-
Note was then written down to $73.1 million, reflecting a credit
for additional interest that accured during the negotiation of the
loan modification. Interest advances that accrued prior to the
initiation of modification negotiation totaling $14.8 million were
paid off by the borrower in full.

In addition to the recently realized losses, Moody's anticipates
an additional $160.0 million of losses from the B-Note, which is
structured with an option that expires on July 1, 2015 that
permits the borrower to pay off the note at an 80% discount to the
outstanding balance upon full payment of the A-Note. Under the
terms of the modification, A-Note will receive interest only
payments at a rate of 4.35% for the remaining term and 80% of all
excess cash flow from the property after expenses and interest on
the A-Note will be directed to amortize the principal balance of
the B-Note. Both notes mature in January 2017 and there is no
lockout period or penalties associated with prepayment.

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

Moody's rating action reflects a cumulative base expected loss of
9.9% of the current balance, the same as at last review. Moody's
base expected loss does not include realized losses to the trust,
which increased to $112.4 million from $19.0 million at last
review. Moody's stressed scenario loss is 29.3% of the current
balance. Moody's provides a current list of base and stress
scenario losses for conduit and fusion CMBS transactions on
moodys.com at:

   http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

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

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011 The hotel
and multifamily sectors are continuing to show signs of recovery,
while recovery in the office and retail sectors will be tied to
recovery of the broader economy. The availability of debt capital
continues to improve with terms returning toward market norms.
Moody's central global macroeconomic scenario reflects an overall
sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit estimate of the loan which corresponds to a range of credit
enhancement levels. Actual fusion credit enhancement levels are
selected based on loan level diversity, pool leverage and other
concentrations and correlations within the pool. Negative pooling,
or adding credit enhancement at the credit estimate level, is
incorporated for loans with similar credit estimates in the same
transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 38 compared to 33 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated April 22, 2011.

DEAL PERFORMANCE

As of the July 11, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 11% to $2.51
billion from $2.81 billion at securitization. The Certificates are
collateralized by 198 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten loans representing
40% of the pool. The pool contains one loan with an investment
grade credit estimate, representing 0.6% of the pool.

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

Nine loans have been liquidated from the pool, resulting in a
realized loss of $38.4 million (25% loss severity). Currently
fourteen loans, representing 15% of the pool, are in special
servicing. The largest specially serviced loan is the World Market
Center Loan ($273.1 million -- 10.9% of the pool), which is
secured by a 1.4 million square foot (SF) home furnishings design
center and showroom located in Las Vegas.

The remaining thirteen specially serviced properties are secured
by a mix of property types. Moody's estimates an aggregate $182.8
million loss for the specially serviced loans (55% expected loss
on average).

Moody's has assumed a high default probability for four poorly
performing loans representing 1% of the pool and has estimated an
aggregate $7.8 million loss (22% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 95%
of the pool's non-specially serviced loans. Excluding specially
serviced and troubled loans, Moody's weighted average LTV is 114%,
the same as at last review. Moody's net cash flow reflects a
weighted average haircut of 10% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 9.2%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.26X and 0.92X, the same as at last review.
Moody's actual DSCR is based on Moody's net cash flow (NCF) and
the loan's actual debt service. Moody's stressed DSCR is based on
Moody's NCF and a 9.25% stressed rate applied to the loan balance.

The loan with a credit estimate is the Commerce Crossings Nine
Loan ($14.4 million -- 0.6% of the pool), which is secured by a
500,000 SF industrial building located in Louisville, Kentucky.
Solectron USA, a fully owned subsidiary of Flextronics
International (Moody's long term corporate family rating Ba1,
stable outlook) has leased the entire property until September
2026. The loan is amortizing on a twenty-one year schedule.
Moody's analysis incorporated the risk associated with the lack of
tenant diversity. Moody's credit estimate and stressed DSCR are
Baa2 and 1.44X, respectively, the same as at last review.

The top three conduit loans represent 13% of the pool. The largest
conduit loan is the AMB-SGP, L.P. Portfolio Loan ($147.6 million -
- 5.9% of the pool), which is secured by 20 industrial properties
totaling 6.5 million SF located in five states. The loan
represents an 80% pari passu interest in a $185.4 million A-Note.
The portfolio is also encumbered by a non-pooled interest only
$105.0 million B-Note. Revenue at the properties declined by 11%
in 2010 from the prior year due to decreases in occupancy. Due to
the deterioration of the portfolio's performance, Moody's removed
the loan's credit estimate at this review. Moody's A-Note LTV and
stressed DSCR are 74% and 1.31X, respectively, compared to 64% and
1.52X at last review.

The second largest conduit loan is the 1325 G Street Loan ($100.0
million -- 4.0% of the pool), which is secured by a 306,563 SF
office property located in Washington, D.C. The loan is interest
only for the full term. The property's tenant base consists of
several government entities including the Neighborhood
Reinvestment Corp (17% of the net rentable area (NRA); lease
expiration May 13, 2013 and the FBI (14% of the NRA; lease
expiration unknown). As of December 2010, the property was 94%
leased, which was in-line with last review. Performance declined
slightly since last review due to lower expense reimbursement
revenue than the prior year. Moody's LTV and stressed DSCR are
113% and 0.81X, respectively, compared to 105% and 0.88X at last
review.

The third largest conduit loan is the Cherry Hill Town Center Loan
($88.0 million -- 3.4% of the pool), which is secured by a 511,306
SF retail center located in Cherry Hill, New Jersey -- a suburb of
Philadelphia. Major tenants include Home Depot (30% of the NRA;
lease expiration January 31, 2031), Wegmans Food Markets (25% of
the NRA; lease expiration February 28, 2031) and Bed Bath & Beyond
(17% of the NRA; lease expiration January 31, 2032). The property
was 99% leased in December 2010, which is in-line with last review
and securitization. Only 2% of tenant leases expire within the
next 24 months. Performance has been stable. Moody's LTV and
stressed DSCR are 101% and 0.88X, respectively, compared to 104%
and 0.86X at last review.


BEAR STEARNS: Moody's Affirms Ratings of Five CMBS Classes
----------------------------------------------------------
Moody's Investors Service has affirmed the credit ratings of Unum
Group (Unum; NYSE: UNM; senior debt at Baa3), and the A3 insurance
financial strength (IFS) ratings of the company's U.S. life
insurance subsidiaries. Moody's also changed the outlook on Unum
and all of its insurance affiliates to positive from stable.

RATINGS RATIONALE

Commenting on the change in Unum's rating outlook to positive,
Moody's Vice President and Senior Credit Officer Ann Perry said,
"Unum's positive earnings momentum, improving business
diversification, and continuing improvement in financial
flexibility is strengthening its credit profile relative to its
current ratings." Moody's noted that Unum's earnings
diversification has improved as voluntary benefits contribute a
growing share of the company's earnings. In addition, because
benefit ratios in the company's core long term disability (LTD)
business have remained relatively stable throughout the economic
slowdown, Moody's expects limited downside risk from an
acceleration of claims under its base scenario of a continued
sluggish economic recovery.

The rating agency added that the positive outlook also reflects
the expectation of further reductions in Unum's financial
leverage, currently in the low 20% range, over the next year and
continued improvement in the company's earnings coverage, driven
both by lower interest expense as debt reduces and by stronger
GAAP and statutory earnings.

Moody's said that the ratings affirmation reflects Unum's leading
market share in the group long-term and individual disability
markets and the company's established position in the voluntary
benefits market. The ratings also benefit from the company's
access to a huge claims data base, focus on claims management and
return-to-work programs, and its strong position in the group life
market.

According to the rating agency, Unum also has a good quality and
liquid investment portfolio, minimal exposure to structured
securities, including non-agency RMBS securities, as well as below
average investment concentration in commercial mortgages. During
the financial crisis, Unum's impairments as a percent of invested
assets were among the lowest in the industry. The rating agency
added that it expects future investment losses will continue to be
manageable relative to Unum's earnings capacity.

Commenting on the challenges facing Unum, Moody's said that
despite improvement in business diversification, a sizeable amount
of Unum's product risk profile and earnings are associated with
the disability business in both the U.S. and UK. Moody's views the
disability product risk profile as one of the higher in the life
insurance industry, as this is a long-tailed business and claims
development can be influenced in unexpected ways by a variety of
economic and societal factors. With the sluggish recovery and
persistent unemployment, the rating agency said that claims could
increase if there is a double dip recession or unemployment rates
increase. However, Moody's noted that the A3 IFS rating
incorporates potential for a moderate increase in the incidence
and/or duration of disability claims.

Moody's said that the following would place upward pressure on
Unum's ratings: 1) a sustained consolidated NAIC RBC ratio of at
least 325%; 2) continued pricing discipline and no deterioration
of loss ratios (i.e., sustained U.S. group disability loss ratio
of not greater than 85%;) 3) adjusted financial leverage remains
below 25%; and 4) cash flow and earnings coverage are maintained
at levels of at least 5 times and 8 times, respectively.
Conversely, the following could result in a return of the outlook
back to stable: 1) sustained U.S. group disability loss ratio of
over 85%; 2) regulatory capitalization falls below a 325% NAIC RBC
ratio; 3) adjusted financial leverage exceeds 25%; or 4) cash-flow
and earnings coverage fall below 5 times and 8 times,
respectively.

These ratings have been affirmed with the outlook changed to
positive from stable:

Unum Group: Senior unsecured debt at Baa3; senior unsecured shelf
at (P)Baa3; subordinate shelf at (P)Ba1; preferred shelf at
(P)Ba2;

UNUM Corporation: Senior unsecured debt at Baa3;

Provident Companies, Inc.: Senior unsecured debt at Baa3;

Provident Financing Trust I: Preferred stock at Ba1 (hyb);

UnumProvident Finance Company plc: Senior unsecured debt at Baa3;

UNUM Life Insurance Company of America: Insurance financial
strength at A3;

First UNUM Life Insurance Company: Insurance financial strength at
A3;

Colonial Life & Accident Insurance Company: Insurance financial
strength at A3;

Provident Life and Accident Insurance Co.: Insurance financial
strength at A3;

Paul Revere Life Insurance Company: Insurance financial strength
at A3;

Paul Revere Variable Annuity Insurance Co.: Insurance financial
strength at A3.

Unum Group Financing Trust I/II: Preferred stock shelf at (P)Ba1.

Unum Group is headquartered in Chattanooga, Tennessee. At June 30,
2011, Unum had total assets of approximately $58 billion and total
shareholders' equity of about $9 billion.

The principal methodology used in this rating was Moody's Global
Rating Methodology for Life Insurers published in May 2010.


BEAR STEARNS: Moody's Upgrades Ratings of Eight CMBS Classes
------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of eight
classes and affirmed five classes of Bear Stearns Commercial
Mortgage Securities Trust 2001-TOP4, Commercial Mortgage Pass-
Through Certificates, Series 2001-TOP4:

Cl. A-3, Affirmed at Aaa (sf); previously on Nov 8, 2001
Definitive Rating Assigned Aaa (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on Nov 8, 2001 Assigned
Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Aug 16, 2006 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Sep 25, 2008 Upgraded
to Aaa (sf)

Cl. D, Upgraded to Aaa (sf); previously on Dec 2, 2010 Upgraded to
Aa1 (sf)

Cl. E, Upgraded to Aa1 (sf); previously on Dec 2, 2010 Upgraded to
A2 (sf)

Cl. F, Upgraded to A2 (sf); previously on Nov 8, 2001 Definitive
Rating Assigned Baa3 (sf)

Cl. G, Upgraded to Baa1 (sf); previously on Nov 8, 2001 Definitive
Rating Assigned Ba1 (sf)

Cl. H, Upgraded to Baa3 (sf); previously on Nov 8, 2001 Definitive
Rating Assigned Ba2 (sf)

Cl. J, Upgraded to B2 (sf); previously on Dec 2, 2010 Downgraded
to B3 (sf)

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

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

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

RATINGS RATIONALE

The upgrades are due to increased subordination from loan payoffs
and amortization and the pool's overall stable performance. The
pool has paid down by 71% since Moody's last review.

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

Moody's rating action reflects a cumulative base expected loss of
4.1% of the current balance compared to 3.4% at last review.
Although the current base expected loss is lower than at the
previous review ($5.6 million compared to $16.2 million), it is
higher on a percentage basis because of the significant paydowns
since last review. Moody's stressed scenario loss is 6.0% of the
current balance. Moody's provides a current list of base and
stress scenario losses for conduit and fusion CMBS transactions on
moodys.com at:

   http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

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

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011. The
hotel and multifamily sectors are continuing to show signs of
recovery, while recovery in the office and retail sectors will be
tied to recovery of the broader economy. The availability of debt
capital continues to improve with terms returning toward market
norms. Moody's central global macroeconomic scenario reflects an
overall sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

The primary methodology used in this rating was: "CMBS: Moody's
Approach to Rating Fusion U.S. CMBS Transactions " published in
April 2005. The other methodology used in this rating was " CMBS:
Moody's Approach to Rating CMBS Large Loan/Single Borrower
Transactions" published in July 2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit estimate of the loan which corresponds to a range of credit
enhancement levels. Actual fusion credit enhancement levels are
selected based on loan level diversity, pool leverage and other
concentrations and correlations within the pool. Negative pooling,
or adding credit enhancement at the credit estimate level, is
incorporated for loans with similar credit estimates in the same
transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 18 compared to 35 at Moody's prior review.

In cases where the Herf falls below 20, Moody's employs also the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.1. The large loan model derives
credit enhancement levels based on an aggregation of adjusted loan
level proceeds derived from Moody's loan level LTV ratios. Major
adjustments to determining proceeds include leverage, loan
structure, property type, and sponsorship. These aggregated
proceeds are then further adjusted for any pooling benefits
associated with loan level diversity, other concentrations and
correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 2, 2010. Please see
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 85% to
$138.4 million from $902.5 million at securitization. The
Certificates are collateralized by 38 mortgage loans ranging
in size from less than 1% to 9% of the pool, with the top ten
loans representing 55% of the pool.

Eleven loans, representing 34% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Four loans have been liquidated from the pool since
securitization, resulting in an aggregate $6.0 million loss (50%
loss severity on average). Currently, there are four loans,
representing 9% of the pool, in special servicing. Moody's has
estimated an aggregate loss of $2.0 million (31% expected loss on
average) for the specially serviced loans.

Moody's has assumed a high default probability for two poorly
performing loans, representing 8% of the pool, and estimated an
aggregate $2.1 million loss (20% expected loss based on a 50%
probability of default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 98% and 47% of the pool, respectively.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV is 61% compared to 66% at last review. Moody's net
cash flow reflects a weighted average haircut of 11% to the most
recently available net operating income. Moody's value reflects a
weighted average capitalization rate of 9.6.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.63X and 1.97X, respectively, compared to
1.53X and 1.78X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The loan with a credit estimate is the Tyson's Square Loan
($12.2 million -- 8.8%), which is secured by a 163,000 square foot
(SF) retail power center located in Tyson's Corner, Virginia. The
property was 99% leased as of March 2011 compared to 83% at last
review. Major tenants include Marshalls and the Sports Authority.
The loan has benefited from 33% amortization since securitization.
Moody's current credit estimate and stressed DSCR are Aa2 and
2.10X, respectively, compared to Aa2 and 2.05X at the prior
review.

The top three conduit loans represent 24% of the outstanding
pool balance. The largest loan is The Crossing at Stonegate Loan
($12.8 million -- 9.2% of the pool), which is secured by a 109,000
SF grocery anchored retail center located in Parker, Colorado. The
property was 97% leased as of March 2011 compared to 98% at last
review. Performance has been stable. Moody's LTV and stressed DSCR
are 80% and 1.28X, respectively, compared to 85% and 1.20X at last
review.

The second largest loan is the Feather Down Shopping Center Loan
($11.3 million -- 8.2% of the pool), which is secured by a 177,000
SF retail shopping center located in Yuba City, California. The
property was 97% leased as of March 2011, the same as last review.
Year-end 2010 performance has declined compared to year-end 2009
due to higher expenses but it was still above the level at
securitization. Moody's LTV and stressed DSCR are 67% and 1.53X,
respectively, compared to 60% and 1.72X at last review.

The third largest loan is the Pinellas Business Center Loan
($8.8 million -- 6.4% of the pool), which is secured by a
203,000 SF industrial property located in St. Petersburg, Florida.
Performance has declined since last review due to lower revenues.
Year-end 2010 Net Operating Income (NOI) has decreased by 15%
compared to year-end 2009. The property was 55% leased as of May
2011 compared to 71% at last review. The loan is on the servicer's
watchlist due to performance issue and upcoming maturity. The loan
matures in September 2011. Moody's has recognized this loan as a
troubled loan. Moody's LTV and stressed DSCR are 123% and 0.84X,
respectively, compared to 112% and 0.92X at last review.


BECKMAN COULTER: Fitch Holds 'BB-' Rating on $97 Mil. Class Notes
-----------------------------------------------------------------
Fitch Ratings has affirmed and revised the Outlook on this class
of Beckman Coulter, Inc., series BC 2000-A:

  -- $97.3 million class A at 'BB-'; Outlook to Positive from
     Stable.

The affirmation is the result of stable performance at the two
collateral properties and continued creditworthiness of the
tenant.  The single tenant at both properties -- Beckman Coulter,
Inc. -- was recently acquired by Danaher Corporation, an
investment grade-rated tenant.  The effects of the acquisition
from an operational perspective are unknown to Fitch at this time.
The Positive Outlook reflects the potential for a future upgrade
if the tenant continues to operate at both of the subject
properties and if the loan continues to amortize as expected
through the maturity date.

The loans are secured by two single-tenant office/research and
development facilities, located in Brea, CA and Miami, FL and
comprising a total of approximately 1.1 million square feet.  Each
property is subject to a triple-net lease in which the tenant is
obligated to remit rental payments at a rate reflecting an amount
equal to the loan's principal and interest payments.  The leases
expire within one month of the loans' maturity dates of June 30,
2018.  Assuming no defaults or prepayments, the combined balance
of the loans at maturity is expected to be approximately $53.1
million ($46 per square foot).  According to the servicer's 2010
inspection report, the Brea property recently underwent extensive
interior renovations at a cost of approximately $80 million.

The loan remains current on its principal and interest payments.
As part of its analysis, Fitch took the current in-place rents
and deducted market vacancy factors, market management fees, and
assumed capital expenditures and leasing costs in order to derive
a normalized operating cash flow for the properties.  The
resulting stressed debt service coverage ratio, which gives credit
for amortization and is based upon Fitch's stressed cash flow and
a debt service constant of 9.66%, is 1.39 times (x).


BLUEMOUNTAIN CLO: S&P Gives 'BB' Rating on Class E Notes
--------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to
BlueMountain CLO 2011-1 Ltd./BlueMountain CLO 2011-1 LLC's
$322.0 million floating-rate notes.

The ratings reflect S&P's assessment of:

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

    The transaction's credit enhancement, which is sufficient to
    withstand the defaults applicable for the supplemental tests
    (not counting excess spread) and cash flow structure, which
    can withstand the default rate projected by Standard & Poor's
    CDO Evaluator model, as assessed by Standard & Poor's using
    the assumptions and methods outlined in its corporate
    collateralized debt obligation (CDO) criteria, (see 'Update To
    Global Methodologies And Assumptions For Corporate Cash Flow
    And Synthetic CDOs,' published Sept. 17, 2009).

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

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

    The portfolio manager's experienced management team.

    "Our projections regarding the timely interest and ultimate
    principal payments on the rated notes, which we assessed using
    our cash flow analysis and assumptions commensurate with the
    assigned ratings under various interest-rate scenarios,
    including LIBOR ranging from 0.16%-13.80%," S&P related.

    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 reinvestment overcollateralization test, a
    failure of which will lead to the reclassification of excess
    interest proceeds that are available prior to paying uncapped
    administrative expenses and fees, subordinated hedge
    termination payments, portfolio manager incentive fees, and
    subordinated note payments to principal proceeds for the
    purchase of additional collateral assets during the
    reinvestment period.

Ratings Assigned

BlueMountain CLO 2011-1 Ltd./BlueMountain CLO 2011-1 LLC

Class               Rating        Amount (mil. $)
A                   AAA (sf)                228.0
B                   AA (sf)                  34.0
C (deferrable)      A (sf)                   28.0
D (deferrable)      BBB (sf)                 17.0
E (deferrable)      BB (sf)                  15.0
Subordinated notes  NR                       39.0

NR -- Not rated.


BRIDGEPORT CLO: Moody's Upgrades Ratings of 4 Classes of CLO Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Bridgeport CLO Ltd.:

US$24,000,000 Class A-2 Senior Floating Rate Notes, Upgraded to
Aa3 (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$22,000,000 Class B Deferrable Mezzanine Floating Rate Notes,
Upgraded to Baa1 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$25,000,000 Class C Deferrable Mezzanine Floating Rate Notes,
Upgraded to Ba2 (sf); previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$17,500,000 Class D Deferrable Mezzanine Floating Rate Notes
(current balance of $14,292,792), Upgraded to B1 (sf); previously
on June 22, 2011 B3 (sf) Placed Under Review for Possible Upgrade.

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

US$387,500,000 Class A-1 Senior Floating Rate Notes (current
balance of $372,534,589), Confirmed at Aa1 (sf); previously on
June 22, 2011 Aa1 (sf) Placed Under Review for Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in September
2009. Based on the July 2011 trustee report, the weighted average
rating factor is currently 2409 compared to 2798 in August 2009.
Based on the same trustee report, the Class A, Class B, Class C,
and Class D overcollateralization ratios are reported at 119.82%,
113.52%, 107.12, and 103.78%, respectively, versus August 2009
levels of 113.91%, 108.05%, 102.07, and 98.91%, respectively, and
all related overcollateralization tests are currently in
compliance. In particular, the Class D overcollateralization ratio
has increased in part due to the diversion of excess interest to
delever the Class D notes in the event of a Class D
overcollateralization test failure. Moody's also notes that the
Class D Notes are no longer deferring interest and that all
previously deferred interest has been paid in full.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par and weighted average recovery
rate may be different from the trustee's reported numbers. In its
base case, Moody's analyzed the underlying collateral pool to have
a performing par and principal proceeds balance of $474.5 million,
defaulted par of $5.6 million, a weighted average default
probability of 21.19% (implying a WARF of 2626), a weighted
average recovery rate upon default of 47.23%, and a diversity
score of 80. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

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

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor and diversity score. However, as part of the base
   case, Moody's considered spread levels higher than the covenant
   levels due to the large difference between the reported and
   covenant levels.


BRIDGEPORT CLO: Moody's Upgrades Ratings of Floating Rate Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Bridgeport CLO II Ltd.:

US$26,000,000 Class B Deferrable Mezzanine Floating Rate Notes Due
2021, Upgraded to Baa1 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$22,000,000 Class C Deferrable Mezzanine Floating Rate Notes Due
2021, Upgraded to Ba1 (sf); previously on June 22, 2011 Ba3 (sf)
Placed Under Review for Possible Upgrade;

US$19,000,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2021 (current outstanding balance of $14,319,674), Upgraded to Ba3
(sf); previously on June 22, 2011 B3 (sf) Placed Under Review for
Possible Upgrade.

In addition, Moody's confirmed the ratings of these notes:

US$390,000,000 Class A-1 Senior Floating Rate Notes Due 2021
(current outstanding balance of $386,363,301), Confirmed at Aa1
(sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$21,000,000 Class A-2 Senior Floating Rate Notes Due 2021,
Confirmed at A1 (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The actions reflect key
changes to the modeling assumptions, which incorporate (1) a
removal of the temporary 30% default probability macro stress
implemented in February 2009 as well as (2) increased BET
liability stress factors and increased recovery rate assumptions.

The actions also reflect an improvement in the credit quality of
the underlying portfolio. Based on the latest trustee report from
July 2011, the weighted average rating factor is currently 2452
compared to 2813 in the August 2009 report. Additionally, the
Class D overcollateralization ratio has increased in part due to
the diversion of excess interest to delever the Class D notes.
Since the rating action in September 2009, $2.5 million of
interest proceeds have reduced the outstanding balance of the
Class D Notes by 15%. Moody's also notes that the Class D Notes
are no longer deferring interest and that all previously deferred
interest has been paid in full.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $483 million,
defaulted par of $7 million, a weighted average default
probability of 22.4% (implying a WARF of 2732), a weighted average
recovery rate upon default of 48.5%, and a diversity score of 72.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Bridgeport CLO II Ltd., issued in June 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior, 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, and diversity score.
   However, as part of the base case, Moody's considered spread
   and diversity levels higher than the covenant levels due to the
   large difference between the reported and covenant levels.


CALLIDUS DEBT: Moody's Upgrades Ratings of 5 Classes of Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Callidus Debt Partners CLO Fund V, Ltd.:

US$23,000,000 Class A-2 Senior Secured Floating Rate Notes Due
2020, Upgraded to Aa3 (sf); previously on June 22, 2011 A1 (sf)
Placed Under Review for Possible Upgrade;

US$21,000,000 Class B Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to Baa1 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$20,600,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to Ba1 (sf); previously on June 22, 2011
B1 (sf) Placed Under Review for Possible Upgrade;

US$13,000,000 Class D Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded at B1 (sf); previously on June 22, 2011
Caa2 (sf) Placed Under Review for Possible Upgrade; and

US$10,000,000 Class Q-1 Securities Due 2020 (current rated balance
of $6,070,107), Upgraded to Baa3 (sf); previously on June 22, 2011
Ba3 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $399 million,
defaulted par of $339,032, a weighted average default probability
of 23.56% (implying a WARF of 2,969), a weighted average recovery
rate upon default of 48.95%, and a diversity score of 65. The
default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Callidus Debt Partners CLO Fund V, Ltd., issued in December 2006,
is a collateralized loan obligation backed primarily by a
portfolio of senior secured loans.

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

Other methodology used in this rating was "Using the Structured
Note Methodology to Rate CDO Combo-Notes" published in February
2004.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score. However, as part of the base case,
   Moody's considered spread, coupon, and diversity levels higher
   than the covenants and WARF level lower than the covenant due
   to the large difference between the reported and covenant
   levels.


CASHEL ROCK: S&P Withdraws 'B+' Rating on Class B Notes
-------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 12
classes of notes from eight collateralized debt obligation (CDO)
transactions.

The withdrawals follow the complete paydown of the notes on their
most recent payment dates.

505 CLO II Ltd. is a collateralized loan obligation (CLO) managed
by CIT Asset Management LLC. The class A-1 and A-2 notes were paid
in full on the May 10, 2011, payment date. Each had an outstanding
balance of $44.04 million.

Archimedes Funding IV (Cayman) Ltd. is a CLO managed by West Gate
Horizons Advisors LLC. The class A-2 notes were paid in full on
the May 25, 2011, payment date from an outstanding balance of
$15.42 million.

CapitalSource Commercial Loan Trust 2006-2 is a CLO serviced by
CapitalSource Finance LLC. The class A-PT and class A-1B notes
were paid in full on the May 20, 2011, payment date from
outstanding balances of $2.89 million and $6.72 million,
respectively. The class B notes were paid in full on the June 20,
2011, payment date from an outstanding balance of $34.56 million.

Cashel Rock CBO Ltd. is a collateralized bond obligation (CBO)
managed by Allied Irish Banks N.A. Inc. The class A-3 and class B
notes were paid in full following a notice of optional redemption.
"We received this notice on June 14, 2011, indicating that greater
than 50% of the voting holders had directed a full redemption of
the notes. The class A-3 notes and B notes were paid in full on
the July 15, 2011, payment date from outstanding balances of
$11.90 million and $25.65 million," S&P related.

Crest G-Star 2001-1 LP is a cash flow CDO backed by commercial
mortgage backed securities and managed by Ventras Capital
Advisors. The class A notes were paid in full on the May 31, 2011,
payment date from an outstanding balance of $46.13 million.

Landmark II CDO Ltd. is a CLO managed by Aladdin Capital
Management LLC.  The class B notes were paid in full on July 7,
2011, from an outstanding balance of $0.99 million. The special
distribution was made following the resolution of the interpleader
request previously filed with the U.S. courts.  The order of the
resolution directed the trustee to release all previously escrowed
funds to pay the principal balance of the class B notes before
paying class C interest.

Lone Star CBO Funding Ltd. is a CBO managed by Sage Advisory
Services Ltd.

The class A notes were paid in full on the June 15, 2011, payment
date from an outstanding balance of $25.89 million.

Triaxx Prime CDO 2006-2 Ltd. is a cash flow CDO backed by high-
grade structured finance assets managed by ICP Asset Management
LLC. The class A-1B1 notes were paid in full on the April 4, 2011,
payment date from an outstanding balance of $11.01 million.

Ratings Withdrawn

505 CLO II Ltd.
                            Rating
Class               To                  From
A-1                 NR                  AAA (sf)
A-2                 NR                  AAA (sf)

Archimedes Funding IV (Cayman) Ltd.
                            Rating
Class               To                  From
A-2                 NR                  AAA (sf)

CapitalSource Commercial Loan Trust 2006-2
                            Rating
Class               To                  From
A-PT                NR                  AAA (sf)
A-1B                NR                  AAA (sf)
B                   NR                  AAA (sf)

Cashel Rock CBO Ltd.
                            Rating
Class               To                  From
A-3                 NR                  A- (sf)
B                   NR                  B+ (sf)

Crest G-Star 2001-1 LP
                            Rating
Class               To                  From
A                   NR                  AA+ (sf)

Landmark II CDO Ltd.
                            Rating
Class               To                  From
B                   NR                  BB+ (sf)

Lone Star CBO Funding Ltd.
                            Rating
Class               To                  From
A                   NR                  AAA (sf)

Triaxx Prime CDO 2006-2 Ltd.
                            Rating
Class               To                  From
A-1B1               NR                  B (sf)

NR -- Not rated.


CIT MARINE: S&P Affirms Rating on Certificate at 'B'
----------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on class
A-4, as well as the certificate class from CIT Marine Trust 1999-
A. "Concurrently, we removed the rating on class A-4 from
CreditWatch, where we placed it with negative implications on
March 16, 2011," S&P related.

"We placed the rating on CreditWatch in March due to deteriorating
collateral performance and the resulting draws from the reserve
fund," S&P said.

The transaction is a securitization of marine installment sales
contracts and loans secured by new and used boats, boat motors,
and boat trailers. "We lowered our lifetime cumulative net loss
expectations to 6.75%-6.90%. Additional collateral data, as well
as improved loss-to-liquidation rates prompted our revision.
However, approximately 450 of the initial 23,000 loans remain
outstanding, but the average loan balance has only dropped to
$25,000 from $32,000, resulting from large remaining loan
balances. In order to address the potential impact of tail-end
defaults on the loss coverage, we used a concentration risk
analysis to assess remaining losses, in which we assumed the
obligors with the highest remaining balances default. The drops in
our remaining loss expectations, coupled with credit enhancement
that has increased as a percent of the amortizing pool balance
since our CreditWatch placement, translates to loss coverage
commensurate with the affirmed ratings," S&P said.

"When we placed the rating on class A4 on CreditWatch negative on
March 16, 2011, the pool's net loss-to-liquidation rate was 22.0%
for January 2010-January 2011, compared with the current 12.4%
from June 2010-June 2011, a marked improvement from 37.7%, the
highest 12-month rate from March 2009-March 2010. The net loss-to-
liquidation rate we observed over the life of the transaction is
6.65% (the average rate of loss-to-liquidation when considering
the loss-to-liquidation rate from inception to the current date).
We expect loss-to-liquidation rates to remain within the range
observed over the past two years over the remaining life of the
transaction," S&P said.

Table 1
Collateral Performance (%)
As of July 2011 distribution
                            Former      Revised
    Pool   Current 60+ day  lifetime    lifetime
Mo. factor CNL     delinq.  CNL exp.*   CNL exp.
149 1.58   6.55    2.83     6.80-7.00   6.75-6.90
CNL exp.-cumulative net loss expectation.
*The initial lifetime CNL expectation was 3.65%-3.75%

The transaction was initially structured as a priority pro rata
principal payment structure with credit enhancement in the form of
a reserve account, overcollateralization, subordination for the
class A notes, and excess spread. In addition, the transaction
benefits from an irrevocable and unconditional bond insurance
policy provided by MBIA Insurance Corp. (MBIA; 'B' insurance
financial strength rating) that guarantees the timely payment of
interest and ultimate payment of principal by the legal final
maturity date on the notes and certificates.

The transaction documents specified an initial reserve amount
equal to $27.6 million (3.75% of the initial pool balance) that
amortized down to the floor amount of $7.35 million (1.00% of the
initial pool balance). The transaction also started with zero
overcollateralization (O/C), which increased to the specified
target amount of 1.25% of the initial pool balance. The current
reserve account balance is equal to $1.39 million (12.03% of the
current pool balance), which is below the specified floor of
$7.35 million. Due to high losses in the past several years,
the transaction depleted its O/C and made multiple draws on
the reserve account since July 2008, reducing the balance by
$5.96 million. Improved performance over the past 12 months has
slowed the rate at which the transaction is withdrawing from the
reserve account. In addition, despite the 12.7% decrease on a
dollar basis over the past six months, the reserve account balance
rose as a percentage of the current pool outstanding. In addition,
there was also a slight build in O/C in the amount of $13,403
equal to 0.12% of the current collateral outstanding. The class A
notes also benefit from subordination of the certificate class.
"The affirmations reflect our view that the credit enhancement
available to cover losses (as it relates to our revised
expectations for remaining cumulative net losses) is sufficient
to maintain the ratings at their current levels," S&P said.

Table 2
Reserve And OC Levels (%)
(As of the July 2011 distribution date)

Initial   Reserve   Current   Current
reserve   account   reserve   reserve  OC       Current
deposit   floor     account   account  target   OC
(% of     (% of     (% of     (% of    (% of    (% of
initial)  initial)  initial)  current) initial) current)
3.75      1.00      0.19      12.03    1.25     0.12

OC -- overcollateralization.

Table 3
Hard Credit Enhancement
(As of the July 2011 distribution date)

                                    Current
                  Total hard        total hard
       Pool       credit support    credit support*
Class  factor(%)  at issuance*      (% of current)
A-4    1.58       5.25              32.55
Cert   1.58       3.75              12.15

*Consists of a reserve account and overcollateralization, as well
as subordination for the class A-4, and excludes the monoline
insurance wrap and excess spread that can also provide additional
enhancement.

"Our analysis of this transaction included the review of current
and historical performance to estimate future performance. The
various scenarios included forward-looking assumptions on defaults
and recoveries that we believe are appropriate given the
transaction's current performance. The results demonstrated, in
our view, that the outstanding A-4 and certificate classes have
adequate credit enhancement available at the affirmed rating
levels," S&P said.

"Standard & Poor's will continue to monitor the performance of the
transaction to ensure the credit enhancement remains sufficient,
in our view, to cover our revised cumulative net loss expectations
under our stress scenarios for each of the rated classes," S&P
added.

Rating Affirmed And Removed From Creditwatch Negative

CIT Marine Trust 1999-A
                         Rating
Class           To                   From
A-4             BBB+ (sf)            BBB+/Watch Neg (sf)

Rating Affirmed

CIT Marine Trust 1999-A

Class           Rating
Certificate     B (sf)


CITIGROUP COMMERCIAL: S&P Cuts Rating on Class HTT-2 to 'CCC+'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on two
nonpooled classes of commercial mortgage pass-through certificates
from Citigroup Commercial Mortgage Trust 2007-FL3 (CGCMT 2007-
FL3). "At the same time, we affirmed our ratings on 12 pooled and
two nonpooled classes from the same transaction. In addition, we
affirmed our ratings on two raked classes of commercial mortgage
pass-through certificates from Wachovia Bank Commercial Mortgage
Trust's series 2007-WHALE8 (WBCMT 2007-WHALE8). Both transactions
are U.S. commercial mortgage-backed securities (CMBS)
transactions," S&P related.

"Our affirmations and downgrades follow our analysis of the CGCMT
2007-FL3 transaction, which included our revaluation of the
lodging properties securing the remaining seven floating-rate
loans in the pool, one of which is currently with the special
servicer. All of the loans are indexed to one-month LIBOR. The
reported one-month LIBOR was 0.188% (according to the July 15,
2011, trustee remittance report). Our weighed average adjusted
valuations on the hotel properties were comparable to the levels
we assessed in our last review dated May 22, 2009," S&P said.

"We lowered our ratings on the 'HTT' raked certificate classes
from CGCMT 2007-FL3, which derive 100% of their cash flow from a
subordinate nonpooled component of the Hotel 30 30 loan," S&P
said.

"We affirmed our 'CCC- (sf)' ratings on the "THH" and "HH" raked
certificate classes from CGCMT 2007-FL3 and WBCMT 2007-WHALE8,
respectively. These certificates derive 100% of their cash flow
from a subordinate nonpooled component of the Hudson Hotel loan,"
S&P related.

"We affirmed our 'AAA (sf)' rating on the class X-2 interest-only
certificate in CGCMT 2007-FL3 based on our current criteria," S&P
said.

"We based our analysis of the hotel properties in CGCMT 2007-FL3,
in part, on a review of the borrowers' operating statements for
the trailing 12-month period ended 2011 and year-end 2010, as well
as available Smith Travel Research (STR) reports," S&P related.

As of the July 15, 2011, trustee remittance report for CGCMT 2007-
FL3, the collateral pooled trust balance includes seven floating-
rate loans secured by lodging properties totaling $400.5 million.
The hotel properties are located in Scottsdale, Ariz. (33.2%),
Manhattan (63.2%), and Beverly Hills, Calif. (3.6%).

Details of the three largest loans and the Hotel 30 30 loan
comprising 81.5% of the pooled trust balance in CGCMT 2007-FL3
are:

The Fairmont Scottsdale Princess loan, the largest loan in the
CGCMT 2007-FL3 trust ($133.0 million, 33.2%), is secured by a 651-
room full-service hotel resort in Scottsdale. KeyBank Real Estate
Capital (KeyBank), one of the two special servicers in the CGCMT
2007-FL3 transaction, recently restructured the loan. "It is our
understanding from KeyBank that any expenses related to the loan
restructuring will be paid by the borrower. The loan also appears
on the master servicer's watchlist due to the recent loan
restructuring. According to KeyBank, the restructuring agreement
closed and was made effective as of June 9, 2011. The
restructuring terms include the conversion of the $40.0 million
mezzanine note to equity, the extension of the maturity date of
the trust note to Dec. 31, 2013, a principal paydown of $7.0
million to the trust balance, and a construction reserve to expand
the ballroom and meeting space. As of the trailing 12-month period
ending March 31, 2011, the reported occupancy and average daily
rate (ADR) for the resort property were 65.3% and $204.69,
yielding a revenue per available room (RevPAR) of $133.61, up from
the reported $127.74 as of year-end 2010. Standard & Poor's
analysis yielded a stressed loan-to-value (LTV) ratio of 111.5% of
the pooled trust balance. The master servicer, also KeyBank,
reported a debt service coverage (DSC) of 7.18x for the 12 months
ending March 31, 2011," S&P related.

The Hudson Hotel loan, the second-largest loan in the CGCMT 2007-
FL3 pool, has a whole-loan balance of $201.2 million that consists
of a $189.0 million senior participation and a $12.2 million
nontrust junior participation. The senior participation is further
split into two pari passu pieces. The first is a $94.5 million
pari passu loan that is further divided into a $86.6 million
senior pooled component (21.6% of the CGCMT 2007-FL3 pool trust
balance), and a $7.9 million nonpooled subordinate component in
CGCMT 2007-FL3 that is raked to the class THH-1 and THH-2
certificates. The senior portion of the other $86.6 million pari
passu piece is included in the WBCMT 2007-WHALE8 transaction, as
well as a $7.9 million nonpooled subordinate component that is
raked to the class HH-1 and HH-2 certificates. This loan was
transferred to the special servicer, CWCapital Asset Management
LLC (CWCapital), on May 20, 2010, due to imminent default. The
loan has a current payment status and matures on Oct. 15, 2011.
The loan is secured by an 805-room full-service boutique hotel in
midtown Manhattan. The borrower's year-end 2010 operating
statements reported an increase in net operating income of 33.4%
from 2009 and a RevPAR of $195.22, up 15.1% from year-end 2009.
Our analysis yielded a stressed LTV ratio of 107.4% on the CGCMT
2007-FL3 trust balance. "Consequently, we affirmed our 'CCC- (sf)'
ratings on the raked certificates in CGCMT 2007-FL3 and WBCMT
2007-WHALE8. CWCapital indicated that the subordinate nontrust
participation should absorb the workout and special servicing fees
on this loan. KeyBank reported a 7.84x DSC for the 12 months ended
June 30, 2010," S&P related.

The Hilton Garden Inn Times Square loan, the third-largest loan in
the CGCMT 2007-FL3 pool, has a trust and whole-loan balance of
$77.5 million (19.4% of the pool trust balance) and is secured by
a 369-room limited-service hotel, located in New York City. As of
year-end 2010, the reported occupancy and ADR for the property
were 99.1% and $244.69, yielding a RevPAR of $242.59, down from
$248.90 as of year-end 2009. Standard & Poor's analysis
yielded a stressed LTV ratio of 66.4% on the trust balance.
KeyBank reported a DSC of 9.53x for the 12 months ended March 31,
2011.

The Hotel 30 30 loan, the fifth-largest loan in the CGCMT 2007-FL3
pool, has a whole-loan balance of $57.0 million that is divided
into a $29.1 million senior pooled component that makes up 7.3% of
the CGCMT 2007-FL3 pooled trust balance and a $3.9 million
subordinate nonpooled component that is raked to the "HTT"
certificates. The loan is secured by a 232-room limited-service
hotel, located in New York City. As of year-end 2010, the reported
occupancy and ADR for the property were 93.2% and $125.64,
yielding a RevPAR of $117.10, down from $133.45 as of year-end
2009. Standard & Poor's analysis yielded a stressed LTV ratio of
86.7% on the trust balance. KeyBank reported a DSC of 11.24x for
the 12 months ended March 31, 2011.

Ratings Lowered

Citigroup Commercial Mortgage Trust 2007-FL3
Commercial mortgage pass-through certificates
                 Rating
Class      To              From      Credit Enhancement (%)
HTT-1      B (sf)          B+ (sf)                      N/A
HTT-2      CCC+ (sf)       B- (sf)                      N/A

Ratings Affirmed

Citigroup Commercial Mortgage Trust 2007-FL3
Commercial mortgage pass-through certificates


Class          Rating        Credit enhancement (%)
A-1            AAA (sf)                       75.67
A-2            A+ (sf)                        34.57
B              BBB+ (sf)                      28.35
C              BBB- (sf)                      23.38
D              BB+ (sf)                       20.15
E              BB (sf)                        17.16
F              BB- (sf)                       13.93
G              B- (sf)                        10.94
H              CCC+ (sf)                       7.96
J              CCC (sf)                        4.97
K              CCC- (sf)                        N/A
THH-1          CCC- (sf)                        N/A
THH-2          CCC- (sf)                        N/A
X-2            AAA (sf)                         N/A

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2007-WHALE8

Class        Rating       Credit enhancement (%)
HH-1         CCC- (sf)                     N/A
HH-2         CCC- (sf)                     N/A

N/A -- not applicable.


COLUMBUS PARK: Moody's Upgrades Ratings of 3 Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Columbus Park CDO Ltd.:

US$19,000,000 Class B Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to A2 (sf); previously on June 22, 2011
Baa2 (sf) Placed Under Review for Possible Upgrade;

US$12,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to Baa2 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$13,000,000 Class D Secured Deferrable Floating Rate Notes due
2020, Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf)
Placed Under Review for Possible Upgrade.

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

US$19,000,000 Class A-2 Senior Secured Floating Rate Notes due
2020, Confirmed at Aa2 (sf); previously on June 22, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $410 million,
which is higher than the effective date amount, a weighted average
default probability of 21.61% (implying a WARF of 2700), a
weighted average recovery rate upon default of 47.50%, and a
diversity score of 60. The default and recovery properties of the
collateral pool are incorporated in cash flow model analysis where
they are subject to stresses as a function of the target rating of
each CLO liability being reviewed. The default probability is
derived from the credit quality of the collateral pool and Moody's
expectation of the remaining life of the collateral pool. The
average recovery rate to be realized on future defaults is based
primarily on the seniority of the assets in the collateral pool.
In each case, historical and market performance trends and
collateral manager latitude for trading the collateral are also
factors.

Columbus Park CDO Ltd., issued in April 2008, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   spread and diversity score. However, as part of the base case,
   Moody's considered a WARF level lower than the covenant level
   due to the large difference between the reported and covenant
   levels.


COLUMBUSNOVA CLO: Moody's Raises Ratings of Five Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by ColumbusNova CLO Ltd. 2006-II:

US$375,000,000 Class A Senior Notes Due April 4, 2018 (current
outstanding balance of $372,535,745), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$30,000,000 Class B Senior Notes Due April 4, 2018, Upgraded to
Aa3 (sf); previously on June 22, 2011 A1 (sf) Placed Under Review
for Possible Upgrade;

US$22,000,000 Class C Deferrable Mezzanine Notes Due April 4,
2018, Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$20,000,000 Class D Deferrable Mezzanine Notes Due April 4,
2018, Upgraded to Ba1 (sf); previously on June 22, 2011 Ba3 (sf)
Placed Under Review for Possible Upgrade;

US$15,000,000 Class E Deferrable Junior Notes Due April 4, 2018,
Upgraded to Ba3 (sf); previously on June 22, 2011 B3 (sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio since the rating action in September
2009. Based on the June 2011 trustee report, the weighted average
rating factor is currently 2372 compared to 2848 in August 2009.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes. Based on the June 2011 trustee report,
reference securities that mature after the maturity date of the
notes currently make up approximately 4.2% of the underlying
reference portfolio. These investments potentially expose the
notes to market risk in the event of liquidation at the time of
the notes' maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $491.4 million,
no defaulted par, a weighted average default probability of 19.52%
(implying a WARF of 2667), a weighted average recovery rate upon
default of 49.82%, and a diversity score of 75. The default and
recovery properties of the collateral pool are incorporated in
cash flow model analysis where they are subject to stresses as a
function of the target rating of each CLO liability being
reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

ColumbusNova CLO Ltd. 2006-II, issued in December 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor and diversity score. However, as part of the base
   case, Moody's considered spread level higher than the covenant
   and WARF level lower than the covenant due to the large
   difference between the reported and covenant level.


COLUMBUSNOVA CLO: Moody's Upgrades Ratings of CLO Notes
-------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by ColumbusNova CLO Ltd. 2006-I:

US$300,000,000 Class A Senior Notes (current balance of
$295,595,472), Upgraded to Aaa (sf); previously on June 22, 2011
Aa1 (sf) Placed Under Review for Possible Upgrade;

US$24,000,000 Class B Senior Notes, Upgraded to Aa3 (sf);
previously on June 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

US$18,000,000 Class C Deferrable Mezzanine Notes, Upgraded to Baa2
(sf); previously on June 22, 2011 Baa3 (sf) Placed Under Review
for Possible Upgrade;

US$15,500,000 Class D Deferrable Mezzanine Notes, Upgraded to Ba2
(sf); previously on June 22, 2011 Ba3 (sf) Placed Under Review for
Possible Upgrade;

US$12,000,000 Class E Deferrable Junior Notes, Upgraded to B1
(sf); previously on June 22, 2011 Caa1 (sf) Placed Under Review
for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Moody's notes that the deal has benefited from an improvement in
the credit quality of the underlying portfolio. Based on the
latest trustee report dated July 8, 2011, the weighted average
rating factor is currently 2358 compared to 2824 in the August
2009 report.

The overcollateralization ratios of the rated notes have also
improved since the rating action in September 2009. The Senior
overcollateralization ratio (covering Class A and B Notes) and
Mezzanine overcollateralization ratio (covering Class A, B, C and
D Notes) are reported at 120.98% and 109.5%, respectively, versus
August 2009 levels of 115.07% and 104.16%, respectively, and all
related overcollateralization tests are currently in compliance.
Moody's also notes that the Class E Notes are no longer deferring
interest and that all previously deferred interest has been paid
in full.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $386.7 million,
defaulted par of $1 million, a weighted average default
probability of 20.2% (implying a WARF of 2853), a weighted average
recovery rate upon default of 49.9%, and a diversity score of 75.
The default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

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

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011. Please see the Credit Policy page on www.moodys.com for
a copy of this methodology.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for diversity score.
   However, as part of the base case, Moody's considered spread
   level higher than the covenant level and weighted average
   rating factor lower than the covenant level due to the large
   difference between the reported and covenant levels.


COMM 2004-LNB4: Moody's Downgrades Ratings of Seven CMBS Classes
----------------------------------------------------------------
Moody's Investors Service (Moody's) downgraded the ratings of
seven classes and kept three classes on review for possible
downgrade, confirmed one class and affirmed seven classes of COMM
2004-LNB4 Commercial Mortgage Pass-Through Certificates, Series
2004-LNB4:

Cl. A-4, Affirmed at Aaa (sf); previously on Feb 3, 2011 Upgraded
to Aaa (sf)

Cl. X-C, Affirmed at Aaa (sf); previously on Dec 1, 2004
Definitive Rating Assigned Aaa (sf)

Cl. X-P, Affirmed at Aaa (sf); previously on Dec 1, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-5, Downgraded to A1 (sf); previously on Jul 20, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. A-1A, Downgraded to A1 (sf); previously on Jul 20, 2011 Aa3
(sf) Placed Under Review for Possible Downgrade

Cl. B, Downgraded to Baa2 (sf) and Remains On Review for Possible
Downgrade; previously on Jul 20, 2011 A2 (sf) Placed Under Review
for Possible Downgrade

Cl. C, Downgraded to Ba2 (sf) and Remains On Review for Possible
Downgrade; previously on Jul 20, 2011 Baa2 (sf) Placed Under
Review for Possible Downgrade

Cl. D, Downgraded to B2 (sf) and Remains On Review for Possible
Downgrade; previously on Jul 20, 2011 Ba2 (sf) Placed Under Review
for Possible Downgrade

Cl. E, Downgraded to Caa1 (sf); previously on Jul 20, 2011 B2 (sf)
Placed Under Review for Possible Downgrade

Cl. F, Downgraded to Caa3 (sf); previously on Jul 20, 2011 Caa2
(sf) Placed Under Review for Possible Downgrade

Cl. G, Confirmed at Ca (sf); previously on Jul 20, 2011 Ca (sf)
Placed Under Review for Possible Downgrade

Cl. H, Affirmed at C (sf); previously on Mar 25, 2010 Downgraded
to C (sf)

Cl. J, Affirmed at C (sf); previously on Mar 25, 2010 Downgraded
to C (sf)

Cl. K, Affirmed at C (sf); previously on Mar 25, 2010 Downgraded
to C (sf)

Cl. L, Affirmed at C (sf); previously on Mar 25, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

The downgrades are due to higher expected losses resulting from
anticipated losses from specially and troubled loans and interest
shortfalls. Currently 16% of the pool is in special servicing
compared to 9% at last review. Three classes which were downgraded
remain on review for possible downgrade due to uncertainty about
future interest shortfalls due to reporting discreptancies in the
most recent remittance statement.

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

Moody's rating action reflects a cumulative base expected loss of
8.9% of the current balance. At last review, Moody's cumulative
base expected loss was 7.2%. Moody's stressed scenario loss is
14.7% of the current balance. Moody's provides a current list of
base and stress scenario losses for conduit and fusion CMBS
transactions on moodys.com at:

   http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

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

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011. The
hotel and multifamily sectors are continuing to show signs of
recovery, while recovery in the office and retail sectors will be
tied to recovery of the broader economy. The availability of debt
capital continues to improve with terms returning toward market
norms. Moody's central global macroeconomic scenario reflects an
overall sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit estimate of the loan which corresponds to a range of credit
enhancement levels. Actual fusion credit enhancement levels are
selected based on loan level diversity, pool leverage and other
concentrations and correlations within the pool. Negative pooling,
or adding credit enhancement at the credit estimate level, is
incorporated for loans with similar credit estimates in the same
transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 32, the same as Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated February 2, 2011.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 33% to
$817.2 million from $1.22 billion at securitization. The
Certificates are collateralized by 94 mortgage loans ranging
in size from less than 1% to 9% of the pool, with the top ten
loans representing 45% of the pool. Five loans, representing
5% of the pool, have defeased and are collateralized with U.S.
Government securities. One loan, representing 7% of the pool, has
an investment grade credit estimate.

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

Eight loans have been liquidated from the pool since
securitization, resulting in an aggregate $30.6 million loss (54%
loss severity on average). There are currently seven loans,
representing 16% of the pool, in special servicing. Two loans,
representing 2% of the pool, were recently modified, reclassified
as performing loans and returned to the master servicer. The
master servicer has recognized an aggregate $49.1 million
appraisal reduction for seven of the specially serviced loans.
Moody's has estimated an aggregate loss of $50.0 million (48%
expected loss on average) for all of the specially serviced loans.

Moody's has assumed a high default probability for eight poorly
performing loans representing 9% of the pool. Moody's has
estimated a $10.5 million loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Based on the most recent remittance statement, Classes P through
B have experienced cumulative interest shortfalls totaling
$5.2 million. In July interest shortfalls spiked from Class D to
Class B due to two loan modifications which resulted in reduced
interest payments and the servicer taking back advances and fees.
Classes B, C and D remain on review until Moody's determines the
full impact of the loan modifications. Moody's anticipates that
the pool will continue to experience interest shortfalls due to
the modifications and the high exposure to specially serviced
loans. Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, appraisal subordinate
entitlement reductions (ASERs), modifications, extraordinary trust
expenses and non-advancing by the master servicer based on a
determination of non-recoverability.

Moody's was provided with full year 2010 operating results for 88%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 87% compared to 92% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 10% to the most recently available net operating
income. Moody's value reflects a weighted average capitalization
rate of 9.4%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.35X and 1.25X, respectively, compared to
1.55X and 1.19X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The loan with a credit estimate is the 731 Lexington Avenue Loan
($61.0 million -- 7.5% of the pool), which is a 23.6%
participation interest in a $258.8 million loan. The property is
also encumbered by a $86 million junior loan which is held outside
the trust. The loan is secured by a 694,634 square foot (SF)
office building located in New York City. The property is 100%
leased to Bloomberg, LP until 2028. Performance has been stable.
Moody's current credit estimate and stressed DSCR are A3 and
2.02X, respectively, compared to A3 and 2.01X at last full review.

The top three performing conduit loans represent 18% of the pool
balance. The largest loan is the Crossings at Corona-Phase I & II
Loan ($75.4 million -- 9.2% of the pool), which is secured by a
503,037 SF retail power center located in Corona, California. The
property was 98% leased as of March 2011. Property performance has
been stable. Moody's LTV and stressed DSCR are 103% and 0.9X,
respectively, compared to 101% and 0.91X at last full review.

The second largest loan is the Woodyard Crossing Shopping Center
Loan ($37.8 million -- 4.6% of the pool), which is secured by a
483,724 SF retail power center located in Washington, DC. The
property was 99% leased as of April 2011, the same as last review.
The largest tenants are Wal-Mart and Lowe's. Performance has been
stable. Moody's LTV and stressed DSCR are 76% and 1.29X,
respectively, compared to 78% and 1.25X at last full review.

The third largest loan is the 280 Trumbull Street Loan ($31.7
million -- 3.9% of the pool), which is secured by a 664,479 SF
office property located in Hartford, Connecticut. The property was
70% leased as of May 2011. The loan is on the servicer's watchlist
due to high vacancy and decreased income. Although performance has
declined over the past two years, the property is generating
sufficient cash flow to cover the debt service. Year-end 2010 DSCR
was 1.61X. Moody's LTV and stressed DSCR are 89% and 1.16X,
respectively, compared to 85% and 1.2X at last review.


COMM 2004-RS1: S&P Lowers Ratings on 3 Classes of Certs. to 'CCC-'
------------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on seven
classes of commercial mortgage-backed securities (CMBS) pass-
through certificates from COMM 2004-RS1, a U.S. resecuritized real
estate mortgage investment conduit (re-REMIC) transaction. "At the
same time, we affirmed our ratings on nine classes from the same
transaction," S&P said.

"The downgrades and affirmations primarily reflect our analysis of
the transaction following its exposure to downgraded CMBS
certificates that serve as underlying CMBS collateral. The
downgraded CMBS certificates have a total balance of $37.4 million
(11.1% of the pool balance) and are from five distinct CMBS
transactions. We affirmed our ratings on the IO-1 and IO-2
interest-only (IO) certificates based on our current criteria,"
S&P related.

According to the Aug. 4, 2011, trustee report, COMM 2004-RS1 was
collateralized by 15 CMBS classes ($77.1 million, 22.9%) from 11
distinct transactions issued in either 2001 or 2004. The current
assets also included six classes ($260 million, 77.1%) of
commercial real estate collateralized debt obligation (CRE CDO)
bonds from Marquee 2004-1 Ltd. (not rated). COMM 2004-RS1 has
exposure to these downgraded transactions:

    GMAC Commercial Mortgage Securities Inc. series 2004-C2
   (classes F, G, and H; $12.2 million, 3.6%);

    Banc of America Commercial Mortgage Inc. series 2004-1 (class
    H; $12.0 million, 3.6%);

    JPMorgan Chase Commercial Mortgage Securities Corp. series
    2004-CIBC8 (class H; $5.3 million, 1.6%); and

    Banc of America Commercial Mortgage Inc. series 2004-3 (class
    H; $4.9 million, 1.5%).

Standard & Poor's analyzed COMM 2004-RS1 and its underlying
collateral according to its current criteria. "Our analysis is
consistent with the lowered and affirmed ratings," S&P added.

Ratings Lowered

COMM 2004-RS1
                     Rating
Class          To               From
D              BB+ (sf)         BBB (sf)
E              BB (sf)          BBB- (sf)
F              B (sf)           BB+ (sf)
G              CCC+ (sf)        BB (sf)
H              CCC- (sf)        B+ (sf)
J              CCC- (sf)        B (sf)
K              CCC- (sf)        CCC (sf)

Ratings Affirmed

COMM 2004-RS1

Class          Rating
A              AA (sf)
B-1            A- (sf)
B-2            A- (sf)
C              BBB+ (sf)
L              CCC- (sf)
M              CCC- (sf)
N              CCC- (sf)
IO-1           AAA (sf)
IO-2           AAA (sf)


COMMERCIAL MORTGAGE: Moody's Affirms Ratings of 11 CMBS Classes
---------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 11
classes of Commercial Mortgage Asset Trust, Commercial Mortgage
Pass-Through Certificates, Series 1999-C2:

Cl. A-3, Affirmed at Aaa (sf); previously on Oct 26, 1999
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Feb 17, 2005 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Feb 17, 2005 Upgraded
to Aaa (sf)

Cl. D, Affirmed at Aaa (sf); previously on May 16, 2006 Upgraded
to Aaa (sf)

Cl. E, Affirmed at A3 (sf); previously on Dec 2, 2010 Downgraded
to A3 (sf)

Cl. F, Affirmed at B1 (sf); previously on Dec 2, 2010 Downgraded
to B1 (sf)

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

Cl. H, Affirmed at Ca (sf); previously on Dec 2, 2010 Downgraded
to Ca (sf)

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

Cl. K, Affirmed at C (sf); previously on Dec 17, 2009 Downgraded
to C (sf)

Cl. X, Affirmed at Aaa (sf); previously on Oct 26, 1999 Definitive
Rating Assigned Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
8.2% of the current balance. At last review, Moody's cumulative
base expected loss was 12.6%. Moody's stressed scenario loss is
11.2% of the current balance. Moody's provides a current list of
base and stress scenario losses for conduit and fusion CMBS
transactions on moodys.com at:

   http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

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

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011 The hotel
and multifamily sectors are continuing to show signs of recovery,
while recovery in the office and retail sectors will be tied to
recovery of the broader economy. The availability of debt capital
continues to improve with terms returning toward market norms.
Moody's central global macroeconomic scenario reflects an overall
sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

The primary methodology used in this rating was: "CMBS:
Moody's Approach to Rating Conduit Transactions" published on
September 15, 2000. Moody's also considered other methodologies,
including "CMBS: Moody's Approach to Rating Large Loan/Single
Borrower Transactions" published in July 2000 and "CMBS: Moody's
Approach to Rating Credit Tenant Lease (CTL) Backed Transactions"
published on October 2, 1998.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit estimate of the loan which corresponds to a range of credit
enhancement levels. Actual fusion credit enhancement levels are
selected based on loan level diversity, pool leverage and other
concentrations and correlations within the pool. Negative pooling,
or adding credit enhancement at the credit estimate level, is
incorporated for loans with similar credit estimates in the same
transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 5 compared to 6 at Moody's prior review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 2, 2010.

Moody's Investors Service did not receive or take into account a
third party due diligence report on the underlying assets or
financial instruments related to the monitoring of this
transaction in the past six months.

DEAL PERFORMANCE

As of the July 18, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 69% to $241 million
from $775 million at securitization. The Certificates are
collateralized by 21 mortgage loans ranging in size from less than
1% to 14% of the pool, with the top ten non-defeased loans
representing 57% of the pool. Nine loans, representing 43% of the
pool, have defeased and are secured by U.S. Government securities.
Defeasance at last review represented 41% of the pool. The pool
contains a credit tenant lease (CTL) component, representing 14%
of the pool.

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

Fourteen loans have been liquidated from the pool, resulting in a
realized loss of $40.0 million (44% loss severity overall).
Currently one loan, representing 12% of the pool, is in special
servicing. The specially serviced loan is the Henry W. Oliver
Building Loan ($29.1 million -- 12.1% of the pool), which is
secured by a 472,000 square foot, Class B office building located
in Pittsburgh, Pennsylvania. The loan was transferred to special
servicing in October 2009 for imminent default due to potential
cash flow issues. The largest tenant occupying 53% of the NRA
vacated its space at lease expiration in December 2009. As of
March 2011, the property was 33% leased compared to 31% at last
review. In November 2011, the special servicer and borrower
negotiated an agreement to market the property for sale and a
purchase and sale agreement (PSA) was executed in July 2011. The
sale of the property is expected to be completed within the next
three months. Moody's estimates an aggregate $19.0 million loss
for this loan (65% expected loss).

Moody's was provided with full year 2010 operating results for
100% of the non defeased pool. Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 60% compared to
69% at Moody's prior review. Moody's net cash flow reflects a
weighted average haircut of 9% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 10.5%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.47X and 1.98X, respectively, compared to
1.33X and 1.73X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three conduit loans represent 23% of the pool. The largest
conduit loan is the Westin Denver Tabor Center Loan ($34.4 million
-- 14% of the pool), which is secured by a 430-room full-service
hotel located in downtown Denver, Colorado. The hotel is part of
an upscale mixed-use complex that includes a 570,000 square foot
office building and an urban mall. The loan sponsor is Starwood
Hotels. Performance has improved since the prior review due to a
12% increase in occupancy (64% at YE 2009 compared to 76% at June
2011 TTM). Moody's LTV and stressed DSCR are 50% and 2.39X,
respectively, compared to 64% and 1.96X at last review.

The second largest conduit loan is the Geneva Crossing Loan
($11.4 million -- 4.7% of the pool), which is secured by a 123,000
square foot unanchored retail center located in Carol Stream,
Illinois. As of June 2011, the property was 99% leased compared to
97% at last review. Performance has been stable since last review
and the loan is benefitting from amortization. Moody's LTV and
stressed DSCR are 78% and 1.31X, respectively, compared to 87% and
1.19X at last review.

The third largest loan is the Auerbach Retail Portfolio
($10.5 million -- 4.4% of the pool), which is secured by two
retail properties located in California. As of June 2011, the
properties were 99% leased compared to 100% at last review.
Performance has been stable since last review and the loan is
benefitting from amortization. Moody's LTV and stressed DSCR are
77% and 1.39X, respectively, compared to 81% and 1.34X at last
review.

The CTL component includes one loan secured by a portfolio of
hotels leased under bondable leases to Accor SA ($34.1 million).
Moody's has issued a private credit estimate for this loan.


COMMERCIAL MORTGAGE: Moody's Affirms Ratings of Seven CMBS Classes
------------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed seven classes of
Commercial Mortgage Acceptance Corp, Commercial Mortgage Pass-
Through Certificates 1999-C1:

Cl. J, Affirmed at Baa3 (sf); previously on May 24, 2007 Upgraded
to Baa3 (sf)

Cl. K, Affirmed at Ba2 (sf); previously on May 24, 2007 Upgraded
to Ba2 (sf)

Cl. L, Affirmed at Caa1 (sf); previously on Jul 30, 2009
Downgraded to Caa1 (sf)

Cl. M, Affirmed at C (sf); previously on Oct 28, 2010 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Oct 28, 2010 Downgraded
to C (sf)

Cl. O, Affirmed at C (sf); previously on Oct 28, 2010 Downgraded
to C (sf)

Cl. X, Affirmed at Aaa (sf); previously on Jul 27, 1999 Assigned
Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
27.3% of the current balance. At last full review, Moody's
cumulative base expected loss was 28.8%. Moody's stressed scenario
loss is 35.5% of the current balance. Moody's provides a current
list of base and stress scenario losses for conduit and fusion
CMBS transactions on moodys.com at:

   http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

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

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011. The
hotel and multifamily sectors are continuing to show signs of
recovery, while recovery in the office and retail sectors will be
tied to recovery of the broader economy. The availability of debt
capital continues to improve with terms returning toward market
norms. Moody's central global macroeconomic scenario reflects an
overall sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

The primary methodology used in this rating was "CMBS: Moody's
Approach to Rating U.S. Conduit Transactions" published in
September 2000. Moody's also considered in its analysis, "Moody's
Approach to Rating Large Loan/Single Borrower Transactions",
published in July 2000.

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

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

In cases where the Herf falls below 20, Moody's employs also the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.0. The large loan model derives
credit enhancement levels based on an aggregation of adjusted loan
level proceeds derived from Moody's loan level LTV ratios. Major
adjustments to determining proceeds include leverage, loan
structure, property type, and sponsorship. These aggregated
proceeds are then further adjusted for any pooling benefits
associated with loan level diversity, other concentrations and
correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated October 28, 2010.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 95% to
$35.8 million from $733.8 million at securitization. The
Certificates are collateralized by 20 mortgage loans ranging in
size from less than 1% to 18% of the pool, with the top ten loans
representing 82% of the pool. The pool contains 12 conduit loans
representing 46% of the pool. The remaining pool consists of four
defeased loans (10% of the pool) and four specially serviced loans
(44% of the pool).

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

Eighteen loans have been liquidated from the pool since
securitization, resulting in an aggregate $13.4 million loss (25%
loss severity on average). Currently, four loans, representing 44%
of the pool, are in special servicing. Despite a large percentage
of the pool in special servicing, two of these loans, representing
17% of the pool, are pending modification due to maturity default.
The remaining two loans are currently either real estate owned
(REO) or in foreclosure. The master servicer has recognized an
aggregate $5.6 million appraisal reduction on two of the specially
serviced loans. Moody's has estimated an aggregate $8.1 million
loss (51% expected loss on average) for the specially serviced
loans.

Based on the most recent remittance statement, Classes L
through P have experienced cumulative interest shortfalls totaling
$3.5 million. Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced loans, thereby inhibiting upgrades of the
outstanding senior certificates. Interest shortfalls are caused by
special servicing fees, including workout and liquidation fees,
appraisal subordinate entitlement reductions (ASERs) and
extraordinary trust expenses.

Moody's was provided with full year 2009 and 2010 operating
results for 83% and 64%, respectively, of the pool. Excluding
specially serviced and troubled loans, Moody's weighted average
LTV for the conduit component is 78% compared to 44% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 5% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
10.7%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.23X and 2.41X,
respectively, compared to 1.46X and 2.99X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three performing conduit loans represent 27% of the
pool. The largest loan is the Holiday Inn Express and Suites
Loan ($5.4 million -- 15.1%), which is secured by a 120-key
hotel located in Eagan, Minnesota. The loan had been transferred
into special servicing in November 2009 when the borrower sought a
modification. The modification was denied and the loan returned to
the master servicer in July 2010. The loan has been on the master
servicer's watchlist since August 2010 due to low DSCR. Property
performance deteriorated in 2009 due to low room revenues
resulting from low occupancy and room rates. However, increased
occupancy improved performance in 2010. Moody's LTV and stressed
DSCR are 141% and 0.92X, respectively, compared to 167% and 0.78X,
at last review.

The second largest loan is the Holiday Inn, New Ulm Loan
($2.2 million -- 6.1% of the pool), which is secured by a 126-key
hotel located in New Ulm, Minnesota. At last review, Moody's value
incorporated a stressed cash flow due to overall weakness in the
hotel sector. However, property performance has improved every
year since 2008. The loan is also benefiting from a 300-month
amortization schedule. Moody's LTV and stressed DSCR 58% and
2.24X, respectively, compared to 125% and 1.04X at last review.

The third largest loan is the Deon Square Shopping Center Loan
($1.9 million -- 5.4% of the pool), which is secured by a 77,000
square foot retail property located in Bristol, Pennsylvania.
Property performance remains stable and the loan is benefiting
from amortization. The loan is fully amortizing and matures in
June 2015. Moody's LTV and stressed DSCR 28% and 3.69X,
respectively, compared to 31% and 3.35X at last review.


CREDIT SUISSE: Fitch Affirms Ratings of 14 Classes
--------------------------------------------------
Fitch Ratings has downgraded two and affirmed 14 classes of Credit
Suisse First Boston Mortgage Securities Corp., series 2002-CP5
(CSFB 2002-CP5).

The downgrades reflect Fitch modeled losses of 4.13% of the
remaining pool. Fitch has designated 24 loans (16.2%) as Fitch
Loans of Concern, which includes nine specially-serviced loans
(4.4%). Fitch expects classes N through P to be fully depleted and
class M to be impacted significantly from losses associated with
the specially serviced assets.

As of the July 2011 distribution date, the pool's aggregate
principal balance has reduced by 28.8% to $843.5 million from
$1.19 billion at issuance. In addition, 19 loans (34.6%) have been
fully defeased. Interest shortfalls totaling $1,265,430 are
currently affecting classes M through Q.

The largest contributor to modeled losses is a specially serviced
loan (1.5%) secured by six industrial properties located in
Michigan, Ohio, and Indiana totaling 612,000 square feet (sf). The
loan transferred to special servicing in August 2010 due to
imminent default. The most recent aggregate servicer-reported
occupancy is 63%, with three properties 100% vacant and three
properties 100% occupied. The special servicer has agreed to a
Deed in Lieu of Foreclosure and is expected to take title to the
properties soon.

The second largest contributor to modeled losses is a loan (1.2%)
secured by a 273 unit apartment complex located in San Antonio,
TX. The loan was previously in special servicing but transferred
back to the master servicer in March 2011. The servicer-reported
occupancy increased to 85% with the help of rent concessions, and
the debt service coverage ratio (DSCR) is .46 times (x) as of
year-end (YE) 2010.

The third largest contributor to modeled losses is a loan (1.63%)
secured by a 151,530 sf of office space located on a corporate
campus in Florham Park, NJ. The servicer-reported occupancy as of
May 2011 is 73% and the YE 2010 DSCR is .73x. While occupancy
increased by YE 2010, effective gross income dropped by 5%
compared to YE 2009.

Fitch has downgraded and revised or assigned Recovery Ratings
(RRs) on these classes:

   -- $8.9 million class L to 'CCCsf/RR2' from 'B-sf';

   -- $7.4 million class M to 'Csf/RR5' from 'CCsf/RR2'.

Fitch has also affirmed these classes and revised Outlooks:

   -- $32.7 million class A-1 at 'AAAsf'; Outlook Stable;

   -- $620.3 million class A-2 at 'AAAsf'; Outlook Stable;

   -- $41.5 million class B at 'AAAsf'; Outlook Stable;

   -- $22.2 million class C at 'AAAsf'; Outlook Stable;

   -- $14.8 million class D at 'AAAsf'; Outlook Stable.

   -- $17.8 million class E at 'AA+sf'; Outlook Stable;

   -- $8.9 million class F at 'AA'sf; Outlook Stable;

   -- $16.3 million class G at 'Asf' ; Outlook Stable;

   -- $14.8 million class H at 'BBB-sf'; Outlook to Stable from
      Negative;

   -- $22.2 million class J at 'B-sf'; Outlook to Stable from
      Negative;

   -- $5.9 million class K at 'B-sf'; Outlook Negative;

   -- $4.4 million class N at 'Csf/RR6';

   -- $4.7 million class O at 'Csf/RR6';

   -- $599 thousand class P at 'Dsf/RR6'.

Class Q, which is not rated by Fitch has been reduced to zero from
14.8 million at issuance due to realized losses.

Fitch has withdrawn the rating on the interest-only class A-X.


DAVIS SQUARE: S&P Lowers Ratings on 5 Classes of Notes to 'D'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on the
class A-1a, A-1b, A-2, A-3, and B notes from Davis Square Funding
VII Ltd., a U.S. collateralized debt obligation (CDO) transaction
backed primarily by residential mortgage-backed securities (RMBS)
and commercial mortgage-backed securities (CMBS), to 'D (sf)' from
'CC (sf)'. "We affirmed our ratings on the class C, D, and S notes
from the same transaction and removed our rating on the class S
notes from CreditWatch with negative implications," S&P related.

"The downgrades follow our receipt from the trustee of a July 13,
2011, notice of an event of default based on the transaction's
failure to pay interest due and payable to the class A and B notes
for a period of seven days," S&P said.

"We affirmed our 'CC (sf)' ratings on the class C and D notes
because they continue to defer interest. We affirmed the rating on
the S notes and removed it from CreditWatch with negative
implications because the event of default causes interest and
principal to be redirected to the S notes until they are
paid in full," S&P said.

Rating And Creditwatch Actions

Davis Square Funding VII Ltd.
                        Rating
Class              To           From
A-1a               D (sf)       CC (sf)
A-1b               D (sf)       CC (sf)
A-2                D (sf)       CC (sf)
A-3                D (sf)       CC (sf)
B                  D (sf)       CC (sf)
S                  BBB (sf)     BBB (sf)/Watch Neg


ratings affirmed

Davis Square Funding VII Ltd.
Class                 Rating
C                     CC (sf)
D                     CC (sf)


DLJ COMMERCIAL: Fitch Downgrades Rating on Class B-5 to 'Dsf/RR6'
-----------------------------------------------------------------
Fitch Ratings has downgraded and revised the Recovery Rating (RR)
for this class of DLJ Commercial Mortgage Corp.'s (DLJ) commercial
mortgage pass-through certificates, series 2000-CKP1:

   -- $17.7 million class B-5 to 'Dsf/RR6' from 'Csf/RR5'.

Additionally, Fitch affirms, revises RRs and Rating Outlooks for
these classes:

   -- $8.7 million class A-3 at 'AAAsf'; Outlook Stable;

   -- $16.1 million class A-4 at 'AAAsf'; Outlook Stable;

   -- $16.1 million class B-1 at 'AAAsf'; Outlook Stable;

   -- $25.8 million class B-2 at 'AA-sf'; Outlook to Stable from
      Negative;

   -- $12.9 million class B-3 at 'A-sf'; Outlook to Stable from
      Negative;

   -- $33.9 million class B-4 at 'CCCsf'; RR to 'RR1' from 'RR5';

   -- $0 class B-6 at 'Dsf/RR6';

   -- $0 class B-7 at 'Dsf/RR6'.

Classes A-1A, A-1B, and A-2 have paid in full while the class B-6,
B-7, B-8, and B-9 certificates have been reduced due to realized
losses.

Fitch previously withdrew the ratings on the zero balance B-8 and
B-9 classes. Fitch did not rate class C.

Fitch expects losses of 10.9% of the remaining pool balance. As of
the July 2011 distribution date, the pool's collateral balance has
paid down 89.8% to $131.2 million from $1.3 billion at issuance.
There are 22 loans (54.9%) in special servicing.

The largest specially serviced loan (5.7%) is secured by a retail
property located in Streetsboro, OH. The loan transferred to the
special servicer in June 2010 due to pending maturity and the
borrower has been unable to secure takeout financing. The borrower
is currently negotiating a loan extension with the special
servicer. As of the July 2011 distribution date, the loan was
current and the most recent occupancy was 88% with a debt service
coverage ratio (DSCR) of 1.31 times (x).

The second largest specially serviced loan (4.33%) is secured by a
386 unit multi-family built in 1974 and located in Dallas, TX. The
loan transferred to special servicing in March 2011 due to
imminent monetary default. The loan had tax exempt status under a
low-income housing program until 2009 when the loan was assumed.
The borrower was unaware that assumption of the loan would change
the tax status of the property. The master servicer has advanced
2009 and 2010 tax payments. The borrower is attempting to
refinance the property.


DRYDEN VII-LEVERAGED: Moody's Upgrades Ratings of CLO Notes
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Dryden VII-Leveraged Loan CDO 2004:

US$26,000,000 Class A-2L Floating Rate Notes, Upgraded to Aaa
(sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$22,000,000 Class A-3F Fixed Rate Notes, Upgraded to Aaa (sf);
previously on June 22, 2011 A3 (sf) Placed Under Review for
Possible Upgrade;

US$22,000,000 Class B-1L Floating Rate Notes, Upgraded to A3 (sf);
previously on June 22, 2011 Ba2 (sf) Placed Under Review for
Possible Upgrade;

US$7,500,000 Class B-2L Floating Rate Notes, Upgraded to Baa3
(sf); previously on June 22, 2011 B3 (sf) Placed Under Review for
Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios due to the delevering
of the senior notes since the rating action in February 2011.
Moody's notes that the Class A-1L and A-1LA Notes have been paid
down by approximately 44% or $70.2 million since the rating action
in February 2011. As a result of the delevering, the
overcollateralization ratios have increased since the rating
action in February 2011. Based on the latest trustee report dated
July 7, 2011, the Senior Class A, Class A, Class B-1L, and Class
B-2L overcollateralization ratios are reported at 170.08%,
142.83%, 123.11%, and 117.57%, respectively, versus January 2011
levels of 143.61%, 128.39%, 116.09%, and 112.41%, respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $196.6 million,
defaulted par of $4 million, a weighted average default
probability of 17.7% (implying a WARF of 3072), a weighted average
recovery rate upon default of 48.25%, and a diversity score of 39.
The default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Dryden VII-Leveraged Loan CDO 2004, issued in July 2004, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

Further information on Moody's analysis of this transaction is
available on www.moodys.com. In addition, Moody's publishes a
weekly summary of structured finance credit, ratings and
methodologies, available to all registered users of Moody's web
site, at www.moodys.com/SFQuickCheck.


DUNSMUIR CITY: Moody's Lowers Certificates Rating To Ba2 From Ba1
-----------------------------------------------------------------
Moody's Investors Service has downgraded to Ba2 from Ba1 the
rating on City of Dunsmuir California's Refunding Certificates of
Participation (Water Enterprise Project), Series 2000. The
certificates are secured by the city's pledge of net revenues from
its water enterprise.

RATING RATIONALE

The downgrade reflects the continued, budgeted rate covenant
violation and the city's repeal of previously approved multi-year
rate increases. While one significant rate increase remains in
place, the enterprise's future financial results will be weakened
from what had previously been anticipated. The rating also
incorporates the small customer base, limited capital needs, and
local ground water sources requiring minimal treatment.

STRENGTHS

-- Rapid payout of rated debt

-- Local ground water sources requiring minimal treatment

-- New ten-year contract with industrial customer

CHALLENGES

-- Political opposition to rate increases

-- History of rate covenant violations

-- Weakened financial position with limited net working capital
    and operational flexibility

-- Below one-times debt service coverage

-- Reliance on operating reserve funds to pay debt service

DETAILED CREDIT DISCUSSION

MULTI-YEAR RATE INCREASES REPEALED; WEAKENED FINANCIAL POSITION
AND BUDGETED RATE COVENANT VIOLATION

The December 2010 upgrade of the rating reflected multi-year rate
increases that were projected to improve the enterprise's
financial position and prevent further violations of the bond's
rate covenant. The fiscal year 2011 increases were implemented,
but unexpectedly, all future year's increases have been repealed
by the city due to political opposition to the rate increases. As
a result, the enterprise is budgeted to violate its rate covenant
in fiscal year 2012. The enterprise's financial profile is also
budgeted to erode, with debt service payments and operations and
maintenance dependant on operating reserve funds.

The bonds are secured by the enterprise's senior pledge of net
water revenues, and the legal covenants notably include the
maintenance of rates sufficient to generate net revenues at least
1.25x debt service. As noted in the December 2010 report, debt
service coverage in fiscal year 2009 and 2010 were both below the
covenanted level at, 1.11 times and 0.84 times, respectively.
Fiscal 2010 debt service was paid in part with cash from the
enterprise's operating reserve funds, which were at an unaudited
cash balance of $140,058 at the end of fiscal year 2011. The
December 2010 upgrade of the bonds incorporated the expectation
that these rate covenant violations would occur, but also included
the approved multi-year rate increases intended to correct the
violations. The first of these rate increases occurred in fiscal
year 2011, but debt service coverage is now estimated to be 0.53
times, far below the 1.96 times originally budgeted for the year.
With the repeal of the future rate increases the debt service
coverage is budgeted to once again violate the bonds' rate
covenant at 0.71 times in fiscal year 2012. Moody's believes the
city will likely continue to pay its debt service until the bonds
mature in fiscal year 2015, but its current rating at a below
investment grade level reflects the increased risk that arises
from the demonstrated willingness to violate the bond's legal
covenants and the enterprise's limited financial resources.

The financial profile of the enterprise is budgeted to erode
further, although portions of remaining debt service payments for
the Water Enterprise's Refunding Certificates of Participation
(Water Enterprise Project), Series 2000 debt service is set aside
in a separate reserve account. At the end of the fiscal year 2010
net working capital fell to $126,000, 48.9% of operations and
maintenance expenditures. Based on fiscal year 2011 estimated
actuals, net working capital is set to decline to $90,000, 23.6%
of operations and maintenance expenditures. Much of the fund's
reserves are designated to pay future debt service. In fiscal year
2010 this amounted to $116,899 in unrestricted cash. Repayment of
the remaining debt service is contingent on the use of these
reserves, new revenues from the 2011 rate increase, and new
revenues from a ten-year lease signed with Flora Inc. Flora Inc.
has agreed to pay a minimum of $25,000 per year for water used in
its health food manufacturing facility. The new revenue sources
are estimated to return net revenues and debt service coverage to
a level above one-times by fiscal year 2013. While Moody's
believes the city will continue to pay debt service on the rated
debt, it considers the multiyear projections questionable given
the demonstrated underperformance of previous year's projections
and the city's resistance to rate increases. This is a strong
credit negative and is reflected in the downgrade to a Ba2 rating.

LIMITED CUSTOMER BASE WITH BELOW AVERAGE WEALTH LEVELS

Moody's expects the enterprise's customer base to remain limited
due to little opportunity for economic expansion in the area. The
enterprise serves the City of Dunsmuir (not rated) which is
located in northern California, approximately fifty miles north of
the City of Redding near Mt. Shasta, which is the water source for
the area. The customer base is largely residential (65.1% of
revenues) with some commercial (12.5% of revenues) and a
significant industrial presence (22.3% of revenues). The city's
wealth levels are below average with per capita income and median
family income at 74.0% and 54.8% of the nation, respectively. The
customer base has grown from 1,278 connections in fiscal 2005 to
1,314 connections in fiscal 2008, an average annual rate of 0.93%.
The enterprise's top ten customers represent 26.4% of total
gallons purchased, with Union Pacific Railroad (Senior unsecured
Baa2), the largest customer, representing 12.3% of total gallons
purchased. Flora Inc., has signed a ten-year lease with the city
for use of the city-owned bottling plant, previously given to the
city by Coca Cola Inc. The lease includes a minimum annual
purchase of $25,000 of water per year from the city. The city
anticipates that this amount will likely be larger and that the
after the facility opens in November 2011, Flora Inc. will become
the top customer.

MODEST DEBT RATIO WITH NO FUTURE DEBT PLANS

Moody's expects the enterprise's debt ratio will remain manageable
given the system's ample capacity and no expectations for growth
in the medium term. The enterprise is currently using only 9%, or
0.10 MGD, on average of total capacity (1.05 MGD). The
enterprise's debt ratio is modest at 24.6%. Debt amortization is
average with 59.1% of debt retired in 10 years.

STANDARD LEGAL COVENANTS

The enterprise covenanted to collect revenues in each fiscal year
to yield at least 1.25 times of that fiscal year's debt service.
The additional bonds test is also 1.25 times annual net revenues
though there are no plans for debt issuance. The bonds are
additionally secured by the debt service reserve fund which must
be equal to the lesser of maximum annual debt service, 1.25 times
average annual debt service, or 10% of bond proceeds. The required
debt service reserve fund remains cash funded in fiscal year 2010
at the required $114,884 amount.

KEY STATISTICS

City of Dunsmuir Median Family Income (as% of state and US):
$27,420 (51.71% of CA and 54.8% of US)

City of Dunsmuir Per Capita Income (as% of state and US): $15,982
(70.4% of CA and 74.0% of US)

Operating ratio (2010): 73.5%

Operating ratio (2011, estimated): 88%

Operating ratio (2012, budget): 83.9%

Debt ratio (2010): 24.6%

Debt ratio (2011, estimated): 23.1%

Annual debt service coverage, 2010: 0.84 times

Annual debt service coverage, 2011 estimated: 0.53 times

Annual debt service coverage, 2012 budgeted: 0.71 times

Maximum Annual debt service coverage (occurs 2012), using FY 2010
net revenues: 0.72 times

WHAT COULD CHANGE THE RATING - UP

Sustained and material improvement of debt service coverage.

Continued compliance with rate covenants.

Long-term stable customer growth.

WHAT COULD CHANGE THE RATING - DOWN

Decline of debt service coverage.

Loss of customers and revenue sources.

Further violations of bond covenants.

The principal methodology used in this rating was Analytical
Framework For Water And Sewer System Ratings published in August
1999.


EATON VANCE: Moody's Upgrades Ratings of Six Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Eaton Vance CDO IX, Ltd.:

US$45,000,000 Class A-1-B Floating Rate Notes Due 2019, Upgraded
to Aa2 (sf); previously on June 22, 2011 A1 (sf) Placed Under
Review for Possible Upgrade;

US$160,000,000 Class A-2 Floating Rate Notes Due 2019, Upgraded to
Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$20,000,000 Class B Floating Rate Notes Due 2019, Upgraded to A1
(sf); previously on June 22, 2011 Baa1 (sf) Placed Under Review
for Possible Upgrade;

US$27,500,000 Class C Floating Rate Deferrable Notes Due 2019,
Upgraded to Baa1 (sf); previously on June 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$35,000,000 Class D Floating Rate Deferrable Notes Due 2019,
Upgraded to Ba2 (sf); previously on June 22, 2011 Caa1 (sf) Placed
Under Review for Possible Upgrade;

US$6,000,000 Class 2 Combination Notes Due 2019 (current rated
balance of $3,725,000), Upgraded to Ba1 (sf); previously on June
22, 2011 B1 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an improvement in the
credit quality of the underlying portfolio and an increase in the
overcollateralization ratio of the rated notes since the rating
action in August 2009. Based on the latest trustee report dated
July 11, 2011, the weighted average rating factor is currently
2333 compared to 2740 in the July 2009 report. The Senior
overcollateralization ratio covering the Class A and Class B Notes
is currently reported at 120.61% versus July 2009 level of
115.24%.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $488.5 million,
defaulted par of $0.8 million, a weighted average default
probability of 21.5% (implying a WARF of 2936), a weighted average
recovery rate upon default of 51.5%, and a diversity score of 80.
Moody's generally analyzes deals in their reinvestment period by
assuming the worse of reported and covenanted values for all
collateral quality tests. However, in this case given the limited
time remaining in the deal's reinvestment period, Moody's analysis
reflects the benefit of assuming a higher likelihood that the
collateral pool characteristics will continue to maintain a
positive "cushion" relative to certain covenant requirements, as
seen in the actual collateral quality measurements. The default
and recovery properties of the collateral pool are incorporated in
cash flow model analysis where they are subject to stresses as a
function of the target rating of each CLO liability being
reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Eaton Vance CDO IX, Ltd., issued in March 2007, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

A secondary methodology used was "Using the Structured Note
Methodology to Rate CDO Combo-Notes" published in February 2004.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Other collateral quality metrics: The deal is allowed to
reinvest and the manager has the ability to deteriorate the
collateral quality metrics' existing cushions against the covenant
levels. Moody's analyzed the impact of assuming the worse of
reported and covenanted values for diversity score. However, as
part of the base case, Moody's considered spread level higher than
the covenant level and weighted average rating factor lower than
the covenant level due to the large difference between the
reported and covenant levels.


FMC REAL ESTATE: Moody's Upgrades Ratings of Four CRE CDO Classes
-----------------------------------------------------------------
Moody's has upgraded four and affirmed five classes of Notes
issued by FMC Real Estate CDO 2005-1, Ltd. due to the the rapid
amortization of the collateral pool since last review. The
affirmations are a result of the key transaction parameters
performing within levels commensurate with the existing ratings
levels The rating action is the result of Moody's on-going
surveillance of commercial real estate collateralized debt
obligation (CRE CDO) transactions.

Cl. A-1, Affirmed at Aaa (sf); previously on Apr 15, 2009
Confirmed at Aaa (sf)

Cl. A-2, Upgraded to Aaa (sf); previously on Sep 9, 2010
Downgraded to Aa3 (sf)

Cl. B, Upgraded to Aa3 (sf); previously on Sep 9, 2010 Downgraded
to A3 (sf)

Cl. C, Upgraded to Baa2 (sf); previously on Sep 9, 2010 Downgraded
to Ba2 (sf)

Cl. D, Upgraded to B2 (sf); previously on Sep 9, 2010 Downgraded
to Caa1 (sf)

Cl. E, Affirmed at Caa2 (sf); previously on Sep 9, 2010 Downgraded
to Caa2 (sf)

Cl. F, Affirmed at Caa3 (sf); previously on Sep 9, 2010 Downgraded
to Caa3 (sf)

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

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

RATINGS RATIONALE

FMC Real Estate CDO 2005-1, Ltd is a cash CRE CDO CLO transaction
backed by a portfolio A-Notes and whole loans (45.1% of the pool
balance), B-Notes (31.5%), and mezzanine loans (23.4%). As of the
July 21, 2011 Trustee report, the aggregate Note balance of the
transaction has decreased to $313.8 million from $439.4 million at
issuance, with the paydown directed to the Class A-1 Notes, as a
result of the end of the Reinvestment Period which occurred in
August 2010.

There are two assets with a par balance of $9.7 million (3.0% of
the collateral balance) that are considered Defaulted Securities
as of the July 21, 2011 Trustee report. However, there are
currently no realized losses to date.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 7,743 compared to 6,408 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (0.9% compared to 1.7% at last review), A1-A3
(2.0% compared to 0.0% at last review), Baa1-Baa3 (0.0% compared
to 1.1% at last review), Ba1-Ba3 (0.0% compared to 5.1% at last
review), B1-B3 (3.3% compared to 5.4% at last review), and Caa1-C
(93.8% compared to 86.6% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 2.3 years compared
to 6.6 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
37.5% compared to 20.6% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 100.0% compared to 12.9% at last review.
The high MAC is due to high default probability collateral
concentrated within a small number of collateral names.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

The cash flow model, CDOEdge(R) v3.2.1.0, was used to analyze the
cash flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption up from
37.5% to 42.5% would result in average rating movement on the
rated tranches of 0 to 3 notches upward, while changing the
recovery rate assumption down from 37.5% to 32.5% would result in
average rating movement of 0 to 6 notches downward.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of assumption uncertainty
are the current sluggish macroeconomic environment and varying
performance in the commercial real estate property markets.
However, Moody's expects to see increasing or stabilizing property
values, higher transaction volumes, a slowing in the pace of loan
delinquencies and greater liquidity for commercial real estate in
2011 The hotel and multifamily sectors are continuing to show
signs of recovery, while recovery in the office and retail sectors
will be tied to recovery of the broader economy. The availability
of debt capital continues to improve with terms returning toward
market norms. Moody's central global macroeconomic scenario
reflects an overall sluggish recovery through 2012, amidst ongoing
individual, corporate and governmental deleveraging, persistent
unemployment, and government budget considerations.

The principal methodology used in these ratings was "Moody's
Approach to Rating SF CDOs" published in November 2010.

Other methodology used in this rating was "Moody's Approach to
Rating Commercial Real Estate CDOs" published in July 2011.


FOUR CORNERS: Moody's Upgrades Ratings of 5 classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Four Corners CLO III, Ltd.:

US$230,400,000 Class A Floating Rate Notes Due 2020 (current
outstanding balance of $188,197,962), Upgraded to Aaa (sf);
previously on June 22, 2011, A1 (sf) Placed Under Review for
Possible Upgrade;

US$9,000,000 Class B Floating Rate Notes Due 2020, Upgraded to Aa3
(sf); previously on June 22, 2011, Baa2 (sf) Placed Under Review
for Possible Upgrade;

US$18,000,000 Class C Deferrable Floating Rate Notes Due 2020,
Upgraded to Baa1 (sf); previously on June 22, 2011, Ba2 (sf)
Placed Under Review for Possible Upgrade;

US$9,000,000 Class D Deferrable Floating Rate Notes Due 2020,
Upgraded to Ba2 (sf); previously on June 22, 2011, B2 (sf) Placed
Under Review for Possible Upgrade; and

US$9,600,000 Class E Deferrable Floating Rate Notes Due 2020,
Upgraded to B1 (sf); previously on June 22, 2011, Caa3 (sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The rating actions also reflect consideration of improvement in
the credit quality of the underlying portfolio and an increase in
the transaction's overcollateralization ratios since the rating
action in September 2009. Based on the latest trustee report dated
July 12, 2011, the weighted average rating factor is currently
2251 compared to 2736 in August 2009. The Class A/B, Class C,
Class D, and Class E overcollateralization ratios are reported at
121.89%, 111.69%, 107.21%, and 102.81%, respectively, versus
August 2009 levels of 117.43%, 109.06%, 105.31%, and 101.59%,
respectively, and all related overcollateralization tests are
currently in compliance. Moody's notes that the Class A notes have
been paid down by approximately 16% or $37.4 million since the
rating action in September 2009 due to special redemption under
Section 9.5 of the indenture as well as Class E
overcollateralization test failure.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $240.36 million,
defaulted par of $0, a weighted average default probability of
17.4% (implying a WARF of 2549), a weighted average recovery rate
upon default of 49.7%, and a diversity score of 50. These default
and recovery properties of the collateral pool are incorporated in
cash flow model analysis where they are subject to stresses as a
function of the target rating of each CLO liability being
reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Four Corners CLO III, Ltd., issued in September 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, and diversity score.


FRANKLIN CLO: Moody's Upgrades Ratings of 3 Classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Franklin CLO IV, Ltd.:

US$18,500,000 Class C Floating Rate Deferrable Interest Senior
Secured Notes due 2015, Upgraded to Aaa (sf); previously on
June 22, 2011 Aa1 (sf) Placed Under Review for Possible Upgrade;

US$15,250,000 Class D Floating Rate Deferrable Interest Senior
Secured Notes due 2015, Upgraded to Aa3 (sf); previously on June
22, 2011 Baa3 (sf) Placed Under Review for Possible Upgrade;

US$8,000,000 Class E Floating Rate Deferrable Interest Senior
Secured Notes due 2015 (current outstanding balance of
$6,105,112), Upgraded to Ba2 (sf); previously on June 22, 2011
Caa1 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of delevering of the senior
notes since the rating action in April 2011. Moody's notes that
the Class A Notes have been paid down by approximately 74% or
$22 million since the rating action in April 2011. As a result of
the delevering, the overcollateralization ratios have increased.
Based on the latest trustee report dated July 13, 2011, the Class
B, Class C, Class D and Class E overcollateralization ratios are
reported at 235.77%, 150.39%, 115.82% and 106.06%, respectively,
versus April 2011 levels of 181.25%, 135.29%, 111.90% and 104.66%,
respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $78 million,
defaulted par of $2 million, a weighted average default
probability of 9.28% (implying a WARF of 2154), a weighted average
recovery rate upon default of 50.22%, and a diversity score of 17.
The default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Franklin CLO IV, Ltd., issued in August 2003, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans. As of the July 2011 report, the deal has 45 assets from 28
issuers and a diversity score of 17.

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

Moody's modeled the transaction using the Binomial Expansion
Technique, as described in Section 2.3.2.1 of the "Moody's
Approach to Rating Collateralized Loan Obligations" rating
methodology published in June 2011. In addition, due to the low
diversity of the collateral pool, CDOROM 2.8 was used to simulate
a default distribution that was then applied as an input in the
cash flow model.

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CLO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

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


GALAXY IV CLO: Moody's Upgrades Ratings of 7 Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Galaxy IV CLO, Ltd.:

$235,000,000 Class A-1 Senior Term Notes Due 2017 (current
outstanding balance of $209,903,647), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa3 (sf) Placed Under Review for
Possible Upgrade;

$65,000,000 Class A-2 Senior Delayed Draw Notes Due 2017 (current
outstanding balance of $58,058,456), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa3 (sf) Placed Under Review for
Possible Upgrade;

$21,000,000 Class B Senior Floating Rate Notes Due 2017, Upgraded
to Aa1 (sf); previously on June 22, 2011 A3 (sf) Placed Under
Review for Possible Upgrade;

$25,000,000 Class C Deferrable Mezzanine Notes Due 2017, Upgraded
to Baa1 (sf); previously on June 22, 2011 Ba2 (sf) Placed Under
Review for Possible Upgrade;

$14,500,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2017, Upgraded to Ba2 (sf); previously on June 22, 2011 Caa3 (sf)
Placed Under Review for Possible Upgrade;

$5,500,000 Class D Deferrable Mezzanine Fixed Rate Notes Due 2017,
Upgraded to Ba2 (sf); previously on June 22, 2011 Caa3 (sf) Placed
Under Review for Possible Upgrade;

$8,000,000 Class Z Combination Notes, (current Rated Amount of
$846,527), Upgraded to Aa2 (sf), previously on June 22, 2011 B2
(sf) Placed Under Review for Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in June 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2561 compared to 3134 in May 2009.
Additionally, the Senior and Mezzanine overcollateralization
ratios are reported at 121.42% and 106.32%, respectively, versus
May 2009 levels of 115.37% and 101.03%, respectively, and all
overcollateralization tests are currently in compliance.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $355 million,
defaulted par of $1 million, a weighted average default
probability of 15.8% (implying a WARF of 2643), a weighted average
recovery rate upon default of 50.9%, and a diversity score of 68.
The default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Galaxy IV CLO, Ltd., issued in March 2005, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

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


GE CAPITAL: Fitch Downgrades GECC Series 2001-1 Ratings
-------------------------------------------------------
Fitch Ratings downgrades GE Capital Commercial Mortgage
Corporation (GECC) commercial mortgage pass-through certificates,
series 2001-1:

   -- $25.4 million class H to 'CCCsf/RR1' from 'Bsf';

   -- $18.3 million class I to 'CCsf/RR6' from 'B-sf';

   -- $9.9 million class J to 'Csf/RR6' from 'CCCsf/RR4'.

Fitch affirms these ratings:

   -- $19.3 million class C at 'AAAsf'; Outlook Stable;

   -- $15.5 million class D at 'AAAsf'; Outlook Stable;

   -- $15.5 million class E at 'AAAsf'; Outlook Stable;

   -- $15.5 million class F at 'AAAsf'; Outlook Stable;

   -- $14.1 million class G at 'Asf'; Outlook Stable.

Fitch does not rate classes K, L, M, and N. Classes A-1, A-2, B
and X-2 have all paid in full.

In addition, Fitch withdraws the rating on the interest-only
classes X-1.

The downgrades reflect Fitch expected losses from specially
serviced loans and adverse selection due to increasing pool
concentrations. Fitch modeled losses of 29.3% of the remaining
pool.

As of the July 2011 remittance report, the transaction has paid
down 87.0% to $147.1 million from $1.1 billion at issuance.
Twenty-four of the original 151 loans remain outstanding. Twenty-
one loans (89%) are in special servicing. Interest shortfalls are
affecting classes H through N.

The largest contributor to Fitch modeled losses is a 163,798
square foot (sf) retail center located in Federal Way, WA. The
special servicer foreclosed on this property in April 2011, and it
is currently being marketed for sale. Fitch expects losses upon
liquidation of the asset based on recent valuations obtained by
the servicer.

The second largest contributor to Fitch modeled losses is secured
by a 280 unit hotel in Atlanta, GA. A receiver has been appointed
to manage the property and market it for sale. Fitch modeled
losses upon liquidation of the asset based on recent valuations
obtained by the servicer.


GE COMMERCIAL: Stable Performance Cues Fitch to Affirm Ratings
--------------------------------------------------------------
Fitch Ratings affirms GE Commercial Mortgage Corporation
commercial mortgage pass-through certificates.

Fitch has affirmed these classes and revised Rating Outlooks and
Recovery Ratings (RRs) as indicated:

  -- $42.4 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $406.1 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $159.7 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $35.5 million class B at 'AAAsf'; Outlook Stable;
  -- $14.8 million class C at 'AAAsf'; Outlook Stable;
  -- $26.6 million class D at 'AAAsf'; Outlook Stable;
  -- $14.8 million class E at 'AAAsf'; Outlook Stable;
  -- $14.8 million class F at 'AAAsf'; Outlook Stable;
  -- $14.8 million class G at 'AAsf'; Outlook Stable;
  -- $14.8 million class H at 'Asf'; Outlook Stable;
  -- $19.2 million class J at 'BBBsf'; Outlook Stable;
  -- $7.4 million class K at 'BB+sf'; Outlook to Stable from
     Negative;
  -- $8.9 million class L at 'Bsf'; Outlook Negative;
  -- $4.4 million class M at 'CCC/RR1';
  -- $7.4 million class N at 'CC/RR1';
  -- $3.0 million class O at 'C'; RR to 'RR2' from 'RR1';
  -- $624,593 class BLVD-1 at 'A'; Outlook Stable;
  -- $2.5 million class BLVD-2 at 'A-'; Outlook Stable;
  -- $4.5 million class BLVD-3 at 'BBB+'; Outlook Stable;
  -- $3.5 million class BLVD-4 at 'BBB'; Outlook Stable;
  -- $8.0 million class BLVD-5 at 'BB+'; Outlook Stable.

The rating affirmations reflect the stable performance and minimal
losses to date. Fitch modeled losses of 3.1% of the remaining
pool.  Fitch has designated 23 loans (17.6%) as Fitch loans of
concern, which includes two specially serviced loans (2.7%).
As of the July 2011 distribution date, the pool's collateral
balance has paid down 31.9% to $824.3 million from $1.2 billion at
issuance.  Twenty-five of the remaining loans have defeased
(29.8%).

The largest contributor to loss (2.0%), also specially serviced,
is secured by an 1,124,432 square foot (sf) industrial/warehouse
distribution center located in Memphis, TN.  The loan was
transferred to special servicing in May 2010 due to imminent
default.  The decline in performance was a result of the largest
tenant vacating at lease expiration in May 2010 and the bankruptcy
of the second largest tenant.  Title was acquired via foreclosure
at a trustee sale in May 2011.  A property manager and leasing
agent have been hired.

The second largest contributor to loss (0.8%) is secured by a
63,602 sf office property located in Tukwila, WA.  The property
has suffered declines in performance since late 2008 due to low
occupancy and soft market.  The property is currently 82% occupied
as of March 2011.  Leasing activity is limited and the borrower is
offering concessions.

The third largest contributor to loss (0.7%) is secured by an
office property located in Golden, CO.  The loan was transferred
to special servicing in May 2010 due to payment default.
Occupancy at the property had declined as a result of two tenants
vacating in 2007 and 2010, respectively.  A receiver has been
appointed and has taken over control of the property.  Leasing
activity at the property is limited and there are no prospective
tenants at this time.  The property was 23% occupied as of
February 2011.  The special servicer is proceeding with
foreclosure.

Classes A-1 and A-2 have paid in full.  Classes BLVD-1 through 5
represent the subordinate note rake classes for the Boulevard
Mall.  Fitch has previously withdrawn the rating of the interest-
only classes X-1, and X-2.


GMAC COMMERCIAL: S&P Lowers Ratings on 3 Classes of Certs. to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 10
classes of commercial mortgage pass-through certificates from two
U.S. commercial mortgage-backed securities (CMBS) transactions due
to interest shortfalls.

"The downgrades reflect current and potential interest shortfalls.
We lowered our ratings on six of these classes to 'D (sf)' because
we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. The six classes that we
downgraded to 'D (sf)' have had accumulated interest shortfalls
outstanding for three to 12 months," S&P related. The recurring
interest shortfalls for the respective certificates are primarily
due to one or more of these factors:

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

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

    Special servicing fees; and

    Interest rate reductions or deferrals resulting from loan
    modifications.

Standard & Poor's analysis primarily considered the ASER amounts
based on appraisal reduction amounts (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals. "We
also considered servicer nonrecoverable advance declarations and
special servicing fees that are likely, in our view, to cause
recurring interest shortfalls," S&P said.

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

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

"We detail the 10 downgraded classes from the two U.S. CMBS
transactions," S&P said.

     GMAC Commercial Mortgage Securities Inc. Series 2001-C2

"We lowered our ratings on the class E, F, G, H, J, K, and L
certificates from GMAC Commercial Mortgage Securities Inc.'s
series 2001-C2. We lowered our ratings on the class J, K, and L
certificates to 'D (sf)' to reflect accumulated interest
shortfalls outstanding of three to 12 months resulting
from ASER amounts related to five ($98.6 million; 52.0%) of the 18
assets ($170.8 million; 90.2%) that are currently with the special
servicer, CWCapital Asset Management LLC (CWCapital), as well as
special servicing fees and servicer nonrecoverable determinations
($123,381). We lowered our rating on class H due to the potential
for this class to experience interest shortfalls in the future
relating to the specially serviced assets. We lowered our ratings
on classes E, F, and G due to reduced liquidity support available
to these classes resulting from the recurring interest shortfalls.
As of the July 15, 2011, trustee remittance reports, ARAs totaling
$18.5 million were in effect for six loans, and the total reported
ASER amount was $177,488. The reported monthly interest
shortfalls, excluding an ASER recovery this month of $303,015,
totaled $117,247 and have affected all of the classes subordinate
to and including class J," S&P related.

  GMAC Commercial Mortgage Securities Inc. Series 2006-C1 Trust

"We lowered our ratings on the class J, K, and L certificates from
GMAC Commercial Mortgage Securities Inc. Series 2006-C1 Trust to
'D (sf)' to reflect accumulated interest shortfalls outstanding
for 10 months resulting from ASER amounts related to six ($55.1
million; 4.1%) of the 10 ($208.3 million; 15.5%) assets that are
currently with the special servicer, Berkadia Commercial Mortgage
LLC (Berkadia), as well as special servicing fees. As of the July
11, 2011, trustee remittance report, ARAs totaling $16.9 million
were in effect for six assets, and the total reported monthly ASER
amount on these assets was $30,711. The reported monthly interest
shortfalls totaled $75,123 and have affected all of the classes
subordinate to and including class J," S&P said.

Ratings Lowered

GMAC Commercial Mortgage Securities Inc.
Commercial Mortgage Pass-Through Certificates Series 2001-C2
                           Credit           Reported
        Rating         enhancement     interest shortfalls ($)
Class  To        From          (%)     Current     Accumulated
E      BBB+ sf)  AA (sf)     41.66          0                0
F      BB+ (sf)  A+ (sf)     33.70          0                0
G      CCC (sf)  BBB- (sf)   28.22          0                0
H      CCC- (sf) B (sf)      23.24          0                0
J      D (sf)    CCC+ (sf)   10.78      5,730          200,415
K      D (sf)    CCC (sf)     7.80     30,669          135,309
L      D (sf)    CCC- (sf)    4.81     30,669          309,402

GMAC Commercial Mortgage Securities Inc. Series 2006-C1 Trust
Commercial Mortgage Pass-Through Certificates
                           Credit           Reported
        Rating        enhancement      interest shortfalls ($)
Class  To      From           (%)      Current     Accumulated
J      D (sf)  CCC- (sf)     0.97       21,843         717,245
K      D (sf)  CCC- (sf)     0.49       26,090         260,900
L      D (sf)  CCC- (sf)     0.02       26,086         260,859


GOLDMAN SACHS: Moody's Upgrades Ratings of 6 Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Goldman Sachs Asset Management CLO, P.L.C.:

US$257,400,000 Class A-1 Floating Rate Notes Due 2022 (current
balance of $248,464,041), Upgraded to Aaa (sf); previously on
June 22, 2011 Aa1 (sf) Placed under review for possible upgrade;

US$28,600,000 Class A-2 Floating Rate Notes Due 2022, Upgraded to
Aa1 (sf); previously on June 22, 2011 A1 (sf) Placed under review
for possible upgrade;

US$27,000,000 Class B Floating Rate Notes Due 2022, Upgraded to A1
(sf); previously on June 22, 2011 A3 (sf) Placed under review for
possible upgrade;

US$21,000,000 Class C Deferrable Floating Rate Notes Due 2022,
Upgraded to Baa1 (sf); previously on June 22, 2011 Baa3 (sf)
Placed under review for possible upgrade;

US$18,000,000 Class D Deferrable Floating Rate Notes Due 2022,
Upgraded to Ba1 (sf); previously on June 22, 2011 B2 (sf) Placed
under review for possible upgrade;

US$16,000,000 Class E Deferrable Floating Rate Notes Due 2022
(current balance of $13,562,573), Upgraded to Ba3 (sf); previously
on June 22, 2011 Caa3 (sf) Placed under review for possible
upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio since the rating action in December 2010.
Based on the June 2011 trustee report, the weighted average rating
factor is currently 2522 compared to 2735 in November 2010.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $375 million,
defaulted par of $4.3 million, a weighted average default
probability of 23.03% (implying a WARF of 2854), a weighted
average recovery rate upon default of 50%, and a diversity score
of 55. The default and recovery properties of the collateral pool
are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Goldman Sachs Asset Management CLO, P.L.C., issued in July 2007,
is a collateralized loan obligation backed primarily by a
portfolio of senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score. However, as part of the base case,
   Moody's considered spread levels higher than the covenant
   levels due to the large difference between the reported and
   covenant levels.

3) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.


GRAMERCY REAL: Fitch Affirms Ratings of All Classes
---------------------------------------------------
Fitch Ratings has affirmed 11 classes of Gramercy Real Estate CDO
2005-1, Ltd./LLC (Gramercy 2005-1) reflecting Fitch's base case
loss expectation of 25.2%. Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market values and cash flow declines.

Since last review, the CDO exited its reinvestment period. Six
assets are no longer in the pool, including four CRE CDO
securities sold at a loss; one mezzanine loan paid in full; and
one real estate owned (REO) office property, which was exchanged
for a performing office loan, as allowed under the transaction
documents. While all overcollateralization tests are now passing,
as of the June 2011 trustee report, the CDO was previously failing
at least one test since March 2010 leading to the diversion of
interest payments due on the junior classes to pay down class A-1.
Total paydown to class A-1 from loan amortization, diverted
interest, and asset sales since last review is $67.3 million. As
of the June 2011 trustee report, principal proceeds of $39.9
million were available to further pay down the class A-1 notes at
the next payment date.

Commercial real estate loans (CREL) comprise the majority of the
collateral. Approximately 51% of the total collateral is whole
loans or A-notes while 10% is B-notes and 5% mezzanine debt.
Defaulted CREL assets have increased slightly to 10.7% from 10.3%
while loans of concern increased to 21.8% from 19.3% at last
review. CMBS represent 26.6% of the collateral. Since last review,
the average Fitch derived rating for the underlying CMBS
collateral declined to 'BB+/BB' from 'BBB-/BB+'.

Under Fitch's updated methodology, approximately 51.1% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress. Fitch estimates that average recoveries
will be 50.7%.

The largest component of Fitch's base case loss expectation is a
mezzanine loan (3.7%) secured by ownership interests in a
multifamily property located in New York, NY. The property
contains over 11,000 residential units and approximately 120,000
square feet of office and retail space. The sponsors' plan was to
convert the majority of rent controlled units to market rates;
however, the plan has faced significant economic and legal
hurdles. The loan became delinquent in January 2010. Fitch modeled
no recovery on this highly leveraged mezzanine position.

The next largest component of Fitch's base case loss expectation
is the modeled losses on the CMBS bond collateral.

The third largest component of Fitch's base case loss expectation
is an REO land property (3.6%) located in Antioch, CA. The 2,115
acre land parcel loan defaulted in April 2009 with foreclosure
completed in January 2010. The entitlement process continues and
no lot sales are anticipated prior to late 2011. Fitch modeled a
substantial loss on this property in its base case scenario.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio. Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to classes A-1 through F were then compared
to the modeled expected losses, and determined to be consistent
with the rating assigned below. Based on prior modeling results,
no material impact was anticipated from cash flow modeling the
transaction. The Rating Outlooks for classes A-1 through D are
revised to Stable from Negative reflecting the paydown of the
senior notes. Class E and F maintain a Negative Rating Outlook
reflecting Fitch's expectation of further potential negative
credit migration of the underlying collateral.

The 'CCC' and below ratings for classes G through K are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement. These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Gramercy 2005-1 is a commercial real estate (CRE) CDO managed by
GKK Manager LLC (GKKM), an affiliate of Gramercy Capital Corp.

Fitch has affirmed, and revised Outlooks and Recovery Ratings, to
these classes:

   -- $429,770,447 class A-1 at 'BBBsf'; Outlook to Stable from
      Negative;

   -- $57,000,000 class A-2 at 'BBsf'; Outlook to Stable from
      Negative;

   -- $102,500,000 class B at 'BBsf'; Outlook to Stable from
      Negative;

   -- $47,000,000 class C at 'Bsf'; Outlook to Stable from
      Negative;

   -- $12,500,000 class D at 'Bsf'; Outlook to Stable from
      Negative;

   -- $16,000,000 class E at 'Bsf'; Outlook Negative;

   -- $16,000,000 class F at 'Bsf'; Outlook Negative;

   -- $18,500,000 class G at 'CCCsf/RR1' from 'CCCsf/RR6';

   -- $28,000,000 class H at 'CCCsf/RR6';

   -- $49,500,000 class J at 'CCsf/RR6';

   -- $35,000,000 class K at 'CCsf/RR6'.


GRANITE VENTURES: Moody's Upgrades Ratings of CLO Notes
-------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Granite Ventures III Ltd.:

US$312,000,000 Class A-1 Floating Rate Senior Notes (current
balance of $157,986,391), Upgraded to Aaa (sf); previously on
June 22, 2011 Aa1 (sf) Placed Under Review for Possible Upgrade;

US$19,000,000 Class A-2 Floating Rate Senior Notes, Upgraded to
Aaa (sf); previously on June 22, 2011 A1 (sf) Placed Under Review
for Possible Upgrade;

US$20,000,000 Class B Deferrable Floating Rate Senior Subordinate
Notes, Upgraded to Aa3 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$17,000,000 Class C Deferrable Floating Rate Subordinate Notes,
Upgraded to Baa3 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

US$7,000,000 Class D Deferrable Floating Rate Subordinate Notes,
Upgraded to Ba2 (sf); previously on June 22, 2011 Caa2 (sf) Placed
Under Review for Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Moody's notes that the Class A-1 Notes have been paid down by
approximately 43.9% or $154 million since the rating action in
August 2009. As a result of the delevering, the
overcollateralization ratios have increased since the rating
action in August 2009. Based on the latest trustee report dated
July 11, 2011 the Class A, Class B, Class C and Class D
overcollateralization ratios are reported at 126.32%, 116.13%,
108.68% and 105.89%, respectively, versus July 2009 levels of
117.25%, 110.57%, 105.46% and 103.49%, respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $236.1 million,
defaulted par of $2.4 million, a weighted average default
probability of 15.46% (implying a WARF of 2484), a weighted
average recovery rate upon default of 49.31%, and a diversity
score of 52. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Granite Ventures III Ltd., issued in May of 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

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


GRAYSON CLO: Moody's Upgrades Ratings of 7 Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Grayson CLO, Ltd.:

US$1,015,000,000 Class A-1a Floating Rate Senior Secured
Extendable Notes Due 2021 (current outstanding balance of
$922,206,093), Upgraded to Aaa (sf); previously on Jun 22, 2011 A2
(sf) Placed Under Review for Possible Upgrade;

US$111,500,000 Class A-1b Floating Rate Senior Secured Extendable
Notes Due 2021, Upgraded to Aa1 (sf); previously on Jun 22, 2011
Baa2 (sf) Placed Under Review for Possible Upgrade;

US$68,000,000 Class A-2 Floating Rate Senior Secured Extendable
Notes Due 2021, Upgraded to A1 (sf); previously on Jun 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$72,000,000 Class B Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due 2021, Upgraded to Baa1 (sf);
previously on Jun 22, 2011 B1 (sf) Placed Under Review for
Possible Upgrade;

US$75,000,000 Class C Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due 2021, Upgraded to B1 (sf);
previously on Jun 22, 2011 Ca (sf) Placed Under Review for
Possible Upgrade;

US$31,000,000 Class D Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due 2021 (current outstanding balance of
$18,075,526), Upgraded to B2 (sf); previously on Jun 22, 2011 C
(sf) Placed Under Review for Possible Upgrade;

US$90,000,000 aggregate face amount of Grayson Combination Trust
2006 Pass Through Certificates due 2021 (current rated balance of
$70,696,776), Upgraded to Ba1 (sf); previously on Jun 22, 2011 B2
(sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios due to delevering of the senior notes
since the rating action in July 2009. Moody's notes that the Class
A-1a Notes have been paid down by approximately 6.24% or $83.1
million since the rating action in July 2009. As a result of the
delevering, the overcollateralization ratios have increased since
the rating action in July 2009. Based on the latest trustee report
dated June 30, 2011, the Class A, Class B, Class C and Class D
overcollateralization ratios are reported at 117.10%, 109.92%,
103.31% and 101.53%, respectively, versus May 2009 levels of
107.9%, 101.72%, 95.99% and 94.43%, respectively. In particular,
the Class D overcollateralization ratio has increased in part due
to the diversion of excess interest to delever the Class D notes
in the event of a Class D overcollateralization test failure.
Since the rating action in July, $4 million of interest proceeds
have reduced the outstanding balance of the Class D Notes by
18.4%. Moody's also notes that the Class C and Class D Notes are
no longer deferring interest and that all previously deferred
interest has been paid in full.

Moody's notes that the deal has benefited from an improvement in
the credit quality of the underlying portfolio. Based on the
latest trustee report dated June, 2011 the weighted average rating
factor is currently 2562 compared to 3053 in the May 2009 report.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $1.272 billion,
defaulted par of $124 million, a weighted average default
probability of 22.41% (implying a WARF of 2796), a weighted
average recovery rate upon default of 47.9%, and a diversity score
of 60. The default and recovery properties of the collateral pool
are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

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

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, and diversity score.

4) Exposure to other structured finance products: The deal is
   exposed to a number of CLO tranches in the underlying portfolio
   whose ratings are more volatile on average compared to
   corporate loan ratings.


GREENWICH CAPITAL: Fitch Affirms Ratings of All Classes
-------------------------------------------------------
Fitch Ratings affirms all classes of Greenwich Capital Commercial
Funding Corp. commercial mortgage pass-through certificates,
series 2004-FL2 (GCCFC 2004-FL2).

The class L remains at 'D' due to principal losses. To date, the
class has incurred $375,585 of losses. The affirmations of the
remaining classes are a result of adequate credit enhancement to
withstand Fitch's loss expectations, which incorporate prospective
views of cash flow declines and commercial real estate market
value declines. The Negative Rating Outlooks reflect the binary
risk associated with the one loan remaining in the pool,
Southfield Town Center.

Southfield Town Center loan is secured by a 2.2 million square
foot office complex located in Southfield, Michigan. Occupancy has
been declining over the last three years, reported at 68.5% as of
May 2011, compared to 70.5% at year end (YE) 2010 and 75% at YE
2009. The Southfield submarket of Detroit reported a vacancy of
21.8% as of mid-year 2011, which indicates the subject is
underperforming the market. Rollover averages about 10% over the
next three years, which may put further pressure on occupancy. The
Fitch stressed value based on YE 2010 net operating income (NOI)
indicates that recovery prospects are strong, should performance
remain stable through maturity. The loan exercised its final
extension in July 2011, and matures in July 2012.

Fitch affirms these classes and Outlooks:

   -- $6.9 million class C at 'AAAsf'; Outlook Stable;

   -- $22.7 million class D at 'AAAsf'; Outlook Stable;

   -- $12.4 million class E at 'AAAsf'; Outlook Stable;

   -- $22.8 million class F at 'AAAsf'; Outlook Stable;

   -- $19.5 million class G at 'AAAsf'; Outlook Stable;

   -- $14.5 million class H at 'AAsf'; Outlook Stable;

   -- $23.1 million class J at 'A-sf'; Outlook Negative;

   -- $10.3 million class K at 'BBBsf'; Outlook Negative;

   -- $15.3 million class L at 'Dsf/RR1';

   -- $7.5 million class N-SO at 'BBB-sf'; Outlook Negative.


GS MORTGAGE: S&P Lowers Ratings on 3 Classes of Notes to 'D'
------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on four
classes of commercial mortgage-backed securities (CMBS) pass-
through certificates from GS Mortgage Securities Trust 2007-GKK1
(GSMST 2007-GKK1), a U.S. resecuritized real estate mortgage
investment conduit (re-REMIC) transaction. "We downgraded classes
A-2 through C to 'D (sf)' due to interest shortfalls that we
expect will continue for the foreseeable future," S&P said.

"The downgrades primarily reflect our analysis of the transaction
following interest shortfalls to the transaction. Our analysis
also reflects the transaction's exposure to downgraded CMBS
certificates that serve as underlying CMBS collateral. The
downgraded CMBS certificates have a total balance of $333.4
million (52.9% of the pool balance) and are from 22 distinct
CMBS transactions," S&P related.

According to the July 21, 2011, trustee report, remaining deferred
interest to the transaction totaled $10.6 million affecting class
A-2 and the classes subordinate to it. The interest shortfalls to
GSMST 2007-GKK1 resulted from interest shortfalls on 34 of the
underlying CMBS certificates, primarily due to the master
servicer's recovery of prior advances, appraisal subordinate
entitlement reductions (ASERs), servicers' nonrecoverability
determinations for advances, and special servicing fees. "We
lowered our ratings on classes A-2 through C to 'D (sf)' due to
interest shortfalls that we expect will continue for the
foreseeable future," S&P said.

According to the July 21, 2011, trustee report, GSMST 2007-GKK1 is
collateralized by 73 CMBS classes ($629.8 million, 100%) from 46
distinct transactions issued between 1998 and 2007. GSMST 2007-
GKK1 has significant exposure to these CMBS certificates that
Standard & Poor's has downgraded:

    ML-CFC Commercial Mortgage Trust 2006-4 (classes G, H, and J;
    $44.9 million, 7.1%);

    Credit Suisse Commercial Mortgage Trust series 2006-C5
    (classes G and H; $30.1 million, 4.8%);

    Greenwich Capital Commercial Funding Corp. series 2007-GG9
    (classes J and K; $27 million, 4.3%); and

    GS Mortgage Securities Corp II series 2005-GG4 (classes C, D,
    and G; $25.3 million, 4.0%).

Standard & Poor's analyzed the transaction and its underlying
collateral assets according to its current criteria. "Our analysis
is consistent with the lowered ratings," S&P said.

Ratings Lowered

GS Mortgage Securities Trust 2007-GKK1
Commercial mortgage-backed securities pass-through certificates
                       Rating
Class            To               From
A-1              CCC- (sf)        B- (sf)
A-2              D (sf)           CCC- (sf)
B                D (sf)           CCC- (sf)
C                D (sf)           CCC- (sf)


GUGGENHEIM 2006-3: Fitch Affirms Junk Rating on 3 Class Notes
-------------------------------------------------------------
Fitch Ratings has upgraded three classes of Guggenheim Structured
Real Estate Funding 2006-3 Ltd./LLC reflecting significant paydown
since Fitch's last review.  Fitch's base case loss expectation is
currently 37.1% for the remaining assets.  Fitch's performance
expectation incorporates prospective views regarding commercial
real estate market value and cash flow declines.

Fitch has upgraded, affirmed, and revised or assigned Outlooks on
these classes as indicated:

  -- $20,000,000 class S affirmed at 'Asf', Outlook to Stable from
     Negative;

  -- $24,357,606 class B upgraded to 'A' from 'BB'; Outlook to
     Stable from Negative;

  -- $42,053,000 class C upgraded to 'BB' from 'B; Outlook to
     Stable from Negative;

  -- $24,029,000 class D upgrade to 'B' from 'CCC/RR6'; Outlook
     Stable;

  -- $28,827,789 class E affirm at 'CCC/RR6';

  -- $22,054,477 class F affirm at 'CC/RR6';

  - -$22,126,278 class G affirm at 'CC/RR6'.

Class A-1 and A-2 have paid in full.

Since Fitch's last review, the transaction has benefited from
significant repayments of approximately $155.9 million.  The
transaction is now considered concentrated with only 12 obligors.
Guggenheim 2006-3 is primarily collateralized by commercial real
estate (CRE) debt of which approximately 45.8% is subordinate debt
or non-senior tranches from structured finance transactions.
Fitch expects significant losses upon default for the subordinate
positions, since they are generally highly leveraged.  Two loans
(11%) are currently defaulted and one loan (21.7%) is considered a
Fitch loan of concern.  Fitch expects significant losses on the
defaulted assets.

Guggenheim 2006-3 is a CRE collateralized debt obligation (CDO)
managed by GSREA, LLC with approximately $184.7 million of
collateral.  The transaction has a five-year reinvestment period,
which ends in August 2011.

As of the July 2011 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: CRE subordinate
debt (28.1%), A-notes/whole loans (42.6%), CMBS (8.7%), and CRE
CDOs (20.6%).  In general, Fitch treats non-senior, single-
borrower CMBS as CRE B-notes.  The average Fitch derived rating
for the remaining collateral that carries a public rating is
'B/B+'.

All overcollateralization (OC) and interest coverage (IC) tests,
except for the class E OC test, are passing, as of the July 2011
trustee report.  As a result of the class E OC test failure,
interest and principal proceeds (after class E) are being
redirected to redeem class A-1.  The failure, however, is slight
and Fitch anticipates that it will cure in the next payment
period.

Under Fitch's updated methodology, approximately 57.8% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 8.5% from the most recent available cash
flows (generally from year-end 2010).  Fitch estimates that
recoveries will average 35.8%.

The largest component of Fitch's base case loss expectation is the
expected loss assigned to the CRE CDO collateral.

The second largest component of loss expectation is a highly
leveraged whole loan (21.7%) on a full-service hotel located one
block east of Chicago's Magnificent Mile.  The hotel's most
recently reported trailing 12-month net cash flow is again lower
than the prior year.  Although the hotel is still covering its
debt service payments given historically low LIBOR, Fitch modeled
a term default in its base case scenario.

The third largest component of Fitch's base case loss expectation
is an A-note (10.1%) secured by an undeveloped land parcel in
Orlando, FL. Fitch is modeling a term default in its base case
scenario with substantial modeled losses.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S. CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio. Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to class B through D was then compared to
the modeled expected losses, and in consideration of the high
concentration of the pool, the credit enhancement was determined
to be consistent with the ratings assigned below.  Based on prior
modeling results, no material impact was anticipated from cash
flow modeling the transaction. The Rating Outlooks for classes B
through D are Stable reflecting the paydown of the senior notes.

The 'CCC' and below ratings for classes E through G are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Class S is an interest-only class with a notional balance of
$20 million. The interest amount is paid monthly out of CDO cash
flows and is pari passu in priority to class A-1.  Class S credit
characteristics are consistent with a 'A' rating; there are only
two payments remaining.


GUGGENHEIM 2006-4: Fitch Affirms Junk Rating on Six Class Notes
---------------------------------------------------------------
Fitch Ratings has affirmed all classes of Guggenheim Structured
Real Estate Funding 2006-4 Ltd./LLC reflecting Fitch's base case
loss expectation of 40.7% for the remaining assets.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market value and cash flow declines.

Fitch has affirmed the ratings, and revised Outlooks on these
classes as indicated:

  -- $6,000,000 class S at 'BB'; Outlook to Stable from Negative;
  -- $91,145,375 class A-1 at 'BB'; Outlook to Stable from
     Negative;
  -- $34,833,426 class A-2 at 'B'; Outlook to Stable from
     Negative;
  -- $42,040,342 class B at 'B'; Outlook Negative;
  -- $26,143,106 class C at 'CCC'; 'RR6';
  -- $14,004,731 class D at 'CCC'; 'RR6;
  -- $13,426,314 class E at 'CCC'; 'RR6';
  -- $13,582,609 class F at 'CC'; 'RR6';
  -- $14.895,706 class G at 'C'; 'RR6';
  -- $10,692,678 class H at 'C'; 'RR6'.

Since last review the class A-1 notes have amortized by an
additional $90.8 million due to the removal of four assets (three
of which paid in full), the partial paydown and amortization of
several other loans, and through interest diversion. The disposal
of one asset resulted in the realized loss to the CDO of
$4.1 million.

Guggenheim 2006-4 is concentrated with 14 obligors of commercial
real estate (CRE) debt of which approximately 84.3% is subordinate
debt or subordinate tranches of structured finance transactions.
Fitch expects significant losses upon default for the subordinate
positions since they are generally highly leveraged. Positions
from three obligors (26.2%) are currently defaulted and one loan
(3.3%) is considered a Fitch loan of concern.  Fitch expects
significant losses on the defaulted assets.

Guggenheim 2006-4 is a CRE collateralized debt obligation (CDO)
managed by GSREA, LLC with approximately $302.2 million of
collateral. The transaction has a five-year reinvestment period,
which ends in February 2012.

As of the July 2011 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: CRE subordinate B-
notes/mezzanine loans (57.4%), A-notes/whole loans (15.4%), CMBS
(10.2%), and CRE CDOs (17%).  In general, Fitch treats non-senior,
single-borrower CMBS as CRE B-notes.  The average Fitch derived
rating for the remaining collateral that carries a public rating
is 'CCC+'.

All overcollateralization (OC) tests are failing, as of the July
2011 trustee report.  As a result all interest proceeds remaining
after the payment of the class B interest are redirected to redeem
class A-1.

Under Fitch's updated methodology, approximately 61.7% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress.  In this scenario, the modeled average
cash flow decline is 8.2% from the most recent available cash
flows (generally from year-end 2010).  Fitch estimates that
recoveries will average 34.0%.

The largest component of Fitch's base case loss expectation is the
expected loss assigned to the CRE CDO collateral.

The second largest component of Fitch's base case loss expectation
is the expected loss on three B-notes (10.9%) on a portfolio of
three hotel/gaming properties that have experienced significant
declines in performance.  Fitch modeled a term default in its base
case scenario with a full loss on the subordinate positions.

The third largest component of Fitch's base case loss expectation
is an A-note (12.1%) secured by an undeveloped land parcel in
Orlando, FL.  Fitch is modeling a term default in its base case
scenario with substantial modeled losses.

This transaction was analyzed according to the 'Surveillance
Criteria for U.S.  CREL CDOs and CMBS Large Loan Floating-Rate
Transactions', which applies stresses to property cash flows and
debt service coverage ratio (DSCR) tests to project future default
levels for the underlying portfolio.  Recoveries are based on
stressed cash flows and Fitch's long-term capitalization rates.
The credit enhancement to class A-1 through B was then compared to
the modeled expected losses, and in consideration of the high
concentration of the pool, the credit enhancement was determined
to be consistent with the ratings assigned below.  Based on prior
modeling results, no material impact was anticipated from cash
flow modeling the transaction.  The Rating Outlooks for classes A-
1, A-2, and S are revised to Stable from Negative reflecting the
paydown of the senior notes.  Class B maintains a Negative Rating
Outlook reflecting Fitch's expectation of further potential
negative credit migration of the underlying collateral.

The 'CCC' and below ratings for classes C through H are based on a
deterministic analysis that considers Fitch's base case loss
expectation for the pool and the current percentage of defaulted
assets and Fitch Loans of Concern factoring in anticipated
recoveries relative to each class' credit enhancement.  These
classes were assigned Recovery Ratings (RR) in order to provide a
forward-looking estimate of recoveries on currently distressed or
defaulted structured finance securities.

Class S is an interest-only class with a notional balance of
$6 million. The interest amount is paid monthly out of CDO cash
flows and is pari passu in priority to class A-1.  Class S credit
characteristics are consistent with a 'BBsf' rating.
coverage ratio below 1.0x.


GULF STREAM: Moody's Upgrades Ratings of 7 Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Gulf Stream-Compass CLO 2005-II, Ltd.:

US$35,000,000 Class A-1 Senior Secured Variable Funding Floating
Rate Notes due 2020 (current outstanding balance of
$34,566,272.85), Upgraded to Aaa (sf); previously on June 22, 2011
Aa3 (sf) Placed Under Review for Possible Upgrade;

US$350,000,000 Class A-2 Senior Secured Floating Rate Notes due
2020 (current outstanding balance of $345,662,728.46), Upgraded to
Aaa (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$15,000,000 Class B Senior Secured Floating Rate Notes due 2020,
Upgraded to Aa1 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$35,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2020, Upgraded to Baa1 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$25,000,000 Class D Secured Deferrable Floating Rate Notes due
2020, Upgraded to Ba3 (sf); previously on June 22, 2011 Caa2 (sf)
Placed Under Review for Possible Upgrade;

US$5,000,000 Type I Composite Notes due 2020 (current outstanding
Rated Balance of $3,255,869.98), Upgraded to Aaa (sf); previously
on June 22, 2011 A2 (sf) Placed Under Review for Possible Upgrade;

US$10,000,000 Type II Composite Notes due 2020 (current
outstanding Rated Balance of $4,964,736.30), Upgraded to Baa2
(sf); previously on June 22, 2011 B2 (sf) Placed Under Review for
Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in June 2009.
The Class A/B, Class C and Class D overcollateralization ratios
are reported at 120.91%, 111.08% and 104.98%, respectively, versus
May 2009 levels of 116.80%, 107.34% and 101.46%, respectively, and
all related overcollateralization tests are currently in
compliance. Based on the July 2011 trustee report, the weighted
average rating factor is currently 2453 compared to 2812 in May
2009.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $478.1 million,
defaulted par of $3.5 million, a weighted average default
probability of 17.35% (implying a WARF of 2545), a weighted
average recovery rate upon default of 48.63%, and a diversity
score of 89. Moody's generally analyzes deals in their
reinvestment period by assuming the worse of reported and
covenanted values for all collateral quality tests. However, in
this case given the limited time remaining in the deal's
reinvestment period, Moody's analysis reflects the benefit of
assuming a higher likelihood that the collateral pool
characteristics will continue to maintain a positive "cushion"
relative to certain covenant requirements, as seen in the actual
collateral quality measurements. The default and recovery
properties of the collateral pool are incorporated in cash flow
model analysis where they are subject to stresses as a function of
the target rating of each CLO liability being reviewed. The
default probability is derived from the credit quality of the
collateral pool and Moody's expectation of the remaining life of
the collateral pool. The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool. In each case, historical and market
performance trends and collateral manager latitude for trading the
collateral are also factors.

Gulf Stream-Compass CLO 2005-II, Ltd., issued in January 2006, is
a collateralized loan obligation backed primarily by a portfolio
of senior secured loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011. Other methodology used in this rating was "Using the
Structured Note Methodology to Rate CDO Combo-Notes" published in
February 2004. Please see the Credit Policy page on www.moodys.com
for a copy of these methodologies.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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


HALCYON STRUCTURED: Moody's Raises Ratings of of CLO Notes
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Halcyon Structured Asset Management Long Secured/Short
Unsecured 2007-3 Ltd.:

US$260,000,000 Class X Senior Interest Only Secured Notes, Due
2019 (current balance of $256,894,386), Upgraded to Aaa(sf);
previously on June 22, 2011 Aa1(sf) Placed Under Review for
Possible Upgrade;

US$324,000,000 Class A-1 Senior Secured Floating Rate Notes, Due
2019 (current balance of $320,129,927), Upgraded to Aaa(sf);
previously on June 22, 2011 Aa1(sf) Placed Under Review for
Possible Upgrade;

US$31,500,000 Class A-2 Senior Secured Floating Rate Notes, Due
2019, Upgraded to A1(sf); previously on June 22, 2011 A3(sf)
Placed Under Review for Possible Upgrade;

US$21,000,000 Class B Senior Secured Deferrable Floating Rate
Notes, Due 2019, Upgraded to Baa2(sf); previously on June 22, 2011
Baa3(sf) Placed Under Review for Possible Upgrade;

US$9,100,000 Class C Secured Deferrable Floating Rate Notes, Due
2019, Upgraded to Ba1(sf); previously on June 22, 2011 Ba3(sf)
Placed Under Review for Possible Upgrade;

US$21,700,000 Class D Secured Deferrable Floating Rate Notes, Due
2011, Upgraded to B1(sf); previously on June 22, 2011 Caa1(sf)
Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of a credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in September
2009. Based on the July 2011 trustee report, the weighted average
rating factor is currently 2654 compared to 2877 in August 2009.
The overcollateralization ratios of the rated notes have also
improved since the rating action in September 2009. The Class A,
Class B, Class C, and Class D overcollateralization ratios are
reported at 125.29%, 118.23%, 115.41% and 109.21%, respectively,
versus August 2009 levels of 118.11%, 111.49%, and 108.85% and
102.91%, respectively, and all related overcollateralization tests
are currently in compliance. Moody's also notes that the Class D
Notes are no longer deferring interest and that all previously
deferred interest has been paid in full.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $440.5 million, a
weighted average default probability of 21.72% (implying a WARF of
2762), a weighted average recovery rate upon default of 48.28%,
and a diversity score of 53. The default and recovery properties
of the collateral pool are incorporated in cash flow model
analysis where they are subject to stresses as a function of the
target rating of each CLO liability being reviewed. The default
probability is derived from the credit quality of the collateral
pool and Moody's expectation of the remaining life of the
collateral pool. The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool. In each case, historical and market
performance trends and collateral manager latitude for trading the
collateral are also factors.

Halcyon Structured Asset Management Long Secured/Short Unsecured
2007-3 Ltd., issued in November 2007, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, and weighted average coupon. However, as part of
   the base case, Moody's considered spread/diversity levels
   higher than the covenant levels due to the large difference
   between the reported and covenant levels.


ING INVESTMENT: Moody's Upgrades Ratings of 6 Classes of CLO Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by ING Investment Management CLO III, Ltd.:

US$255,000,000 Class A-1 Floating Rate Notes Due December 13,
2020, Upgraded to Aaa (sf); previously on June 22, 2011 Aa1 (sf)
Placed Under Review for Possible Upgrade;

US$25,000,000 Class A-2b Floating Rate Notes Due December 13,
2020, Upgraded to Aa1 (sf); previously on June 22, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade;

US$23,000,000 Class A-3 Floating Rate Notes Due December 13, 2020,
Upgraded to Aa3 (sf); previously on June 22, 2011 A2 (sf) Placed
Under Review for Possible Upgrade;

US$29,500,000 Class B Deferrable Floating Rate Notes Due December
13, 2020, Upgraded to Baa1 (sf); previously on June 22, 2011 Baa3
(sf) Placed Under Review for Possible Upgrade;

US$15,500,000 Class C Floating Rate Notes Due December 13, 2020,
Upgraded to Ba1 (sf); previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$13,000,000 Class D Floating Rate Notes Due December 13, 2020,
Upgraded to B1 (sf); previously on June 22, 2011 Caa1 (sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Moody's notes that the deal has benefited from an improvement in
the credit quality of the underlying portfolio since the rating
action in September 2009. Based on the July 2011 trustee report,
the weighted average rating factor is currently 2495 compared to
2838 in August 2009.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $480.5 million,
defaulted par of $2.7 million, a weighted average default
probability of 21.32% (implying a WARF of 2653), a weighted
average recovery rate upon default of 50.46%, and a diversity
score of 80. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

ING Investment Management CLO III, Ltd., issued in December 2006,
is a collateralized loan obligation backed primarily by a
portfolio of senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor and diversity score. However, as part of the base
   case, Moody's considered spread and coupon levels higher than
   the covenant levels due to the large difference between the
   reported and covenant levels.


JEFFERIES RESECURITIZATION: S&P Affirms 'CC' Ratings on 2 Classes
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 52
classes from Jefferies Resecuritization Trust 2009-R4 and removed
40 of them from CreditWatch with negative implications.

"In addition, we affirmed our ratings on 52 classes from the same
transaction and removed 46 of them from CreditWatch negative.
Jefferies Resecuritization Trust 2009-R4 is a residential
mortgage-backed securities (RMBS) resecuritized real estate
mortgage investment conduit (re-REMIC) transaction that pays
interest pro rata within each of its groups," S&P related.

"On Dec. 15, 2010, we placed our ratings on 86 classes from this
transaction on CreditWatch negative, along with ratings from a
group of other RMBS re-REMIC securities (for more information, see
'S&P Corrects: 1,196 Ratings on 129 U.S. RMBS Re-REMIC
Transactions Placed on CreditWatch Negative'). Additionally, on
April 1, 2011, we provided an update on the CreditWatch placements
and provided clarification regarding our analysis of interest
payment amounts within re-REMIC transactions (see 'Standard &
Poor's Provides An Update On Outstanding RMBS Re-REMIC CreditWatch
Placements And Outlines Their Resolution')," S&P said.

"We intend our ratings on the re-REMIC classes to address the
timely payment of interest and the full payment of principal. We
reviewed the interest and principal amounts due on the underlying
securities, which are then passed through to the applicable re-
REMIC classes. When performing this analysis, we applied our loss
projections, incorporating, where applicable, our recently revised
loss assumptions to the underlying collateral to identify the
principal and interest amounts that could be passed through from
the underlying securities under our rating scenario stresses. We
stressed our loss projections at various rating categories to
assess whether the re-REMIC classes could withstand the stressed
losses associated with their ratings while receiving timely
payment of interest and principal consistent with our criteria,"
S&P said.

"In applying our loss projections we incorporated, where
applicable, our recently revised loss assumptions as outlined in
'Revised Lifetime Loss Projections For Prime, Subprime, And Alt-A
U.S. RMBS Issued In 2005-2007,' published on March 25, 2011, into
our review. Such updates pertain to the 2005-2007 vintage prime,
subprime, and Alternative-A (Alt-A) transactions; some of which
are associated with the re-REMICs we reviewed," S&P said.

Table 1
Lifetime Loss Projections For Prime And Subprime RMBS
(Percent of original balance)
           Prime RMBS      Subprime RMBS
            Aggregate        Aggregate
Vintage  Updated  Prior    Updated  Prior
2005         5.5   4.00      18.25  15.40
2006        9.25   6.60      38.25  35.00
2007       11.75   9.75      48.50  43.20

Table 2
Lifetime Loss Projections For Alternative-A RMBS
(Percent of original balance)
                            Fixed/
          Aggregate       long-reset
Vintage Updated  Prior  Updated  Prior
2005      13.75  11.25    12.75   9.60
2006      29.50  26.25    25.25  25.00
2007      36.00  31.25    31.75  26.25
         Short-reset
            hybrid        Option ARM
Vintage Updated  Prior  Updated  Prior
2005      13.25  14.75    15.50  13.25
2006      30.00  30.50    34.75  26.75
2007      41.00  40.75    43.50  37.50

"As a result of this review, we lowered our ratings on certain
classes based on our assessment as to whether there were principal
and/or interest shortfalls from the underlying securities that
would impair the re-REMIC classes at the applicable rating
stresses. The affirmations reflect our assessment of the
likelihood that the re-REMIC classes will receive timely payment
of interest and full payment of principal under the applicable
stressed assumptions," S&P said.

"We based our downgrades on our projections of principal loss
amounts and interest shortfalls, allocated to the relevant re-
REMIC classes under the applicable ratings stress scenarios," S&P
added.

Rating Actions

Jefferies Resecuritization Trust 2009-R4
Series      2009-R4
                               Rating
Class      CUSIP       To                   From
18-A2      47232VDS8   B- (sf)              A (sf)/Watch Neg
16-A5      47232VDM1   CC (sf)              CCC (sf)
13-A4      47232VCT7   CCC (sf)             BB- (sf)/Watch Neg
14-A5      47232VDB5   CC (sf)              CCC (sf)
22-A2      47232VEK4   BB+ (sf)             A (sf)/Watch Neg
24-A1      47232VEW8   AAA (sf)             AAA (sf)/Watch Neg
14-A3      47232VCZ3   CCC (sf)             BB- (sf)/Watch Neg
9-A3       47232VBV3   BBB (sf)             BBB (sf)/Watch Neg
16-A1      47232VDF6   A+ (sf)              AAA (sf)/Watch Neg
21-A1      47232VEC2   AAA (sf)             AAA (sf)/Watch Neg
16-A4      47232VDL3   CCC (sf)             B- (sf)/Watch Neg
17-A2      47232VDP4   BB+ (sf)             AA (sf)/Watch Neg
8-A1       47232VBM3   AAA (sf)             AAA (sf)/Watch Neg
24-A4      47232VEZ1   BB (sf)              BB (sf)/Watch Neg
16-A1A     47232VDG4   AAA (sf)             AAA (sf)/Watch Neg
10-A1      47232VBZ4   AAA (sf)             AAA (sf)/Watch Neg
17-A1      47232VDN9   AAA (sf)             AAA (sf)/Watch Neg
9-A4       47232VBW1   BB (sf)              BB (sf)/Watch Neg
10-A3      47232VCB6   BBB (sf)             BBB (sf)/Watch Neg
13-A2      47232VCR1   B (sf)               A (sf)/Watch Neg
10-A5      47232VCD2   CCC (sf)             B- (sf)/Watch Neg
22-A1      47232VEJ7   AAA (sf)             AAA (sf)/Watch Neg
20-A2      47232VEA6   CCC (sf)             BBB+ (sf)/Watch Neg
31-A2      47232VGC0   A (sf)               A (sf)/Watch Neg
7-A4       47232VBK7   CCC (sf)             B (sf)/Watch Neg
24-A2      47232VEX6   A (sf)               A (sf)/Watch Neg
10-A4      47232VCC4   B- (sf)              BB (sf)/Watch Neg
27-A3      47232VFM9   B (sf)               BBB (sf)/Watch Neg
25-A3      47232VFE7   CC (sf)              CCC (sf)
9-A1B      47232VBT8   AAA (sf)             AAA (sf)/Watch Neg
17-A3      47232VDQ2   CC (sf)              B- (sf)/Watch Neg
15-A1      47232VDC3   BB (sf)              AAA (sf)/Watch Neg
8-A2       47232VBN1   A (sf)               A (sf)/Watch Neg
29-A2      47232VFV9   B- (sf)              A+ (sf)/Watch Neg
31-A4      47232VGE6   BB (sf)              BB (sf)/Watch Neg
31-A1      47232VGB2   NR (sf)              AAA (sf)/Watch Neg
18-A3      47232VDT6   CCC (sf)             BBB (sf)/Watch Neg
13-A3      47232VCS9   CCC (sf)             BBB (sf)/Watch Neg
10-A2      47232VCA8   A (sf)               A (sf)/Watch Neg
7-A3       47232VBJ0   B- (sf)              BBB (sf)/Watch Neg
19-A1      47232VDW9   AAA (sf)             AAA (sf)/Watch Neg
20-A1      47232VDZ2   AAA (sf)             AAA (sf)/Watch Neg
27-A1      47232VFK3   AAA (sf)             AAA (sf)/Watch Neg
14-A2      47232VCY6   CCC (sf)             BBB (sf)/Watch Neg
25-A2      47232VFD9   A (sf)               A (sf)/Watch Neg
9-A5       47232VBX9   B+ (sf)              B+ (sf)/Watch Neg
19-A2      47232VDX7   CCC (sf)             A+ (sf)/Watch Neg
23-A4      47232VET5   BB (sf)              BB (sf)/Watch Neg
25-A1      47232VFC1   AAA (sf)             AAA (sf)/Watch Neg
8-A4       47232VBQ4   CC (sf)              CCC (sf)
23-A2      47232VER9   A (sf)               A (sf)/Watch Neg
18-A1      47232VDR0   A- (sf)              AAA (sf)/Watch Neg
29-A3      47232VGR7   CC (sf)              CCC (sf)
14-A1A     47232VCW0   AAA (sf)             AAA (sf)/Watch Neg
14-A1      47232VCV2   B+ (sf)              AA+ (sf)/Watch Neg
23-A3      47232VES7   BBB (sf)             BBB (sf)/Watch Neg
30-A1      47232VFW7   AAA (sf)             AAA (sf)/Watch Neg
14-A1B     47232VCX8   B+ (sf)              AA+ (sf)/Watch Neg
21-A3      47232VEE8   BBB (sf)             BBB (sf)/Watch Neg
23-A1      47232VEQ1   AAA (sf)             AAA (sf)/Watch Neg
21-A4      47232VEF5   B+ (sf)              BB (sf)/Watch Neg
31-A3      47232VGD8   BBB (sf)             BBB (sf)/Watch Neg
22-A4      47232VEM0   CCC (sf)             BB (sf)/Watch Neg
27-A2      47232VFL1   A (sf)               A (sf)/Watch Neg
26-A2      47232VFG2   A (sf)               A (sf)/Watch Neg
26-A1      47232VFF4   AAA (sf)             AAA (sf)/Watch Neg
7-A2       47232VBH4   BBB- (sf)            A (sf)/Watch Neg
30-A3      47232VFY3   BBB- (sf)            BBB (sf)/Watch Neg
13-A5      47232VCU4   CC (sf)              CCC (sf)
21-A2      47232VED0   A (sf)               A (sf)/Watch Neg
19-A3      47232VDY5   CC (sf)              CCC (sf)
29-A1      47232VFU1   AAA (sf)             AAA (sf)/Watch Neg
12-A3      47232VCP5   CC (sf)              CCC (sf)
30-A2      47232VFX5   A (sf)               A (sf)/Watch Neg
14-A4      47232VDA7   CCC (sf)             B- (sf)/Watch Neg
9-A1A      47232VBS0   AAA (sf)             AAA (sf)/Watch Neg
16-A3      47232VDK5   CCC (sf)             BBB- (sf)/Watch Neg
23-A5      47232VEU2   B (sf)               B (sf)/Watch Neg
26-A3      47232VFH0   BBB (sf)             BBB (sf)/Watch Neg
9-A1       47232VBR2   AAA (sf)             AAA (sf)/Watch Neg
18-A4      47232VDU3   CCC (sf)             BB (sf)/Watch Neg
31-A6      47232VGG1   CC (sf)              CCC (sf)
22-A3      47232VEL2   CCC (sf)             BBB (sf)/Watch Neg
27-A4      47232VFN7   CC (sf)              B+ (sf)/Watch Neg
12-A2      47232VCN0   BB (sf)              A (sf)/Watch Neg
7-A1       47232VBG6   AAA (sf)             AAA (sf)/Watch Neg
16-A2      47232VDJ8   B- (sf)              A (sf)/Watch Neg
24-A3      47232VEY4   BBB (sf)             BBB (sf)/Watch Neg
9-A2       47232VBU5   A (sf)               A (sf)/Watch Neg
21-A5      47232VEG3   CCC (sf)             B- (sf)/Watch Neg
26-A4      47232VFJ6   CC (sf)              CCC (sf)
31-A5      47232VGF3   CCC (sf)             B (sf)/Watch Neg
15-A3      47232VDE9   CC (sf)              CCC (sf)
12-A1      47232VCM2   AAA (sf)             AAA (sf)/Watch Neg
15-A2      47232VDD1   CCC (sf)             AA (sf)/Watch Neg
13-A1      47232VCQ3   A- (sf)              AAA (sf)/Watch Neg
16-A1B     47232VDH2   A+ (sf)              AAA (sf)/Watch Neg
20-A3      47232VEB4   CC (sf)              CCC (sf)
8-A3       47232VBP6   BBB (sf)             BBB (sf)/Watch Neg

Ratings Affirmed

Jefferies Resecuritization Trust 2009-R4
Series      2009-R4
Class      CUSIP       Rating
30-A5      47232VGA4   CCC (sf)
7-A5       47232VBL5   CC (sf)
22-A5      47232VEN8   CCC (sf)
30-A4      47232VFZ0   CCC (sf)
24-A5      47232VFA5   CCC (sf)
9-A6       47232VBY7   CC (sf)


JERSEY STREET: Moody's Upgrades Ratings of Four Classes of Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Jersey Street CLO, Ltd.

US$236,000,000 Class A Senior Secured Floating Rate Notes Due
2018, Upgraded to Aaa (sf); previously on June 22, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade;

US$14,000,000 Class B Senior Secured Floating Rate Notes Due 2018,
Upgraded to Aa3 (sf); previously on June 22, 2011 Baa1 (sf) Placed
Under Review for Possible Upgrade;

US$20,250,000 Class C Secured Deferrable Floating Rate Notes Due
2018, Upgraded to Baa2 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$11,250,000 Class D Secured Deferrable Floating Rate Notes Due
2018, Upgraded to Ba1 (sf); previously on June 22, 2011 Caa1 (sf)
Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in the publication "Moody's Approach to Rating
Collateralized Loan Obligations" published in June 2011. The
primary changes to the modeling assumptions include (1) a removal
of the temporary 30% default probability macro stress implemented
in February 2009 as well as (2) increased BET liability stress
factors and increased recovery rate assumptions.

The actions also reflect consideration of and an increase in the
transaction's overcollateralization ratios and credit improvement
of the underlying portfolio since the rating action in August
2009. The overcollateralization ratios of the rated notes have
increased due to a decrease in defaulted securities and securities
rated Caa1 and below. Based on the latest trustee report dated
July 11, 2011, the Class A/B, Class C, and Class D
overcollateralization ratios are reported at 121.3%, 112.2% and
107.7%, respectively, versus July 2009 levels of 113.0%, 104.8%
and 100.6% respectively. Based on the July 2011 trustee report,
the weighted average rating factor is currently 2553 compared to
2861 in July 2009. Moody's adjusted WARF has also declined due to
a decrease in the percentage of securities with ratings on "Review
for Possible Downgrade" or with a "Negative Outlook."

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $304 million, a
weighted average default probability of 21.1% (implying a WARF of
2654), a weighted average recovery rate upon default of 51.8%, and
a diversity score of 65. These default and recovery properties of
the collateral pool are incorporated in cash flow model analysis
where they are subject to stresses as a function of the target
rating of each CLO liability being reviewed. The default
probability is derived from the credit quality of the collateral
pool and Moody's expectation of the remaining life of the
collateral pool. The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool. In each case, historical and market
performance trends and collateral manager latitude for trading the
collateral are also factors.

Jersey Street CLO, Ltd., issued in September 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2. Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3. Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score. However, as part of the base case,
   Moody's considered spread levels higher than the covenant
   levels due to the large difference between the reported and
   covenant levels.


JP MORGAN: Losses Across the Pool Cues Fitch to Lower Ratings
-------------------------------------------------------------
Fitch Ratings has downgraded three classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp. 2001-CIBC3.

Fitch downgrades these classes and assigns Recovery Ratings (RRs)
as indicated:

  -- $7.6 million class K to 'CCsf/RR3' from 'B-sf';
  -- $4.3 million class L to 'Csf/RR6' from 'B-sf';
  -- $4.3 million class M to 'Csf/RR6' from 'CCCsf/RR4'.

Classes K and L previously carried a Negative Rating Outlook.

Fitch also affirms these classes and revises the Ratings Outlooks
as indicated:

  -- $184.9 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $36.9 million class B at 'AAAsf'; Outlook Stable;
  -- $36.9 million class C at 'AAAsf'; Outlook Stable;
  -- $9.8 million class D at 'AAAsf'; Outlook Stable;
  -- $27.1 million class E at 'AAAsf'; Outlook Stable;
  -- $10.8 million class F at 'AAsf'; Outlook to Stable from
     Negative;
  -- $17.3 million class G at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $6.5 million class H at 'BBsf'; Outlook to Stable from
     Negative;
  -- $6.5 million class J at 'Bsf'; Outlook Negative.

The downgrades reflect an increase in Fitch expected losses across
the pool.  Fitch modeled losses of 4.7% of the remaining pool.
Fitch has designated 14 loans (22.5%) as Fitch Loans of Concern,
which includes five specially serviced loans (7.8%). Fitch expects
classes L through NR may be fully depleted from losses associated
with the specially serviced assets.

As of the July 2011 distribution date, the pool's aggregate
principal balance has been paid down by approximately 59.2% to
$354.2 million from $867.5 billion at issuance.  Nineteen loans
(25.6%) are defeased. Interest shortfalls are affecting classes K
through NR.

The largest contributor to loss (2.6% of pool balance) is secured
by a 233,709 square foot (sf) retail center in Madison, WI. The
property is anchored by TJ Maxx (14% of net rentable area [NRA]).
The most recent servicer reported occupancy is 48% as of December
2010 and year end (YE) 2010 debt service coverage ratio (DSCR) was
reported at 0.32 times (x).The loan had transferred to special
servicing in March 2009 due to imminent monetary default and is
now greater than 90 days delinquent.  The special servicer has
approved a discounted payoff and executed a settlement agreement
with the borrower. Fitch expects losses upon resolution of the
loan.

The next largest contributor to losses (3%) is secured by a
107,822 sf office property in Newark, DE. At issuance, the
property was 100% occupied by a large single tenant who had
subsequently vacated a portion of the space (42% NRA) in 2009,
with the remaining space (58% NRA) vacated in December 2010.  The
most recent reported occupancy is 41.1% as of February 2011 and
the YE 2010 DSCR was reported at 0.98x.  The loan transferred to
special servicing in February 2011 due to monetary default.  The
special servicer is awaiting a loan modification proposal from the
borrower while simultaneously pursuing foreclosure.

The third largest contributor to losses (1.1%) is secured by three
one-story mixed-use buildings totaling 85,443 sf located in
Waterford, MI near the Oakland County International Airport.  The
property had suffered cash flow issues due to occupancy declines
and transferred to special servicing in April 2009.  The servicer
is currently pursuing foreclosure.  The most recent occupancy is
37.5% as of the June 2011 rent roll and the borrower continues to
make sporadic partial debt service payments.

Fitch does not rate class NR, which has been reduced to $1.2
million from $16.3 million due to realized losses.  Classes A-1,
A-2 and X-2 have paid in full.

Fitch withdraws the rating on the interest-only classes X-1.


JP MORGAN: Stable Performance Prompts Fitch to Affirm Ratings
-------------------------------------------------------------
Fitch Ratings has affirmed 11 classes and placed five classes of
J.P. Morgan Chase Commercial Mortgage Securities Corp., series
2003-PM1 (JPMCC 2003-PM1) on Rating Watch Positive.

Fitch affirms the classes, places classes on Rating Watch
Positive, and revises Recovery Ratings (RRs) as indicated:

  -- $299.5 million class A1A at 'AAAsf'; Outlook Stable;
  -- $82.6 million class A-3 at 'AAAsf'; Outlook Stable;
  -- $282 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $33.2 million class B at 'AAAsf'; Outlook Stable;
  -- $13 million class C at 'AAsf'; Rating Watch Positive;
  -- $27.5 million class D at 'BBB-sf'; Rating Watch Positive;
  -- $13 million class E at 'BBsf'; Rating Watch Positive;
  -- $15.9 million class F at 'CCCsf/RR1'; Rating Watch Positive;
  -- $13 million class G at 'CCCsf/RR1'; Rating Watch Positive;
  -- $18.8 million class H at 'Csf/RR2';
  -- $15.9 million class J at 'Csf'; RR to RR4' from 'RR6';
  -- $7.2 million class K at 'Csf/RR6';
  -- $8.7 million class L at 'Csf/RR6';
  -- $7.2 million class M at 'Csf/RR6';
  -- $4.3 million class N at 'Csf/RR6';
  -- $2.9 million class P at 'Csf/RR6'.

The affirmations are due to stable performance of the transaction
since Fitch's most recent formal review.  Classes C through G have
been placed on Rating Watch Positive due to a decrease in losses
from special servicing since Fitch's last formal review.  Fitch
expects to resolve the Watch status upon the resolution of loans
in special servicing which is expected to occur within six months.

As of the July 2011 distribution date, the pool's aggregate
principal balance has reduced by 29.5% to $815.8 million from
$1.16 billion at issuance. In addition, 16 loans (22.5%) have been
fully defeased.

Fitch modeled losses of 7.22% of the remaining pool.  Fitch has
designated 27 loans (22.7%) as Fitch Loans of Concern, which
includes nine specially-serviced loans (10.10%).  Fitch expects
classes K through NR to be fully depleted and class J to be
affected significantly from losses associated with the specially
serviced assets.  Interest shortfalls totaling $6,098,680 are
currently affecting classes G through NR.

The largest contributor to Fitch modeled losses is a specially
serviced loan (6.53%) secured by a 702,427 square foot (sf) mall
located in West Palm Beach FL.  The loan transferred to special
servicing in March 2009 due to imminent default and the property
was foreclosed on in March 2010.  The mall closed in January 2010
and only three tenants with outdoor entrances remain.  Fitch
expects losses upon liquidation of the property based on
valuations obtained by the special servicer.

The second largest contributor to Fitch modeled losses is a
specially loan (1.52%) secured by 127,676 sf of office space
located in Hauppauge, NY.  The loan transferred to special
servicing in September 2009 due to imminent default The servicer-
reported occupancy as of March 2011 is 53% with some tenants on a
month-to-month lease.

The third largest contributor to modeled losses is a loan (2.14%)
secured by a 369 unit apartment complex located in North Las
Vegas.  The loan remains current as of the July remittance report;
however, the property does not generate sufficient cash flow to
meet debt service.  The most recent servicer reported occupancy is
81% as of December 2010 and the debt service coverage ratio has
declined to .80 times for year end 2010.

Class NR, which is not rated by Fitch has been reduced to
$1.52 million from $20.2 million at issuance due to realized
losses.


JPMORGAN: Fitch Downgrades JPMorgan Series 2000-C10 Ratings
-----------------------------------------------------------
Fitch Ratings has downgraded J.P. Morgan Commercial Mortgage
Finance Corp. series 2000-C10 commercial mortgage pass-through
certificates.

The downgrades are the result of realized losses and Fitch
expected losses associated with loans currently in special
servicing. The affirmations of the senior classes are the result
of sufficient credit enhancement to offset Fitch expected losses.
Fitch modeled losses of 23.8% based on Fitch adjustments to recent
property valuations obtained by the special servicer for the
specially serviced properties.

As of the July 2011 distribution date, the pool's certificate
balance has paid down 90.2% to $72.6 million from $738.5 million.
Eight (69.1%) of the remaining 16 loans in the pool have been
designated Fitch Loans of Concern (LOC), of which five (63.6%) are
in special servicing, but only four (59.3%) contribute expected
losses.

The largest contributor to Fitch expected losses, the pool's
second largest specially serviced loan (18.5%), is collateralized
by a 237 room full-service hotel located in Deerfield, IL, a
suburb of Chicago. The loan transferred to special servicing in
October 2009 due to monetary default and a deed-in-lieu of
foreclosure closed in December 2010. Contributing to the default
in 2009, the property suffered from low occupancy and a decrease
in revenue that was insufficient to make debt payments. The
property is currently listed for sale.

The second largest contributor to Fitch expected losses is a loan
(11.3%) collateralized by a 95,089 square foot (sf) grocery
anchored retail center in Flint, MI. The loan transferred to
special servicing in April 2010 due to imminent default. Revenue
at the property declined when the largest tenant (63%), A&P, filed
bankruptcy and vacated the building. The special servicer reports
the borrower is currently trying to lease the space.

The third largest contributor to Fitch expected losses is a loan
(25%) that is secured by a 435,402 sf anchored retail shopping
center in Martinsville, VA. The loan transferred to special
servicing in December 2009 due to imminent default due to
increased operating expenses and declining occupancy. The Special
servicer has filed for foreclosure.

Fitch downgrades these classes:

   -- $10.1 million class F to 'Asf' from 'AAAsf'; Outlook
      Negative.

   -- $14.7 million class G to 'CCsf/RR2' from 'CCCsf/RR1';

   -- $14.7 million class H to 'Dsf' from 'CCsf/RR1'.

Fitch affirms these classes:

   -- $3 million class C at 'AAAsf'; Outlook Stable;

   -- $9.2 million class D at 'AAAsf'; Outlook Stable;

   -- $23 million class E at 'AAAsf'; Outlook Stable.

Fitch does not rate class NR.

Classes A-1, A-2, B, and C have paid in full. Due to realized
losses, classes J, K, L and M have been reduced to zero.

Fitch has withdrawn the rating on interest-only class X.


KATONAH 2007-1: Moody's Upgrades Ratings of Floating Rate Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Katonah 2007-I CLO Ltd.:

US$227,000,000 Class A-1L Floating Rate Notes Due 2022, Upgraded
to Aaa (sf); previously on June 22, 2011 Aa2 (sf) Placed Under
Review for Possible Upgrade;

US$26,000,000 Class A-2L Floating Rate Notes Due 2022, Upgraded to
Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed Under Review
for Possible Upgrade;

US$18,000,000 Class A-3L Floating Rate Notes Due 2022, Upgraded to
A3 (sf); previously on June 22, 2011 Ba1 (sf) Placed Under Review
for Possible Upgrade;

US$11,000,000 Class B-1L Floating Rate Notes Due 2022, Upgraded to
Baa3 (sf); previously on June 22, 2011 B1 (sf) Placed Under Review
for Possible Upgrade;

US$10,500,000 Class B-2L Floating Rate Notes Due 2022, Upgraded to
Ba2 (sf); previously on June 22, 2011 Caa2 (sf) Placed Under
Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in August
2009. Based on the July 2011 trustee report, the weighted average
rating factor is currently 2456 compared to 2827 in July 2009.
Additionally, the Senior Class A, Class A-3L, Class B-1L, and
Class B-2L overcollateralization ratios are reported at 125.22%,
116.90%, 112.34%, and 108.31%, respectively, versus July 2009
levels of 123.59%, 115.38%, 110.88%, and 105.07%, respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $316 million,
defaulted par of $1.4 million, a weighted average default
probability of 21.9% (implying a WARF of 2754), a weighted average
recovery rate upon default of 49.5%, and a diversity score of 62.
The default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Katonah 2007-I CLO Ltd., issued in January 2008, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score. However, as part of the base case,
   Moody's considered spread level higher than the covenant level
   due to the large difference between the reported and covenant
   levels.

3) Exposure to other structured finance products: The deal is
   exposed to a number of CLO tranches in the underlying portfolio
   whose ratings are more volatile on average compared to
   corporate loan ratings.


LANDMARK VI: Moody's Upgrades Ratings of 5 Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Landmark VI CDO Ltd.:

$222,000,000 Class A Senior Secured Floating Rate Notes due 2018
(current balance of $205,682,872), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa3 (sf) Placed under review for
possible upgrade;

$15,000,000 Class B Senior Secured Floating Rate Notes due 2018,
Upgraded to Aa1 (sf); previously on June 22, 2011 Baa1 (sf) Placed
under review for possible upgrade;

$19,000,000 Class C Secured Deferrable Floating Rate Notes due
2018, Upgraded to A1 (sf); previously on June 22, 2011 Ba2 (sf)
Placed under review for possible upgrade;

$15,000,000 Class D Secured Deferrable Floating Rate Notes due
2018 Upgraded to Baa3 (sf); previously on June 22, 2011 Caa2 (sf)
Placed under review for possible upgrade;

$10,000,000 Class E Secured Deferrable Floating Rate Notes due
2018 Upgraded to B1 (sf); previously on June 22, 2011 Ca (sf)
Placed under review for possible upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in June 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2718 compared to 3103 in April 2009. The
improvement in the overcollateralization ratios is a result of
delevering of the Class A Notes, which have paid down by
approximately 4% or $9.5 million since the rating action in June
2009, and lower overcollateralization ratio haircuts from excess
Caa/CCC rated securities. Based on the July 2011 trustee report,
the Class A/B, Class C, Class D, and E overcollateralization
ratios are reported at 124.33%, 114.48%, 107.74%, and 103.67%,
respectively, versus April 2009 levels of 111.46%, 102.93%,
97.04%, and 93.37%, respectively, and all overcollateralization
tests are currently in compliance.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $272.5 million,
defaulted par of $12 million, a weighted average default
probability of 19.82% (implying a WARF of 2858), a weighted
average recovery rate upon default of 48.6%, and a diversity score
of 78. Moody's generally analyzes deals in their reinvestment
period by assuming the worse of reported and covenanted values for
all collateral quality tests. However, in this case given the
limited time remaining in the deal's reinvestment period, Moody's
analysis reflects the benefit of assuming a higher likelihood that
certain collateral pool characteristics will continue to maintain
a positive "cushion" relative to the covenant requirements, as
seen in the actual collateral quality measurements. The default
and recovery properties of the collateral pool are incorporated in
cash flow model analysis where they are subject to stresses as a
function of the target rating of each CLO liability being
reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Landmark CLO VI Ltd., issued in January of 2006, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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


LB-UBS COMMERCIAL: Expected Losses Cue Fitch to Downgrade Ratings
-----------------------------------------------------------------
Fitch Ratings has downgraded three classes and upgraded two
classes of LB-UBS Commercial Mortgage, series 2002-C4, commercial
mortgage pass-through certificates.

Fitch has downgraded these classes:

  -- $7.2 million class N to 'B-sf' from 'B+sf; Outlook Negative;
  -- $3.6 million class Q to 'Csf/RR4' from 'CCCsf/RR1';
  -- $1.8 million class S to 'Csf/RR6' from 'CCsf/RR3'.

Fitch has upgraded these classes:

  -- $12.7 million class J to 'AAsf' from 'AA-sf'; Outlook Stable;
  -- $12.7 million class K to 'Asf' from 'A-sf'; Outlook Stable.

Fitch has affirmed these classes:

  -- $12.7 million class A-3 at 'AAAsf; Outlook Stable;
  -- $21.3 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $850.5 million class A-5 at 'AAAsf; Outlook Stable;
  -- $18.2 million class B at 'AAAsf'; Outlook Stable;
  -- $20 million class C at 'AAAsf; Outlook Stable;
  -- $20 million class D at 'AAAsf; Outlook Stable;
  -- $12.7 million class E at 'AAAsf'; Outlook Stable;
  -- $16.3 million class F at 'AAAsf; Outlook Stable;
  -- $10.9 million class G at 'AAAsf'; Outlook Stable;
  -- $12.7 million class H at 'AAAsf; Outlook Stable;
  -- $20 million class L at 'BBB-sf'; Outlook to Negative from
     Stable.
  -- $7.2 million class M at 'BBsf; Outlook Negative;
  -- $3.6 million class T at 'Csf/RR6'.

The downgrades are the result of Fitch expected losses associated
with specially serviced loans that Fitch expects to be liquidated.
The upgrades of the senior classes are the result of sufficient
credit enhancement to offset Fitch expected losses. Fitch modeled
losses of 2.3% of the remaining pool.

Fitch has designated 18 loans (7.5%) as Fitch Loans of Concern,
which includes seven specially serviced loans (4.0%).  Fitch
expects losses associated with the specially serviced assets to
deplete classes S through U and impair class Q.

As of the July 2011 distribution date, the pool's aggregate
principal balance has been paid down by approximately 25.9% to
$1.08 billion from $1.46 billion at issuance.  Interest shortfalls
are affecting classes N through U with cumulative unpaid interest
totaling $1.8 million.  Of the 82 remaining loans in the pool, 23
are defeased (40.8%) including ten of the top 15 loans (33.1%).

The largest contributor Fitch modeled losses is a 171,103 square
foot (sf) class B office building located in Norwalk, CT.  The
property became a real estate owned asset (REO) in December 2010
and recent property valuations obtained by the special servicer
indicated losses upon liquidation.

The second largest contributor to Fitch modeled losses is a
298,179 sf industrial property located in Kansas City, KS.  Loan
transferred to Special Servicing in March 2011 due to monetary
default.  The property's largest tenant occupying 34% vacated when
its lease expired in June 2010. Special servicer is proceeding
with foreclosure.

The third largest contributor Fitch modeled losses is a 75,195 sf
strip mall in Madeira, OH.  Loan transferred to the Special
Servicer in October 2010 due to imminent default.  The property's
largest tenant vacated in first quarter 2009 resulting in below
1.0 times (x) debt servicer coverage ratio (DSCR).  The property
is currently 38% vacant and the special servicer is pursuing
foreclosure.

Fitch does not rate the $7.3 million class P and the $1.3 million
class U. Classes A-1 and A-2 have paid in full.

Fitch has withdrawn the rating of the interest only classes X-CL,
X-CP and X-VF. (For additional information, see 'Fitch Revises
Practice for Rating IO & Pre-Payment Related Structured Finance
Securities', dated June 23, 2010.)


LB-UBS COMMERCIAL: Moody's Affirms Ratings of 13 CMBS Classes
-------------------------------------------------------------
Moody's Investors Service (Moody's) downgraded the ratings of
three classes, placed two classes on review for possible
downgrade, and affirmed 13 classes of LB-UBS Commercial Mortgage
Trust Series 2004-C1:

Cl. A-3, Affirmed at Aaa (sf); previously on Feb 20, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Feb 20, 2004
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Nov 21, 2006 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Nov 21, 2006 Upgraded
to Aaa (sf)

Cl. E, Affirmed at Aa3 (sf); previously on Nov 21, 2006 Upgraded
to Aa3 (sf)

Cl. D, Affirmed at Aa1 (sf); previously on Nov 21, 2006 Upgraded
to Aa1 (sf)

Cl. F, Affirmed at A1 (sf); previously on Nov 21, 2006 Upgraded to
A1 (sf)

Cl. G, Affirmed at A3 (sf); previously on Feb 20, 2004 Definitive
Rating Assigned A3 (sf)

Cl. H, Downgraded to Ba1 (sf) and Placed Under Review for Possible
Downgrade; previously on Nov 18, 2010 Downgraded to Baa2 (sf)

Cl. J, Downgraded to B1 (sf) and Placed Under Review for Possible
Downgrade; previously on Nov 18, 2010 Downgraded to Ba2 (sf)

Cl. K, Downgraded to Caa3 (sf); previously on Nov 18, 2010
Downgraded to Caa1 (sf)

Cl. L, Affirmed at Ca (sf); previously on Nov 18, 2010 Downgraded
to Ca (sf)

Cl. M, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (sf)

Cl. X-CL, Affirmed at Aaa (sf); previously on Feb 20, 2004
Definitive Rating Assigned Aaa (sf)

Cl. X-ST, Affirmed at Aaa (sf); previously on Feb 20, 2004
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The downgrades are due to higher expected losses for the pool
resulting from realized and anticipated losses from specially
serviced and troubled loans, interest shortfalls and concerns
about refinance risk associated with loans approaching maturity.
Sixty-nine loans, representing 70% of the pool, mature within the
next 36 months. Eighteen of these loans, representing 13% of the
pool, have a Moody's stressed debt service coverage ratio (DSCR)
below 1.00X. Two of the downgraded classes are placed on review
for possible downgrade because of concerns relative to potential
increased interest shortfalls due to loan modifications.

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

Moody's rating action reflects a cumulative base expected loss of
4.7% of the current balance. At last review, Moody's cumulative
base expected loss was 4.3%. Moody's stressed scenario loss is
7.0% of the current balance. Moody's provides a current list of
base and stress scenario losses for conduit and fusion CMBS
transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011. The
hotel and multifamily sectors are continuing to show signs of
recovery, while recovery in the office and retail sectors will be
tied to recovery of the broader economy. The availability of debt
capital continues to improve with terms returning toward market
norms. Moody's central global macroeconomic scenario reflects an
overall sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

The primary methodology used in this rating was "Moody's Approach
to Rating Fusion U.S. CMBS Transactions", published in April 2005.
The other methodology used in this rating was "CMBS: Moody's
Approach to Rating Large Loan/Single Borrower Transactions",
published in July 2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 10 compared to 11 at Moody's prior full review.

In cases where the Herf falls below 20, Moody's also employs the
large loan/single borrower methodology. This methodology uses the
excel-based Large Loan Model v 8.0 and then reconciles and weights
the results from the two models in formulating a rating
recommendation. The large loan model derives credit enhancement
levels based on an aggregation of adjusted loan level proceeds
derived from Moody's loan level LTV ratios. Major adjustments to
determining proceeds include leverage, loan structure, property
type, and sponsorship. These aggregated proceeds are then further
adjusted for any pooling benefits associated with loan level
diversity, other concentrations and correlations.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated November 18, 2010. Please see
the ratings tab on the issuer / entity page on moodys.com for the
last rating action and the ratings history.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 29% to $1.0 billion
from $1.4 billion at securitization. The Certificates are
collateralized by 82 mortgage loans ranging in size from less than
1% to 20% of the pool, with the top ten loans representing 64% of
the pool. The pool contains four loans with investment grade
credit estimates that represent 50% of the pool. Seven loans,
representing 6% of the pool, have defeased and are collateralized
with U.S. Government securities.

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

Eight loans have been liquidated from the pool, resulting in an
aggregate realized loss of $12.0 million (38% loss severity
overall). Currently 4 loans, representing 7% of the pool, are in
special servicing. The largest specially serviced loan is the
Passaic Street Industrial Park Loan ($37.2 million -- 3.7% of the
pool), which is secured by 2.2 million square foot (SF) Class C
industrial warehouse space located in Woodridge, New Jersey. The
loan was transferred to special servicing in March 2010 due to
monetary default and is currently dual tracking foreclosure/loan
modification. The remaining three specially serviced loans are
secured by a mix of office and industrial warehouse property
types. The master servicer has recognized an aggregate $38.5
million appraisal reduction for four of the specially serviced
loans. Moody's has estimated an aggregate $39.9 million loss (59%
expected loss on average) for the specially serviced loans.

As of the most recent remittance date, the pool has experienced
cumulative interest shortfalls totaling $1.6 million and affecting
Classes T through J. Moody's anticipates that the pool will
continue to experience interest shortfalls caused by specially
serviced loans. Interest shortfalls are caused by special
servicing fees, including workout and liquidation fees, appraisal
subordinate entitlement reductions (ASERs), extraordinary trust
expenses and non-advancing by the master servicer based on a
determination of non-recoverability. Moody's placed two classes on
review for possible downgrade because of concerns that interest
shortfalls may increase if any specially serviced loans are
modified.

Moody's was provided with full and partial year 2010 and partial
year 2011 operating results for 84% and 39% of the pool's non-
defeased loans, respectively. Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 83%, essentially
the same at Moody's prior review. Moody's net cash flow reflects a
weighted average haircut of 12% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 9.4%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.43X and 1.28X, respectively, compared to
1.45X and 1.27X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The largest loan with a credit estimate is the GIC Office
Portfolio Loan ($193.8 million -- 19.1%), which is a pari-passu
interest in a $678.3 million first mortgage loan. The loan is
secured by a portfolio of 12 office properties located in seven
states and totalling 6.4 million SF. The largest geographic
concentrations are Illinois (39%), Pennsylvania (17%) and
California (12%). The portfolio was 87% leased as of December 2010
compared to 90% as of December 2009. Property performance has
declined due to decreased rental income. The property is also
encumbered by a $121.1 million B Note. The loan had a 60-month
interest only period and is amortizing on a 360-month schedule
maturing in January 2014. Moody's current credit estimate and
stressed DSCR are Baa3 and 1.43X, respectively, compared to Baa3
and 1.45X at Moody's last review.

The second largest loan with a credit estimate is the UBS Center -
- Stamford Loan ($190.0 million -- 18.7%), which is secured by the
leasehold interest in a 682,000 SF Class A office property located
in Stamford, Connecticut. The property is 100% leased to UBS AG
and serves as the U.S. headquarters of UBS Investment Bank. The
lease is triple net and expires in December 2017. The loan is
structured with a 23.75 year amortization schedule and matures in
October 2016. Moody's current credit estimate is A3, the same as
at Moody's last review.

The third largest loan with a credit estimate is the MGM Tower
Loan ($113.4 million -- 11.2%), which is secured by a 777,000 SF
Class A office building located in the Century City office
submarket of Los Angeles, California. As of March 2011, the
property was 84% leased compared to 98% as of June 2010. The
largest tenants are MGM (34% of the NRA; lease expiration May
2018) and International Lease Finance Corporation (19% of the NRA;
lease expiration August 2015). The loan is on the master
servicer's watchlist because MGM recently filed for bankruptcy
protection. Three leases, totaling 104,000 SF (13% of the NRA)
have recently been signed, bringing the total space leased to 97%.
The property is also encumbered by a $78.4 million B Note.
Property performance remains stable and the loan is benefitting
from amortization. Moody's current credit estimate and stressed
DSCR are Aa1 and 2.70X, respectively, compared to Aa1 and 2.62X at
Moody's last review.

The remaining loan with a credit estimate is the is the Southgate
Mall Loan ($6.9 million -- 0.7%), which is secured by a 473,000 SF
regional mall located in Missoula, Montana. The mall is anchored
by Dillard's, Sears and J.C. Penney. The loan fully amortizes over
a 240-month period and has paid down 52% since securitization.
Moody's current credit estimate is Aaa, the same as at Moody's
last review.

The top three performing conduit loans represent 6% of the pool
balance. The largest conduit loan is the Kurtell Medical Office
Portfolio Loan ($26.9 million -- 2.7%), which is secured by five
medical office buildings and one out-patient surgical center
located in Nashville, Tennessee (5) and Orlando, Florida. The
portfolio has a total of 212,000 SF. Moody's LTV and stressed DSCR
are 81% and 1.34X, respectively, essentially the same as at
Moody's last review.

The second largest loan is The Fountains Loan ($19.7 million --
1.9%), which is secured by a 130,200 SF grocery-anchored retail
center located in Overland Park, Kansas. As of December 2010, the
property was 94% leased compared to 89% as of December 2009.
Performance has declined since Moody's last review due to a
decline in effective gross income. Moody's LTV and stressed DSCR
are 102% and 1.10X, respectively, compared to 88% and 1.10X at
last full review.

The third largest loan is the Green River Loan ($18.4 million --
1.8% of the pool), which is secured by a 333-unit mobile home park
located in Corona, California. The park was 90% leased as of March
2011 compared to 94% as of June 2010. Performance is stable and
the loan is benefitting from amortization. Moody's LTV and
stressed DSCR are 67% and 1.38X, respectively, essentially the
same as at Moody's last review.


LB-UBS COMMERCIAL: Moody's Affirms Ratings of 19 CMBS Classes
-------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 19
classes of LB-UBS Commercial Mortgage Trust, Commercial Mortgage
Pass Through Certificates, Series 2007-C6:

Cl. A-2, Affirmed at Aaa (sf); previously on Sep 11, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Sep 11, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Sep 11, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on May 26, 2010
Confirmed at Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on May 26, 2010
Confirmed at Aaa (sf)

Cl. A-M, Affirmed at A1 (sf); previously on Oct 28, 2010
Downgraded to A1 (sf)

Cl. A-J, Affirmed at Ba1 (sf); previously on Oct 28, 2010
Downgraded to Ba1 (sf)

Cl. B, Affirmed at B1 (sf); previously on Oct 28, 2010 Downgraded
to B1 (sf)

Cl. C, Affirmed at Caa1 (sf); previously on Oct 28, 2010
Downgraded to Caa1 (sf)

Cl. D, Affirmed at Caa3 (sf); previously on Oct 28, 2010
Downgraded to Caa3 (sf)

Cl. E, Affirmed at Ca (sf); previously on Oct 28, 2010 Downgraded
to Ca (sf)

Cl. F, Affirmed at Ca (sf); previously on Oct 28, 2010 Downgraded
to Ca (sf)

Cl. X, Affirmed at Aaa (sf); previously on Sep 11, 2007 Definitive
Rating Assigned Aaa (sf)

Cl. A-2FL, Affirmed at Aaa (sf); previously on Sep 11, 2007
Assigned Aaa (sf)

Cl. A-MFL, Affirmed at A1 (sf); previously on Oct 28, 2010
Downgraded to A1 (sf)

Cl. G, Affirmed at C (sf); previously on Oct 28, 2010 Downgraded
to C (sf)

Cl. H, Affirmed at C (sf); previously on May 26, 2010 Downgraded
to C (sf)

Cl. J, Affirmed at C (sf); previously on May 26, 2010 Downgraded
to C (sf)

Cl. K, Affirmed at C (sf); previously on May 26, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
11.1% of the current balance. At last review, Moody's cumulative
base expected loss was 12.0%. The decline in Moody's cumulative
base expected loss is largely due to lower expected losses for the
Innkeepers Portfolio Loan ($412.7 million -- 14.0% pre-
modification share of the pool). Although the recently agreed to
terms of the Innkeepers Portfolio Loan modification indicate
losses on the loan will be lower than Moody's previously
anticipated, there is uncertainty surrounding the method of
recovery of $19.8 million of outstanding servicer advances which
could result in higher losses than currently estimated. Moody's
stressed scenario loss is 31.9% of the current balance. Moody's
provides a current list of base and stress scenario losses for
conduit and fusion CMBS transactions on moodys.com at
http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255.
Depending on the timing of loan payoffs and the severity and
timing of losses from specially serviced loans, the credit
enhancement level for investment grade classes could decline below
the current levels. If future performance materially declines, the
expected level of credit enhancement and the priority in the cash
flow waterfall may be insufficient for the current ratings of
these classes.

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011 The hotel
and multifamily sectors are continuing to show signs of recovery,
while recovery in the office and retail sectors will be tied to
recovery of the broader economy. The availability of debt capital
continues to improve with terms returning toward market norms.
Moody's central global macroeconomic scenario reflects an overall
sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

The primarymethodology used in this rating was: "CMBS: Moody's
Approach to Rating Conduit Transactions" published on September
2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
credit estimate of the loan which corresponds to a range of credit
enhancement levels. Actual fusion credit enhancement levels are
selected based on loan level diversity, pool leverage and other
concentrations and correlations within the pool. Negative pooling,
or adding credit enhancement at the credit estimate level, is
incorporated for loans with similar credit estimates in the same
transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 20, the same as at prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated October 28, 2010.

DEAL PERFORMANCE

As of the July 11, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 11% to
$2.95 billion from $2.98 billion at securitization. The
Certificates are collateralized by 180 mortgage loans ranging
in size from less than 1% to 14% of the pool, with the top ten
loans representing 58% of the pool. The pool does not contain any
defeased loans or loans with investment grade credit estimates.

Forty-four loans, representing 33% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Two loans has been liquidated from the pool, resulting in a
realized loss of $4.7 million. Currently fifteen loans,
representing 18% of the pool, are in special servicing. The
largest specially serviced loan is the Innkeepers Portfolio Loan
($412.7 million -- 14.0% pre-modification share of the pool),
which represents a 50% pari passu interest in an $825.4 million A-
Note. The loan is secured by a portfolio of 45 extended stay and
limited service hotels located in sixteen states with a total of
5,683 rooms. The loan transferred to special servicing in April
2010 and the sponsor subsequently filed for bankruptcy in July
2010. An investor syndicate consisting of Chatham Lodging Trust
and Cerberus teamed up to submit the winning bid on the portfolio,
which was approved in bankruptcy court in June 2011. The sale and
assumption agreement also included a modification of the loan with
a principal write down of $42.5 million on the 50% pari passu
interest in the A-Note secured in the trust. Outstanding advances
on the interest in the loan currently total $19.8 million. The
master servicer indicated the method of recoupment of the
outstanding advances has not yet been determined. The modification
of the loan may impact the trust as early as the September 2011
payment period.

The remaining fourteen specially serviced properties are secured
by a mix of property types. Moody's estimates an aggregate $111.7
million loss for the specially serviced loans (21% expected loss
on average).

Moody's has assumed a high default probability for 17 poorly
performing loans representing 21% of the pool and has estimated an
aggregate $155.9 million loss (21% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 84%
of the pool's non-specially serviced loans. Excluding specially
serviced and troubled loans, Moody's weighted average LTV is 109%,
compared to 112% at last review. Moody's net cash flow reflects a
weighted average haircut of 13% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 9.0%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.29X and 0.91X, compared to 1.25X and 0.85X at
last review. Moody's actual DSCR is based on Moody's net cash flow
(NCF) and the loan's actual debt service. Moody's stressed DSCR is
based on Moody's NCF and a 9.25% stressed rate applied to the loan
balance.

The three largest loans represent 24% of the pool. The largest
loan is the PECO Portfolio Loan ($323.9 million -- 11% of the
pool), which is consists of 39 cross-collateralized and cross-
default loans secured by 39 retail properties totaling 4.3 million
SF located in 13 states. The collateral has a high value
diversity, as no property accounted for more than 7% of Moody's
total portfolio at origination. The loan has been interest-only
since securitization but will start amortizing on a 420 month
schedule in July 2013. Performance of the portfolio has been
stable. Moody's LTV and stressed DSCR are 117% and 0.84X,
respectively, compared to 114% and 0.86X at last review.

The second largest loan is the Potomac Mills Loan ($246.0 million
-- 8.3% of the pool), which represents a 60% pari-passu interest
in a $410 million first mortgage loan. The loan is secured by a
1.5 million square foot retail center in Woodbridge, Virginia.
Anchor tenants include Costco (9.9% of the NRA; lease expiration -
- May 2032) and JC Penney (6.7% of the NRA; lease expiration --
December 2021). The property has strong sponsorship from Simon
Property Group. The property was 91% occupied in December 2010.
Performance has been stable. Moody's LTV and stressed DSCR are
119% and 0.77X, respectively, the same as at last review.

The third largest loan is the One Sansome Street Loan
($139.6 million -- 4.7% of the pool), which is secured by a
Class A office building located in the financial district of San
Francisco, California. The property was acquired by Prudential in
April 2010 via a mezzanine takeover. The new sponsor is currently
renovating the property. Occupancy declined from 80% in 2009 to
66% in March 2011, however, Moody's analysis incorporated upside
in occupancy to reflect market vacancy rates and the benefit of
the ongoing renovations upon completion. Moody's LTV and stressed
DSCR are 116% and 0.80X, respectively, compared to 0.77X at last
review.


LCM II: Moody's Upgrades Ratings of Six Classes of CLO Notes
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by LCM II:

US$10,750,000 Class B Floating Rate Senior Secured Notes due 2016,
Upgraded to Aaa (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

US$13,500,000 Class C Floating Rate Deferrable Interest Notes due
2016, Upgraded to Aa3 (sf); previously on June 22, 2011 Baa2(sf)
Placed Under Review for Possible Upgrade;

US$21,000,000 Class D Floating Rate Deferrable Interest Notes due
2016, Upgraded to Baa3 (sf); previously on June 22, 2011 Ba3 (sf)
Placed Under Review for Possible Upgrade;

US$4,800,000 Class E-1 Floating Rate Deferrable Interest Notes due
2016 (current outstanding balance of $2,124,691), Upgraded to Ba1
(sf); previously on June 22, 2011 Caa2 (sf) Placed Under Review
for Possible Upgrade;

US$4,200,000 Class E-2 Fixed Rate Deferrable Interest Notes due
2016 (current outstanding balance of $1,859,105), Upgraded to Ba1
(sf); previously on June 22, 2011 Caa2 (sf) Placed Under Review
for Possible Upgrade;

US$5,000,000 Series I Combination Securities due 2016 (current
outstanding Rated Balance of $244,937), Upgraded to Aa2 (sf);
previously on June 22, 2011 B1(sf) Placed Under Review for
Possible Upgrade.

In addition Moody's has withdrawn the ratings on these notes:

US$6,820,000 Series III Combination Securities due 2016 (current
outstanding Rated Balance of $10,000), Rating Withdrawn;
previously on August 2, 2011 Confirmed at Aaa (sf);

US$5,205,000 Series IV Combination Securities due 2016 (current
outstanding Rated Balance of $10,000), Rating Withdrawn;
previously on August 2, 2011 Confirmed at Aaa (sf).

According to Moody's, the ratings on the Series III and Series IV
Combination Securities were withdrawn because all of the Treasury
strips that support the notes have been sold.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of deleveraging of the
senior notes since the rating action in July 2009. Moody's notes
that the Class A Notes have been paid down by approximately 36% or
$98.5 million since the rating action in July 2009. In addition,
excess interest proceeds have reduced the Class outstanding
balance of the Class E1 Notes and Class E2 Notes by $1.4 million
and $1.2 million, respectively. As a result of the deleveraging,
the overcollateralization ratios have increased. Based on the
latest trustee report dated July 14, 2010, the Class A/B, Class C,
Class D and Class E overcollateralization ratios are reported at
125.30%, 118.70%, 109.71% and 108.05%, respectively, versus May
2009 levels of 119.63%, 114.27%, 106.82% and 104.67%,
respectively. Moody's notes that these reported
overcollateralization ratios do not reflect the impact of the
recent pay down of the Class A Notes, Class E1 Notes and Class E2
Notes which were reduced by $53.52 million, $0.15 million and
$0.13 million, respectively, on the July 22, 2011 payment date.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes. Based on the July 2011 trustee report,
reference securities that mature after the maturity date of the
notes currently make up approximately 14% of the underlying
reference portfolio. These investments potentially expose the
notes to market risk in the event of liquidation at the time of
the notes' maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $250 million,
defaulted par of $0 million, a weighted average default
probability of 14.44% (implying a WARF of 2440), a weighted
average recovery rate upon default of 51.56%, and a diversity
score of 48. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

LCM II, issued in November 2004, is a collateralized loan
obligation backed primarily by a portfolio of senior secured
loans.

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

Other methodology used in this rating was "Using the Structured
Note Methodology to Rate CDO Combo-Notes" published in February
2004.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

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


LIGHTPOINT CLO: Moody's Upgrades Ratings of 5 Classes of Notes
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Lightpoint CLO IV, Ltd.

US$100,000,000 Class A-1 Senior Secured Floating Rate Notes Due
2018, Upgraded to Aa1 (sf); previously on June 22, 2011 A1 (sf)
Placed Under Review for Possible Upgrade;

US$ 210,800,000 Class A-2A Senior Secured Floating Rate Notes Due
2018, Upgraded to Aaa (sf); previously on June 22, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade;

US$ 12,950,000 Class A-2B Senior Secured Floating Rate Notes Due
2018, Upgraded to Aa2 (sf); previously on June 22, 2011 A3 (sf)
Placed Under Review for Possible Upgrade;

US$ 12,540,000 Class B Senior Secured Deferrable Rate Notes Due
2018, Upgraded to A1 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$ 26,250,000 Class C Secured Floating Rate Notes Due 2018,
Upgraded to Baa3 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in the publication "Moody's Approach to Rating
Collateralized Loan Obligations" published in June 2011. The
primary changes to the modeling assumptions include (1) a removal
of the temporary 30% default probability macro stress implemented
in February 2009 as well as (2) increased BET liability stress
factors and increased recovery rate assumptions.

The actions also reflect consideration of and an increase in the
transaction's overcollateralization ratios and credit improvement
of the underlying portfolio since the rating action in August
2009. The overcollateralization ratios of the rated notes have
increased due to a decrease in defaulted securities and securities
rated Caa1 and below. Based on the latest trustee report dated
June 30, 2011, the senior overcollateralization ratio is reported
at 121.5%, versus the July 2009 level of 116.4%, and the weighted
average rating factor is currently 2569 compared to 2737 in July
2009.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $355 million, a
weighted average default probability of 19.5% (implying a WARF of
2884), a weighted average recovery rate upon default of 49.5%, and
a diversity score of 65. These default and recovery properties of
the collateral pool are incorporated in cash flow model analysis
where they are subject to stresses as a function of the target
rating of each CLO liability being reviewed. The default
probability is derived from the credit quality of the collateral
pool and Moody's expectation of the remaining life of the
collateral pool. The average recovery rate to be realized on
future defaults is based primarily on the seniority of the assets
in the collateral pool. In each case, historical and market
performance trends and collateral manager latitude for trading the
collateral are also factors.

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

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2. Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

3. Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average spread, weighted average
   coupon, and diversity score. However, as part of the base case,
   Moody's considered spread levels higher than the covenant
   levels due to the large difference between the reported and
   covenant levels.


MARKET SQUARE: Moody's Upgrades Ratings of Four Classes of Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Market Square CLO Ltd.:

US$232,500,000 Class A Senior Secured Floating Rate Notes Due 2017
(current outstanding balance of $152,764,421), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$27,000,000 Class B Second Priority Deferrable Floating Rate
Notes Due 2017, Upgraded to A1 (sf); previously on June 22, 2011
Baa2 (sf) Placed Under Review for Possible Upgrade;

US$8,250,000 Class C Third Priority Deferrable Floating Rate Notes
Due 2017, Upgraded to Baa2 (sf); previously on June 22, 2011 Ba3
(sf) Placed Under Review for Possible Upgrade;

US$8,250,000 Class D Fourth Priority Deferrable Floating Rate
Notes Due 2017, Upgraded to B1 (sf); previously on June 22, 2011
Caa2 (sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios due to delevering of
the senior notes since the rating action in April 2011. Moody's
notes that the Class A Notes have been paid down by approximately
$36.4 million since the rating action in April 2011. As a result
of the delevering, the overcollateralization ratios have
increased. Based on the note valuation report dated July 20, 2011,
Moody's calculated the Class A, Class B, Class C, and Class D
overcollateralization ratios to be 135.20%, 114.90%, 109.85%, and
105.24% respectively, versus reported April 2011 levels of
127.59%, 111.76%, 107.68%, and 103.84% respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par balance, including principal proceeds, of $205
million, defaulted par of $5.3 million, a weighted average default
probability of 14.7% (implying a WARF of 2411), a weighted average
recovery rate upon default of 48.0%, and a diversity score of 68.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends, and collateral manager
latitude for trading the collateral are also factors.

Market Square CLO Ltd., issued in April 2005, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations", published in
June 2011. Please see the Credit Policy page on www.moodys.com for
a copy of this methodology.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2016 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the managers'
investment strategies and behavior and 2) divergence in legal
interpretation of CLO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

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


MORGAN STANLEY: Fitch Takes Action on MSCI 2004-Top13 Ratings
-------------------------------------------------------------
Fitch Ratings takes several rating actions on 17 classes of Morgan
Stanley Capital I Trust commercial mortgage pass-through
certificates, series 2004-TOP13.

Fitch downgrades these classes:

   -- $24.2 million class D to 'AAsf' from 'AAAsf'; Outlook
      Stable;

   -- $12.1 million class E to 'Asf' from 'AA+sf'; Outlook Stable;

   -- $9.1 million class F to 'BBBsf' from 'AAsf'; Outlook Stable;

   -- $10.6 million class G to 'BBsf' from 'A-sf'; Outlook Stable;

   -- $9.1 million class H to 'BBsf' from 'BBB+sf'; Outlook
      Stable;

   -- $9.1 million class J to 'Bsf' from 'BBBsf'; Outlook Stable;

   -- $3 million class K to 'CCCsf/RR1' from 'BB+sf';

   -- $3 million class L to 'CCCsf/RR1' from 'BBsf';

   -- $3 million class M to 'CCCsf/RR1' from 'BB-sf'

   -- $4.5 million class N to 'CCCsf/RR1' from 'Bsf';

   -- $3 million class O to 'CCCsf/RR1' from 'B-sf'.

Fitch affirms these classes:

   -- $70.4 million class A-3 at 'AAAsf'; Outlook Stable;

   -- $589.2 million class A-4 at 'AAAsf'; Outlook Stable;

   -- $31.8 million class B at 'AAAsf'; Outlook Stable;

   -- $12.1 million class C at 'AAAsf'; Outlook Stable;

The ratings on classes X-1 and X-2 are being withdrawn in
accordance with Fitch's criteria.

Classes A-1 and A-2 have paid in full. Fitch does not rate class
P.

Fitch expects losses of approximately 3.7% of the remaining pool
balance, approximately $30.3 million, from the loans in special
servicing and the loans that are not expected to refinance at
maturity or default during the term.

As of the July 2011 distribution date, the pool's collateral
balance has paid down 33.5% to $805.6 million from $1.21 billion
at issuance. Twelve of the remaining loans have defeased (9.1%),
and as of July 2011, there are four specially serviced loans
(9.2%).

The largest specially serviced loan (8.1%) is the second largest
loan in the transaction and is secured by a 1.4 million square
foot (sf) Class A office building located in downtown Los Angeles,
CA. The loan transferred to special servicing in June 2011 when
the borrower requested an extension of the loan, which was denied.
The loan matures in 2013. The loan had been on the watchlist since
April 2010 due to occupancy declines. The loan remains current.
Fitch does not expect losses on the loan.

The second largest specially serviced loan (0.6%) is secured by a
151,000 sf retail property built in 1990 located in Lincoln, IL.
The loan transferred to special servicing in October 2010 due to
the loss of a major anchor tenant (65% NRA), following their lease
expiration. Recent valuations indicate a loss on this loan.

The third largest specially serviced loan (0.37%) is 90+ days past
due and is secured by a 47,000 sf retail property built in 1995
located in Oshkosh, WI. The asset is scheduled for an online note
auction scheduled to occur in September 2011. Recent values
indicate a loss on this loan.

The fourth largest specially serviced loan (0.2%) is 90+ days past
due and secured by an 80 unit multifamily property located in
Pensacola, FL built in 1980. The loan was cross-collateralized and
cross-defaulted with a sixty-eight unit multifamily property
located in Bay Minette, AL that liquidated with a loss in June
2011. The loans transferred to special servicing in February 2010
due to monetary default. The remaining property is scheduled for
online note auction in August 2011. Recent values indicate an
expected loss for this property.


MORGAN STANLEY: Fitch Takes Various Rating Actions
--------------------------------------------------
Fitch Takes Various Actions on Morgan Stanley Capital I Trust
2004-IQ8
Fitch Ratings-New York-04 August 2011:

Fitch Ratings has downgraded nine classes and affirmed six classes
of Morgan Stanley Capital I Trust commercial mortgage pass-through
certificates, series 2004-IQ8.

The downgrades reflect Fitch expected losses, most of which are
associated with the specially serviced loans. Fitch modeled losses
of 4.83% of the remaining pool; expected losses based on the
original pool size are 3.66%, which reflect losses already
incurred. Fitch designated 23 loans (31.03%) as Fitch Loans of
Concern, including six specially serviced loans (6.81%). Fitch
expects class O will be partially depleted from losses from loans
currently in special servicing.

As of the July 2011 distribution date, the pool's aggregate
principal balance has reduced by 24.27% to $575 million from $759
million at issuance. Interest shortfalls are affecting classes K
through O. Four loans (6.6%) have defeased since issuance.

The largest contributor to Fitch expected losses is secured by an
11-building medical and office park located in Las Vegas, NV. The
loan (3.2% of the outstanding pool) transferred to special
servicing in August 2009. An assumption with a principal writedown
recently closed.

The next largest contributor to Fitch expected losses is a secured
by a 19,540 sf strip retail center (0.6% of the outstanding pool),
located in Las Vegas, NV. The loan transferred to special
servicing in October 2009 due to imminent default. Receivership
was appointed in May 2010 and a sale, approved in May 2011, is in
the process of closing.

Fitch downgrades these classes and revises Rating Outlooks and
Recovery Ratings:

   -- $7.6 million class D to 'BBB-sf' from 'A-sf'; Outlook to
      Stable from Negative;

   -- $8.5 million class E to 'BBsf' from 'BBBsf'; Outlook to
      Stable from Negative;

   -- $4.7 million class F to 'Bsf' from 'BBsf'; Outlook to Stable
      from Negative;

   -- $6.6 million class G to 'B-sf' from 'BBsf'; Outlook to
      Stable from Negative;

   -- $5.7 million class H to 'CCCsf/RR1' from 'B-sf';

   -- $2.8 million class J to 'CCCsf/RR1' from 'B-sf';

   -- $3.8 million class K to 'CCsf/RR1' from 'B-sf';

   -- $2.8 million class L to 'Csf/RR1' from 'CCCsf/RR6';

   -- $0.9 million class M to 'Csf/RR1' from 'CCsf/RR6';

Fitch also affirms these classes and revises Recovery Ratings and
Outlooks:

   -- $7.2 million class A-3 at 'AAAsf'; Outlook Stable;

   -- $123.5 million class A-4 at 'AAAsf'; Outlook Stable;

   -- $354.1 million class A-5 at 'AAAsf'; Outlook Stable;

   -- $19 million class B at 'AAsf'; Outlook Stable;

   -- $21.8 million class C at 'Asf'; Outlook to Stable from
      Negative;

   -- $0.9 million class N to 'Csf/RR1' from 'Csf/RR6'; Outlook
      Stable.

Fitch does not rate the $4.8 million class O. Class A-1 and A-2
have paid in full.

Fitch withdraws the rating on the interest-only classes X-1 and X-
2.


MORGAN STANLEY: Moody's Downgrades Ratings of 3 CRE CDO Classes
---------------------------------------------------------------
Moody's has downgraded three and affirmed fifteen classes of
Certificates issued by Morgan Stanley Capital I Inc. 2005-RR6 ,
Ltd. due to the deterioration in the credit quality of the
underlying portfolio as evidenced by increase in the weighted
average rating factor (WARF), and decrease in the weighted average
recovery rate (WARR). The affirmations are a result of the key
transaction parameters performing within levels commensurate with
the existing ratings levels. The rating action is the result of
Moody's on-going surveillance of commercial real estate
collateralized debt obligation (CRE CDO) transactions.

Cl. A-2FX, Affirmed at Aaa (sf); previously on Jan 30, 2009
Confirmed at Aaa (sf)

Cl. A-2FL, Affirmed at Aaa (sf); previously on Jan 30, 2009
Confirmed at Aaa (sf)

Cl. A-3FX, Downgraded to Aa1 (sf); previously on Jan 30, 2009
Confirmed at Aaa (sf)

Cl. A-3FL, Downgraded to Aa1 (sf); previously on Jan 30, 2009
Confirmed at Aaa (sf)

Cl. A-J, Downgraded to B3 (sf); previously on Oct 7, 2010
Downgraded to Ba3 (sf)

Cl. B, Affirmed at Caa3 (sf); previously on Oct 7, 2010 Downgraded
to Caa3 (sf)

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

Cl. D, Affirmed at Ca (sf); previously on Oct 7, 2010 Downgraded
to Ca (sf)

Cl. E, Affirmed at Ca (sf); previously on Oct 7, 2010 Downgraded
to Ca (sf)

Cl. F, Affirmed at Ca (sf); previously on Oct 7, 2010 Downgraded
to Ca (sf)

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

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

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

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

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

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

Cl. N, Affirmed at C (sf); previously on Jan 30, 2009 Downgraded
to C (sf)

Cl. X, Affirmed at Aaa (sf); previously on Jan 30, 2009 Confirmed
at Aaa (sf)

RATINGS RATIONALE

Morgan Stanley Capital I Inc. 2005-RR6 is a static cash CRE CDO
and ReRemic transaction backed by a portfolio of commercial
mortgage backed securities (CMBS) (100% of the pool balance). As
of the July 25, 2011 Trustee report, the aggregate Certificate
balance of the transaction has decreased to $374.0 million from
$564.1 million at issuance, with the paydown directed to the Class
A-2FX and Class A-2FL Certificates , as a result of amortization
of the underlying collateral. Class A-1 has paid down in full and
the deal has had realized losses of $8.8 million.

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

WARF is a primary measure of the credit quality of a CRE CDO pool.
Moody's has completed updated credit estimates for the non-Moody's
rated collateral. The bottom-dollar WARF is a measure of the
default probability within a collateral pool. Moody's modeled a
bottom-dollar WARF of 2,779 compared to 2,325 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (34.3% compared to 33.0% at last review), A1-A3
(17.6% compared to 17.5% at last review), Baa1-Baa3 (1.0% compared
to 9.4% at last review), Ba1-Ba3 (8.3% compared to 8.7% at last
review), B1-B3 (14.7% compared to 12.9% at last review), and Caa1-
C (24.1% compared to 18.5% at last review).

WAL acts to adjust the probability of default of the collateral in
the pool for time. Moody's modeled to a WAL of 2.2 years compared
to 2.5 years at last review.

WARR is the par-weighted average of the mean recovery values for
the collateral assets in the pool. Moody's modeled a fixed WARR of
26.4% compared to 40.6% at last review.

MAC is a single factor that describes the pair-wise asset
correlation to the default distribution among the instruments
within the collateral pool (i.e. the measure of diversity).
Moody's modeled a MAC of 2.5% compared to 3.6% at last review.

Moody's review incorporated CDOROM(R) v2.8, one of Moody's CDO
rating models, which was released on January 24, 2011.

The cash flow model, CDOEdge(R) v3.2.1.0, was used to analyze the
cash flow waterfall and its effect on the capital structure of the
deal.

Changes in any one or combination of the key parameters may have
rating implications on certain classes of rated notes. However, in
many instances, a change in key parameter assumptions in certain
stress scenarios may be offset by a change in one or more of the
other key parameters. Rated notes are particularly sensitive to
changes in recovery rate assumptions. Holding all other key
parameters static, changing the recovery rate assumption down from
26.4% to 21.4% or up to 31.4% would result in average rating
movement on the rated tranches of 0 to 2 notches downward and 0 to
1 notch upward, respectively.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of assumption uncertainty
are the current sluggish macroeconomic environment and varying
performance in the commercial real estate property markets.
However, Moody's expects to see increasing or stabilizing property
values, higher transaction volumes, a slowing in the pace of loan
delinquencies and greater liquidity for commercial real estate in
2011 The hotel and multifamily sectors are continuing to show
signs of recovery, while recovery in the office and retail sectors
will be tied to recovery of the broader economy. The availability
of debt capital continues to improve with terms returning toward
market norms. Moody's central global macroeconomic scenario
reflects an overall sluggish recovery through 2012, amidst ongoing
individual, corporate and governmental deleveraging, persistent
unemployment, and government budget considerations.

The principal methodology used in these ratings is "Moody's
Approach to Rating SF CDOs" published in November 2010.

Other methodology used in this rating was "Moody's Approach to
Rating Commercial Real Estate CDOs" published in July 2011. Please
see the Credit Policy page on www.moodys.com for a copy of these
methodologies.


MOSELLE CLO: S&P Raises Ratings on 2 Classes of Notes From 'BB+'
----------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on the class
A1E, A-1L, A-1LE, A-1LU, A2E, A2L, A3E, A3L, B1E, and B1L notes
from Moselle CLO S.A., a multi-currency collateralized loan
obligation (CLO) transaction managed by INVESCO Senior Secured
Management Inc. "At the same time, we removed the ratings on
classes B1E and B1L from CreditWatch, where we placed them with
positive implications on May 3, 2011. We also affirmed our rating
on the class C1 CN note," S&P related.

"The upgrades reflect the improved performance we have observed in
the deal's underlying asset portfolio. As of the June 21, 2011,
trustee report, which we considered for our analysis, the
transaction had $29.93 million in securities rated in the 'CCC'
range and $1 million in defaulted securities. This is compared
with $62.38 million in securities rated in the 'CCC' range and
$5.71 million in defaulted securities at the time of our March
2010 rating actions, for which we used the Feb. 22, 2010, trustee
report," S&P said.

The failures of the senior class A, class A, and class B-1
overcollateralization (O/C) coverage tests prompted the class A1E,
A-1L, A-1LE, and A-1LU notes to pay down an additional 5.59% of
their original note balances since February 2010. Currently, the
notes are passing their O/C tests and the deferred interest
balances on the class A3E, A3L, B1E, and B1L notes have been
repaid.

The trustee reported these O/C ratios in the June 21, 2011,
monthly report:

    The senior class A O/C ratio was 122.34%, compared with a
    reported ratio of 100.79% in February 2010;

    The class A O/C ratio was 115.68%, compared with a reported
    ratio of 94.98% in February. 2010; and

    The class B-1 O/C ratio was 112.87%, compared with a reported
    ratio of 102.26% in February 2010.

"The affirmation of our rating on the class C1 CN note reflects
the note's dependency on a French OAT Treasury Strip, which is
linked to the sovereign rating on France. Our rating on this
principal-protected note only addresses the receipt of principal
at or prior to maturity," S&P related.

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

Rating And Creditwatch Actions

Moselle CLO S.A.
              Rating
Class     To          From
A1E       AAA (sf)    AA+ (sf)
A-1L      AAA (sf)    AA+ (sf)
A-1LE     AAA (sf)    AA+ (sf)
A-1LU     AAA (sf)    AA+ (sf)
A2E       AA+ (sf)    AA (sf)
A2L       AA+ (sf)    AA (sf)
A3E       A+ (sf)     A (sf)
A3L       A+ (sf)     A (sf)
B1E       BBB+ (sf)   BB+ (sf)/Watch Pos
B1L       BBB+ (sf)   BB+ (sf)/Watch Pos

Rating Affirmed

Moselle CLO S.A.
Class        Rating
C1 CN        AAA (sf)


MOUNTAIN CAPITAL: Moody's Upgrades Ratings of CLO Notes
-------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Mountain Capital CLO IV Ltd.:

US$134,000,000 Class A-1L Floating Rate Notes due 2018 (current
outstanding balance of $132,331,760), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$9,000,000 Class A-1LB Floating Rate Notes due 2018, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$21,000,000 Class A-2L Floating Rate Notes due 2018, Upgraded to
Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed Under Review
for Possible Upgrade;

US$15,000,000 Class A-3L Floating Rate Notes due 2018, Upgraded to
A3 (sf); previously on June 22, 2011 Ba1 (sf) Placed Under Review
for Possible Upgrade;

US$13,500,000 Class B-1L Floating Rate Notes due 2018, Upgraded to
Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed Under Review
for Possible Upgrade;

US$12,000,000 Class B-2L Floating Rate Notes due 2018 (current
outstanding balance of $11,280,994), Upgraded to B1 (sf);
previously on June 22, 2011 Caa3 (sf) Placed Under Review for
Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

Moody's also notes that the deal has benefited from improvement in
the credit quality of the underlying portfolio since the rating
action in August 2009. Based on the July 2011 trustee report, the
weighted average rating factor is currently 2596 compared to 2881
in July 2009.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $290 million,
defaulted par of $5 million, a weighted average default
probability of 18.40% (implying a WARF of 2676), a weighted
average recovery rate upon default of 48.40%, and a diversity
score of 60. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Mountain Capital CLO IV Ltd., issued in December 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor and diversity score. However, as part of the base
   case, Moody's considered a spread level higher than the
   covenant level due to the large difference between the reported
   and covenant level.


NYLIM FLATIRON: Moody's Upgrades Ratings of Six Classes of Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by NYLIM Flatiron CLO 2005-1:

US$40,000,000 Class A-1 Revolving Floating Rate Notes, Due 2017
(current outstanding balance of $21,622,599), Upgraded to Aaa
(sf); previously on Jun 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$80,000,000 Class A-2 Delayed Drawdown Floating Rate Notes, Due
2017 (current outstanding balance of $43,245,198), Upgraded to Aaa
(sf); previously on Jun 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$180,000,000 Class A-3 Floating Rate Notes, Due 2017 (current
outstanding balance of $97,301,695), Upgraded to Aaa (sf);
previously on Jun 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$12,000,000 Class B Floating Rate Notes, Due 2017, Upgraded to
Aaa (sf); previously on Jun 22, 2011 A1 (sf) Placed Under Review
for Possible Upgrade;

US$26,000,000 Class C Deferrable Floating Rate Notes, Due 2017,
Upgraded to Aa2 (sf); previously on Jun 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$28,000,000 Class D Deferrable Floating Rate Notes, Due 2017,
Upgraded to Ba1 (sf); previously on Jun 22, 2011 B2 (sf) Placed
Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The actions reflect key
changes to the modeling assumptions, which incorporate (1) a
removal of the temporary 30% default probability macro stress
implemented in February 2009 as well as (2) increased BET
liability stress factors and increased recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio, an increase in the transaction's
overcollateralization ratios and delevering of the senior notes
since the rating action in September 2009. Based on the June 2011
trustee report, the weighted average rating factor is currently
2364 compared to 2621 in August 2009. The Class A Notes have been
paid down by approximately 45.9% or $137.8 million since the
rating action in September 2009. As a result of the delevering,
the overcollateralization ratios have increased since the rating
action in September 2009. Based on the latest trustee report dated
June 2011, the Class A/B, Class C and Class D
overcollateralization ratios are reported at 140.6%, 122.4% and
107.3%, respectively, versus August 2009 levels of 121%, 111.7%
and 103.2%, respectively.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $248 million,
defaulted par of $0 million, a weighted average default
probability of 15.4% (implying a WARF of 2459), a weighted average
recovery rate upon default of 49.6%, and a diversity score of 49.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

NYLIM Flatiron CLO 2005-1, issued in August 2005, is a
collateralized loan obligation backed primarily by a portfolio of
senior secured loans.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011. Please see the Credit Policy page on www.moodys.com for
a copy of this methodology.

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CLO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior, 2) divergence in legal
interpretation of CLO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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


OLYMPIC CLO: Moody's Upgrades Ratings of 4 Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Olympic CLO I Ltd.:

US$16M Class A-2L Floating Rate Notes Due May 2016 Bond, Upgraded
to Aaa (sf); previously on Jun 22, 2011 Aa2 (sf) Placed Under
Review for Possible Upgrade

US$19M Class A-3L Floating Rate Notes Due May 2016 Bond, Upgraded
to A1 (sf); previously on Jun 22, 2011 Baa2 (sf) Placed Under
Review for Possible Upgrade

US$15M Class B-1L Floating Rate Notes Due May 2016 Bond, Upgraded
to Ba3 (sf); previously on Jun 22, 2011 B3 (sf) Placed Under
Review for Possible Upgrade

US$4.4M Class B-2LFloating Rate Notes Due May 2016 Bond (current
balance $4,253,920), Upgraded to Caa2 (sf); previously on Jun 22,
2011 Caa3 (sf) Placed Under Review for Possible Upgrade

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect delevering of the senior notes since the
rating action in December 2010. Moody's notes that the Class A
Notes have been paid down by approximately 31% or $41.6 million
since the rating action in December 2010. As a result of the
delevering, the overcollateralization ratios have increased since
the rating action in December 2010. Based on the latest trustee
report dated July 6, 2011, the Class A overcollateralization ratio
is reported at 128..33% versus November 2010 level of 116.01%.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes. Based on the July 2011 trustee report,
reference securities that mature after the maturity date of the
notes currently make up approximately 5.9% of the underlying
reference portfolio. These investments potentially expose the
notes to market risk in the event of liquidation at the time of
the notes' maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $$119 million,
defaulted par of $2.27 million, a weighted average default
probability of 17.04% (implying a WARF of 2855), a weighted
average recovery rate upon default of 29.0%, and a diversity score
of 33. The default and recovery properties of the collateral pool
are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

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

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties.

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


PORTOLA CLO: Moody's Upgrades Ratings of Six Classes of Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Portola CLO, Ltd.:

US$360,000,000 Class A Floating Rate Notes Due November 2021
(current outstanding balance of $339,493,853), Upgraded to Aaa
(sf); previously on June 22, 2011, Aa1 (sf) Placed Under Review
for Possible Upgrade;

US$44,500,000 Class B-1 Floating Rate Notes Due November 2021,
Upgraded to A1 (sf); previously on June 22, 2011, A2 (sf) Placed
Under Review for Possible Upgrade;

US$5,000,000 Class B-2 Fixed Rate Notes Due November 2021,
Upgraded to A1 (sf); previously on June 22, 2011, A2 (sf) Placed
Under Review for Possible Upgrade;

US$22,000,000 Class C Deferrable Floating Rate Notes Due November
2021, Upgraded to Baa2 (sf); previously on June 22, 2011, Baa3
(sf) Placed Under Review for Possible Upgrade;

US$17,500,000 Class D Deferrable Floating Rate Notes Due November
2021, Upgraded to Ba1 (sf); previously on June 22, 2011, Ba3 (sf)
Placed Under Review for Possible Upgrade; and

US$16,500,000 Class E Deferrable Floating Rate Notes Due November
2021 (current outstanding balance of $16,291,920), Upgraded to Ba3
(sf); previously on June 22, 2011, Caa2 (sf) Placed Under Review
for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The rating actions also reflect consideration of improvement in
the credit quality of the underlying portfolio and an increase in
the transaction's overcollateralization ratios since the rating
action in October 2009. Based on the July 2011 trustee report, the
weighted average rating factor is currently 2491 compared to 2827
in September 2009. The Class A/B, Class C, Class D, and Class E
overcollateralization ratios are currently reported at 119.60%,
113.07%, 108.45%, and 104.48%, respectively, versus September 2009
levels of 106.03%, 109.93%, 105.52%, and 99.64%, respectively, and
all related overcollateralization tests are currently in
compliance. Since the rating action in October 2009, $7.4 million
of interest proceeds have reduced the outstanding balance of the
Class A notes by 2.1%.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $463.84 million,
defaulted par of $4.8 million, a weighted average default
probability of 21.62% (implying a WARF of 2668), a weighted
average recovery rate upon default of 47.14%, and a diversity
score of 52. These default and recovery properties of the
collateral pool are incorporated in cash flow model analysis where
they are subject to stresses as a function of the target rating of
each CLO liability being reviewed. The default probability is
derived from the credit quality of the collateral pool and Moody's
expectation of the remaining life of the collateral pool. The
average recovery rate to be realized on future defaults is based
primarily on the seniority of the assets in the collateral pool.
In each case, historical and market performance trends and
collateral manager latitude for trading the collateral are also
factors.

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

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

1) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings. Moody's tested for a
   possible extension of the actual weighted average life in its
   analysis.

2) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor, weighted average coupon, and diversity score.
   However, as part of the base case, Moody's considered spread
   levels higher than the covenant levels due to the large
   difference between the reported and covenant levels.


PREFERRED TERM: S&P Affirms Ratings on 2 Notes Classes at 'CCC-'
----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its 'AAA (sf)' rating
on the class AX notes from Preferred Term Securities XXIII Ltd., a
U.S. trust-preferred securities (TruPS) collateralized debt
obligation (CDO) transaction. "This action followed the complete
paydown of the notes. Three other Standard & Poor's rated tranches
remain outstanding in the transaction," S&P related.

The complete paydown of the class AX notes occurred on the
June 22, 2011, payment date.

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

Rating Actions

Preferred Term Securities XXIII Ltd.
                        Rating
Class              To           From
AX                 NR           AAA (sf)

Other Outstanding Ratings

Preferred Term Securities XXIII Ltd.

Class              Rating
A-1                CCC+ (sf)
A-2                CCC- (sf)
A-FP               CCC- (sf)


PRUDENTIAL SECURITIES: Moody's Raises Ratings of Two CMBS Classes
-----------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded two classes and
affirmed five classes of Prudential Securities Secured Financing
Corp., Mortgage Pass-Through Certificates, Series 1998-C1:

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

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

Cl. H, Upgraded to Aa1 (sf); previously on Nov 11, 2010 Upgraded
to Aa2 (sf)

Cl. J, Upgraded to A3 (sf); previously on Nov 11, 2010 Upgraded to
Baa1 (sf)

Cl. L, Affirmed at Caa3 (sf); previously on Nov 11, 2010
Downgraded to Caa3 (sf)

Cl. M, Affirmed at C (sf); previously on Nov 11, 2010 Downgraded
to C (sf)

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

RATINGS RATIONALE

The upgrades are due to the increase in subordination due to loan
payoffs and amortization and overall improved pool performance.
The pool has paid down by 12% since Moody's last review. The
affirmations are due to key parameters, including Moody's loan to
value (LTV) ratio, Moody's stressed DSCR and the Herfindahl Index
(Herf), remaining within acceptable ranges. Based on Moody's
current base expected loss, the credit enhancement levels for the
affirmed classes are sufficient to maintain their current ratings.

Moody's rating action reflects a cumulative base expected loss of
2.7% of the current balance. At last full review, Moody's
cumulative base expected loss was 3.9%. Moody's stressed scenario
loss is 6.4% of the current balance. Moody's provides a current
list of base and stress scenario losses for conduit and fusion
CMBS transactions on moodys.com at:

  http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

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

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011. The
hotel and multifamily sectors are continuing to show signs of
recovery, while recovery in the office and retail sectors will be
tied to recovery of the broader economy. The availability of debt
capital continues to improve with terms returning toward market
norms. Moody's central global macroeconomic scenario reflects an
overall sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

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

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a paydown analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

Moody's uses a variation of Herf to measure diversity of loan
size, where a higher number represents greater diversity. Loan
concentration has an important bearing on potential rating
volatility, including risk of multiple notch downgrades under
adverse circumstances. The credit neutral Herf score is 40. The
pool has a Herf of 20, compared to 23 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated November 11, 2010.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 90% to
$115.6 million from $1.15 billion at securitization. The
Certificates are collateralized by 41 mortgage loans ranging
in size from less than 1% to 10% of the pool, with the top ten
loans representing 53% of the pool. Two loans, representing 11%
of the pool, have defeased and are collateralized with U.S.
Government securities.

Eight loans, representing 24% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
Moody's ongoing monitoring of a transaction, Moody's reviews the
watchlist to assess which loans have material issues that could
impact performance.

Fifteen loans have been liquidated from the pool since
securitization, resulting in an aggregate $20.9 million loss (36%
loss severity on average). Due to realized losses, class N-1 has
been eliminated entirely and Class M has experienced a 41%
principal loss. Currently, two loans, representing 6% of the pool,
are in special servicing. Moody's has estimated a $1.3 million
loss (20% expected loss) for the specially serviced loans.

Moody's has assumed a high default probability for one poorly
performing loan representing 0.3% of the pool. Moody's has
estimated a $50,641 loss (15% expected loss based on a 30%
probability default) from the troubled loan.

Moody's was provided with full year 2009 and 2010 operating
results for 87% and 91%, respectively, of the non-defeased pool.
Excluding specially serviced and troubled loans, Moody's weighted
average LTV for the conduit component is 62% compared to 64% at
Moody's prior review. Moody's net cash flow reflects a weighted
average haircut of 13% to the most recently available net
operating income. Moody's value reflects a weighted average
capitalization rate of 10.4%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.64X and 2.15X,
respectively, compared to 1.61X and 2.02X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three performing conduit loans represent 25% of the
pool. The largest loan is the Aberfeldy III Portfolio Loan
($11.5 million -- 9.9% of the pool), which is secured by seven
properties located throughout Texas. The portfolio totals 371,000
square feet (SF) and consists of four retail properties, three
office properties and one mixed use property. The portfolio was
79% leased as of year-end 2010, compared to 81% at last review.
Despite the decline in occupancy, performance has improved due to
increased rental revenues and lower operating expenses. Moody's
LTV and stressed DSCR are 85% and 1.36X, respectively, compared to
87% and 1.33X, at last review.

The second largest loan is the Aberfeldy I Portfolio Loan
($9.2 million -- 7.9% of the pool), which is secured by eight
properties located throughout Texas. The portfolio totals 285,000
SF and consists of four office properties, three retail properties
and one mixed use property. The portfolio was 75% leased as of
year-end 2010, compared to 79% at last review. Despite the decline
in occupancy, performance has improved due to increased expense
reimbursements and lower operating expenses. Moody's LTV and
stressed DSCR are 93% and 1.26X, respectively, compared to 95% and
1.22X, at last review.

The third largest loan is the Westwood Plaza Loan ($8.4 million --
7.3% of the pool), which is secured by a 173,854 SF shopping
center located in Westwood, New Jersey. The property was 98%
leased as of January 2011, the same as at last review. Moody's LTV
and stressed DSCR 46% and 2.35X, respectively, compared to 47% and
2.30X at last review.


REPACS TRUST: Moody's Rates Repacs Trust Series Watto I Notes Caa1
------------------------------------------------------------------
Moody's Investors Service has downgraded its rating on REPACS
Trust Series WATTO I certificates, a collateralized debt
obligation transaction referencing a static portfolio of corporate
entities (the "Corporate Synthetic Obligation" or "CSO").

US$10,000,000 REPACS TRUST SERIES WATTO I Notes (current
outstanding balance $5,100,000), Downgraded to Caa3 (sf);
previously on March 13, 2009 Downgraded to Caa1 (sf)

RATING RATIONALE

Moody's explained that the rating action taken is the result of
the deterioration in the credit quality of the reference
portfolio.

The 10 year weighted average rating factor of the portfolio
worsened from 700 as of the last rating action in March 2009 to
1140 currently, equivalent to a Ba2. The remaining life of the
deal is 1.9 years. The tranche's attachment point is 7.75% of the
portfolio notional and realized losses due to credit events amount
to 3.90%, leaving a 3.85% credit enhancement against further
portfolio losses.

Moody's rating action factors in a number of sensitivity analyses
and stress scenarios, discussed below. Results are given in terms
of the number of notches' difference versus the base case, where
higher notches correspond to lower expected losses, and vice-
versa:

Market Implied Ratings ("MIRs") are modeled in place of the
corporate fundamental ratings to derive the default probability of
the reference entities in the portfolio. The gap between an MIR
and a Moody's corporate fundamental rating is an indicator of the
extent of the divergence in credit view between Moody's and the
market. The result of this run is similar to that of the base
case.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations. These qualitative factors include the structural
protections in each transaction, the recent deal performance in
the current market environment, the legal environment, and
specific documentation features. All information available to
rating committees, including macroeconomic forecasts, input from
other Moody's analytical groups, market factors, and judgments
regarding the nature and severity of credit stress on the
transactions, may influence the final rating decision.

The principal methodology used in these ratings was "Moody's
Approach to Rating Corporate Collateralized Synthetic Obligations"
published in September 2009. Please see the Credit Policy page on
www.moodys.com for a copy of this methodology.

Moody's analysis for this transaction is based on CDOROM v2.8.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Corporate Synthetic
Obligations", key model inputs used by Moody's in its analysis may
be different from the manager/arranger's reported numbers. In
particular, rating assumptions for all publicly rated corporate
credits in the underlying portfolio have been adjusted for "Review
for Possible Downgrade", "Review for Possible Upgrade", or
"Negative Outlook".

Moody's does not run a separate loss and cash flow analysis other
than the one already done by the CDOROM model. For a description
of the analysis, refer to the methodology and the CDOROM user's
guide on Moody's website.

Moody's analysis of CSOs is subject to uncertainties, the primary
sources of which include complexity, governance and leverage.
Although the CDOROM model captures many of the dynamics of the
Corporate CSO structure, it remains a simplification of the
complex reality. Of greatest concern are (a) variations over time
in default rates for instruments with a given rating, (b)
variations in recovery rates for instruments with particular
seniority/security characteristics and (c) uncertainty about the
default and recovery correlations characteristics of the reference
pool. Similarly on the legal/structural side, the legal analysis
although typically based in part on opinions (and sometimes
interpretations) of legal experts at the time of issuance, is
still subject to potential changes in law, case law and the
interpretations of courts and (in some cases) regulatory
authorities. The performance of this CSO is also dependent on on-
going decisions made by one or several parties. Although the
impact of these decisions is mitigated by structural constraints,
anticipating the quality of these decisions necessarily introduces
some level of uncertainty in Moody's assumptions. Given the
tranched nature of CSO liabilities, rating transitions in the
reference pool may have leveraged rating implications for the
ratings of the CSO liabilities, thus leading to a high degree of
volatility. All else being equal, the volatility is likely to be
higher for more junior or thinner liabilities.

The base case scenario modeled fits into the central macroeconomic
scenario predicted by Moody's of a sluggish recovery scenario in
the corporate universe. Should macroeconomics conditions evolve,
the CSO ratings will change to reflect the new economic
conditions.


RIVERSIDE PARK: S&P Gives 'BB' Rating on Class D Deferrable Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services assigned its preliminary
ratings to Riverside Park CLO Ltd./Riverside Park CLO Corp.'s
$369.0 million floating-rate notes.

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

The preliminary ratings are based on information as of Aug. 5,
2011. Subsequent information may result in the assignment of final
ratings that differ from the preliminary ratings.

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

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

    The transaction's credit enhancement, which is sufficient to
    withstand the defaults applicable for the supplemental tests
    (not counting excess spread), and cash flow structure, which
    can withstand the default rate projected by Standard & Poor's
    CDO Evaluator model, as assessed by Standard & Poor's using
    the assumptions and methods outlined in its corporate CDO
    criteria (see 'Update To Global Methodologies And Assumptions
    For Corporate Cash Flow And Synthetic CDOs,' published Sept.
    17, 2009).

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

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

    The investment manager's experienced management team.

    "Our projections regarding the timely interest and ultimate
    principal payments on the preliminary rated notes, which we
    assessed using our cash flow analysis and assumptions
    commensurate with the assigned preliminary ratings under
    various interest-rate scenarios, including LIBOR ranging from
    0.30%-12.35%," S&P related.

    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
    outstanding rated notes.

Preliminary Ratings Assigned
Riverside Park CLO Ltd./Riverside Park CLO Corp.

Class                   Rating                      Amount
                                                  (mil. $)
A-1                     AAA (sf)                   266.000
A-2                     AA (sf)                     32.000
B (deferrable)          A (sf)                      36.000
C (deferrable)          BBB (sf)                    20.000
D (deferrable)          BB (sf)                     15.000
Subordinated notes      NR                         108.392

NR -- Not rated.


RYLAND MORTGAGE: Fitch Withdraws Rating on One Class
----------------------------------------------------
Fitch Ratings has withdrawn the rating on one class in Ryland
Mortgage Securities Corp. 1994-5, since the transaction was
terminated.

Fitch has withdrawn this rating:

Ryland Mortgage Securities Corp. 1994-5

   -- Class B-1 (783766QK7) 'Dsf/RR2'.


SECURITY NATIONAL: Moody's Downgrades Ratings of One Tranche
------------------------------------------------------------
Moody's Investors Service has downgraded one tranche issued by
Security National Mortgage Loan Trust 2005-A. The servicer is
Security National Servicing Corporation. The notes are backed by a
pool of miscellaneous loans, including residential and commercial
mortgages. As of the June 2011 distribution date, most of the
residential mortgages had paid off or defaulted, and 44.3% of the
pool balance consisted of commercial real estate mortgages.
Commercial loans including those backed by accounts receivable,
inventory, and furniture, fixtures and equipment, comprised
approximately 31.8% of the outstanding pool balance.

The complete rating action is:

Issuer: Security National Mortgage Loan Trust 2005-A

Cl. B, Downgraded to Caa1 (sf); previously on Jan 4, 2011 B1 (sf)
Placed Under Review for Possible Downgrade

RATING RATIONALE

The downgrade actions resulted from worse than expected
deterioration in collateral performance and reduced credit
enhancement available to support the affected notes. Since the
last rating action in July 2009, cumulative net losses as a
percent of the original pool balance increased to approximately
29.6% from approximately 16.2% of the original balance.
Consequently, the total credit enhancement provided by a reserve
account and overcollateralization decreased to 25.2% from 45.6% of
the outstanding pool balance.

The methodology used in these rating actions included projecting
losses using a loan-by-loan analysis for approximately 93% of the
pool. Moody's assessed the likelihood of each loan to default
based on the levels of current delinquencies, business types,
property locations, past payment histories, borrower's
creditworthiness, and either appraisals or estimates of property
market values. For the remaining portion of the pool, market
recovery rates were applied for each different collateral type to
arrive at projected losses.

Our current lifetime expected net losses for the transaction is
37% to 38% of the original pool balance (29% to 33% relative to
the outstanding June 2011 balance). The expected loss on the pool
was then examined in relation to available credit enhancement,
including a reserve account and overcollateralization.

Primary sources of uncertainty for this transaction are the
general economic environment, commercial property and other
underlying asset values, and the ability of the industries of the
underlying collateral to recover from the recession. If the
lifetime expected losses used in determining the ratings were
increased to 39% of the original pool balance, the Class B notes
may be downgraded.

Other methodologies and factors that may have been considered in
the process of rating these transactions can also be found on
Moody's website. Further information on Moody's analysis of this
transaction is available on www.moodys.com.


STRUCTURED ASSET: Moody's Confirms Ratings of Four Tranches
-----------------------------------------------------------
Moody's Investors Service has confirmed the ratings of four
tranches from Structured Asset Mortgage Investments II Trust 2003-
AR4. The collateral backing these deals primarily consists of
first-lien, adjustable rate Alt-A residential mortgages.

RATINGS RATIONALE

Cl. A-1, Cl. A-2, Cl. X and Cl. M tranches were downgraded as part
of Moody's 27th April, 2011 rating action but remained on review
due to shortfalls in payment of accrued interest and principal in
certain periods. As of this rating action, the unpaid interest
shortfalls on the senior tranches have been recovered. However,
Moody's feels the recurrence of interest shortfalls remains likely
and Moody's updated ratings reflect this. Although these pools
have paid down significantly, the remaining loans are also
affected by the housing and macroeconomic conditions that remain
under duress.

The actions reflect Moody's updated loss expectations on Alt-A
pools issued from prior 2005. The principal methodology used in
these ratings is described in the Monitoring and Performance
Review section in "Moody's Approach to Rating US Residential
Mortgage-Backed Securities" published in December 2008. Other
methodology used in this rating was "Pre-2005 U.S. RMBS
Surveillance Methodology" published in January 2011.

Moody's final rating actions are based on current ratings, level
of credit enhancement, collateral performance and updated pool-
level loss expectations relative to current level of credit
enhancement. Moody's took into account credit enhancement provided
by seniority, cross-collateralization, excess spread, time
tranching, and other structural features within the senior note
waterfalls.

The above mentioned approach "Pre-2005 U.S. RMBS Surveillance
Methodology" is adjusted slightly when estimating losses on pools
left with a small number of loans to account for the volatile
nature of small pools. Even if a few loans in a small pool become
delinquent, there could be a large increase in the overall pool
delinquency level due to the concentration risk. To project losses
on pools with fewer than 100 loans, Moody's first estimates a
"baseline" average rate of new delinquencies for the pool that is
dependent on the vintage of loan origination (10%, 5% and 3% for
the 2004, 2003 and 2002 and prior vintage respectively). The
baseline rates are higher than the average rate of new
delinquencies for larger pools for the respective vintages.

Once the baseline rate is set, further adjustments are made based
on 1) the number of loans remaining in the pool and 2) the level
of current delinquencies in the pool. The fewer the number of
loans remaining in the pool, the higher the volatility in
performance. Once the loan count in a pool falls below 75, the
rate of delinquency is increased by 1% for every loan less than
75. For example, for a pool with 74 loans from the 2004 vintage,
the adjusted rate of new delinquency would be 10.10%. in addition,
if current delinquency levels in a small pool is low, future
delinquencies are expected to reflect this trend. To account for
that, the rate calculated above is multiplied by a factor ranging
from 0.5 to 2.0 for current delinquencies ranging from less than
2.5% to greater than 30% respectively. Delinquencies for
subsequent years and ultimate expected losses are projected using
the approach described in the methodology publication.

The primary source of assumption uncertainty is the current
macroeconomic environment, in which unemployment levels remain
high, and weakness persists in the housing market. Overall,
Moody's assumes a further 2% decline in home prices with
stabilization in 2012, accompanied by continued stress in national
employment levels through that timeframe.

Complete rating actions are:

Issuer: Structured Asset Mortgage Investments II Trust 2003-AR4

Cl. A-1, Confirmed at Ba1 (sf); previously on Apr 27, 2011
Downgraded to Ba1 (sf) and Placed Under Review Direction Uncertain

Cl. A-2, Confirmed at Ba1 (sf); previously on Apr 27, 2011
Downgraded to Ba1 (sf) and Placed Under Review Direction Uncertain

Cl. X, Confirmed at Ba1 (sf); previously on Apr 27, 2011
Downgraded to Ba1 (sf) and Placed Under Review Direction Uncertain

Cl. M, Confirmed at Ba3 (sf); previously on Apr 27, 2011
Downgraded to Ba3 (sf) and Placed Under Review Direction Uncertain


UBS COMMERCIAL: Fitch Upgrades Rating on Class B Loan to 'BB'
-------------------------------------------------------------
Fitch Ratings has upgraded three and affirmed 11 classes of UBS
Commercial Mortgage Trust, series 2007-FL1. Fitch has also revised
Rating Outlooks on several classes. The Outlook revisions and
upgrades are due to revised loss expectations, paydown and
improvement in the performance of certain properties. Fitch's
performance expectation incorporates prospective views regarding
the outlook of the commercial real estate market.

Negative Outlooks reflect concerns with the ability of certain
loans to refinance. The remaining loans which have not been
modified are generally maturing over the next 12 months; the
majority of the loans had an average loan term of five years
(including extensions). As lending standards have changed
considerably from the time these loans were originated, there is
uncertainty as to whether or not the loans will have issues
securing financing at final maturity.

Under Fitch's methodology, approximately 69.9% of the pooled
balance is modeled to default in the base case stress scenario,
defined as the 'B' stress. In this scenario, the modeled average
cash flow decline is 5.9% and pooled expected losses are 9.3%. To
determine a sustainable Fitch cash flow and stressed value, Fitch
analyzed servicer-reported operating statements and STR reports,
updated property valuations, and recent sales comparisons. Fitch
estimates that average recoveries will be strong, with an
approximate base case recovery in excess of 86.7%.

The transaction is collateralized by 21 loans, which are secured
by hotels (52%), multifamily properties (19.5%), office properties
(14.5%) and undeveloped land (14%). The transaction faces near-
term maturity risk. Nineteen loans mature in the next 12 months.
Two loans (1.9%) matured in 2011 and were transferred to the
special servicer for maturity defaults. Fifteen loans (73.2%) have
final maturity dates in 2012 and one loan (4.5%) has a final
maturity in 2013. The remaining three loans (20.4%) have final
maturities in mid-2014.

Eleven loans were modeled to take a loss in the base case: Essex
House (15.2%), Maui Prince Resort and Land (12.2%), Magazine
Multifamily Portfolio (8.9%), W Hotel Washington DC (5.3%),
Waterstone and Copper Canyon (4.5%), Hilton Long Beach (3.2%),
Hilton Westchase (2%), St. Anthony Hotel (1.8%), Renaissance Ft.
Lauderdale (1.7%), Dolce Basking Ridge (1.6%), and the RexCorp
Land Portfolio (1.1%). The largest modeled losses were on the
Essex House, the Hilton Long Beach and the Maui Prince.

The Essex House loan is secured by a by a 515-room luxury full-
service hotel and 26 residential units located in the Central Park
South neighborhood of Manhattan. The building was constructed in
1930 and underwent a $91 million renovation and condo conversion
in 2007. Of the 26 condo units, 18 have sold, and the loan has
been paid down accordingly. Six of the condo units are held by the
sponsor and rented out as hotel rooms, and the two remaining units
are being marketed. At issuance, the loan was underwritten to a
stabilized cash flow, which anticipated significant revenue gains
due to the major renovation. The property's luxury segment of the
market has been especially hard hit by the economic downturn, and
the anticipated increases have not materialized. As of the YE
2010, the servicer-reported NOI was 84% lower than underwritten
but had improved 68% from YE 2009. Loan originally matured in
September 2009 and was extended for twice for one year. There are
no remaining extension options and the loan will reach its final
maturity in September 2011.

The Hilton Long Beach loan is collateralized by a 393-room full-
service hotel in downtown Long Beach, CA. The loan was
underwritten to a stabilized cash flow that envisioned continuing
increases in ADR. The projected increases did not materialize, and
the TTM March 2011 NOI was 64% lower than underwritten and 35%
lower than YE 2009. The loan matured on July 9, 2009 and was
extended three times for one year. There are no remaining
extensions and the final maturity will be in July 2012.

The Maui Prince loan is secured by a 310-room full service hotel,
two 18-hole golf courses and 1,194 acres of undeveloped land
located in Maui, Hawaii. The loan was transferred to special
servicing on June 12, 2009, due to imminent default at its
maturity date. The loan has been assumed, paid down, modified and
extended. The final maturity date is now July 2014. Despite the
paydown and infusion of new capital by the sponsors, Fitch remains
concerned about viability of the business plan to develop the
vacant land as luxury residential housing given the continued
weakness in the housing market. The loan remains with the special
servicer but is expected to transfer back to the master servicer
soon.

Fitch has upgraded these pooled classes and revised Rating
Outlooks:

  -- $605.2 million class A-1 to 'AAAsf/LS2' from 'AAsf/LS2';
     Outlook to Stable from Negative;

  -- $309.5 million class A-2 to 'BBBsf/LS3' from 'BBsf/LS3';
     Outlook to Stable from Negative;

  -- $57.3 million class B to 'BBsf/LS5' from 'Bsf/LS5'; Outlook
     to Stable from Negative.

Fitch has affirmed these pooled classes and revised Rating
Outlooks:

  -- $31 million class C at 'Bsf/LS5'; Outlook to Stable from
     Negative;

  -- $27.2 million class D at 'CCCsf/RR4';

  -- $27.2 million class E at 'CCCsf/RR4';

  -- $27.2 million class F at 'CCsf/RR6';

  -- $27.2 million class G at 'CCsf/RR6';

  -- $29.1 million class H at 'Csf/RR6';

  -- $27.1 million class J at 'Csf/RR6';

  -- $27.1 million class K at 'Csf/RR6'.

Additionally, Fitch has affirmed these non-pooled classes and
revised Rating Outlooks:

  -- $5 million class O-HW at 'CCCsf/RR6';

  -- $1.9 million class O-MD at 'BBB-sf'; Outlook to Stable from
     Negative;

  -- $4.5 million class O-WC at 'CCCsf/RR6'.

Class O-BH has paid in full. Fitch does not rate classes O-SA and
O-HA. Classes L, M-MP, N-MP and O-MP all remain at 'D/RR6' due to
realized losses. Fitch withdrew the rating of the interest-only
class X.


VENTURE IV: Moody's Upgrades Ratings of Seven Classes of CLO Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Venture CDO IV Limited:

US$373,500,000 Class A-1 Floating Rate Notes Due 2016 (current
outstanding balance of $253,388,589), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$27,500,000 Class A-2 Floating Rate Notes Due 2016, Upgraded to
Aaa (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$ 20,500,000 Class B-1 Floating Rate Notes Due 2016, Upgraded to
A2 (sf); previously on June 22, 2011 Ba1 (sf) Placed Under Review
for Possible Upgrade;

US$ 8,500,000 Class B-2 Fixed Rate Notes Due 2016, Upgraded to A2
(sf); previously on June 22, 2011 Ba1 (sf) Placed Under Review for
Possible Upgrade;

US$10,500,000 Class C-1 Floating Rate Notes Due 2016, Upgraded to
Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed Under Review
for Possible Upgrade;

US$6,000,000 Class C-2 Fixed Rate Notes Due 2016, Upgraded to Ba1
(sf); previously on June 22, 2011 B1 (sf) Placed Under Review for
Possible Upgrade; and

US$11,000,000 Class D Floating Rate Notes Due 2016, Upgraded to B1
(sf); previously on June 22, 2011 Caa3 (sf) Placed Under Review
for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios due to delevering of
the Class A-1 notes, which have been paid down by approximately
31.5% or $117.5 million since the rating action in August 2009,
and credit improvement of the underlying portfolio. Based on the
latest trustee report dated July 11, 2011, the Class A, Class B,
Class C, and Class D overcollateralization ratios are reported at
126.67%, 114.82%, 109.01%, and 105.46%, respectively, versus
August 2009 levels of 115.66%, 107.86%, 103.87%, and 101.38%,
respectively. The weighted average rating factor is currently 2477
compared to 2583 in August 2009.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity date of the notes. Based on the July 2011 trustee report,
reference securities that mature after the maturity date of the
notes currently make up approximately 6.76% of the underlying
portfolio. These investments potentially expose the notes to
market risk in the event of liquidation at the time of the notes'
maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $354.8 million,
defaulted par of $13.7 million, a weighted average default
probability of 16.5% (implying a WARF of 2719), a weighted average
recovery rate upon default of 46.99%, and a diversity score of 72.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Venture IV CDO Limited, issued in August 2004, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

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

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


WACHOVIA BANK: Moody's Affirms Ratings of 27 CMBS Classes
---------------------------------------------------------
Moody's Investors Service (Moody's) affirmed 27 classes of
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-
Through Certificates, Series 2007-C30:

Cl. A-2, Affirmed at Aaa (sf); previously on Jul 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jul 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Jul 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-PB, Affirmed at Aaa (sf); previously on Jul 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-5, Affirmed at Aa3 (sf); previously on Dec 2, 2010
Downgraded to Aa3 (sf)

Cl. A-1A, Affirmed at Aa3 (sf); previously on Dec 2, 2010
Downgraded to Aa3 (sf)

Cl. A-M, Affirmed at Baa1 (sf); previously on Dec 2, 2010
Downgraded to Baa1 (sf)

Cl. A-MFL, Affirmed at Baa1 (sf); previously on Dec 2, 2010
Downgraded to Baa1 (sf)

Cl. A-J, Affirmed at B3 (sf); previously on Dec 2, 2010 Downgraded
to B3 (sf)

Cl. B, Affirmed at Caa3 (sf); previously on Dec 2, 2010 Downgraded
to Caa3 (sf)

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

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

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

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

Cl. G, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. H, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. J, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. K, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. L, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. M, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. N, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. O, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. P, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. Q, Affirmed at C (sf); previously on Dec 3, 2009 Downgraded to
C (sf)

Cl. X-P, Affirmed at Aaa (sf); previously on Jul 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-C, Affirmed at Aaa (sf); previously on Jul 9, 2007
Definitive Rating Assigned Aaa (sf)

Cl. X-W, Affirmed at Aaa (sf); previously on Jul 9, 2007
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

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

Moody's rating action reflects a cumulative base expected loss of
12.4% of the current balance compared to 13.5% at last review.
Moody's stressed scenario loss is 29.0% of the current balance,
down from 33.8% at last review. Moody's provides a current list of
base and stress scenario losses for conduit and fusion CMBS
transactions on moodys.com at:

   http://v3.moodys.com/viewresearchdoc.aspx?docid=PBS_SF215255

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

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

Primary sources of assumption uncertainty are the current sluggish
macroeconomic environment and varying performance in the
commercial real estate property markets. However, Moody's expects
to see increasing or stabilizing property values, higher
transaction volumes, a slowing in the pace of loan delinquencies
and greater liquidity for commercial real estate in 2011. The
hotel and multifamily sectors are continuing to show signs of
recovery, while recovery in the office and retail sectors will be
tied to recovery of the broader economy. The availability of debt
capital continues to improve with terms returning toward market
norms. Moody's central global macroeconomic scenario reflects an
overall sluggish recovery through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations.

The primary methodology used in this rating was "CMBS: Moody's
Approach to Rating Fusion Transactions" published in April 2005.
The other methodology used in this rating was "CMBS: Moody's
Approach to Rating Single Tenant/Large Loan Transactions"
published in July 2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 which is used for both conduit and fusion
transactions. Conduit model results at the Aa2 (sf) level are
driven by property type, Moody's actual and stressed DSCR, and
Moody's property quality grade (which reflects the capitalization
rate used by Moody's to estimate Moody's value). Conduit model
results at the B2 (sf) level are driven by a pay down analysis
based on the individual loan level Moody's LTV ratio. Moody's
Herfindahl score (Herf), a measure of loan level diversity, is a
primary determinant of pool level diversity and has a greater
impact on senior certificates. Other concentrations and
correlations may be considered in Moody's analysis. Based on the
model pooled credit enhancement levels at Aa2 (sf) and B2 (sf),
the remaining conduit classes are either interpolated between
these two data points or determined based on a multiple or ratio
of either of these two data points. For fusion deals, the credit
enhancement for loans with investment-grade credit estimates is
melded with the conduit model credit enhancement into an overall
model result. Fusion loan credit enhancement is based on the
underlying rating of the loan which corresponds to a range of
credit enhancement levels. Actual fusion credit enhancement levels
are selected based on loan level diversity, pool leverage and
other concentrations and correlations within the pool. Negative
pooling, or adding credit enhancement at the underlying rating
level, is incorporated for loans with similar credit estimates in
the same transaction.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated December 2, 2010.

DEAL PERFORMANCE

As of the July 11, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by less than 1% to
$7.8 billion from $7.9 billion at securitization. The Certificates
are collateralized by 255 mortgage loans ranging in size from less
than 1% to 19% of the pool, with the top ten loans representing
53% of the pool. The pool includes one loan with an investment
grade credit estimate, representing 1% of the pool. A second loan,
representing less than 1% of the pool, formerly had a credit
estimate. However, due to a decline in performance this loan is
analyzed as part of the conduit pool.

Seventy-five loans, representing 29% of the pool, are on the
master servicer's watchlist. The watchlist includes loans which
meet certain portfolio review guidelines established as part of
the CRE Finance Council (CREFC) monthly reporting package. As part
of Moody's ongoing monitoring of a transaction, Moody's reviews
the watchlist to assess which loans have material issues that
could impact performance.

Ten loans have been liquidated from the pool since securitization,
resulting in an aggregate $43.8 million loss (67% loss severity on
average). At last review the pool had experienced an aggregate
$23.4 million realized loss from four loans. Fifteen loans,
representing 23% of the pool, are currently in special servicing.
The largest specially serviced loan is the Peter Cooper Village
and Stuyvesant (PCV/ST) Loan ($1.5 billion -- 19.1% of the pool),
which represents a pari-passu interest in a $3.0 billion first
mortgage loan spread among five CMBS deals. There is also a
$1.4 billion in mezzanine loan secured by the borrower's interest.
The loan is secured by two adjacent multifamily apartment
complexes with 11,227 units located on the east side of Manhattan.
A September 2010 appraisal valued the property at $2.8 billion,
leading the master servicer to recognize a $308 million appraisal
reduction in November 2010, increasing to an appraisal reduction
totaling $373.5 million in July 2011. Moody's values the PCV/ST
complex at $2.0 billion, which reflects a 30% loss severity for
the first mortgage. Moody's valuation was heavily weighted towards
an income approach based on 2009 actual and preliminary 2010 net
operating income (NOI) adjusted to reflect current market
conditions, including lower concession packages in the form of
broker fees and free rent. Further consideration was given to
recent New York State Supreme court rulings which reinstated
previously converted market-rate apartment rents back to
stabilized levels. Finally, if twenty percent of the complex
(comprised of the 2,481-unit Peter Cooper Village component of the
property) was converted to for sale co-operative housing at a net
per unit sale price of approximately $600,000, there would be no
loss to the first mortgage.

The remaining 14 specially serviced loans are secured by a mix of
property types. The master servicer has recognized an aggregate
$458.6 million appraisal reduction for all of the remaining
specially serviced loans. Moody's has estimated an aggregate
$569.4 million loss (31% expected loss on average) for all of the
specially serviced loans.

Moody's has assumed a high default probability for 34 poorly
performing loans representing 11.7% of the pool and has estimated
an aggregate $163.6 million loss (20% expected loss based on a 50%
probability of default) from these troubled loans.

Based on the most recent remittance statement, Classes E through
S have experienced cumulative interest shortfalls totaling
$35.3 million. Interest shortfalls had increased from Class L to
Class G in November 2010 due to the servicer recognizing appraisal
entitlement reductions (ASERs) on several loans, including the
PCV/ST Loan, based on recent appraisal reductions. Moody's
anticipates that the pool will continue to experience interest
shortfalls because of the high exposure to specially serviced
loans. Interest shortfalls are caused by special servicing fees,
including workout and liquidation fees, ASERs and extraordinary
trust expenses.

Moody's was provided with full year 2010 operating results for 93%
of the pool and partial year 2011 operating results for 32% of the
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV for the conduit component is 126% compared to
125% at Moody's prior review. Moody's net cash flow reflects a
weighted average haircut of 7.4% to the most recently available
net operating income (NOI). Moody's value reflects a weighted
average capitalization rate of 8.9%.

Moody's actual and stressed DSCRs for the performing conduit loans
are 1.12X and 0.80X, respectively, compared to 1.18X and 0.78X at
last review. Moody's actual DSCR is based on Moody's net cash flow
(NCF) and the loan's actual debt service. Moody's stressed DSCR is
based on Moody's NCF and a 9.25% stressed rate applied to the loan
balance.

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

The largest loan with an investment grade credit estimate is the 9
West 57th Street Loan ($100.0 million -- 1.3%), which is secured
by the fee interest in a 1.4 acre land parcel located in Midtown
Manhattan. The land is leased to Solow Building Company LLC
pursuant to a 130-year ground lease that expires in May 2098. The
collateral is improved with a 1.4 million square foot (SF) Class A
office building. The ground lease payments are $12 million per
year and remain flat for the entire lease term. Moody's credit
estimate is Aaa, the same as at the prior review.

The loan that formerly had a credit estimate is the Concord Square
Shopping Center Loan ($34.6 million -- 0.4%), which is secured by
a 237,000 SF retail center located in Wilmington, Delaware. The
anchor tenants include Giant Food and Marshall's. Border's was the
third anchor, but it has vacated the center following a Chapter 11
bankruptcy and liquidation. Performance had declined due to a rise
in vacancy and decline in base rent. Moody's LTV and stressed DSCR
are 78% and 1.18X, respectively, compared to 70% and 1.32X at last
review.

The three largest performing conduit loans represent 17% of the
pool balance. The largest loan is the Five Times Square Loan
($536.0 million -- 6.9% of the pool), which represents a 50% pari-
passu interest in a $1.07 billion first mortgage loan. The A note
had $184.0 million in mezzanine debt and a $67.0 million B note
behind it at securitization. The loan is secured by a 1.1 million
SF Class A office building located in Midtown Manhattan, New York.
The property has maintained 100% occupancy since securitization.
The office component represents 97% of the total building's net
rentable area (NRA) of which 89% is leased to Ernst and Young
through May 2022 and serves as its U.S. World Headquarters.
Property performance has been stable. The loan is on the
servicer's watchlist due to a low DSCR. The loan is interest only
for the full ten-year term. Moody's LTV and stressed DSCR are 159%
and 0.58X, respectively, compared to 172% and 0.54X at last
review.

The second largest loan is the 350 Park Avenue Loan
($430.0 million -- 5.5% of the pool), which is secured by a
538,000 SF office building located in Midtown Manhattan, New York.
The property was 91% leased as of December 2010 compared to 88% at
last review. The largest tenant is Ziff Brothers Investments,
which leases 36% of the property through April 2021. The loan is
on the servicer's watchlist due to a low DSCR. The loan is
interest only for its entire five-year term. Moody's LTV and
stressed DSCR are 164% and 0.56X, respectively, the same as at
last review.

The third largest loan is the State Street Financial Center Loan
($387.5 million -- 4.9% of the pool), which represents a 50% pari-
passu interest in a $775.0 million first mortgage loan. The loan
is secured by a 1.0 million SF Class A office building located in
the Financial District of Boston, Massachusetts. The property is
100% leased to State Street Corporation (Moody's senior unsecured
rating A1, negative outlook) through September 2023 and serves as
its headquarters. The loan is interest only for its entire ten-
year term. Moody's LTV and stressed DSCR are 133% and 0.71X,
respectively, compared to 135% and 0.70X at last review.


WACHOVIA BANK: Fitch Affirms Ratings of Pooled Classes
------------------------------------------------------
Fitch Ratings has affirmed the pooled classes of Wachovia Bank
Commercial Mortgage Trust 2007-WHALE 8 commercial mortgage pass-
through certificates and downgraded five non-pooled (rake)
classes. The affirmations reflect overall stable loss expectations
for the pooled classes as well as paydown since Fitch's last
review. The downgrades of the rake classes reflect the continued
performance deterioration of the LXR Hotel Portfolio and the
Longhouse Portfolio. Fitch's performance expectation incorporates
prospective views regarding the outlook of the commercial real
estate market.

All of the remaining loans are maturing over the next 12 months.
At issuance, the majority of the loans had an average loan term of
five years (including extensions). As lending standards have
changed considerably from the time these loans were originated,
there is uncertainty as to whether or not the loans will have
issues securing financing at final maturity.

Under Fitch's methodology, approximately 97.9% of the pooled
balance is modeled to default in the base case stress scenario,
defined as the 'B' stress. In this scenario, the modeled average
cash flow decline is 19.3% and pooled expected losses are 27.6%.
To determine a sustainable Fitch cash flow and stressed value,
Fitch analyzed servicer-reported operating statements and STR
reports, updated property valuations, and recent sales
comparisons. Fitch estimates that average recoveries will be
approximately 71.9% in the base case.

The transaction is collateralized by eight assets, six of which
are secured by hotels (95%), one by multifamily (3.3%), and one by
golf courses (1.7%). One loan (5.8%) matures in 2011, six loans
(90.6%) mature in 2012 and one asset (3.6%) is real estate owned
(REO).

Fitch's analysis resulted in loss expectations for seven of the
pooled senior components and for all of the non-pooled components
in the base case. The three largest pooled contributors to losses
(by unpaid principal balance) in the 'B' stress scenario are: The
LXR Portfolio (66.1%), Longhouse Portfolio (10.2%) and The Hudson
Hotel (5.8%).

The LXR Portfolio includes 12 luxury resorts and hotels and 4,742
keys located in desirable beachfront and waterfront locations,
including Puerto Rico, Jamaica, Florida, Arizona, and California.
The portfolio includes two golf courses, four exclusive Golden
Door spas, three casinos and one marina. The hotels are branded
under Blackstone's LXR platform, which is now part of the Hilton
brand. The borrower recently entered into new management
agreements at seven properties, five changed to Waldorf Astoria
and one to Hilton Conrad and one is now affiliated with Hilton
International.

Despite a general uptrend in hotel performance the portfolio
continues to trend downwards. The year-end (YE) 2010 servicer-
reported net operating income (NOI) was approximately 43% lower
than YE 2008 and 73% below issuance underwriting. The YE 2010
occupancy and revenue per available room (RevPAR) were 67.7% and
$121.75, respectively, compared to 78% and $206.99, respectively,
at issuance.

The Longhouse Portfolio loan is secured by 42 extended stay
lodging properties (approximately 5,600 keys) located throughout
11 states and 21 distinct metropolitan statistical areas (MSAs).
Major markets include Atlanta, New Orleans, Orlando, Houston and
Dallas. The portfolio is managed by Park Management Group, a
wholly owned subsidiary of the sponsor, and includes the Sun
Suites, Crestwood Suites and Lodge America brands. The Sun Suites
and Lodge America were priced in the high-end of the economy
segment, while the Crestwood Suites are positioned in the mid-
price segment.

The loan transferred to the special servicer in October 2010 due
to imminent default. The loan remains current and is expected to
be transferred back to the master servicer soon.

At issuance, 12 properties had not reached stabilization and had
not been considered fully implemented into the brand, with nine
properties being purchased by the sponsor during 2005-2006. As of
the trailing 12 month (TTM) March 2011, the occupancy and RevPAR
were 53.1% and $19.37, compared to 73.2% and $31.44, respectively,
at issuance. The NOI for the same period had declined 50% from YE
2008 and 26% from YE 2009.

The Hudson Hotel is secured by the fee and leasehold interest in
an 805-room full-service hotel located in midtown Manhattan, NY,
on the south side of West 58th Street between Eighth and Ninth
Avenues. The loan transferred to the special servicer in May 2010
due to imminent maturity default. The property was originally
constructed in 1928 and underwent a three-year, $125 million
($155,279 per key) renovation following the purchase in 1997 by
Morgan Hotels. The renovation was Ian Schrager's first New York
City hotel in over 10 years.

At issuance, the loan was underwritten with the expectation that
continued strength in the New York City market would continue to
drive average daily rate (ADR) and higher cash flows. The property
failed to achieve the projected increases, due in large part to
the difficulty the economy has experienced. As of TTM April 2011
servicer reported NOI had declined by approximately 62% from YE
2008 and 65% from issuance underwriting. The decline is primarily
driven by erosion in room revenue as a result of the economic
downturn. Property performance is now trending positively with
April TTM NOI up 30% from YE 2009. The loan is in special
servicing due to a maturity default. The loan has been modified
and extended and is pending return to the master servicer.


Fitch has downgraded these non-pooled classes:

   -- $53 million class LXR-1 to 'Csf/RR6' from 'CCsf/RR6';

   -- $70.8 million class LXR-2 to 'Csf/RR6' from 'CCsf/RR6';

   -- $3.8 million class LP-1 to 'Csf/RR6' from 'CCCsf/RR6';

   -- $9.1 million class LP-2 to 'Csf/RR6' from 'CCCsf/RR6';

   -- $2.1 million class LP-3 to 'Csf/RR6' from 'CCCsf/RR6'.

Fitch has affirmed these classes and revised Rating Outlooks:

   -- $727 million class A-1 at 'AAsf'; Outlook to Stable from
      Negative;

   -- $345.4 million class A-2 at 'Bsf'; Outlook Negative;

   -- $61.6 million class B at 'CCCsf/RR5';

   -- $47.5 million class C at 'CCCsf/RR6';

   -- $71.2 million class D at 'CCCsf/RR6';

   -- $46.6 million class E at 'CCCsf/RR6';

   -- $46.6 million class F at 'CCCsf/RR6';

   -- $46.6 million class G at 'CCsf/RR6';

   -- $30.5 million class H at 'CCsf/RR6';

   -- $10.1 million class J at 'Csf/RR6';

   -- $5.2 million class K at 'Csf/RR6';

   -- $12.5 million class L at 'Csf/RR6';

   -- $1.9 million class AP-1 at 'CCCsf/RR6';

   -- $5 million class AP-2 at 'CCsf/RR6';

   -- $3.5 million class HH-1 at 'CCsf/RR6';

   -- $3.3 million class FSN-1 at 'Csf/RR6'.

Fitch withdrew the ratings of the interest-only class X-1B.
Interest-only class X-1A and Classes MH-1 and FA have paid in
full. Fitch does not rate classes AP-3, AP-4, HH-2, FSN-2 and MH-
2.


WACHOVIA BANK: Moody's Reviews Nine CMBS Classes; Might Downgrade
-----------------------------------------------------------------
Moody's Investors Service (Moody's) placed nine classes of
Wachovia Bank Commercial Mortgage Trust, Commercial Mortgage Pass-
Through Certificates, Series 2004-C14 on review for possible
downgrade:

Cl. F, Baa1 (sf) Placed Under Review for Possible Downgrade;
previously on Sep 15, 2004 Definitive Rating Assigned Baa1 (sf)

Cl. G, Baa2 (sf) Placed Under Review for Possible Downgrade;
previously on Sep 15, 2004 Definitive Rating Assigned Baa2 (sf)

Cl. H, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Sep 15, 2004 Definitive Rating Assigned Baa3 (sf)

Cl. J, Ba1 (sf) Placed Under Review for Possible Downgrade;
previously on Sep 15, 2004 Definitive Rating Assigned Ba1 (sf)

Cl. K, Ba2 (sf) Placed Under Review for Possible Downgrade;
previously on Sep 15, 2004 Definitive Rating Assigned Ba2 (sf)

Cl. L, B1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 9, 2011 Downgraded to B1 (sf)

Cl. M, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 9, 2011 Downgraded to B3 (sf)

Cl. N, Caa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 9, 2011 Downgraded to Caa1 (sf)

Cl. O, Caa2 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 9, 2011 Downgraded to Caa2 (sf)

The classes were placed on review due to an increased interest
shortfalls. The deal's largest loan, the Park Place Mall Loan
($134.1 million A-note and $35.8 million B-note -- 15.1% of the
pool) paid off in April 2011. Because the loan had been in special
servicing due to General Growth Properties' (GGP) bankruptcy, the
special servicer, CWCapital Asset Management LLC, was entitled to
a 1% workout fee when the loan paid off. The special servicer
elected to take the fee over several months but the recovery of
the fee still caused interest shortfalls to spike to Class H. To
date, the servicer has recovered approximately $1.1 million of the
workout fee, leaving approximately $746,000 still to be paid. The
recovery of the remaining fee will continue to impact interest
shortfalls over the near term.

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through two sets of
quantitative tools -- MOST(R) (Moody's Surveillance Trends) and
CMM (Commercial Mortgage Metrics) on Trepp -- and on a periodic
basis through a comprehensive review. Moody's prior full review is
summarized in a press release dated March 9, 2011.

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

DEAL AND PERFORMANCE SUMMARY

As of the July 17, 2011 distribution date, the deal's aggregate
certificate balance has decreased by 43% to $661.9 million from
$1.2 billion at securitization. The Certificates are
collateralized by 60 mortgage loans ranging in size from less than
1% to 12% of the pool, with the top ten non-defeased loans
representing 43% of the pool. Six loans, representing 17% of the
pool, have defeased and are secured by U.S. Government securities.

Thirteen loans, representing 21% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC; formerly the Commercial Mortgage
Securities Association) 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.

Three loans have been liquidated from the pool, resulting in an
aggregate realized loss of $1.7 million (11% average loss
severity). Three loans, representing 5% of the pool, are currently
in special servicing. The specially serviced loans are secured by
a mix of multifamily and retail property types. The master
servicer has recognized an aggregate $8.5 million appraisal
reduction for the specially serviced loans.

Moody's review will focus on the impact that the current and
expected interest shortfalls will have on the trust certificates.


WESTWOOD CDO: Moody's Upgrades Ratings of 6 Classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Westwood CDO II, Ltd.:

US$237,825,000 Class A-1 Floating Rate Notes due 2022 (current
outstanding balance of $221,773,753), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$26,425,000 Class A-2 Floating Rate Notes due 2022, Upgraded to
Aa3 (sf); previously on June 22, 2011 Baa1 (sf) Placed Under
Review for Possible Upgrade;

US$8,750,000 Class B Floating Rate Notes due 2022, Upgraded to A1
(sf); previously on June 22, 2011 Baa3 (sf) Placed Under Review
for Possible Upgrade;

US$19,250,000 Class C Deferrable Floating Rate Notes due 2022,
Upgraded to Baa2 (sf); previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$17,500,000 Class D Deferrable Floating Rate Notes due 2022,
Upgraded to Ba2 (sf); previously on June 22, 2011 Ca (sf) Placed
Under Review for Possible Upgrade;

US$14,000,000 Class E Deferrable Floating Rate Notes due 2022
(current outstanding balance of $13,366,433), Upgraded to B1 (sf);
previously on June 22, 2011 C (sf) Placed Under Review for
Possible Upgrade;

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration of credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in October
2010. Based on the July 2011 trustee report, the weighted average
rating factor is currently 2381 compared to 2632 in August 2010.
Moody's also notes that the overcollateralization ratios of the
rated notes have also improved since the rating action in October
2010. The Class A/B, Class C, Class D and Class E
overcollateralization ratios are reported at 121.8%, 113.3%,
106.5% and 101.9%, respectively, versus August 2010 levels of
114.4%, 106.5%, 100.0% and 95.3%, respectively, and all related
overcollateralization tests are currently in compliance. In
particular, the Class E overcollateralization ratio has increased
in part due to the diversion of excess interest to delever the
Class E notes in the event of a Class E overcollateralization test
failure. Moody's also notes that the Class D and Class E Notes are
no longer deferring interest and that all previously deferred
interest has been paid in full.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $312.2 million,
defaulted par of $4.2 million, a weighted average default
probability of 21.8% (implying a WARF of 2770), a weighted average
recovery rate upon default of 49.34%, and a diversity score of 57.
The default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Westwood CDO II, Ltd., issued in April 2007, is a collateralized
loan obligation backed primarily by a portfolio of senior secured
loans.

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Weighted average life: The notes' ratings are sensitive to the
   weighted average life assumption of the portfolio, which may be
   extended due to the manager's decision to reinvest into new
   issue loans or other loans with longer maturities and/or
   participate in amend-to-extend offerings.

3) Other collateral quality metrics: The deal is allowed to
   reinvest and the manager has the ability to deteriorate the
   collateral quality metrics' existing cushions against the
   covenant levels. Moody's analyzed the impact of assuming the
   worse of reported and covenanted values for weighted average
   rating factor and weighted average spread. However, as part of
   the base case, Moody's considered spread and diversity levels
   higher than the covenant levels due to the large difference
   between the reported and covenant levels.


WIND RIVER: Moody's Upgrades Ratings of Six Classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Wind River CLO I, Ltd.:

US$365,000,000 Class A-1 Senior Secured Floating Rate Notes, Due
2016 (current outstanding balance of $280,770,062), Upgraded to
Aaa (sf); previously on June 22, 2011, A1 (sf) Placed Under Review
for Possible Upgrade;

US$23,000,000 Class A-2 Senior Secured Floating Rate Notes, Due
2016, Upgraded to A1 (sf); previously on June 22, 2011, Baa2 (sf)
Placed Under Review for Possible Upgrade;

US$25,000,000 Class B-1 Senior Secured Deferrable Floating Rate
Notes, Due 2016, Upgraded to Baa2 (sf); previously on June 22,
2011, Ba2 (sf) Placed Under Review for Possible Upgrade;

US$7,000,000 Class B-2 Senior Secured Deferrable Fixed Rate Notes,
Due 2016, Upgraded to Baa2 (sf); previously on June 22, 2011, Ba2
(sf) Placed Under Review for Possible Upgrade;

US$15,000,000 Class C-1 Senior Secured Deferrable Floating Rate
Notes, Due 2016, Upgraded to Ba3 (sf); previously on June 22,
2011, Caa2 (sf) Placed Under Review for Possible Upgrade; and

US$12,000,000 Class C-2 Senior Secured Deferrable Fixed Rate
Notes, Due 2016, Upgraded to Ba3 (sf); previously on June 22,
2011, Caa2 (sf) Placed Under Review for Possible Upgrade.

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

US$9,000,000 Class D Secured Deferrable Fixed Rate Notes, Due
2016, Confirmed at Caa3 (sf); previously on June 22, 2011 Caa3
(sf) Placed Under Review for Possible Upgrade.

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes are
primarily a result of applying Moody's revised CLO assumptions
described in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011. The primary changes to the
modeling assumptions include (1) a removal of the temporary 30%
default probability macro stress implemented in February 2009 as
well as (2) increased BET liability stress factors and increased
recovery rate assumptions.

The actions also reflect consideration Moody's notes of an
increase in the transaction's overcollateralization ratios due to
delevering of the Class A-1 notes, which have been paid down by
approximately 23% or $84.23 million since the rating action in
October 2009. Based on the latest trustee report dated July 1,
2011, the Class A, Class B, Class C, and Class D
overcollateralization ratios are reported at 134.23%, 121.44%,
109.97%, and 107.37%, respectively, versus August 2009 levels of
123.08%, 113.71%, 104.96%, and 102.92%, respectively.

Additionally, Moody's notes that the underlying portfolio includes
a number of investments in securities that mature after the
maturity of the notes. Based on the July 2011 trustee report,
reference securities that mature after the maturity date of the
notes currently make up approximately 7.97% of the underlying
portfolio. These investments potentially expose the notes to
market risk in the event of liquidation at the time of the notes'
maturity.

Due to the impact of revised and updated key assumptions
referenced in "Moody's Approach to Rating Collateralized Loan
Obligations" published in June 2011, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, diversity score, and weighted average recovery rate, may
be different from the trustee's reported numbers. In its base
case, Moody's analyzed the underlying collateral pool to have a
performing par and principal proceeds balance of $410.5 million,
defaulted par of $6.6 million, a weighted average default
probability of 22.5% (implying a WARF of 3341), a weighted average
recovery rate upon default of 45.25%, and a diversity score of 41.
These default and recovery properties of the collateral pool are
incorporated in cash flow model analysis where they are subject to
stresses as a function of the target rating of each CLO liability
being reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

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

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

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

Moody's notes that this transaction is subject to a high level of
macroeconomic uncertainty, as evidenced by 1) uncertainties of
credit conditions in the general economy and 2) the large
concentration of speculative-grade debt maturing between 2013 and
2015 which may create challenges for issuers to refinance. CDO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CDO documentation by different transactional
parties due to embedded ambiguities.

Sources of additional performance uncertainties are:

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

2) Recovery of defaulted assets: Market value fluctuations in
   defaulted assets reported by the trustee and those assumed to
   be defaulted by Moody's may create volatility in the deal's
   overcollateralization levels. Further, the timing of recoveries
   and the manager's decision to work out versus sell defaulted
   assets create additional uncertainties.

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


ZAIS INVESTMENT: Moody's Upgrades Ratings of Four Classes of Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings four classes of
notes issued by ZAIS Investment Grade Limited V. The classes of
notes affected by the rating actions are as follows:

US$285,000,000 Class A-1 Senior Secured Floating Rate Notes Notes,
(current balance $193,882,863), Upgraded to Baa1 (sf) and Remains
On Review for Possible Upgrade; previously on Jun 24, 2011 B1 (sf)
Placed Under Review for Possible Upgrade

US$25,000,000 Class A-2 Senior Secured Fixed Rate Notes Notes,
Upgraded to B1 (sf) and Remains On Review for Possible Upgrade;
previously on Jun 24, 2011 C (sf) Placed Under Review for Possible
Upgrade

US$37,000,000 Class B-1 Senior Secured Floating Rate Notes Notes,
Upgraded to Caa3 (sf) and Remains On Review for Possible Upgrade;
previously on Jun 24, 2011 C (sf) Placed Under Review for Possible
Upgrade

US$14,000,000 Class B-2 Senior Secured Fixed Rate Notes Notes,
Upgraded to Caa3 (sf) and Remains On Review for Possible Upgrade;
previously on Jun 24, 2011 C (sf) Placed Under Review for Possible
Upgrade

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes result
primarily from the improvement of the credit quality of the
portfolio.

As of the latest trustee report dated July 6, 2011, the Class A
and Class B overcollateralization ratios are reported at 96.89%
and 79.32%, respectively, versus March 2011 levels of 89.40% and
73.52%. Based on this July report the WARF reported is 2449 versus
March 2011 reported WARF of 3958. The transaction triggered an EOD
on April 27, 2009 and, subsequently, acceleration was declared on
August 6, 2009. Therefore, the Class A-1 is receiving all interest
and principal payments and the Class A-2, B-1 and B-2 are
currently deferring interest.

Following an announcement by Moody's on June 22nd that nearly all
CLO tranches currently rated Aa1 and below were placed on review
for possible upgrade ("Moody's places 4,220 tranches from 611 U.S.
and 171 European CLO transactions on review for upgrade"), 98
tranches of U.S. and European Structured Finance (SF) CDOs with
material exposure to CLOs were also placed on review for possible
upgrade ("Moody's places 98 tranches from 19 U.S. and 3 European
SF CDO transactions with exposure to CLOs on review for upgrade").
The rating action on the notes reflects CLO tranche upgrades that
have taken place thus far, as well as a two notch adjustment for
CLO tranches which remain on review for possible upgrade.
According to Moody's, 27% of the collateral has been upgraded
since June 22nd, and 34% remains on review.

ZAIS Investment Grade Limited V is a collateralized debt
obligation backed primarily by a portfolio of CLOs, and SF CDOs.

The principal methodology used in this rating was "Moody's
Approach to Rating SF CDOs" published in November 2010.

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.8 to model the loss distribution for SF CDOs. Within this
framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference
pool. Specifically, correlated defaults are simulated using a
normal (or Gaussian) copula model that applies the asset
correlation framework. Recovery rates for defaulted credits are
generated by applying within the simulation the distributional
assumptions, including correlation between recovery values.
Together, the simulated defaults and recoveries across each of the
Monte Carlo scenarios define the loss distribution for the
reference pool.

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


ZAIS INVESTMENT: Moody's Upgrades Ratings of Six Classes of Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of six classes
of notes issued by ZAIS Investment Grade Limited IX. The classes
of notes affected by the rating actions are:

US$6,090,000 Class X Security Due 2012 (current balance:
$1,290,394), Upgraded to Aaa(sf) ; previously on June 24, 2011
Ba1(sf), Placed on Review for Possible Upgrade

US$81,000,000 Class A-1A Senior Secured Floating Rate Notes Due
2052 (current balance: $57,814,733), Upgraded to B1(sf) and
Remains on Review for Upgrade; previously on June 24, 2011
Caa3(sf), Placed on Review for Possible Upgrade

US$90,079,566 Class A-1B Senior Secured Floating Rate Notes Due
2052 (current balance: $88,691,752), Upgraded to B1 (sf) and
Remains on Review for Upgrade; previously on June 24, 2011 Caa3
(sf), Placed on Review for Possible Upgrade

US$39,920,434 Class A-1C Senior Secured Floating Rate Notes Due
2052, Upgraded to B2(sf) and Placed Under Review for Possible
Upgrade; previously on Sep 9, 2009 Downgraded to Ca(sf)

US$54,000,000 Class A-2 Senior Secured Floating Rate Notes Due
2052, Upgraded to Caa1(sf) and Remains on Review for Upgrade ;
previously on June 24, 2011 Ca(sf), Placed on Review for Possible
Upgrade

US$58,000,000 Class B Senior Secured Floating Rate Notes Due 2052,
Upgraded to Caa3(sf); previously on June 24, 2011 Ca(sf), Placed
on Review for Possible Upgrade

RATINGS RATIONALE

According to Moody's, the rating actions taken on the notes
results primarily from the improvement of the credit quality of
the portfolio.

As of the latest trustee report dated June 3, 2011, the Class A
and Class A/B overcollateralization ratios are reported at 117.8%
and 74.45%, respectively, versus August 2009 levels of 114.6% and
71.19%, respectively. Based on this June report the WARF reported
is 3378 versus August 2009 reported WARF of 4005. Additionally the
Class A-1A notes have paid down approximately $16 million.

Following an announcement by Moody's on June 22nd that nearly all
CLO tranches currently rated Aa1 and below were placed on review
for possible upgrade ("Moody's places 4,220 tranches from 611 U.S.
and 171 European CLO transactions on review for upgrade"), 98
tranches of U.S. and European Structured Finance (SF) CDOs with
material exposure to CLOs were also placed on review for possible
upgrade ("Moody's places 98 tranches from 19 U.S. and 3 European
SF CDO transactions with exposure to CLOs on review for upgrade").
The rating action on the notes reflects CLO tranche upgrades that
have taken place thus far, as well as a two notch adjustment for
CLO tranches which remain on review for possible upgrade.
According to Moody's, 12% of the collateral has been upgraded
since June 22nd, and 68% remains on review.

ZAIS Investment Grade Limited IX. is a collateralized debt
obligation backed primarily by a portfolio of CLOs, and SF CDOs.

The principal methodology used in this rating was "Moody's
Approach to Rating SF CDOs" published in November 2010.

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.8 to model the loss distribution for SF CDOs. Within this
framework, defaults are generated so that they occur with the
frequency indicated by the adjusted default probability pool (the
default probability associated with the current rating multiplied
by the Resecuritization Stress) for each credit in the reference
pool. Specifically, correlated defaults are simulated using a
normal (or Gaussian) copula model that applies the asset
correlation framework. Recovery rates for defaulted credits are
generated by applying within the simulation the distributional
assumptions, including correlation between recovery values.
Together, the simulated defaults and recoveries across each of the
Monte Carlo scenarios define the loss distribution for the
reference pool.

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


* S&P Cuts Ratings on 10 Classes of Certs. to 'D' on Shortfalls
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes of commercial mortgage pass-through certificates from
three U.S. commercial mortgage-backed securities (CMBS)
transactions due to interest shortfalls.

"The downgrades reflect current and potential interest shortfalls.
We lowered our ratings on 10 of these classes to 'D (sf)' because
we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. Nine of the 10 classes
that we downgraded to 'D (sf)' have had accumulated interest
shortfalls outstanding for five or more months," S&P related. The
recurring interest shortfalls for the certificates are primarily
due to one or more of these factors:

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

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

    Special servicing fees; and

    Interest rate reductions or deferrals resulting from loan
    modifications.

Standard & Poor's analysis primarily considered the ASER amounts
based on appraisal reduction amounts (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals. "We
also considered servicer nonrecoverable advance declarations,
interest rate deferrals associated with modified loans, and
special servicing fees that are likely, in our view, to
cause recurring interest shortfalls," S&P related.

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

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

"We detail the 15 downgraded classes from the three U.S. CMBS
transactions," S&P said.

   Salomon Bros. Mortgage Securities VII Inc.'s Series 2000-C1

"We lowered our ratings on the class K, L, and M certificates from
Salomon Bros. Mortgage Securities VII Inc.'s series 2000-C1. We
lowered our ratings on classes L and M to 'D (sf)' to reflect
accumulated interest shortfalls outstanding for five and six
months primarily due to $60,042 of interest not advanced by the
master servicer, Berkadia Commercial Mortgage LLC (Berkadia).
Berkadia has made nonrecoverability determinations on four ($12.6
million, 20.4%) of the seven ($8.4 million, 13.5%) loans with the
special servicer, also Berkadia. This caused Berkadia to not
advance interest totaling $60,042 according to the July 2011
trustee remittance report. Special servicing fees and an ASER
amounts also contributed to the interest shortfalls. We downgraded
class K due to reduced liquidity support available to this class
and its potential to experience interest shortfalls relating to
the specially serviced assets. As of the July 2011 trustee
remittance report, an ARA totaling $295,704 was in effect for one
asset (this excludes the assets for which nonrecoverability
determinations have been made). The associated monthly ASER amount
was $2,185. The reported monthly interest shortfalls totaled
$72,108 and have affected all of the classes subordinate to and
including class J," S&P related.

  Salomon Bros. Commercial Mortgage Trust's Series 2000-C3

"We lowered our ratings on the class G and H certificates from
Salomon Bros. Commercial Mortgage Trust's series 2000-C3. We
lowered our rating to 'D (sf)' on the class H certificate to
reflect accumulated interest shortfalls outstanding for 11 months,
primarily due to ASER amounts related to three ($44.8 million,
47.8%) of the nine assets ($73.3 million, 78.1%) that are
currently with the special servicer, LNR Partners Inc. Shortfalls
due to the interest rate modifications of the specially serviced
Granite State Marketplace and Horizon Health Center loans
($21,386), as well as special servicing fees, also contributed to
the interest shortfalls. We lowered our rating on class G due to
reduced liquidity support available to this class its potential to
experience interest shortfalls relating to the specially serviced
assets. As of the July 2011, trustee remittance report, ARAs
totaling $38.1 million were in effect for four assets and the
total reported monthly ASER amount on these assets was $198,479.
The reported monthly interest shortfalls totaled $255,792 and have
affected all of the classes subordinate to and including class H,"
S&P related.

         Merrill Lynch Mortgage Trust's Series 2003-KEY1

"We lowered our ratings on the class E, F, G, H, J, K, L, M, N,
and P certificates from Merrill Lynch Mortgage Trust's series
2003-KEY1. We lowered our ratings on classes H, J, K, L, M, N, and
P to 'D (sf)' to reflect accumulated interest shortfalls
outstanding between one (class H) and 13 months (remaining
classes), primarily due to an ASER amount related to one ($37.2
million, 4.7%) of the two ($40.7 million, 5.1%) assets that are
currently with the special servicer, C-III Asset Management LLC,
and special servicing fees. We downgraded classes E, F, and G due
to reduced liquidity support available to these classes and the
potential for these classes to experience interest shortfalls
relating to the specially serviced assets. As of the July 2011
trustee remittance report, an ARA totaling $35.1 million, (up
from $29.6 million as of the June 2011 trustee remittance report)
was in effect for one asset, the Anchor Bay loan. The total
reported monthly ASER amount was $159,239 (based on an appraisal
amount of $5.7 million from March 2011), compared with the June
2011 figure of $139,019. The reported monthly interest shortfalls
totaled $170,881 and have affected all of the classes subordinate
to and including class H," S&P added.

Ratings Lowered

Salomon Bros. Mortgage Securities VII Inc.
Commercial mortgage pass-through certificates series 2000-C1

                            Credit          Reported
          Rating       enhancement    interest shortfalls ($)
Class  To         From         (%)     Current  Accumulated
K      CCC- (sf)  B- (sf)    23.84      30,093      65,671
L      D (sf)     CCC (sf)   18.10      20,801     104,008
M      D (sf)     CCC- (sf)   6.61      41,609     244,277

Salomon Bros. Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2000-C3

                            Credit          Reported
          Rating       enhancement    interest shortfalls ($)
Class  To         From         (%)     Current  Accumulated
G      CCC+ (sf)  B+ (sf)    54.17           0            0
H      D (sf)     CCC+ (sf)  24.91     119,532      743,146

Merrill Lynch Mortgage Trust
Commercial mortgage pass-through certificates series 2003-KEY1

                            Credit          Reported
          Rating       enhancement    interest shortfalls ($)
Class  To        From          (%)     Current  Accumulated
E      BB+ (sf)  BBB (sf)     7.90           0            0
F      B+ (sf)   BB+ (sf)     6.40           0            0
G      CCC- (sf) B+ (sf)      5.40           0            0
H      D (sf)    CCC (sf)     4.07      25,006       25,006
J      D (sf)    CCC- (sf)    3.40      23,890      179,478
K      D (sf)    CCC- (sf)    2.73      23,889      310,832
L      D (sf)    CCC- (sf)    2.23      17,915      233,095
M      D (sf)    CCC- (sf)    1.40      29,860      388,511
N      D (sf)    CCC- (sf)    1.06      11,945      155,416
P      D (sf)    CCC- (sf)    0.90       5,975       77,738


* S&P Cuts Ratings on 10 Classes of Pass-through Certs. to 'D'
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes of commercial mortgage pass-through certificates from
three U.S. commercial mortgage-backed securities (CMBS)
transactions due to interest shortfalls.

"The downgrades reflect current and potential interest shortfalls.
We lowered our ratings on 10 of these classes to 'D (sf)' because
we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. Of the 10 classes that we
downgraded to 'D (sf)', eight have had accumulated interest
shortfalls outstanding for six or more months. The remaining two
classes have had accumulated interest shortfalls outstanding for
two months," S&P related. The recurring interest shortfalls for
the certificates are primarily due to one or more of these
factors:

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

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

    Special servicing fees; and

    Interest rate reductions or deferrals resulting from loan
    modifications.

Standard & Poor's analysis primarily considered the ASER amounts
based on appraisal reduction amounts (ARAs) calculated using
recent Member of the Appraisal Institute (MAI) appraisals. "We
also considered servicer nonrecoverable advance declarations and
special servicing fees that are likely, in our view, to cause
recurring interest shortfalls," S&P related.

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

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

"We detail the 15 downgraded classes from the three U.S. CMBS
transactions," S&P said.

      Morgan Stanley Dean Witter Capital I Trust 2002-HQ

"We downgraded the class L and M certificates to 'D (sf)' from
Morgan Stanley Dean Witter Capital I Trust 2002-HQ to reflect
accumulated interest shortfalls outstanding for seven and 10
months resulting primarily from interest not advanced from
servicer nonrecoverable advance declarations ($25,753) and
additional expenses ($39,842), both related to the Southwick
Office Building I asset, which is currently with the special
servicer, CWCapital Asset Management LLC (CWCapital). As of the
July 15, 2011, trustee remittance report, two assets ($18.8
million, 6.3%) were with the special servicer. The reported
monthly interest shortfalls totaled $79,026 and have affected all
of the classes subordinate to and including class L," S&P related.

              Morgan Stanley Capital I Trust 2005-HQ5

"We downgraded the class G, H, J, K, L, M, N, O and P certificates
from Morgan Stanley Capital I Trust 2005-HQ5. We lowered our
ratings on classes L, M, N,O, and P to 'D (sf)' to reflect
accumulated interest shortfalls outstanding between two and nine
months, resulting from ASER amounts related to three ($24.4
million, 2.0%) of the seven ($56.2 million, 4.7%) assets that are
currently with the special servicer, CWCapital, as well as special
servicing fees. We downgraded classes G, H, J, and K due to
reduced liquidity support available to these classes, resulting
from the continued interest shortfalls related to the specially
serviced assets. As of the July 14, 2011, trustee remittance
report, ARAs totaling $13.9 million were in effect for three
assets and the total reported ASER amount on these assets was
$63,865. The reported monthly interest shortfalls totaled $73,144
and have affected all of the classes subordinate to and including
class L," S&P related.

            Morgan Stanley Capital I Trust 2007-HQ13

"We downgraded the class C, D, E, and F certificates from Morgan
Stanley Capital I Trust 2007-HQ13. We lowered our ratings on
classes D, E, and F to 'D (sf)' to reflect accumulated interest
shortfalls outstanding between two and 13 months, primarily
resulting from ASER amounts related to four ($101.5 million,
11.4%) of the nine ($227.1 million, 25.5%) assets that are
currently with the special servicer, C-III Asset Management LLC,
as well as special servicing fees and nonrecoverable declaration
for one of the specially serviced assets. We downgraded class C
due to reduced liquidity support available to this class, and the
potential for this class to experience interest shortfalls in the
future relating to the specially serviced assets. As of the July
15, 2011, trustee remittance report, ARAs totaling $47.2 million
were in effect for four assets and the total reported ASER amount
on these assets was $215,543. The reported monthly interest
shortfalls totaled $455,570 and have affected all of the classes
subordinate to and including class D," S&P added.

Ratings Lowered

Morgan Stanley Dean Witter Capital I Trust 2002-HQ
Commercial mortgage pass-through certificates
                              Credit          Reported
          Rating         enhancement    Interest Shortfalls ($)
Class  To        From            (%)     Current  Accumulated
L      D (sf)    CCC (sf)       4.12      42,935      156,800
M      D (sf)    CCC- (sf)      1.98      32,196      314,036

Morgan Stanley Capital I Trust 2005-HQ5
Commercial mortgage pass-through certificates
                            Credit          Reported
          Rating       enhancement    Interest Shortfalls ($)
Class  To         From          (%)     Current   Accumulated
G      BB+ (sf)   BBB- (sf)    5.24           0             0
H      B+ (sf)    BB+ (sf)     4.12           0             0
J      CCC (sf)   BB- (sf)     2.37           0             0
K      CCC- (sf)  B+ (sf)      1.89           0             0
L      D (sf)     B (sf)       1.41       2,994         4,855
M      D (sf)     CCC+ (sf)    0.93      23,870        77,186
N      D (sf)     CCC (sf)     0.61      15,912        80,228
O      D (sf)     CCC- (sf)    0.45       7,958        40,125
P      D (sf)     CCC- (sf)    0.13      15,912       123,542

Morgan Stanley Capital I Trust 2007-HQ13
Commercial mortgage pass-through certificates
                            Credit          Reported
          Rating         enhancement    Interest Shortfalls ($)
Class  To         From           (%)     Current   Accumulated
C      CCC+ (sf)  B+ (sf)      11.03           0             0
D      D (sf)     CCC+ (sf)     9.13      84,768       128,840
E      D (sf)     CCC- (sf)     7.67      66,159       287,922
F      D (sf)     CCC- (sf)     6.35      59,549       704,193


* S&P Raises Ratings on 8 Ford-Related Transactions to 'BB-'
------------------------------------------------------------
Standard & Poor's Ratings Services raised its ratings on eight
Ford Motor Co.-related transactions to 'BB-' from 'B+'.

"All of the transactions are pass-through structures. The ratings
on each of them are dependent on the ratings on one of the
following underlying securities (see the ratings list for more
detailed information): Ford Motor Co.'s 7.45% debentures due July
16, 2031 ('BB-'); Ford Motor Co.'s 7.7% debentures due May 15,
2097 ('BB-'); and Ford Motor Co.'s 7.4% debentures due
Nov. 1, 2046 ('BB-')," S&P said.

"The upgrades follow our July 29, 2011, raising of our ratings on
the three underlying securities to 'BB-' from 'B+'. We may take
subsequent rating actions on these transactions due to changes in
our ratings assigned to the underlying securities," S&P said.

Ratings Raised

Corporate Backed Trust Certificates Ford Motor Co. Debenture-
Backed Series
2001-36 Trust
US$58.501 million pass-through series 2001-36 due May 15, 2097
(underlying security: Ford Motor Co.'s 7.7% debentures due May 15,
2097)
                          Rating
Class              To                  From
A1                 BB-                 B+

CorTS Trust For Ford Debentures
$300 million 7.4% pass-through due Nov. 1, 2046
(underlying security: Ford Motor Co.'s 7.4% debentures due Nov. 1,
2046)
                          Rating
Class              To                  From
Certs              BB-                 B+

CorTS Trust II For Ford Notes
$219.584 million 8% pass-through series 2003-3 due July 16, 2031
(underlying security: Ford Motor Co.'s 7.45% debentures due July
16, 2031)
                           Rating
Class              To                  From
Certs              BB-                 B+

PPLUS Trust Series FMC-1
$40 million 8.25% pass-through series FMC-1 due July 16, 2031
(underlying security: Ford Motor Co.'s 7.45% debentures due July
16, 2031)
                           Rating
Class              To                  From
Certs              BB-                 B+

PreferredPlus Trust Series FRD-1
$50 million trust certificates series FRD-1
(underlying security: Ford Motor Co.'s 7.4% debentures due Nov. 1,
2046)
                          Rating
Class              To                  From
Certs              BB-                 B+

Public STEERS Series 1998 F-Z4 Trust
$231.903 million pass-through series 1998 F-Z4 due Nov. 15, 2018
(underlying security: Ford Motor Co.'s 7.7% debentures due May 15,
2097)
                           Rating
Class              To                  From
A                  BB- (sf)            B+ (sf)
B                  BB- (sf)            B+ (sf)

SATURNS Trust No. 2003-5
$75.027 million 8.125% pass-through series 2003-5 due July 16,
2031
(underlying security: Ford Motor Co.'s 7.45% debentures due July
16, 2031)
                          Rating
Class              To                  From
Units              BB-                 B+

Trust Certificates (TRUCs) Series 2002-1 Trust
$32 million 7.7% pass-through series 2002-1 due May 15, 2097
(underlying security: Ford Motor Co.'s 7.7% debentures due May 15,
2097)
                           Rating
Class              To                  From
A-1                BB-                 B+

                           *********

Monday's edition of the TCR delivers a list of indicative prices
for bond issues that reportedly trade well below par.  Prices are
obtained by TCR editors from a variety of outside sources during
the prior week we think are reliable.  Those sources may not,
however, be complete or accurate.  The Monday Bond Pricing table
is compiled on the Friday prior to publication.  Prices reported
are not intended to reflect actual trades.  Prices for actual
trades are probably different.  Our objective is to share
information, not make markets in publicly traded securities.
Nothing in the TCR constitutes an offer or solicitation to buy or
sell any security of any kind.  It is likely that some entity
affiliated with a TCR editor holds some position in the issuers"
public debt and equity securities about which we report.

Each Tuesday edition of the TCR contains a list of companies with
insolvent balance sheets whose shares trade higher than $3 per
share in public markets.  At first glance, this list may look like
the definitive compilation of stocks that are ideal to sell short.
Don't be fooled.  Assets, for example, reported at historical cost
net of depreciation may understate the true value of a firm's
assets.  A company may establish reserves on its balance sheet for
liabilities that may never materialize.  The prices at which
equity securities trade in public market are determined by more
than a balance sheet solvency test.

A list of Meetings, Conferences and Seminars appears in each
Wednesday's edition of the TCR.  Submissions about insolvency-
related conferences are encouraged.  Send announcements to
conferences@bankrupt.com/

On Thursdays, the TCR delivers a list of recently filed
Chapter 11 cases involving less than $1,000,000 in assets and
liabilities delivered to nation's bankruptcy courts.  The list
includes links to freely downloadable images of these small-dollar
petitions in Acrobat PDF format.

Each Friday's edition of the TCR includes a review about a book of
interest to troubled company professionals.  All titles are
available at your local bookstore or through Amazon.com.  Go to
http://www.bankrupt.com/books/to order any title today.

Monthly Operating Reports are summarized in every Saturday edition
of the TCR.

The Sunday TCR delivers securitization rating news from the week
then-ending.

For copies of court documents filed in the District of Delaware,
please contact Vito at Parcels, Inc., at 302-658-9911.  For
bankruptcy documents filed in cases pending outside the District
of Delaware, contact Ken Troubh at Nationwide Research &
Consulting at 207/791-2852.

                           *********

S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter is a daily newsletter co-published
by Bankruptcy Creditors" Service, Inc., Fairless Hills,
Pennsylvania, USA, and Beard Group, Inc., Frederick, Maryland,
USA.  Jhonas Dampog, Marites Claro, Joy Agravante, Rousel Elaine
Tumanda, Howard C. Tolentino, Joseph Medel C. Martirez, Denise
Marie Varquez, Ronald C. Sy, Joel Anthony G. Lopez, Cecil R.
Villacampa, Sheryl Joy P. Olano, Carlo Fernandez, Christopher G.
Patalinghug, and Peter A. Chapman, Editors.

Copyright 2011.  All rights reserved.  ISSN: 1520-9474.

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

The TCR subscription rate is $775 for 6 months delivered via e-
mail.  Additional e-mail subscriptions for members of the same
firm for the term of the initial subscription or balance thereof
are $25 each.  For subscription information, contact Christopher
Beard at 240/629-3300.


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