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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 21, 2011, Vol. 15, No. 231

                            Headlines

ABERDEEN LOAN: Moody's Upgrades Ratings of 5 Classes of CLO Notes
ACAS BLT 2007-2: Fitch Affirms Ratings on 5 Classes of Notes
ACAS BLT 2004-1: Fitch Affirms Class D Notes at 'CCCsf'
ACAS BLT 2005-1: Fitch Affirms Ratings on 3 Classes
ACAS BLT 2006-1: Fitch Affirms Ratings on 4 Classes of Notes

ACAS BLT 2007-1: Fitch Affirms Ratings on 4 Classes of Notes
ACAS CLO: Fitch Affirms 'Bsf' Rating on $15.5-Mil. Class D Notes
ACA CLO: Moody's Upgrades Ratings of Class D Notes to 'B1'
ADRASTEA SHG: S&P Lowers Ratings on 4 Classes to 'D'
AIMCO CLO: Moody's Upgrades Ratings of Series 2006-A Notes

ALPINE SECURITIZATION: DBRS Puts 'BB' Liquidity Facility Rating
AMERICREDIT AUTOMOBILE: Moody's Raises Ratings of Auto Loan ABS
AMMC CLO: Moody's Upgrades Ratings of Floatin Rate Notes
AMMC VII: Moody's Raises Rating of Class C Notes to A3 From Ba1
APIDOS CDO: Moody's Upgrades Class B Notes Rating to A3 From Ba1

APIDOS CDO: Moody's Upgrades Rating of Class C Notes to 'Ba1'
APIDOS CINCO: Moody's Upgrades Ratings of Class C Notes to 'Ba1'
APIDOS QUATTRO: Moody's Upgrades Ratings of Class D Notes to 'Ba1'
ARES NF: Moody's Upgrades Ratings of Class D Notes to Ba1 From B1
ARES VII: Fitch Lowers Rating on $26-Mil. Class C Notes to 'D'

ARLO IX: S&P Puts 'B+' Rating on Tranche 2007 on Watch Positive
AVALON CAPITAL: Moody's Upgrades Class D Notes Ratings to 'Ba2'
AVENUE CLO: Moody's Upgrades Ratings of Five Classes of CLO Notes
AVERY STREET: Moody's Upgrades Class D Notes Due 2018 to 'Ba2'
AVIS BUDGET: Moody's Assigns Ratings to Series 2011-5 Sr. ABS

BABSON CLO: Moody's Upgrades Class C-1 Notes Rating to 'Ba1'
BABSON CLO: S&P Gives 'BB' Rating on Class D Deferrable Notes
BAKER STREET: Moody's Upgrades Ratings of 6 Classes of CLO Notes
BANC OF AMERICA: Fitch Affirms BALL 2005-MIB1 Ratings
BANC OF AMERICA: S&P Cuts Rating on Class N Certificates to 'D'

BANC OF AMERICA: S&P Lowers Rating on Class B Certs. to 'CCC'
BARRINGTON II: S&P Affirms Ratings on 9 Classes of Notes at 'CC'
BEAR STEARNS: Fitch Takes Various Rating Actions
BEAR STEARNS: DBRS Downgrades Class B From 'BB' to 'B'
BEAR STEARNS: Moody's Downgrades Class C Notes Rating to 'Ba1'

BECKMAN COULTER: Fitch Affirms Class A at 'BB-'
BERKELEY STREET: Moody's Upgrades Class A-2 Notes Rating to 'Ba3'
BLACKROCK SENIOR: Moody's Raises Ratings of 7 Classes of CLO Notes
BLUEMOUNTAIN CLO: Moody's Upgrades Class E Notes Rating to 'Ba2'
CALIFORNIA HOUSING: Moody's Lowers IFSR to 'C' From 'Caa3'

CALLIDUS DEBT: Moody's Raises Ratings of Class D Notes to 'Ba1'
CAMBER 3: S&P Affirms Ratings on 5 Classes of Notes at 'CC'
CANADA MORTGAGE: Moody's Withdraws Ratings On Three Transactions
CAPITALSOURCE REAL: Fitch Affirms Junk Rating on 7 Note Classes
CAVALRY CLO: Moody's Upgrades Class D Notes Rating to Baa3 From B3

CEAGO ABS: S&P Lowers Ratings on 5 Classes of Notes to 'D'
CENT CDO: Moody's Upgrades Class D Notes Rating to 'Ba3'
CENT CDO: Moody's Upgrades Rating of Class D Notes to 'Ba2'
CENT CDO: Moody's Upgrades Ratings of Five Classes of CLO Notes
CENTURION CDO: Moody's Raises Rating of Class C-1 Notes to 'Ba1'

COAST INVESTMENT: Moody's Raises Class B-1 Rating to Baa3 from B2
COBALT CMBS: Moody's Affirms Cl. A-JFX Notes Rating at 'Ba3'
COMM 2004-LNB2: S&P Lowers Rating on Class K Certs. to 'D'
CORNERSTONE CLO: Moody's Upgrades Ratings of Four Classes of Notes
CRESS 2008-1: S&P Affirms Ratings on 9 Classes at 'CCC-'

CREST 2003-2: Moody's Affirms Ratings of Nine Classes of Notes
CS FIRST: Moody's Affirms Class J Notes Rating at 'C'
CSFB 2001-CP4: Modeled Losses Cue Fitch to Downgrade Ratings
DENALI CAPITAL: Moody's Raises Class C Rating to Baa1 From B1
DRYDEN XI-LEVERAGED: Moody's Upgrades Ratings of CLO Notes

DUANE STREET: Moody's Upgrades Rating of Class D Notes to 'Ba1'
DUANE STREET: Moody's Upgrades Rating of Class D Notes to 'Ba3'
FLAGSHIP CLO: Moody's Raises Rating of Class C to Baa3 from Ba3
FLAGSHIP CLO: Moody's Upgrades Ratings of Class D Notes to 'Ba1'
FLAGSHIP CLO: Moody's Upgrades Ratings of Five Classes of Notes

FOOTHILL CLO: Moody's Upgrades Ratings of Five Classes of Notes
FRANKLIN CLO: Moody's Upgrades Class D Notes Rating to Ba1 From B2
GALAXY VI: Moody's Upgrades Ratings of Seven Classes of Notes
GALAXY X CLO: Moody's Upgrades Class C Notes to 'A2' From 'Ba1'
GANNETT PEAK: Moody's Upgrades Ratings of 8 Classes of CLO Notes

GCO ELF: Fitch Lowers Rating on Four Classes of Notes to 'Bsf'
GE COMMERCIAL: Fitch Affirms GECMC 2003-C2 Ratings
GENERAL ELECTRIC: Fitch Affirm Rating on $1.8MM Notes at 'Dsf'
GMAC COMMERCIAL: Fitch Affirms Rating on $3.3-Mil. Notes at 'D'
GREEN LANE: Moody's Raises Class Notes Rating to A2(sf) From Ba2

GULF STREAM: Moody's Upgrades Ratings of 4 Classes of CLO Notes
HALCYON STRUCTURED: Moody's Raises Ratings of CLO Notes
HALCYON STRUCTURED: Moody's Upgrades Ratings of CLO Notes Due 2021
IXIS ABS: S&P Lowers Ratings on 2 Classes of Notes to 'D'
JASPER CLO: Moody's Upgrades Class C Notes Rating to 'Ba1'

JP MORGAN: Fitch Affirm Junk Rating on Eight Note Classes
JP MORGAN: Moody's Affirms 17 CMBS Classes of JPMCC 2007-CIBC18
JP MORGAN: Moody's Affirms 18 CMBS Classes of JPMCC 2006-CIBC14
JP MORGAN: Moody's Affirms Cl. A-J Notes Rating at 'B1'
JP MORGAN: Moody's Upgrades Class G Notes Rating to 'B1'

JPMORGAN CHASE: Fitch Downgrades Ratings on 3 Classes
JPMORGAN CHASE: Fitch Places 5 Classes on Positive Watch
JPMORGAN CHASE: S&P Lowers Rating on Class J Certificates to 'D'
KENNECOTT FUNDING: Moody's Upgrades Ratings of CLO Notes
KNOWLEDGEFUNDING OHIO: Moody's Lowers Bond Ratings to 'Caa3'

LAGUNA ABS: S&P Lowers Ratings on 3 Classes of Notes to 'CC'
LANDMARK V CDO: Moody's Raises Ratings of Class B-1L Notes to Ba1
LANDMARK VIII: Moody's Upgrades Class D Notes Rating to 'Ba1'
LB-UBS COMMERCIAL: Fitch Takes Various Rating Actions
LB-UBS COMMERCIAL: Moody's Affirms Class J Notes Rating at 'Caa2'

LCM IX: S&P Gives 'BB' Rating on Class E Deferrable Notes
LNR CDO: Fitch Withdraw 'Dsf' Rating on 10 Note Classes
LNR CDO: S&P Lowers Ratings on 9 Classes to 'D' Foll. Liquidation
MADISON PARK: Moody's Upgrades Ratings of 8 Classes of CLO Notes
MADISON PARK: S&P Affirms 'BB' Rating on Class E Deferrable Notes

MARATHON REAL: Fitch Affirms Junk Ratings on Four Note Classes
MAXIM HIGH: Fitch Withdraws 'Dsf' Rating on 10 Note Classes
MERCATOR CLO: Moody's Upgrades Ratings of EUR277.9-Mil. CLO Notes
MERRILL LYNCH: Moody's Affirms Cl. F Notes Rating at 'Ba2'
MERRILL LYNCH: Moody's Affirms Ratings of Six CMBS Classes

MM COMMUNITY: Moody's Lowers Rating of Class A-2 Notes to 'Ba1'
MONTANA HIGHER: Fitch Affirms 'B' Rating on Seven Note Classes
MONUMENT PARK: Moody's Upgrades Ratings of CLO Notes
MORGAN STANLEY: Moody's Affirms Class G Notes Rating at 'Ba2'
MORGAN STANLEY: Moody's Upgrades Class H Notes Rating to 'Ba2'

NAVIGATOR CDO: Moody's Assigns Ba3 Rating to Class B Certificates
NAVIGATOR CDO: Moody's Updgrades Class C-1 Notes Rating to Ba1
NORTHWESTERN INVESTMENTS: Fitch Holds Junk Rating on Two Notes
NORTHWOODS CAPITAL: Moody's Raises & Confirms Ratings of CLO Notes
OCEAN TRAILS: Moody's Upgrades Class C Notes Rating to 'Ba2'

PARTS STUDENT: Moody's Reviews Ratings for Possible Downgrade
PETRA CRE: Fitch Affirms Junk Ratings on Seven Note Classes
PHOENIX CLO: Moody's Updgrades Ratings of Class D Notes to 'Ba2'
PLC CAPITAL: Moody's Rates Preferred Stock at (P) Ba1
PREMIUM LOAN: Moody's Upgrades Rating of Class C Notes to 'Caa1'

PRIMUS CLO: Moody's Upgrades Ratings of Five Classes of Notes
RENTAL CAR: Moody's Raises Ratings of Rental Car Asset Notes
REPACS TRUST: Moody's Upgrades Ratings of Class A Debt Unit to B1
RESOURCE REAL: Fitch Affirms Junk Ratings on Nine Note Classes
RESOURCE REAL: Fitch Affirms Junk Ratings on Six Note Classes

RFC CDO: Fitch Affirms Junk Ratings on All Notes Classes
SANDELMAN REALTY: Moody's Upgrades Cl. A-2 Notes Ratings to 'B3'
SIERRA TIMESHARE: S&P Affirms Rating on Class C Notes at 'BB'
SIMSBURY CLO: Fitch Lifts Junk Rating on $1 Mil. Notes to 'BBsf'
SLM STUDENT: Fitch Affirms 'BBsf' Rating on Class B Notes

SILVER MARLIN: Fitch Withdraws 'D' Rating on Nine Note Classes
TRICADIA CDO: Moody's Raises Class A-1LA Rating to Aa3 From Ba1
TRICADIA CDO: Moody's Upgrades Class B Notes Rating to 'B3'
TROPIC CDO: Moody's Downgrades Rating of Class A-3L Notes to Caa1
VERITAS CLO: Moody's Upgrades Class D Notes Rating to 'Ba1'

VICTORIA FALLS: Moody's Upgrades Class D Notes Due 2017 to 'B1'
VITESSE CLO: Moody's Raises Rating of Class B-1L Rating to 'Ba1'
WACHOVIA BANK: Moody's Affirms Cl. LXR-1 Notes Rating at 'B2'
WACHOVIA BANK: Moody's Affirms Ratings of 17 Classes of Notes
WASHINGTON MUTUAL: Modeled Losses Cue Fitch to Downgrade Ratings

WFRBS COMMERCIAL: Moody's Assigns Ratings to 14 CMBS Classes
WHITE KNIGHT: DBRS Confirms Floating Rate Note Rating at 'B'

* S&P Cuts Ratings on 11 Classes of 3 Wachovia Bank Certs. to 'D'
* S&P Cuts Ratings on 1,435 Classes from 363 CMBS Subprime Deals
* S&P Cuts Ratings on 1,692 Classes from 256 CMBS Transactions
* S&P Withdraws Ratings on 119 Classes from 59 CMBS and CDO Deals



                            *********



ABERDEEN LOAN: Moody's Upgrades Ratings of 5 Classes of CLO Notes
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Aberdeen Loan Funding, Ltd.:

US$376,000,000 Class A Floating Rate Senior Secured Extendable
Notes Due 2018 (current outstanding balance of $363,049,707),
Upgraded to Aa1 (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

US$29,500,000 Class B Floating Rate Senior Secured Extendable
Notes Due 2018, Upgraded to A2 (sf); previously on June 22, 2011
Baa2 (sf) Placed Under Review for Possible Upgrade;

US$25,250,000 Class C Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due 2018, Upgraded to Baa3 (sf);
previously on June 22, 2011 Ba2 (sf) Placed Under Review for
Possible Upgrade;

US$19,250,000 Class D Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due 2018, Upgraded to Ba2 (sf);
previously on June 22, 2011 Caa1 (sf) Placed Under Review for
Possible Upgrade; and

US$17,250,000 Class E Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due 2018 (current balance of
$11,756,506), 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.

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 $478.9 million,
defaulted par of $3.9 million, a weighted average default
probability of 24.2% (implying a WARF of 3028), a weighted average
recovery rate upon default of 51.9%, 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.

Aberdeen Loan Funding, 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.

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

4) 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.


ACAS BLT 2007-2: Fitch Affirms Ratings on 5 Classes of Notes
------------------------------------------------------------
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.


ACAS BLT 2004-1: Fitch Affirms Class D Notes at 'CCCsf'
--------------------------------------------------------
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 BLT 2005-1: Fitch Affirms Ratings on 3 Classes
---------------------------------------------------
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 (and the
affirmations of the class A-1 and A-2B [collectively, the class A
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 BLT 2006-1: Fitch Affirms Ratings on 4 Classes of Notes
------------------------------------------------------------
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, 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 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 BLT 2007-1: Fitch Affirms Ratings on 4 Classes of Notes
------------------------------------------------------------
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 CLO: Fitch Affirms 'Bsf' Rating on $15.5-Mil. Class D Notes
----------------------------------------------------------------
Fitch Ratings has affirmed seven classes of notes issued by ACAS
CLO 2007-1 Ltd./Corp.(ACAS CLO 2007-1) and revised Rating Outlooks
as:

  -- $110,750,000 class A-1 notes at 'AAAsf'; Outlook Stable;
  -- $135,000,000 class A-1-S notes at 'AAAsf'; Outlook Stable;
  -- $33,750,000 class A-1-J notes at 'AAAsf'; Outlook Stable;
  -- $25,000,000 class A-2 notes at 'AAsf'; Outlook Stable;
  -- $22,000,000 class B notes at 'Asf'; Outlook Stable;
  -- $21,000,000 class C notes at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $15,500,000 class D notes at 'Bsf'; Outlook to Stable from
     Negative.

The affirmation of the notes is based on the steady credit
enhancement levels for all classes, as well as the stable
performance of the underlying portfolio since Fitch's last rating
action in August 2010.  Fitch expects the ratings on the notes to
remain stable in the near term and has maintained the Stable
Outlook on the class A-1, A-1-S, A-1-J, A-2 and B notes.  This is
also reflected in Fitch's outlook revision to Stable from Negative
for the class C and D notes.

The current portfolio continues to generate a considerable amount
of excess spread, and all classes of notes are likely to perform
at or above their current ratings under modeled stresses.
However, upgrades are not warranted at this time since the
transaction remains in its reinvestment period until April 2014
and may be managed to covenanted levels which may negatively
affect the portfolio and future cash flows.  In its analysis,
Fitch applied stress scenarios at covenanted levels including
weighted-average rating factor, weighted-average life and
weighted-average spread.

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'.  Fitch's modeling results for the class A-2, B, and D
notes indicated a higher passing rating when analyzing with the
current portfolio's characteristics; however, analysis with the
portfolio stressed to covenanted levels indicated that an upgrade
was not warranted for these notes.

ACAS CLO 2007-1 is a cash flow CLO that closed April 26, 2007, and
is managed by American Capital Asset Management, LLC.  The
portfolio is currently composed of 92.1% senior secured loans,
3.1% senior secured debt, 2.4% junior secured/mezzanine debt and
2.4% structured finance assets.  Approximately 14.6% of the $374
million collateral is not publicly rated, however, Fitch has
credit opinions for these performing loans. Information for the
credit opinions was gathered from financial statements provided to
Fitch by the manager or the public domain.  ACAS CLO 2007-1 is
currently in its reinvestment period through April 20, 2014.
During the reinvestment period, failure of the reinvestment
overcollateralization test (OC) test will divert up to 50% of
excess interest to invest in additional collateral to build credit
enhancement for the notes.


ACA CLO: Moody's Upgrades Ratings of Class D Notes to 'B1'
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by ACA CLO 2006-1, Ltd.:

US$255,500,000 Class A-1 Senior Secured Floating Rate Notes, Due
July 2018 (current balance of $245,631,309), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa1 (sf) Placed on Review for Possible
Upgrade;

US$21,000,000 Class A-2 Senior Secured Floating Rate Notes, Due
July 2018, Upgraded to Aa2 (sf); previously on June 22, 2011 A2
(sf) Placed on Review for Possible Upgrade;

US$22,750,000 Class B Deferrable Floating Rate Notes, Due July
2018, Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed on Review for Possible Upgrade;

US$11,375,000 Class C Deferrable Floating Rate Notes, Due July
2018 Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf)
Placed on Review for Possible Upgrade;

US$11,375,000 Class D Deferrable Floating Rate Notes, Due July
2018, Upgraded to B1 (sf); previously on June 22, 2011 Caa3 (sf)
Placed on 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 latest trustee report dated July 13, 2011, the
weighted average rating factor is currently 2586 compared to 2677
in the August 2009 report. The Class A, Class B, Class C and Class
D overcollateralization ratios are reported at 123.50%, 113.79%,
109.48 and 105.49%, respectively, versus August 2009 levels of
121.08%, 111.56%, 107.34 and 103.13%, 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 $329 million,
defaulted par of $4.3 million, a weighted average default
probability of 19.67% (implying a WARF of 2787), a weighted
average recovery rate upon default of 49.55%, and a diversity
score of 70. 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.

ACA CLO 2006-1, Ltd., issued in July 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) 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.


ADRASTEA SHG: S&P Lowers Ratings on 4 Classes to 'D'
----------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D (sf)'
on four classes from Adrastea SHG 2007-1 Ltd. following the
nonpayment of timely interest to these classes. "At the same time,
we affirmed our ratings on three classes at 'CC (sf)' from the
same transaction. The transaction is a U.S. hybrid collateralized
debt obligation transaction backed substantially by residential
mortgage-backed securities," S&P said.

"The rating actions reflect our criteria for ratings on CDO
transactions that have triggered an event of default (EOD) and may
be subject to acceleration or liquidation," S&P related.

Rating Actions
Adrastea SHG 2007-1 Ltd.
                            Rating
Class               To                 From
A-1Q                D (sf)             CC (sf)
A-2                 D (sf)             CC (sf)
A-3                 D (sf)             CC (sf)
A-4                 D (sf)             CC (sf)

Ratings Affirmed

Adrastea SHG 2007-1 Ltd.
Class               Rating
A-1M                CC (sf)
A-1M Unfunded       CC (sf)
B                   CC (sf)


AIMCO CLO: Moody's Upgrades Ratings of Series 2006-A Notes
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by AIMCO CLO, Series 2006-A

US$305,000,000 Class A-1 Senior Notes Due 2020 (current
outstanding balance of $300,308,883), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$21,500,000 Class A-2 Senior Notes Due 2020, Upgraded to Aa3
(sf), previously on June 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

US$20,000,000 Class B Deferrable Mezzanine Notes Due 2020,
Upgraded to A3 (sf), previously on June 22, 2011 Baa3 (sf) Placed
Under Review for Possible Upgrade;

US$19,000,000 Class C Deferrable Mezzanine Notes Due 2020,
Upgraded to Ba1 (sf), previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

US$12,500,000 Class D Deferrable Mezzanine Notes Due 2020 (current
outstanding balance of $10,446,966), 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 actions also reflect consideration of improvement in the
credit quality of the underlying portfolio since the rating action
in July 2009. Based on the July 2011 trustee report, the weighted
average rating factor is currently 2350 compared to 2619 in June
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 $392 million,
defaulted par of $2 million, a weighted average default
probability of 19% (implying a WARF of 2598), a weighted average
recovery rate upon default of 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.

AIMCO CLO, Series 2006-A, issued in July 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 is:

1) 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.


ALPINE SECURITIZATION: DBRS Puts 'BB' Liquidity Facility Rating
---------------------------------------------------------------
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 $8,076,325,106 aggregate liquidity facilities are tranched as:

  -- $7,713,433,205 rated AAA (sf)
  -- $80,774,558 rated AA (sf)
  -- $42,126,112 rated A (sf)
  -- $64,026,683 rated BBB (sf)
  -- $59,205,924 rated BB (sf)
  -- $44,160,861 rated B (sf)
  -- $72,597,763 unrated (sf)

The ratings are based on April 30, 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 our website under Methodologies.


AMERICREDIT AUTOMOBILE: Moody's Raises Ratings of Auto Loan ABS
---------------------------------------------------------------
Moody's Investors Service has upgraded five tranches from three
near-prime transactions and 26 tranches from 11 subprime auto loan
transactions sponsored by AmeriCredit Financial Services, Inc
(AmeriCredit).

Complete rating actions are:

Issuer: AmeriCredit Automobile Receivables Trust 2007-A-X

Cl. A-4, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 Aa3 (sf) Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2007-B-F

Cl. A-4, Upgraded to Aa1 (sf); previously on May 17, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aa1 (sf); previously on May 17,
2011 A3 (sf) Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2007-C-M

Cl. A-4-A, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3
(sf) Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 Aa3 (sf) Placed Under Review for Possible Upgrade

Cl. A-4-B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3
(sf) Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 Aa3 (sf) Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2007-D-F

Cl. A-4-A, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3
(sf) Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 Aa3 (sf) Placed Under Review for Possible Upgrade

Cl. A-4-B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3
(sf) Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 Aa3 (sf) Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2009-1

Cl. B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade

Cl. C, Upgraded to Aaa (sf); previously on May 17, 2011 A2 (sf)
Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Auto Receivables Trust 2010-1

Cl. B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa1 (sf)
Placed Under Review for Possible Upgrade

Cl. C, Upgraded to Aaa (sf); previously on May 17, 2011 A1 (sf)
Placed Under Review for Possible Upgrade

Cl. D, Upgraded to Aa1 (sf); previously on May 17, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2010-2

Cl. B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa1 (sf)
Placed Under Review for Possible Upgrade

Cl. C, Upgraded to Aaa (sf); previously on May 17, 2011 A1 (sf)
Placed Under Review for Possible Upgrade

Cl. D, Upgraded to Aa2 (sf); previously on May 17, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade

Cl. E, Upgraded to A1 (sf); previously on May 17, 2011 Ba3 (sf)
Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2010-3

Cl. B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa1 (sf)
Placed Under Review for Possible Upgrade

Cl. C, Upgraded to Aaa (sf); previously on May 17, 2011 A1 (sf)
Placed Under Review for Possible Upgrade

Cl. D, Upgraded to Aa2 (sf); previously on May 17, 2011 Baa2 (sf)
Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2010-4

Cl. B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa1 (sf)
Placed Under Review for Possible Upgrade

Cl. C, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

Cl. D, Upgraded to Aa2 (sf); previously on May 17, 2011 Baa1 (sf)
Placed Under Review for Possible Upgrade

Cl. E, Upgraded to A2 (sf); previously on May 17, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2010-A

Cl. A-2, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 A1 (sf) Placed Under Review for Possible Upgrade

Cl. A-3, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 A1 (sf) Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Automobile Receivables Trust 2010-B

Cl. A-2, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 A1 (sf) Placed Under Review for Possible Upgrade

Cl. A-3, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 A1 (sf) Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Prime Automobile Receivables Trust 2007-1

Cl. D, Upgraded to Aaa (sf); previously on May 17, 2011 A2 (sf)
Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Prime Automobile Receivables Trust 2007-2-M

Cl. A-4-A, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3
(sf) Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 Aa3 (sf) Placed Under Review for Possible Upgrade

Cl. A-4-B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa3
(sf) Placed Under Review for Possible Upgrade

Underlying Rating: Upgraded to Aaa (sf); previously on May 17,
2011 Aa3 (sf) Placed Under Review for Possible Upgrade

Issuer: AmeriCredit Prime Automobile Receivables Trust 2009-1

Cl. B, Upgraded to Aaa (sf); previously on May 17, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade

Cl. C, Upgraded to Aaa (sf); previously on May 17, 2011 A1 (sf)
Placed Under Review for Possible Upgrade

RATINGS RATIONALE

The actions were driven by a combination of downward revision of
collateral loss expectations and further accretion of credit
enhancement. The upgrades to transactions issued prior to 2009
were predominantly due to buildup in credit enhancement while the
upgrades of the 2009 and 2010 transactions were mostly due to
decrease in expected losses. In the case of the 2007-2-M, 2007-C-
M, 2007-D-F and 2008-A-F, consideration was also given to past
amendments that, among other things, resulted in revised credit
performance triggers and an increase in the amount required for
the spread (reserve) account. For the 2007-A-X and 2007-B-F, the
reserve accounts have increased due to earlier breaches of the
cumulative net loss triggers. Even though the triggers for these
transactions are curable, the current cumulative net losses (CNL)
are higher than the highest trigger level for all these
transactions. The reserve account will therefore not likely step
down.

Below are key performance metrics (as of the July distribution
date) and credit assumptions for each affected transaction. Credit
assumptions include Moody's expected lifetime CNL expectation
which is expressed as a percentage of the original pool balance;
and Moody's lifetime remaining CNL expectation and Moody's Aaa
levels which are expressed as a percentage of the current pool
balance. The Aaa level is the level of credit enhancement that
would be consistent with a Aaa rating for the given asset pool.
Performance metrics include pool factor which is the ratio of the
current collateral balance to the original collateral balance at
closing; total credit enhancement, which typically consists of
subordination, overcollateralization, and a reserve fund; and per
annum excess spread.

AmeriCredit Subprime transactions:

Issuer: AmeriCredit Automobile Receivables Trust 2007-A-X

Lifetime CNL expectation - 18.25%, prior expected range (May
2011) -- 18.00% -- 18.50%

Lifetime Remaining CNL expectation -- 9.99%

Aaa level -- Approximately 30%

Pool factor - 11.7%

Total credit enhancement (excluding excess spread ): Class A --
45.19%

Excess spread -- Approximately 9.7% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2007-B-F

Lifetime CNL expectation - 18.00%, prior expected range (May
2011) -- 18.00% -- 18.50%

Lifetime Remaining CNL expectation -- 10.37%

Aaa level -- Approximately 31%

Pool factor -- 14.17%

Total credit enhancement (excluding excess spread ): Class A --
25.11%

Excess spread -- Approximately 9.1% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2007-C-M

Lifetime CNL expectation - 18.25%, prior expected range (May
2011) -- 18.00% -- 18.50%

Lifetime Remaining CNL expectation -- 9.49%

Aaa level -- Approximately 29%

Pool factor -- 17.77%

Total credit enhancement (excluding excess spread): Class A --
36.32%

Excess spread -- Approximately 8.6% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2007-D-F

Lifetime CNL expectation -- 19.75%, prior expected range (May
2011) -- 19.50% - 20.25%

Lifetime Remaining CNL expectation -- 9.24%

Aaa level -- Approximately 28%

Pool factor - 19.71%

Total credit enhancement (excluding excess spread): Class A -- 41%

Excess spread -- Approximately 8.6% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2009-1

Lifetime CNL expectation -- 13.00%, prior expected range (May
2011) -- 12.75% - 13.50%

Lifetime Remaining CNL expectation -- 13.22%

Aaa level -- Approximately 40%

Pool factor -- 42.32%

Total credit enhancement (excluding excess spread): Class A --
76.16%; Class B -- 60.22%; Class C -- 38.00%

Excess spread -- Approximately 5.6% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2010-1

Lifetime CNL expectation -- 7.00%, prior expected range (May
2011) -- 6.75% -- 7.75%

Lifetime Remaining CNL expectation -- 7.17%

Aaa level -- Approximately 32%

Pool factor - 58.20%

Total credit enhancement (excluding excess spread): Class A --
72.22%; Class B -- 53.32%; Class C -- 33.56%; Class D -- 23.25%

Excess spread -- Approximately 12.2% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2010-2

Lifetime CNL expectation -- 7.00%, prior expected range (May
2011) -- 6.75% -- 8.00%

Lifetime Remaining CNL expectation -- 7.81%

Aaa level -- Approximately 31%

Pool factor -- 64.60%

Total credit enhancement (excluding excess spread ): Class A --
62.07%; Class B -- 49.30%; Class C -- 33.44%; Class D -- 18.73%;
Class E -- 15.25%

Excess spread -- Approximately 11.1% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2010-A

Lifetime CNL expectation -- 8.00%, prior expected range (May 2011)
-- 7.00% - 8.25%

Lifetime Remaining CNL expectation -- 7.77%

Aaa level -- Approximately 31%

Pool factor -- 65.42%

Total credit enhancement (excluding excess spread): Class A --
26.06%

Excess spread -- Approximately 11.5% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2010-B

Lifetime CNL expectation -- 7.00%, prior expected range (May 2011)
-- 6.75% - 8.75%

Lifetime Remaining CNL expectation -- 7.18%

Aaa level -- Approximately 32%

Pool factor -- 76.34%

Total credit enhancement (excluding excess spread): Class A --
24.62%

Excess spread -- Approximately 11.2% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2010-3

Lifetime CNL expectation -- 7.50%, prior expected range (May 2011)
-- 7.75% -- 8.75%

Lifetime Remaining CNL expectation -- 8.16%

Aaa level -- Approximately 32%

Pool factor -- 82.00%

Total credit enhancement (excluding excess spread): Class A --
52.25%; Class B -- 42.80%; Class C -- 30.54%; Class D -- 19.20%

Excess spread -- Approximately 11.5% per annum

Issuer: AmeriCredit Automobile Receivables Trust 2010-4

Lifetime CNL expectation -- 7.50%, prior expected range (May 2011)
-- 7.75% -- 8.75%

Lifetime Remaining CNL expectation -- 8.53%

Aaa level -- Approximately 34%

Pool factor - 77.82%

Total credit enhancement (excluding excess spread): Class A --
50.02%; Class B -- 40.71%; Class C -- 29.14%; Class D -- 17.77%;
Class E -- 14.75%

Excess spread -- Approximately 11.5% per annum

AmeriCredit Near-Prime transactions:

Issuer: AmeriCredit Prime Automobile Receivables Trust 2007-1

Lifetime CNL expectation -- 7.75%, prior expected range (May 2011)
-- 7.50% -- 8.00%

Lifetime Remaining CNL expectation -- 4.69%

Aaa level -- Approximately 21%

Pool factor -- 12.64%

Total credit enhancement (excluding excess spread): Class B --
82.15%; Class C -- 56.43%; Class D -- 28.73%

Excess spread -- Approximately 3.2% per annum

Issuer: AmeriCredit Prime Automobile Receivables Trust 2007-2-M

Lifetime CNL expectation -- 12.00%, prior expected range (May
2011) -- 11.50% -- 12.25%

Lifetime Remaining CNL expectation -- 7.41%

Aaa level -- Approximately 30%

Pool factor - 19.51%

Total credit enhancement (excluding excess spread): Class A --
29.81%

Excess spread -- Approximately 4.5% per annum

Issuer: AmeriCredit Prime Automobile Receivables Trust 2009-1

Lifetime CNL expectation -- 7.00%, prior expected range (May 2011)
-- 6.50% - 7.50%

Lifetime Remaining CNL expectation -- 5.82%

Aaa level -- Approximately 29%

Pool factor -- 45.64%

Total credit enhancement (excluding excess spread): Class A --
50.42%; Class B -- 40.01%; Class C -- 31.25%

Excess spread -- Approximately 5.7% per annum

Ratings on the affected notes could be upgraded (where applicable)
if the lifetime CNLs are lower by 10%, or downgraded if the
lifetime CNLs are higher by 10%.

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 macroeconomic environment,
in which unemployment continues to remain at elevated levels, and
strength in the used vehicle market. Moody's currently views the
used vehicle market as much stronger now than it was at the end of
2008 when the uncertainty relating to the economy as well as the
future of the U.S auto manufacturers was significantly greater.
Overall, Moody's central global scenario remains "Hook-shaped" for
2011; Moody's expects overall a sluggish recovery in most of the
world largest economies, returning to trend growth rate with
elevated fiscal deficits and persistent unemployment levels.

The principal methodology used in these notes was "Moody's
Approach to Rating U.S. Auto Loan Backed Securities (2011)" rating
methodology published in May 2011. Other methodologies and factors
that may have been considered in the process of rating these notes
can also be found on Moody's website.

The underlying ratings reflect the intrinsic credit quality of the
notes in the absence of the transactions' guarantees from monoline
bond insurers. The current ratings on the below notes are
consistent with Moody's practice of rating insured securities at
the higher of the guarantor's insurance financial strength rating
and any underlying rating.

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 6 months.


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

US$330,000,000 Class A-1 Floating Rate Notes Due 2017 (current
balance of 320,980,669), Upgraded to Aaa (sf); previously on
June 22, 2011 Aa2 (sf) Placed under review for possible upgrade;

US$12,500,000 Class A-3 Floating Rate Notes Due 2017, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa3 (sf) Placed under review
for possible upgrade;

US$20,000,000 Class B Floating Rate Notes Due 2017, Upgraded to
Aa1 (sf); previously on June 22, 2011 A2 (sf) Placed under review
for possible upgrade;

US$25,000,000 Class C Floating Rate Deferrable Notes Due 2017,
Upgraded to A2 (sf); previously on June 22, 2011 Baa3 (sf) Placed
under review for possible upgrade;

US$30,000,000 Class D Floating Rate Deferrable Notes Due 2017,
Upgraded to Ba1 (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.

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 2262 compared to 2618 in August 2009.
The improvement in the overcollateralization ratio is a result of
delevering of the Class A-1 and A-2 Notes, which have paid down by
approximately 2.8% or $10.7 million since the rating action in
September 2009, and lower overcollateralization ratio haircuts
from excess Caa/CCC rated securities. Based on the July 2011
trustee report, the senior overcollateralization ratio is reported
at 116.67% 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 $469.5 million,
defaulted par of $5.7 million, a weighted average default
probability of 14.83% (implying a WARF of 2278), a weighted
average recovery rate upon default of 49.3%, 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.

AMMC CLO IV, Limited, 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) 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 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.


AMMC VII: Moody's Raises Rating of Class C Notes to A3 From Ba1
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by AMMC VII, Limited:

US$375,000,000 Class A Floating Rate Notes (current outstanding
balance of $362,231,162), Upgraded to Aaa (sf); previously on
June 22, 2011 A1 (sf) Placed Under Review for Possible Upgrade;

US$22,500,000 Class B Floating Rate Notes, Upgraded to Aa3 (sf);
previously on June 22, 2011 Baa1 (sf) Placed Under Review for
Possible Upgrade;

US$17,500,000 Class C Deferrable Floating Rate Notes, Upgraded to
A3 (sf); previously on June 22, 2011 Ba1 (sf) Placed Under Review
for Possible Upgrade;

US$30,000,000 Class D Deferrable Floating Rate Notes, Upgraded to
Ba2 (sf); previously on June 22, 2011 Caa1 (sf) Placed Under
Review for Possible Upgrade; and

US$15,000,000 Class E Deferrable Floating Rate Notes (current
outstanding balance of 11,237,947), 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.

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 $457.3 million,
defaulted par of $6.3 million, a weighted average default
probability of 22.6% (implying a WARF of 2897), a weighted average
recovery rate upon default of 49.14%, and a diversity score of 74.
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.

AMMC VII, Limited, 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) 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 the 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 and weighted average coupon. However, as part of
   the base case, Moody's considered spread and diversity levels
   higher than the covenant due to the large difference between
   the reported and covenant levels.


APIDOS CDO: Moody's Upgrades Class B Notes Rating to A3 From Ba1
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Apidos CDO II Ltd.:

US$195,000,000 Class A-1 Floating Rate Notes Due 2018 Notes,
Upgraded to Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed
Under Review for Possible Upgrade;

US$100,000,000 Class A-2 Delayed Draw Notes Due 2018 Notes,
Upgraded to Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed
Under Review for Possible Upgrade;

US$22,500,000 Class A-3 Floating Rate Notes Due 2018 Notes,
Upgraded to Aa1 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$24,000,000 Class B Deferrable Floating Rate Notes Due 2018
Notes, Upgraded to A3 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$13,000,000 Class C Floating Rate Notes Due 2018 Notes, Upgraded
to Ba1 (sf); previously on June 22, 2011 B3 (sf) Placed Under
Review for Possible Upgrade;

US$13,500,000 Class D Floating Rate Notes Due 2018 Notes, 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 since the rating action
in September 2009. Based on the July 2011 trustee report, the
Class A, Class B, Class C, and Class D overcollateralization
ratios are reported at 121.64%, 113.10%, 108.95%, and 104.95%,
respectively, versus July 2009 levels of 118.3%, 109.99%, 105.95%,
and 102.07%, 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 $386 million,
defaulted par of $2 million, a weighted average default
probability of 17.5% (implying a WARF of 2566), a weighted average
recovery rate upon default of 49.7%, and a diversity score of 77.
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.

Apidos CDO II Ltd., issued in December of 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. 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) 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.


APIDOS CDO: Moody's Upgrades Rating of Class C Notes to 'Ba1'
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Apidos CDO V:

US$130,000,000 Class A-1 Senior Secured Floating Rate Notes due
2021, Upgraded to Aaa (sf); previously on June 22, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade;

US$17,000,000 Class A-1-J Senior Secured Floating Rate Notes due
2021, Upgraded to Aa1 (sf); previously on June 22, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade;

US$19,000,000 Class A-2 Senior Secured Floating Rate Notes due
2021, 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 2021, Upgraded to Baa1 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$18,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2021, Upgraded to Ba1 (sf); previously on June 22, 2011
B1 (sf) Placed Under Review for Possible Upgrade;

US$12,000,000 Class D Secured Deferrable Floating Rate Notes due
2021, 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. Today's 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 2525 compared to 2755 in the August 2009 report. 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
122.9%, 115.3%, 109.4% and 105.9%, respectively, versus August
2009 levels of 118.5%, 111.1%, 105.5% and 102%, 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 $388 million,
defaulted par of $1.3 million, a weighted average default
probability of 21.7% (implying a WARF of 2750), a weighted average
recovery rate upon default of 49.02%, and a diversity score of 75.
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.

Apidos CDO V, 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.

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:

1) 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.

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.

4) 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.


APIDOS CINCO: Moody's Upgrades Ratings of Class C Notes to 'Ba1'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Apidos Cinco CDO:

US$37,500,000 Class A-1 Floating Rate Notes due 2020, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review
for Possible Upgrade;

US$22,500,000 Class A-2b Floating Rate Notes due 2020, Upgraded to
Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$19,000,000 Class A-3 Floating Rate Notes due 2020, Upgraded to
A1 (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$18,000,000 Class B Deferrable Floating Rate Notes due 2020,
Upgraded to Baa1 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$14,000,000 Class C Floating Rate Notes due 2020, Upgraded to
Ba1 (sf); previously on June 22, 2011 Ba3 (sf) Placed Under Review
for Possible Upgrade;

US$11,000,000 Class D Floating Rate Notes due 2020, 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. Today's 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 2524
compared to 2751 in the August 2009 report. 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
125.2%, 117.6%, 112.3% and 108.5%, respectively, versus August
2009 levels of 122%, 114.6%, 109.4% and 105.7%, 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 $349.6 million,
defaulted par of $361,751, a weighted average default probability
of 21.5% (implying a WARF of 2725), a weighted average recovery
rate upon default of 50.2%, and a diversity score of 76. 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.

Apidos Cinco CDO, issued in May 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. 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:

1) 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.

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 diversity and spread levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.

4) 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.


APIDOS QUATTRO: Moody's Upgrades Ratings of Class D Notes to 'Ba1'
------------------------------------------------------------------
Moody's Investors Service upgraded the ratings of these notes
issued by Apidos Quattro CDO:

$262,000,000 Class A Senior Notes Due 2019, Upgraded to Aaa (sf);
previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

$21,000,000 Class B Senior Notes Due 2019, Upgraded to Aa3 (sf);
previously on June 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

$16,000,000 Class C Deferrable Mezzanine Notes Due 2019, Upgraded
to Baa1 (sf); previously on June 22, 2011 Baa3 (sf) Placed Under
Review for Possible Upgrade;

$14,000,000 Class D Deferrable Mezzanine Notes Due 2019, Upgraded
to Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed Under
Review for Possible Upgrade;

$12,000,000 Class E Deferrable Junior Notes Due 2019, 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. Today's 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 2490
compared to 2630 in the August 2009 report. The
overcollateralization ratios of the rated notes have also improved
since the rating action in September 2009. The Senior and
Mezzanine overcollateralization ratios are reported at 122.4% and
110.6%, respectively, versus August 2009 levels of 119.8% and
108.4%, 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 $346 million,
defaulted par of $0 million, a weighted average default
probability of 18.9% (implying a WARF of 2672), a weighted average
recovery rate upon default of 50.7%, and a diversity score of 75.
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.

Apidos Quattro CDO, 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. 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:

1) 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.

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 and diversity levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.

4) 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 NF: Moody's Upgrades Ratings of Class D Notes to Ba1 From B1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Ares NF CLO XIII Ltd.:

US$16,500,000 Class B Floating Rate Notes, Upgraded to Aa2 (sf);
previously on June 22, 2011 A1 (sf) Placed Under Review for
Possible Upgrade;

US$9,000,000 Class C Deferrable Floating Rate Notes, Upgraded to
A2 (sf); previously on June 22, 2011 Baa3 (sf) Placed Under Review
for Possible Upgrade;

US$27,750,000 Class D Deferrable Floating Rate Notes, 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 credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in July 2009.
Based on the latest trustee report dated July 20, 2011, the
weighted average rating factor is currently 2316 versus 2641 in
June 2009. The Class A/B, Class C, and Class D
overcollateralization ratios are currently reported at 122.14%,
117.67%, and 105.74%, respectively, versus June 2009 levels of
118.91%, 114.56%, and 102.95%, 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 $290 million,
defaulted par of $304,841, a weighted average default probability
of 16.84% (implying a WARF of 2396), a weighted average recovery
rate upon default of 50.82%, and a diversity score of 54. 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 NF CLO XIII 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. 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.

A main source of additional performance uncertainty in this
transaction is the extent of delevering from unscheduled principal
proceeds. Delevering may accelerate due to high prepayment levels
in the loan market and collateral sales by the manager, which may
have significant impact on the notes' ratings.


ARES VII: Fitch Lowers Rating on $26-Mil. Class C Notes to 'D'
--------------------------------------------------------------
Fitch Ratings has downgraded one class of notes issued by Ares
VII, Ltd/Corp. (Ares VII CLO) and withdrawn the rating:

-- $26,718,773 class C notes downgraded to 'D' from 'C/RR5', and
    withdrawn.

The rating actions are the result of the transaction's inability
to pay the full amount of principal due on the redemption date of
Aug. 8, 2011.  At the direction of the class C noteholders, an
optional redemption was declared and the portfolio collateral was
liquidated and proceeds were distributed according to the
transaction documents.

All senior notes were paid in full while the class C notes
received only partial payment consisting of $24,281,227 of
principal and $260,186 of interest; leaving a remaining principal
balance of the class C notes is $26,718,773.

Ares VII CLO is a collateralized debt obligation (CDO) that closed
on May 7, 2003 and is managed by Ares Management, LLC.


ARLO IX: S&P Puts 'B+' Rating on Tranche 2007 on Watch Positive
---------------------------------------------------------------
Standard & Poor's Ratings Services placed its ratings on 16
tranches from 13 corporate-backed synthetic collateralized debt
obligation (CDO) transactions on CreditWatch positive. "At the
same time, we placed our ratings on two tranches from one
synthetic CDO transaction backed by commercial mortgage-backed
securities (CMBS) and six tranches from four corporate-backed
synthetic CDO transactions on CreditWatch negative. In addition,
we affirmed our rating on one tranche from one corporate-backed
synthetic CDO transaction and removed it from CreditWatch
positive. The rating actions followed our monthly review of U.S.
synthetic CDO transactions," S&P related.

The CreditWatch positive placements reflect seasoning of the
transactions, rating stability of the obligors in the underlying
reference portfolios over the past few months, and synthetic rated
overcollateralization (SROC) ratios that had risen above 100% at
the next highest rating level. The CreditWatch negative placements
reflect negative rating migration in the portfolios and SROC
ratios that had fallen below 100% as of the July month-end run.
The affirmation reflects the lack of sufficient cushion at the
next higher rating level.

Rating Actions

ARLO IX Limited
                                 Rating
Class                    To                  From
2007 (Pascal SCO A-1)    B+ (sf)/Watch Pos   B+ (sf)

Athenee CDO PLC
                                 Rating
Class                    To                  From
2007-15                  BB (sf)/Watch Pos   BB (sf)

Cloverie PLC
2007-25
                                 Rating
Class                    To                  From
2007-25                  B- (sf)/Watch Pos   B- (sf)

Cloverie PLC
44
                                 Rating
Class                    To                  From
Nts                      CCC+ (sf)/Watch Neg CCC+ (sf)

Cloverie PLC
43
                                 Rating
Class                    To                  From
Nts                      CCC+ (sf)/Watch Neg CCC+ (sf)

Credit Default Swap
227212/227229/227230
                                 Rating
Class                    To                  From
Trnch                    BB- (sf)/Watch Pos  BB- (sf)

Credit Linked Notes Ltd. 2006-1
2006-1
                                 Rating
Class                    To                  From
Nts                      B (sf)/Watch Neg    B (sf)

Credit-Linked Trust Certificates
2005-I
                                 Rating
Class                    To                  From
2005-I-G                 A (sf)/Watch Pos    A (sf)
2005-I-H                 A- (sf)/Watch Pos   A- (sf)

Greylock Synthetic CDO 2006
1
                                 Rating
Class                    To                  From
A1-$LMS                  BBB- (sf)/Watch Pos BBB- (sf)
A3-$LMS                  BB- (sf)/Watch Pos  BB- (sf)

Greylock Synthetic CDO 2006
3
                                 Rating
Class                    To                  From
A1-EURLMS                  BBB- (sf)/Watch Pos BBB- (sf)

Morgan Stanley ACES SPC
2006-9
                                 Rating
Class                    To                  From
IA                       CCC- (sf)      CCC- (sf)/Watch Pos

Morgan Stanley ACES SPC
2006-27
                                 Rating
Class                    To                  From
Class A                  B (sf)/Watch Pos    B (sf)

Morgan Stanley Managed ACES SPC
2007-16
                                 Rating
Class                    To                  From
IIB                      B (sf)/Watch Pos    B (sf)

Omega Capital Investments PLC
19
                                 Rating
Class                    To                  From
A-1E                     CCC+ (sf)/Watch Pos CCC+ (sf)
A-1U                     CCC+ (sf)/Watch Pos CCC+ (sf)

Pegasus 2007-1, Ltd.
                                 Rating
Class                    To                  From
A1                       BB (sf)/Watch Neg   BB (sf)
A2                       BB (sf)/Watch Neg   BB (sf)

Prelude Europe CDO Ltd.
2006-1
                                 Rating
Class                    To                  From
Nts                      CCC- (sf)/Watch Pos CCC- (sf)

REPACS Trust Series: Warwick
                                 Rating
Class                    To                  From
B Debt Uts               BB (sf)/Watch Pos   BB (sf)

REVE SPC
34, 36, 37, 38, 39, & 40
                                 Rating
Class                    To                  From
Series 37                B- (sf)/Watch Neg   B- (sf)
Series 40                B (sf)/Watch Neg    B (sf)

STARTS (Cayman) Ltd.
2007-9
                                 Rating
Class                    To                  From
Nts                      BB- (sf)/Watch Pos  BB- (sf)

STEERS Credit Linked Trust, Bespoke Credit Tranche
2005-6
                                 Rating
Class                    To                  From
Trust Cert               B+ (sf)/Watch Neg   B+ (sf)


AVALON CAPITAL: Moody's Upgrades Class D Notes Ratings to 'Ba2'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Avalon Capital Ltd. 3:

US$400,000,000 Class A-1 Floating Rate Notes Due 2019 (current
balance of $341,163,051.76), Upgraded to Aa1 (sf); previously on
June 22, 2011 Aa3 (sf) Placed Under Review for Possible Upgrade;

US$50,000,000 Class A-2 Senior Variable Funding Floating Rate
Notes Due 2019 (current balance of $42,645,381.47), Upgraded to
Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$20,200,000 Class B Floating Rate Notes Due 2019, Upgraded to
Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed Under Review
for Possible Upgrade;

US$39,000,000 Class C Floating Rate Deferrable Notes Due 2019,
Upgraded to Baa2 (sf); previously on June 22, 2011 Ba2 (sf) Placed
Under Review for Possible Upgrade; and

US$40,800,000 Class D Floating Rate Deferrable Notes Due 2019
(current balance of $31,641,182.87), Upgraded to Ba2 (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 senior notes since the rating action in June 2009. Moody's
notes that the Class A Notes have been paid down by approximately
13.7% or $61 million since the rating action in June 2009. As a
result of the delevering, the overcollateralization ratios have
increased since the rating action. Based on the latest trustee
report dated July 8, 2011, the Class A/B, Class C, and Class D
overcollateralization ratios are reported at 125.4%, 114.4% and
106.8%, respectively, versus May 2009 levels of 114.0%, 105.3% and
98.2%, 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 $511.5 million
defaulted par of $2.59 million, a weighted average default
probability of 21.52% (implying a WARF of 2,892), a weighted
average recovery rate upon default of 47.79%, and a diversity
score of 63. 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.

Avalon Capital Ltd. 3, issued in February 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:

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.


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

US$34,000,000 Class A-2L Floating Rate Notes Due 2017, Upgraded to
Aaa (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$19,000,000 Class A-3L Floating Rate Notes Due 2017, Upgraded to
A1 (sf); previously on June 22, 2011 Baa3 (sf) Placed Under Review
for Possible Upgrade;

US$9,000,000 Class B-1L Floating Rate Notes Due 2017, Upgraded to
Ba1 (sf); previously on June 22, 2011 B3 (sf) Placed Under Review
for Possible Upgrade;

US$10,000,000 Class B-1F 6.59% Notes Due, Upgraded to Ba1 (sf);
previously on June 22, 2011 B3 (sf) Placed Under Review for
Possible Upgrade;

US$10,000,000 Class B-2L Floating Rate Notes Due 2017 (current
outstanding balance of $8,761,257.08), 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 senior notes since the rating action in November 2010. Moody's
notes that the Class A-1L Notes have been paid down by
approximately 37% or $75.4 million since the rating action in
November 2010. As a result of the delevering, the
overcollateralization ratios have increased. Based on the latest
trustee report dated July 6, 2011, the Senior Class A
overcollateralization ratio (covering Class A-1L Notes), Class A,
Class B-1 and Class B-2L overcollateralization ratios are reported
at 135.4%, 121.3%, 109.8% and 104.4%, respectively, versus October
2010 levels of 124.0%, 114.9%, 107.0% and 103.6%, 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 $219.6 million,
defaulted par of $17.9 million, a weighted average default
probability of 16.98% (implying a WARF of 2771), a weighted
average recovery rate upon default of 47.91%, and a diversity
score of 36. 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 Fund, 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: 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.


AVERY STREET: Moody's Upgrades Class D Notes Due 2018 to 'Ba2'
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Avery Street CLO, Ltd.:

$163,500,000 Class A Senior Floating Rate Notes Due 2018, Upgraded
to Aaa (sf); previously on June 22, 2011 Aa3 (sf) Placed Under
Review for Possible Upgrade;

$50,000,000 Class A2 Senior Delayed Draw Floating Rate Notes Due
2018, Upgraded to Aaa (sf); previously on June 22, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade;

$22,000,000 Class B Senior Floating Rate Notes Due 2018, Upgraded
to A1 (sf); previously on June 22, 2011 Baa2 (sf) Placed Under
Review for Possible Upgrade;

$7,000,000 Class B Senior Fixed Rate Notes Due 2018, Upgraded to
A1 (sf); previously on June 22, 2011 Baa2 (sf) Placed Under Review
for Possible Upgrade;

$14,000,000 Class C Deferrable Mezzanine Floating Rate Notes Due
2018, Upgraded to Baa3 (sf); previously on June 22, 2011 Ba2 (sf)
Placed Under Review for Possible Upgrade;

$12,500,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2018, Upgraded to Ba2 (sf); previously on June 22, 2011 B3 (sf)
Placed Under Review for Possible Upgrade;

$8,000,000 Class E Deferrable Junior Floating Rate Notes Due 2018,
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.

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 $287 million,
defaulted par of $.2 million, a weighted average default
probability of 22.63% (implying a WARF of 2864), a weighted
average recovery rate upon default of 48.64%, 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.

Avery Street CLO, Ltd., issued in March 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) 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.


AVIS BUDGET: Moody's Assigns Ratings to Series 2011-5 Sr. ABS
-------------------------------------------------------------
Moody's Investors Service has assigned provisional ratings of
(P)Aaa(sf) to the Series 2011-5 Class A fixed rate Rental Car
Asset Backed Notes (Class A Notes) and (P)Baa2(sf) to the Series
2011-5 Class B fixed rate Rental Car Asset Backed Notes (Class B
Notes and, together with the Class A Notes, the Series 2011-5
Notes). The Series 2011-5 Notes, which have approximately a 66
month expected final maturity, are expected to be issued by Avis
Budget Rental Car Funding (AESOP) LLC (the Issuer). The Issuer is
an indirect subsidiary of the sponsor, Avis Budget Car Rental, LLC
(ABCR). ABCR is a subsidiary of Avis Budget Group, Inc. (B1
corporate family rating and probability of default rating/stable
outlook). ABCR is the owner and operator of Avis Rent A Car
System, LLC (Avis) and Budget Rent A Car System, Inc. (Budget).

Issuer: Avis Budget Rental Car Funding (AESOP) LLC, Series 2011-5

Series 2011-5 Class A Notes, Assigned (P)Aaa(sf)

Series 2011-5 Class B Notes, Assigned (P)Baa2(sf)

RATINGS RATIONALE

As further described below, the provisional ratings for the Series
2011-5 Notes are based on (1) collateral in the form of rental
fleet vehicles, (2) the presence of ABCR as lessee under operating
leases, (3) minimum liquidity in the form of cash or letters of
credit, (4) the legal structure, (5) the capabilities and the
expertise of ABCR, (6) and in the case of the Class A Notes,
subordination provided by the Class B Notes. The Series 2011-5
Notes are to be issued under a master indenture and will generally
rank pari passu with the Issuer's other outstanding series of
notes.

The total enhancement requirement for the Series 2011-5 Notes is
dynamic and is determined as the sum of (1) 25.00% for vehicles
subject to a guaranteed depreciation or repurchase program from
eligible manufacturers (program vehicles) rated at least Baa2
(unlimited) or Baa3 (subject to a limit of 10% of the total
securitized fleet by net book value); (2) 32.50% for all other
program vehicles; and (3) 35.25% for non-program (risk) vehicles;
in each case, as a percentage of the outstanding note balance.
Consequently, the actual required amount of credit enhancement
fluctuates based on the mix of vehicles in the securitized fleet.
As in prior transactions the required total enhancement must
include a minimum portion which is liquid (in cash and/or letter
of credit), sized as a percentage of the outstanding note balance,
rather than fleet vehicles. The Class A Notes also benefit from
subordination provided by the Class B Notes representing 13% of
the outstanding Series 2011-5 Note balance. This subordination
percentage behind the Class A Notes will increase once principal
amortization begins on the Class A Notes.

The Series 2011-5 Notes are to be sold in a privately negotiated
transaction without registration under the Securities Act of 1933
(the Act) under circumstances reasonably designed to preclude a
distribution thereof in violation of the Act. The issuance is
expected to be designed to permit resale under Rule 144A.

KEY FACTORS IN RATING ANALYSIS

The key factors in Moody's rating analysis include (1) the
probability of default by ABCR, as lessee, (2) the likelihood of a
bankruptcy or default by the auto manufacturers providing vehicles
to the rental car fleet securing the Issuer's outstanding notes,
(3) the composition of the pool's vehicle mix over time and (4)
the realizable value of the portion of the fleet backing the ABS
should fleet liquidation be necessary.

Monte Carlo simulation modeling was used to assess the impact on
bondholders of these variables. Moody's equates the probability of
default of ABCR as lessee to a probability of default rating (PDR)
of B1, based on its parent's B1 PDR. Moody's forward-looking
assumptions about fleet mix relate to the mix by vehicle
manufacturer and the mix between program cars and non-program
cars. These assumptions are driven by a combination of historical
fleet data, current expectations of the sponsor and Moody's
assessment of potential mix volatility or stability. Data is
unavailable on vehicle values in a large scale stressed
liquidation. To address this variability, Moody's applies haircuts
to Moody's projection of vehicle values and make assumptions
Moody's believes to be appropriate about these recovery value
haircuts. Consequently, the rating action is based on limited
historical data.

V-SCORE AND LOSS SENSITIVITY

Moody's V Score. The V Score for this transaction is Medium, which
is the same as the V score assigned for the U.S. Rental Car ABS
sector. The V Score indicates "Medium" uncertainty about critical
assumptions.

Moody's V Scores provide a relative assessment of the quality of
available credit information and the potential variability around
the various inputs to a rating determination. The V Score ranks
transactions by the potential for significant rating changes owing
to uncertainty around the assumptions due to data quality,
historical performance, the level of disclosure, transaction
complexity, the modeling and the transaction governance that
underlie the ratings. V Scores apply to the entire transaction
(rather than individual tranches).

Moody's Parameter Sensitivities. For this exercise, Moody's
analyzed stress scenarios assessing the potential model-indicated
output impact if (a) the current B1 PDR of ABCR's parent was to
immediately decline to B3, Caa1, Caa2 and Caa3 and (b) the assumed
modeled haircuts to estimated depreciated vehicle market values
were increased by 5%, 10% and 15%. Haircuts are expressed as a
percentage of the estimated depreciated market value of the
vehicle collateral. Moody's models potential vehicle collateral
liquidation value by estimating depreciated market value and then
applying haircuts and Moody's uses triangular distributions for
those haircuts (see methodology below). The stresses increase the
base case triangular distribution haircuts by the following
percentage points: 5%, 10% and 15%. For example, if one of the
triangular distribution haircuts in the base case is (5%, 15%,
30%), and this is increased by 5% points, then the resulting
stressed haircut would be a triangular distribution of (10%, 20%,
35%).

Using such assumptions, the Aaa initial model-indicated output for
the Class A Notes might change as follows: (a) with ABCR's
parent's PDR at B1, the Aaa initial note output would remain Aaa
under the base recovery but change to Aa1, Aa2 and A1 with each
lower recovery assumption; (b) with ABCR's parent's PDR at B3, the
Aaa initial note output would remain Aaa under the base recovery
but change to Aa1, Aa3 and A2 with each lower recovery assumption;
(c) with ABCR's parent's PDR at Caa1, the Aaa initial note output
would remain Aaa under the base recovery but change to Aa1, Aa3
and A2 with each lower recovery assumption; (d) with ABCR's
parent's PDR at Caa2, the Aaa initial note output would remain Aaa
under the base recovery but change to Aa1, A1 and A3 with each
lower recovery assumption; (e) with ABCR's parent's PDR at Caa3,
the Aaa initial note output would remain Aaa under the base
recovery but change to Aa1, A1 and A3 with each lower recovery
assumption

Also using the above assumptions, the Baa2 initial model-indicated
output for the Class B Notes might change as follows: (a) with
ABCR's parent's PDR at B1, the Baa2 initial note output would
remain at Baa2 using the base recovery assumption but change to
Ba1, B2 and below B3 with each lower recovery assumption; (b) with
ABCR's parent's PDR at B3, the Baa2 initial note output would
change to Baa3 using the base recovery assumption and change to
Ba3, B3 and below B3 with each lower recovery assumption; (c) with
ABCR's parent's PDR at Caa1, the Baa2 initial note output would
change to Baa3 using the base recovery assumption and change to
B1, below B3 and below B3 with each lower recovery assumption; (d)
with ABCR's parent's PDR at Caa2, the Baa2 initial note output
would change to Baa3 using the base recovery assumption and change
to B2, below B3 and below B3 with each lower recovery assumption;
(e) with ABCR's parent's PDR at Caa3, the Baa2 initial note output
would change to Ba1 using the base recovery assumption and change
to B3, below B3 and below B3 with each lower recovery assumption.

Parameter Sensitivities are not intended to measure how the rating
of the security might migrate over time, rather they are designed
to provide a quantitative calculation of how the initial rating
might change if key input parameters used in the initial rating
process differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.

PRINCIPAL RATING METHODOLOGY

The principal methodology used in this rating was "Moody's Global
Approach to Rating Rental Car ABS and Rental Truck ABS," published
in July 2011. Please see the Credit Policy page on www.moodys.com
for a copy of this methodology. Consistent with Moody's
methodology, for this transaction Moody's assumes a purchase price
for program which is 10% below MSRP, to give credit to the volume
discounts typically achieved by rental car companies. Moody's also
assumes the discount for non-program (risk) vehicles is 15% to
reflect both the terms required under the transaction
documentation and historic performance. Also Moody's notes that
the market value haircuts applied to the vehicles (i.e., the base
haircut and the additional manufacturer haircut) are the same as
the indicative haircuts presented in Moody's methodology.

ADDITIONAL RESEARCH

A pre-sale report for this transaction is forthcoming. The special
reports, "Updated Report on V Scores and Parameter Sensitivities
for Structured Finance Securities" and "V Scores and Parameter
Sensitivities in the U.S. Vehicle ABS Sector" are available on
moodys.com.


BABSON CLO: Moody's Upgrades Class C-1 Notes Rating to 'Ba1'
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Babson CLO Ltd. 2005-II:

US$390,000,000 Class A-1 Senior Notes (current outstanding balance
of $379,850,585), Upgraded to Aaa (sf); previously on
June 22, 2011 Aa2 (sf) Placed Under Review for Possible Upgrade;

US$20,000,000 Class A-2 Senior Notes, Upgraded to Aa1 (sf);
previously on June 22, 2011 A2 (sf) Placed Under Review for
Possible Upgrade;

US$27,000,000 Class B Deferrable Mezzanine Notes, Upgraded to A2
(sf); previously on June 22, 2011 Baa3 (sf) Placed Under Review
for Possible Upgrade;

US$20,500,000 Class C-1 Deferrable Mezzanine Notes, Upgraded to
Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed Under Review
for Possible Upgrade; US

US$5,500,000 Class C-2 Deferrable Mezzanine Notes, Upgraded to Ba1
(sf); previously on June 22, 2011 B1 (sf) Placed Under Review for
Possible Upgrade;

US$11,500,000 Class D-1 Deferrable Mezzanine Notes (current
outstanding balance of $9,965,838), Upgraded to Ba3 (sf);
previously on June 22, 2011 Caa3 (sf) Placed Under Review for
Possible Upgrade;

US$4,500,000 Class D-2 Deferrable Mezzanine Notes (current
outstanding balance of $3,965,904), Upgraded to Ba3 (sf);
previously on June 22, 2011 Caa3 (sf) Placed Under Review for
Possible Upgrade;

US$5,000,000 Class Q-1 Combination Notes (current rated balance of
$2,996,654), Upgraded to Aa3 (sf); previously on June 22, 2011
Baa2 (sf) Placed Under Review for Possible Upgrade;

US$10,000,000 Class Q-3 Combination Notes (current rated balance
of $5,756,541), Upgraded to Ba3 (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.

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 $493.8 million,
defaulted par of $3.7 million, a weighted average default
probability of 20.94% (implying a WARF of 2856), a weighted
average recovery rate upon default of 50.15%, 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.

Babson CLO Ltd. 2005-II, issued in July 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.

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:

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.


BABSON CLO: S&P Gives 'BB' Rating on Class D Deferrable Notes
-------------------------------------------------------------
Standard & Poor's Ratings Services assigned its ratings to Babson
CLO Ltd. 2011-I/Babson CLO 2011-I LLC's $461 million floating-rate
notes.

The transaction is a cash flow collateralized loan obligation
(CLO) securitization of a revolving pool consisting primarily of
broadly syndicated senior secured loans.

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 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 asset 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 0.34%-13.9%," 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.

Ratings Assigned

Babson CLO Ltd. 2011-I/Babson CLO 2011-I LLC

Class                   Rating       Amount (mil. $)
A-1                     AAA (sf)               342.0
A-2                     AA (sf)                 37.0
B (deferrable)          A (sf)                  42.0
C (deferrable)          BBB (sf)                22.0
D (deferrable)          BB (sf)                 18.0
Subordinated notes      NR                      52.9

NR -- Not rated.


BAKER STREET: Moody's Upgrades Ratings of 6 Classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Baker Street CLO II Ltd.:

US$270,000,000 Class A-1 Floating Rate Notes Due October 2019
(current balance of $263,802,663), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$30,000,000 Class A-2 Variable Funding Floating Rate Notes Due
October 2019 (current balance of $29,311,407), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$20,100,000 Class B Floating Rate Notes Due October 2019,
Upgraded to Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$21,000,000 Class C Floating Rate Deferrable Notes Due October
2019, Upgraded to A3 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$15,900,000 Class D Floating Rate Deferrable Notes Due October
2019, Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf)
Placed Under Review for Possible Upgrade;

US$12,000,000 Class E Floating Rate Deferrable Notes Due October
2019 (current balance of $11,402,274), 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.

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 $378 million,
defaulted par of $11 million, a weighted average default
probability of 20.40% (implying a WARF of 2680), a weighted
average recovery rate upon default of 49.84%, 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.

Baker Street CLO II 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.


BANC OF AMERICA: Fitch Affirms BALL 2005-MIB1 Ratings
-----------------------------------------------------
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.

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 (including
extensions). 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 affirms these classes and revises Rating Outlooks:

   -- $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):

   -- $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.

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


BANC OF AMERICA: S&P Cuts Rating on Class N Certificates to 'D'
---------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the
class N commercial mortgage pass-through certificates from Banc
of America Commercial Mortgage Inc.'s series 2002-2, a U.S.
commercial mortgage-backed securities (CMBS) transaction, to 'D
(sf)' from 'CCC- (sf)'.

The downgrade follows a principal loss to the class N
certificates, which was detailed in the Aug. 11, 2011 trustee
remittance report. Class N experienced a 16.2% loss of its
$16.8 million original balance. The class O certificates, the
rating on which Standard & Poor's had previously lowered to 'D
(sf)', lost 100% of their opening balance.

According to the Aug. 11, 2011, trustee remittance report, the
trust experienced a $2.8 million principal loss upon the
liquidation of the Metra-Westwood Apartments asset, which was with
the special servicer, C-III Asset Management LLC. The Metra-
Westwood Apartments is a 120-unit multifamily property in Mary
Esther, Fla. The loan was transferred to the special servicer
in August 2006 because the borrower filed a lawsuit against the
trust regarding the forced placement of windstorm insurance for
the asset. The trial came to a conclusion on October 2010. The
loan experienced a 92.8% loss of its $3.0 million outstanding
balance at the time of liquidation.


BANC OF AMERICA: S&P Lowers Rating on Class B Certs. to 'CCC'
-------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on three
classes of commercial mortgage pass-through certificates from Banc
of America Commercial Mortgage Trust 2006-6, a U.S. commercial
mortgage-backed securities (CMBS) transaction. "In addition, we
affirmed our ratings on seven other classes from the same
transaction," S&P said.

"Our rating actions follow our analysis of the transaction
primarily using our U.S. conduit/fusion CMBS criteria. The
downgrades reflect credit support erosion that we anticipate will
occur upon the resolution of nine ($384.4 million, 16.8%) of the
13 assets ($579.7 million, 25.4%) that are currently with the
special servicer," S&P related.

The affirmed ratings on the principal and interest certificates
reflect subordination and liquidity support levels that are
consistent with the outstanding ratings. "We affirmed our 'AAA
(sf)' ratings on the class XC and XP interest-only certificates
based on our current criteria," S&P said.

"Our analysis included a review of the credit characteristics of
the remaining assets in the pool. Using servicer-provided
financial information, we calculated an adjusted debt service
coverage (DSC) of 1.20x and a loan-to-value (LTV) ratio of 123.7%.
We further stressed the loans' cash flows under our 'AAA' scenario
to yield a weighted average DSC of 0.77x and an LTV ratio of
162.0%. The implied defaults and loss severity under the 'AAA'
scenario were 91.0% and 45.6%, respectively. The DSC and LTV
calculations noted above exclude nine ($384.4 million, 16.8%) of
the 13 assets ($579.7 million, 25.4%) that are currently with the
special servicer. We separately estimated losses for the nine
specially serviced assets and included them in our 'AAA' scenario
implied default and loss severity figures," S&P related.

"We downgraded classes C, D, E, F, G, H, J, K, L, M, N, and O to
'D (sf)' on March 1, 2011, due to interest shortfalls that we
expect will continue in the near term," S&P said. For more
information, see, '69 Ratings Lowered On Nine U.S. CMBS
Transactions Due to Interest Shortfalls,' published March 1, 2011.
As of the July 11, 2011, trustee remittance report, these classes
continue to experience interest shortfalls," S&P related.

                     Credit Considerations

As of the July 11, 2011 trustee remittance report, 11 assets
($565.3 million, 24.7%) in the pool were with the special
servicer, CWCapital Asset Management LLC (CWCapital). The reported
payment status of the specially serviced assets as of the July
2011 trustee remittance report is: four are real estate owned
(REO; $50.9 million, 2.2%), three are 90-plus-days delinquent
($319.1 million, 14.0%), one is 30 days delinquent ($2.8 million,
0.1%), two are in their grace period ($32.0 million, 1.4%), and
one is current ($160.5 million, 7.0%). Appraisal reduction amounts
(ARAs) totaling $195.7 million are in effect against six of the
specially serviced assets. Details of the three largest specially
serviced assets, all of which are top 10 assets," S&P related.

The Riverchase Galleria loan ($305.0 million, 13.3%), the
largest asset in the pool, is secured by 581,630 sq. ft. of a
1.57 million-sq.-ft. regional mall in Hoover, Ala. The loan was
transferred to the special servicer on June 24, 2010, due to
imminent monetary default. The reported payment status of the
loan is 90-plus-days delinquent. However, CWCapital indicated that
the loan's payment status is now current. CWCapital stated that it
is currently negotiating with the borrower to restructure the
loan. The reported net operating income DSC was 1.15x for year-end
2010 and occupancy was 79.8%, according to the March 31, 2011,
rent roll. An ARA of $159.1 million is in effect against the loan
based on a $167.0 million appraisal value as of August 2010. "We
expect a moderate loss upon the eventual resolution of this loan,"
S&P related.

The Chicago Loop Portfolio loan ($160.4 million, $7.0%), the
fifth-largest asset in the pool, is secured by three office
buildings totaling 1.63 million sq. ft. in Chicago, Ill. The loan,
which has a reported current payment status, was transferred to
the special servicer on Oct. 15, 2010, after a tenant filed a suit
against the landlord for not reimbursing its tenant improvement
work. According to CWCapital, tenant improvements have been
funded, and it is currently monitoring the loan's performance. The
reported combined DSC was 0.97x for year-end 2010, and combined
occupancy was 79.9%, according to the February 2011 rent rolls.
Pursuant to the transaction documents, once the loan returns to
the master servicer, the special servicer is entitled to a workout
fee that is 1% of future principal and interest payments if the
loan performs and remains with the master servicer. According
to CWCapital, the borrower is not paying the workout fee on this
loan.

The 1700 Twinbrook Office Center asset ($39.0 million, 1.7%), the
eighth-largest asset in the pool, consists of a 162,357-sq.-ft.
suburban office building in Rockville, Md. The asset was
transferred to the special servicer on June 8, 2009, and became
REO on Sept. 14, 2010. CWCapital has informed us that it will
stabilize occupancy before marketing the property for sale. The
reported occupancy was 73.0% as of April 2011, and reported DSC
was 0.56x as of year-end 2009. An ARA of $22.0 million is in
effect against the asset. "We expect a significant loss upon the
eventual resolution of this asset," S&P related.

The eight remaining specially serviced assets have individual
balances that represent less than 1.20% of the pooled trust
balance. ARAs totaling $14.6 million are in effect against four of
these assets. "We estimated losses for five of the eight assets,
arriving at a weighted-average loss severity of 48.5%. While one
of the remaining three loans has been returned to the master
servicer, the other two loans were transferred to the special
servicer in April 2011, and CWCapital stated that it is in
discussions with the borrowers to workout these loans," S&P said.

In addition, two loans ($14.4 million, 0.7%) were transferred to
the special servicer subsequent to the July 2011 trustee
remittance report. The Kettering Towne Center loan ($11.0 million,
0.5%), secured by a 213,077-sq.-ft. retail center in Kettering,
Ohio, was transferred to the special servicer on July 11, 2011,
due to imminent monetary default. The other loan, the Showtime
Cinemas loan ($3.4 million, 0.2%), secured by a 40,000-sq.-ft.
theater property, was transferred to CWCapital on July 12, 2011,
due to imminent maturity default. "We expect moderate losses upon
the eventual resolution of these two loans," S&P said.

                      Transaction Summary

As of the July 11, 2011, trustee remittance report, the collateral
pool balance was $2.28 billion, which is 92.8% of the balance at
issuance. The pool includes 105 loans and four REO assets, down
from 117 loans at issuance. The master servicer, Bank of America
N.A. (BofA), provided financial information for 98.5% of the loans
in the pool: 80.0% was full-year 2010 data and the remainder was
full-year 2009 data.

"We calculated a weighted average DSC of 1.29x for the loans in
the pool based on the servicer-reported figures. Our adjusted DSC
and LTV ratio were 1.20x and 123.7%. Our adjusted DSC and LTV
figures excluded nine ($384.4 million, 16.8%) of the 13 assets
($579.7 million, 25.4%) that are currently with the special
servicer. We separately estimated losses for the nine specially
serviced assets and included them in our 'AAA' scenario implied
default and loss severity figures. The transaction has experienced
$11.5 million in principal losses from five assets to date. Forty-
three loans ($884.4 million, 38.7%) in the pool are on the master
servicer's watchlist. Nineteen loans ($319.9 million, 14.0%) have
a reported DSC of less than 1.00x, and 17 loans ($522.1 million,
22.8%) have a reported DSC between 1.00x and 1.10x," S&P related.

                      Summary of Top 10 Assets

The top 10 assets have an aggregate outstanding balance of $1.44
billion (62.9%). "Using servicer-reported numbers, we calculated a
weighted average DSC of 1.29x for the top 10 assets. Three of the
top 10 assets ($504.4 million, 22.0%) are with the special
servicer, and three other top 10 assets ($509.0 million, 22.3%)
are on the master servicer's watchlist. Moody's adjusted DSC and
LTV ratio for seven of the top 10 assets are 1.11x and 133.8%,"
S&P said.

The 777 Tower loan ($273.0 million, 11.9%), the second-largest
asset in the pool, is secured by a 1.0 million-sq.-ft. office
building in Los Angeles, Calif. The loan is on the master
servicer's watchlist due to a low reported DSC of 1.12x for year-
end 2010, and occupancy was 79.7%, according to the March 31,
2011, rent roll.

The EZ Storage Portfolio loan, the sixth-largest asset in the
pool, is secured by 48 self-storage facilities totaling 30,800
units (3.7 million sq. ft.) in six states. The whole loan
balance of $300.0 million is divided into two pari passu pieces,
$150.0 million of which makes up 6.6% of the pooled trust balance.
The loan appears on BofA's watchlist due to a low reported
combined DSC on the whole loan of 1.02x and reported combined
occupancy of 58.6% for year-end 2010.

The Impac Center loan ($86.0 million, 3.8%), the seventh-largest
asset in the pool, is secured by two office buildings and one
free-standing restaurant totaling 369,876 sq. ft. in Irvine,
Calif. The loan is on the master servicer's watchlist because the
largest tenant, which leased 56.9% of the net rentable area until
Sept. 30, 2016, does not physically occupy all of its leased
space. The reported DSC and occupancy were 1.17x and 100%,
respectively, as of year-end 2010.

Standard & Poor's stressed the collateral in the pool according to
its current criteria. The resultant credit enhancement levels are
consistent with S&P's lowered and affirmed ratings.

Ratings Lowered

Banc of America Commercial Mortgage Trust 2006-6
Commercial mortgage pass-through certificates
                Rating
Class      To           From        Credit enhancement (%)
A-M        BBB- (sf)    BBB (sf)                    21.04
A-J        B+ (sf)      BB (sf)                     12.56
B          CCC (sf)     CCC+ (sf)                   10.40

Ratings Affirmed

Banc of America Commercial Mortgage Trust 2006-6
Commercial mortgage pass-through certificates

Class      Rating              Credit enhancement (%)
A-2        AAA (sf)                             31.81
A-3        AAA (sf)                             31.81
A-SB       AAA (sf)                             31.81
A-4        A (sf)                               31.81
A-1A       A (sf)                               31.81
XC         AAA (sf)                               N/A
XP         AAA (sf)                               N/A

N/A -- Not applicable.


BARRINGTON II: S&P Affirms Ratings on 9 Classes of Notes at 'CC'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating on the class
X notes from Barrington II CDO Ltd., a U.S. collateralized debt
obligation (CDO) transaction managed by Dynamic Credit Partners
LLC, and removed it from CreditWatch with negative implications,
where it placed it on May 25, 2011. "At the same time, we affirmed
our ratings on the class A1-S, A1-M, A1-Q, A1J-M, A1J-Q, A2, A-3,
B, C, and D notes," S&P said.

The downgrade reflects the observed decrease in the
overcollateralization (O/C) available to support the rated notes.
The trustee reported these ratios in the June 28, 2011, monthly
report and the Feb. 25, 2010, trustee report, which S&P used for
its May 2010 rating actions:

    The class A/B (O/C) ratio test was 6.37%, compared with a
    reported ratio of 13.49% in February 2010;

    The class C (O/C) ratio test was 6.29%, compared with a
    reported ratio of 13.34% in February 2010; and

    The class D (O/C) ratio test was 6.23%, compared with a
    reported ratio of 13.22% in February 2010.

"The affirmations 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

Barrington II CDO Ltd.
                        Rating
Class              To           From
X                  BB+ (sf)     A (sf)/Watch Neg

Ratings Affirmed

Barrington II CDO Ltd.
Class              Rating
A1-S               CCC- (sf)
A1-M               CC (sf)
A1-Q               CC (sf)
A1J-M              CC (sf)
A1J-Q              CC (sf)
A2                 CC (sf)
A-3                CC (sf)
B                  CC (sf)
C                  CC (sf)
D                  CC (sf)


BEAR STEARNS: Fitch Takes Various Rating Actions
------------------------------------------------
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.

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).

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:

   -- $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'

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: DBRS Downgrades Class B From 'BB' to 'B'
------------------------------------------------------
DBRS has downgraded these classes of the Bear Stearns Commercial
Mortgage Securities Trust, Series 2007-TOP26 transaction:

Class A-J from BBB (high) to BBB (low)
Class B from BB to B
Class C from B to CCC

Class C has Interest in Arrears in the amount of $69,596, as of
the July 2011 Remittance Report.

Classes A-J and B have Stable trends.

DBRS has confirmed the other classes as follows:

Class A-1 at AAA
Class A-2 at AAA
Class A-3 at AAA
Class A-AB at AAA
Class A-4 at AAA
Class A-1A at AAA
Class AM at AAA

The above classes were confirmed with a Stable trend.

Class D at CCC
Class E at CCC
Class F at CCC
Class G at C
Class H at C
Class J at C
Class K at C
Class L at C
Class M at D
Class N at D
Class O at D

Classes D through O, cumulatively, have Interest in Arrears of
$1,453,882, as of the July 2011 Remittance Report.

In addition, the notional classes X-1 and X-2 were confirmed at
AAA with a Stable trend.

The downgrades are the result of the decline in the performance
for the loans on the servicer's watchlist and the loans in special
servicing since the last DBRS review in December 2010.

There are 49 loans on the watchlist, comprising 15.48% of the
transaction balance.  Of those loans, three are in the top 15
loans in the pool, comprising 4.89% of the transaction balance.

Updated financial reporting was available for the bulk of the
loans on the servicer's watchlist, with 45 of the 49 loans
reporting YE2010 financials.  Those loans represent 11.13% of the
pool.  Two of 49 loans, representing 2.72% of the pool, were
reporting Q3 2010 figures that were annualized for analysis
purposes; three of the 49 loans, representing 1.64% of the pool,
were reporting YE2009 figures.  For these loans, DBRS determined a
weighted-average NCF decline of 33.07%, from the last reported
year-end figures.  In addition, the weighted-average NCF decline
for these loans from issuance is 33.94%.  The weighted-average
DSCR is 0.95x, down from a weighted-average DSCR of 1.14x for
those loans from the last reported year-end figures.

The largest loan on the servicer's watchlist is Prospectus ID#7,
909 A Street (2.37% of the current pool balance).  This loan is on
the watchlist and the DBRS HotList because the property's sole
tenant, Russell Investments, moved its headquarters to Seattle and
vacated the property in October 2010.  The property is a 210,000
sf office building constructed in 1988, located in downtown
Tacoma, Washington.  The property has excellent curb appeal and is
centrally-located.  The lease on the building expires in November
2013; as the tenant will not be renewing the lease, the loan
documents allow for the servicer to deleverage the asset with the
use of a cash sweep that will be triggered in December 2011.  The
current loan per unit on the asset is quite high at $228 psf with
no amortization occurring during the ten year loan term. Reis
reports the overall submarket vacancy rate for the Tacoma CBD is
at 14.2% for Q2 2011, with an increase to 15.0% projected by
YE2011.  For properties constructed between 1980 and 1989,
comprising 17.0% of the market inventory, the vacancy rate is much
higher, at 38.4% for the same period.  Properties constructed
between 2000 and 2009,comprising 6.0% of the market inventory,
have a vacancy rate of 40.7% .  The average asking rental rate for
the submarket was $20.17 psf, with asking rents averaging $26.07
psf for newer construction.  At YE2010, the DSCR was 1.62x, with a
base rental rate of $23.03 psf for the single tenant.  The
servicer reported in July 2011 that the tenant was marketing the
property for sublease, but that nothing had been secured at that
time.  DBRS will continue to monitor this loan closely for
developments.

Prospectus ID#9, Overlook II (1.56% of the current pool balance),
is on the servicer's watchlist for a low DSCR.  The collateral is
a 255,000 sf Class A office property constructed in 1985 and
located in northwest Atlanta in the Cumberland/I-75 submarket,
near Smyrna.  According to the servicer, the property's DSCR
declined to 0.99x, as of YE2010, due to a drop in occupancy to 80%
from 90% at YE2008.  The largest tenant at origination,
Manugistics (12% of the NRA), vacated the building upon lease
expiration in December 2008 and occupancy has yet to recover.
According to Reis, the Q2 2011 vacancy rate for the submarket was
20.2% overall and 25.0% for properties of similar vintage to the
subject.  Reis predicts vacancy rates will decline in increments
over the next five years for the submarket, with the 2015 vacancy
projected to end at 17.8%.  The average effective rental rate for
the submarket has been on the steady decline since YE2008, when it
fell by 4.7% over YE2007.  At YE2009, the average effective rental
rate declined by another 4.4%.  At YE2010 it dropped once again,
by 3.0% from the YE2009 rates.  The current leverage is $124 psf
and the loan does not amortize during the ten year term, maturing
in March 2017.  DBRS will continue to closely monitor the loan's
performance given the Atlanta office market trend data and the
performance of the subject asset over the past two years.
Prospectus ID#14, Stony Point East (0.96% of the current pool
balance), is secured by a suburban office complex comprised of
three buildings for a total of 200,000 sf in Santa Rosa,
California, located approximately 70 miles west of Sacramento.
The buildings are of Class A quality and were constructed between
1990 and 2000.  This loan was placed on the servicer's watchlist
in 2009, when the YE2009 DSCR fell to 0.73x from 2.07x after a
decrease in occupancy to 55% from the underwritten level of 93%.
The servicer reports that the property was able to maintain
occupancy in 2010 through the use of concessions for existing
tenants in the form of rent abatement periods and lower rental
rates on a case-by-case basis. As such, while the property
occupancy increased to 83% at YE2010, the DSCR fell again, to
0.34x for the period.  The servicer also reports that part of this
decline was due to extraordinary costs in the first half of 2010
that included draining and cleaning the lake feature at the
property.  At Q1 2011, the property occupancy was at 76%, with a
DSCR of 0.52x.  The servicer reported in May 2011 that the
property was being heavily marketed on CoStar and LoopNet, as well
as through the use of local brokerage firms and property signage.
The submarket is reportedly soft and leasing activity has been
very slow.  The current leverage on the asset is considered
reasonable, at $97 psf; the loan is fully amortizing and matures
in March 2013.  DBRS has placed the loan on the DBRS HotList for
close monitoring. There are nine loans in special servicing,
comprising 6.43% of the transaction balance.  The two largest of
these loans are discussed in detail below.  As of the July 1, 2011
remittance report, there were six loans causing a total of
$26.8 million in realized losses to the trust.  Those losses have
resulted in the elimination of Classes N and O and the unrated
Class P.  Furthermore, the Class M balance has been reduced by
approximately 90% since issuance as a result of these losses.  Of
the $26.8 million in losses, approximately 56% is the result of
five loans liquidated out of the trust between May 2010 and June
2011 at a weighted-average loss severity of 48.69%.

The remainder of the losses are due to the modification for
Prospectus ID#6, Viad Corporate Center (2.77% of the current pool
balance), which was finalized in June 2011 by the special
servicer.  The loan is secured by a 476,528 sf Class A office
property located in the Uptown submarket in Phoenix, just north of
McDowell Road on Central Avenue.  The 24-story high-rise was
constructed in 1991, originally serving as the national
headquarters for the Dial Corporation.  The property includes
several retail units, auditorium and conference facilities, a
fitness center, and a performing arts theater.  The subject is
located across the street from the Phoenix Art Museum and is a
prominent fixture in the Central Avenue business district.  The
loan transferred to the special servicer in March 2009 when the
95% managing member in the borrowing entity cited difficulty
making the scheduled interest payments on the loan and refused to
contribute further equity into the property given the perceived
value loss of approximately $60 million since issuance when the
property was valued at $105.6 million.  The May 2010 appraisal
obtained by the special servicer valued the property at
$43 million (a figure which represented an as-is value; the same
firm concluded a stabilized value of $57.3 million for the subject
property in May 2010), indicating the concern over value decline
was substantiated. The property's performance has remained
relatively stable since issuance.  The YE2008 occupancy was at 93%
and the DSCR was reportedly 1.25x, according to the special
servicer.  At YE2009, occupancy had fallen to 82% but the DSCR
remained relatively healthy at 1.19x.  Occupancy has remained near
80% throughout 2010 and into Q1 2011 when it 79%; the NOI DSCR for
Q1 2011 was reported by the special servicer at 1.12x.  In May
2011, the special servicer processed a sale of the property and
loan assumption that resulted in a $9 million principal write down
of the outstanding $65 million balance on the loan.  As part of
the transaction, the new borrower is to establish a capital
reserve in the amount of $8 million to fund tenant improvements,
leasing commissions, and capital repairs.

The realized loss of $9 million as a part of the loan assumption
and modification was applied to the trust as part of the June 13,
2011 remittance report.  DBRS anticipates additional losses as
the special servicer fees and recoveries are collected in the
coming months and added to the loss on this loan; the cumulative
loss amount on this loan is estimated to be approximately
$11.75 million, according to the special servicer.  As such,
the remaining loss figure should be contained to the Class M and
L certificates, which had a respective balance of $231,383 and
$5,265,000, as of the July 13, 2011 remittance report.  These
developments are in line with the DBRS projections for this loan
at the time of the December 2010 review when Classes M and L were
downgraded to C.

Prospectus ID#21, Holiday Inn Santa Maria (1.11% of the current
pool balance), is the second-largest loan in special servicing.
The loan is secured by a 207-unit full-service Holiday Inn hotel
located in Santa Maria, California.  Santa Maria is located
approximately 65 miles north of Santa Barbara along the southern
California coastline; the subject property is located in the north
central section of the city, immediately west of Highway 101,
which provides direct access to Pismo Beach approximately 20
minutes to the north.  Hotel amenities include three meeting
rooms, a fitness facility, outdoor swimming pool, and dining room.
The hotel, like many hotels, has suffered from the market downturn
and the resulting stress on income at the hotel as occupancy rates
have fluctuated and room rates have been depressed.  At YE2008 and
YE2009, the DSCR was 0.97x and 0.59x, respectively; although
occupancy for those periods remained near the underwritten level
of 68%, the revenue at the property was significantly lower due to
declining room rates at the property for those periods as compared
with issuance.  The Q1 2011 cash flow at the property is
indicative of an annualized NOI DSCR of 0.67x.  The loan had an
initial IO period of two years, and began amortizing in April
2009.  The current leverage of $108,000 per key is considered
moderate, given the property's full-service status and location.
In March 2010, the borrower requested relief and the loan
transferred to the special servicer.  The borrower requested a
loan modification and was to submit a proposal to the special
servicer, but it was never received and a foreclosure is in
process, with a close anticipated in late Q3 2011.  A receiver has
been in-place at the property since September 2010; the loan is
now due for the December 2010 payment and all payments due
thereafter.  The appraisal obtained by the special servicer in
August 2010 indicated a property value of $24 million. Since that
time, an updated appraisal from March 2011 has been received,
valuing the property even lower at $15.5 million.  This figure
indicates a loss of approximately $10 million to the trust.  DBRS
will continue to closely monitor this asset's performance through
the workout process.

DBRS shadow-rates 16 loans, representing 20.24% of the current
pool balance.  The shadow ratings indicate the long-term stability
of the underlying assets, as represented in lower-than-average
leverage points for the loans and above-average debt-service
coverage ratios.  Based on the continued strong performance of the
respective assets, DBRS has confirmed all 16 shadow ratings as
listed below:.

One Dag Hammarskjold Plaza (7.41% of the current pool balance) - A
(low)

Fullbright Tower (5.57% of the current pool balance) - BBB (low)

503 Broadway (1.48% of the current pool balance) - A (low)

Harmony Marketplace (1.41% of the current pool balance) - A (high)

Fox Chapel Shopping Center (0.77% of the current pool balance) -
BBB (low)

Byram Plaza Shopping Center (0.72% of the current pool balance) -
BBB (low)

HSBC Sioux Falls (0.68% of the current pool balance) - BBB (low)

38-05 to 38-17 and 37-27/29 Main Street (0.49% of the current pool
balance) - BBB (low)

213 West 35th Street (0.49% of the current pool balance) - BBB
(low)

Newbury Portfolio Roll-Up (0.49% of the current pool balance) -
BBB (low)

Bridgeport Stop & Shop II (0.46% of the current pool balance) -
BBB (low)

Rye Colony Apartment (0.38% of the current pool balance) - AAA

Westover Apartments (0.35% of the current pool balance) - BBB
(high)

Whole Foods Santa Monica (0.26% of the current pool balance) - AA

36 Sutton Place South (0.25% of the current pool balance) - AAA

Tracy Towers (0.15% of the current pool balance) - AAA

As part of this review, DBRS closely analyzed the largest 15 loans
in the pool, all 16 shadow-rated loans, all 49 loans on the
servicer's watchlist and all nine loans in special servicing.
Together, these loans comprise 62.45% of the transaction balance.

DBRS continues to monitor this transaction on a monthly basis in
the Monthly CMBS Surveillance Report, which can provide more
detailed information on the individual loans in the pool.


BEAR STEARNS: Moody's Downgrades Class C Notes Rating to 'Ba1'
--------------------------------------------------------------
Moody's Investors Service (Moody's) downgraded the ratings of
three classes and affirmed 18 classes of Bear Stearns Commercial
Mortgage Securities, Commercial Mortgage Pass-Through
Certificates, Series 2006-PWR12 as:

Issuer: Bear Stearns Commercial Mortgage Securities Trust 2006-
PWR12

Cl. A-2, Affirmed at Aaa (sf); previously on Jun 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Jun 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Jun 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Jun 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Jun 26, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aaa (sf); previously on Dec 17, 2010
Confirmed at Aaa (sf)

Cl. A-J, Affirmed at A3 (sf); previously on Dec 17, 2010
Downgraded to A3 (sf)

Cl. X, Affirmed at Aaa (sf); previously on Jun 26, 2006 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed at Baa2 (sf); previously on Dec 17, 2010
Downgraded to Baa2 (sf)

Cl. C, Downgraded to Ba1 (sf); previously on Dec 17, 2010
Downgraded to Baa3 (sf)

Cl. D, Downgraded to B1 (sf); previously on Dec 17, 2010
Downgraded to Ba3 (sf)

Cl. E, Downgraded to B3 (sf); previously on Dec 17, 2010
Downgraded to B2 (sf)

Cl. F, Affirmed at Caa2 (sf); previously on Dec 17, 2010
Downgraded to Caa2 (sf)

Cl. G, Affirmed at Caa3 (sf); previously on Dec 17, 2010
Downgraded to Caa3 (sf)

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

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

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

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

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

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

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

RATINGS RATIONALE

The downgrades are due to higher realized losses and estimated
losses from specially serviced loans.

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
7.0% of the current balance. At last review, Moody's cumulative
base expected loss was 6.0%. Moody's stressed scenario loss is
20.2% 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 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 "Moody's Approach
to Rating U.S. CMBS Conduit Transactions" published in September,
2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.50 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 46 compared to 49 at Moody's prior review.

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

The rating action is a result of Moody's on-going surveillance of
commercial mortgage backed securities (CMBS) transactions. Moody's
monitors transactions on a monthly basis through 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 17, 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 11, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 8% to $1.91 billion
from $2.08 billion at securitization. The Certificates are
collateralized by 200 mortgage loans ranging in size from less
than 1% to 8% of the pool, with the top ten loans representing 34%
of the pool. The pool does not contain any defeased loans or loans
with investment grade credit estimates.

Sixty-one 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.

Eight loans have been liquidated from the pool, resulting in a
realized loss of $22.9 million (64% loss severity). Currently ten
loans, representing 10% of the pool, are in special servicing. The
largest specially serviced loan is the Tower at Erieview Loan
($42.9 million -- 2.2% of the pool), which is secured by a 703,205
square foot (SF) office building located in Cleveland, Ohio. The
loan was transferred to special servicing for the second time
since securitization in May 2010 due to imminent payment default.
The loan was previously delinquent from November 2008 to August
2009, at which point the delinquency was cured by the borrower. As
of December 2010, the property was 61% leased.

The remaining nine specially serviced loans are secured by a mix
of property types. Moody's estimates an aggregate $61.8 million
loss for the specially serviced loans (33% expected loss on
average).

Moody's has assumed a high default probability for 16 poorly
performing loans representing 16% of the pool and has estimated an
aggregate $20.5 million loss (17% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 81%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 102% compared to 106% 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 9.2%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.33X and 1.00X, respectively, compared to
1.27X and 0.97X at last review. Moody's actual DSCR is based on
Moody's net cash flow (NCF) and the loan's actual debt service.
Moody's stressed DSCR is based on Moody's NCF and a 9.25% stressed
rate applied to the loan balance.

The top three loans represent 21% of the pool. The largest conduit
loan is the 1675 Broadway Loan ($154.8 million -- 8.1% of the
pool), which is secured by a 761,092 SF office building located in
the Midtown Manhattan neighborhood of New York City. The property
is also encumbered by a $25.0 million B-Note. Three tenants occupy
all of the property's office space -- The MacManus Group (47.2% of
the NRA; lease expiration 1/31/2021), Mayer, Brown, Rowe & Maw LLP
(32.6% of the NRA; lease expiration 8/31/2015) and Arent Fox, PPLC
(11.3% of the NRA; lease expiration 6/30/2018). The loan began
amortizing in July 2011 after the conclusion of a sixty month
interest only period. Property performance improved since last
review due to an increase in occupancy from 91% to 100%. Moody's
LTV and stressed DSCR are 86% and 1.14X, respectively, compared to
100% and 1.02X at last review.

The second largest conduit loan is the Woodland Mall Loan
($151.9 million -- 8.0% of the pool), which is secured by the
borrower's interest in a 1.1 million SF mall located in Grand
Rapids, Michigan. The collateral consists of 397,897 SF of in-line
tenant space. Excluded from the collateral are shadow anchors
including, Sears, JC Penney, Macy's and Kohl's. As of April 2011,
the property was 91% leased, compared to 83% at last review. The
loan is sponsored by PREIT. Although occupancy increased, rental
revenue declined due to a significant decline in rental rates
observed in recently signed and renewed leases. Leases accounting
for 23% of the NRA of the collateral space expire in the next 24
months. The property is currently on the master servicer's
watchlist. Moody's LTV and stressed DSCR are 114% and 0.80X,
respectively, the same as at last review.

The third largest conduit loan is the Orange Plaza Loan
($86.5 million -- 4.5% of the pool), which is secured by a
765,390 SF regional power center located in Middletown, New
York. Major tenants include Wal-Mart (30% of the NRA; lease
expiration 4/23/2022), Home Depot (15% of the NRA; lease
expiration 1/31/2015) and Kohl's (12% of the NRA; lease
expiration 1/28/2023). Improved property performance in 2010
due to higher rental revenue and expense recoveries than the
prior year was mostly offset by near-term tenancy risk. Leases
accounting for over 50% of the in-line tenant NRA expire within
the next 24 months. Moody's LTV and stressed DSCR are 109% and
0.84X, respectively, compared to 111% and 0.83X at last review.


BECKMAN COULTER: Fitch Affirms Class A at 'BB-'
-----------------------------------------------
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).


BERKELEY STREET: Moody's Upgrades Class A-2 Notes Rating to 'Ba3'
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Berkeley Street CDO (Cayman) Ltd.:

US$192,500,000 Class A-1 Floating Rate Senior Secured Notes Due
2013 (current outstanding balance of $8,427,921), Upgraded to Aaa
(sf); previously on October 21, 2010 Upgraded to Aa1 (sf);

US$34,800,000 Class A-2 Fixed Rate Senior Secured Notes Due 2013,
Upgraded to Aa2 (sf); previously on October 21, 2010 Upgraded to
Ba3 (sf).

RATINGS RATIONALE

According to Moody's, the rating action taken on the notes is
primarily a result of the substantial delevering of the Class A-1
Notes, which have been paid down by $44.4 million or 84% since the
rating action in October 2010. As a result of the delevering, the
Class A overcollateralization ratio has increased since the rating
action in October 2010. Based on the latest trustee report dated
July 23, 2011, the Class A overcollateralization ratio is reported
at 191.43% versus the September 2010 level of 117.35%. The rating
action also applies Moody's revised CLO assumptions described in
"Moody's Approach to Rating Collateralized Loan Obligations"
published in June 2011, whose 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 $76.3 million,
defaulted par of $21.5 million, a weighted average default
probability of 11.94% (implying a WARF of 3231), a weighted
average recovery rate upon default of 20.0%, and a diversity score
of 14. 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.

Berkeley Street CDO (Cayman) Ltd., issued in March 2001, is a
collateralized bond obligation backed primarily by a portfolio of
senior unsecured bonds.

The principal methodology used in this rating was "Moody's
Approach to Rating Collateralized Loan Obligations" published in
June 2011. This publication incorporates rating criteria that
apply to both collateralized loan obligations and collateralized
bond obligations. 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. 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. CBO
notes' performance may also be impacted by 1) the manager's
investment strategy and behavior and 2) divergence in legal
interpretation of CBO 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 bond market and/or collateral
   sales by the manager, which may have significant impact on the
   notes' ratings.

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

3) Lack of portfolio granularity: The performance of the portfolio
   depends to a large extent on the credit conditions of a few
   large obligors that are rated Caa1 or lower/non investment
   grade, especially when they experience jump to default. Due to
   the deal's low diversity score and lack of granularity, Moody's
   supplemented its typical Binomial Expansion Technique analysis
   with a simulated default distribution using Moody's CDOROM
   software and individual scenario analysis.


BLACKROCK SENIOR: Moody's Raises Ratings of 7 Classes of CLO Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by BlackRock Senior Income Series V, Limited:

US$75,000,000 Class A-1 Senior Multi-Currency Revolving Notes Due
2019 (current outstanding balance of $39,596,342, EUR17,149,465,
and GBP2,884,331), Upgraded to Aa1 (sf); previously on June 22,
2011 A1 (sf) Placed Under Review for Possible Upgrade;

US$180,000,000 Class A-2a Senior Notes Due 2019 (current
outstanding balance of $169,287,624), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa1 (sf) Placed Under Review for
Possible Upgrade;

US$20,000,000 Class A-2b Senior Notes Due 2019, Upgraded to Aa2
(sf); previously on June 22, 2011 A3 (sf) Placed Under Review for
Possible Upgrade;

US$110,000,000 Class A-3 Senior Notes Due 2019 (current
outstanding balance of $104,108,287), Upgraded to Aa1 (sf);
previously on June 22, 2011 A1 (sf) Placed Under Review for
Possible Upgrade;

US$17,000,000 Class B Senior Notes Due 2019, Upgraded to A1 (sf);
previously on June 22, 2011 Baa2 (sf) Placed Under Review for
Possible Upgrade;

US$30,000,000 Class C Deferrable Mezzanine Notes Due 2019,
Upgraded to Baa1 (sf); previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$28,000,000 Class D Deferrable Mezzanine Notes Due 2019,
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 October
2009. In particular, as of the latest trustee report dated June
2011, the weighted average rating factor is currently 2485
compared to 2679 in the August 2009 report. The Class A/B, Class
C, and Class D overcollateralization ratios are reported at
120.95%, 112.09%, and 104.92%, respectively, versus August 2009
levels of 114.94%, 106.81%, and 100.15%, 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 balance, including principal proceeds, of
$459 million, defaulted par of $2.2 million, a weighted average
default probability of 22.9% (implying a WARF of 2856), a weighted
average recovery rate upon default of 50.7%, and a diversity score
of 69. 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.

BlackRock Senior Income Series V, Limited, 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
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) 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 selling 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 worse
   of reported and covenanted values for weighted average rating
   factor, weighted average coupon, and diversity score. Moody's
   considered weighted average spread levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.

4) The deal has material exposure to non-USD denominated assets.
   Volatilities in foreign exchange rates will have a direct
   impact on interest and principal proceeds available to the
   transaction, which may affect the expected loss of the rated
   notes.


BLUEMOUNTAIN CLO: Moody's Upgrades Class E Notes Rating to 'Ba2'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by BlueMountain CLO III Ltd.:

US$31,500,000 Class B Senior Floating Rate Notes due 2021,
Upgraded to Aa2 (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

US$29,250,000 Class C Deferrable Mezzanine Floating Rate Notes due
2021, Upgraded to A3 (sf); previously on June 22, 2011 Baa2 (sf)
Placed Under Review for Possible Upgrade;

US$20,250,000 Class D Deferrable Mezzanine Floating Rate Notes due
2021, Upgraded to Baa3 (sf); previously on June 22, 2011 Ba2 (sf)
Placed Under Review for Possible Upgrade;

US$21,150,000 Class E Deferrable Junior Floating Rate Notes due
2021, 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.

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 $437.2 million, a
weighted average default probability of 24.16% (implying a WARF of
3032), a weighted average recovery rate upon default of 48.85%,
and a diversity score of 59. 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.

BlueMountain CLO III Ltd., issued in 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 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.


CALIFORNIA HOUSING: Moody's Lowers IFSR to 'C' From 'Caa3'
----------------------------------------------------------
Moody's Investors Service has downgraded the insurer financial
strength rating of the California Housing Loan Insurance Fund
(CalHLIF) to C from Caa3.

RATINGS RATIONALE

The action is based on the significant decline in reserves and
other resources available to pay insurance claims on a timely
basis leading to an anticipated shortfall in claims payments
beginning in the third quarter of 2011, the expectation of
continued high levels of claims due to the elevated delinquencies
and foreclosures experienced in the insured mortgage portfolio,
and the potential levels of losses on claims over time. $2.2
billion of insurance in force on primary mortgage insurance (PMI)
plus $1.4 billion of additional "gap" mortgage insurance is
affected by this downgrade.

CalHLIF is an insurance fund established by statutes of the State
of California and authorized to provide mortgage insurance for
residences in the state. CalHLIF is administered by CalHFA but is
capitalized separately from the California Housing Finance Fund,
under which CalHFA operates its revenue bond and other housing
finance programs.

No debt is affected by this rating action. The California Housing
Finance Agency (CalHFA) is the largest beneficiary of CalHLIF
insurance. Moody's ratings of CalHFA's debt, including the
agency's senior unsecured rating of A2 under review for downgrade
and the rating on CalHFA's Home Mortgage Revenue Bonds (HMRB) of
Baa1 under review for downgrade, already incorporate a weakened
position of CalHLIF. The diminished ability of CalHLIF to pay
claims will continue to be factored into Moody's analysis as
Moody's completes current reviews of CalHFA's ratings.

Detailed Credit Discussion

Financial Position Eroded by Increased Claims, which Will Exceed
Available Resources Beginning in Q3 2011

Increases in insurance claims have significantly eroded CalHLIF's
financial position to the point where available resources are
expected to be insufficient to make timely payment of all claims.
CalHLIF's fund equity declined to negative $24.7 million at
12/31/10 from $194 thousand at 12/31/09; CalHLIF's 12/31/10
audited statements express doubt as to CalHLIF's ability to
continue as a going concern and included management's assessment
that CalHLIF "might first deplete available funds to pay claims
and expenses sometime during the third quarter of 2011." Moody's
understands that CalHLIF's shortfalls in full and timely claims
payments may occur during August 2011. CalHLIF has stated that it
intends to pay future claims from premiums received and any other
available funds on a 'first-in, first-out basis in the order in
which the claims and expenses are received."

Operating income for the year ended 12/31/10 was negative $24.9
million, reflecting gross premiums earned of $16.5 million and
loss and loss adjustment expenses of $29.7 million. This compared
with a loss of $54 million for the year ended 12/31/09, reflecting
gross premiums of $20.9 million and loss and loss adjusted
expenses of $60.6 million.

CalHLIF's insurance book consists of two parts: primary mortgage
insurance (PMI) and "gap" mortgage insurance.

CalHLIF had PMI as of 12/31/10 (CalHLIF's most recent audited
financial statements) on approximately $2.2 billion outstanding
principal amount of single family mortgage loans, substantially
all of which were originated under CalHFA's single family mortgage
program for persons of low and moderate income in California. As
to PMI policies covering over 90% of the book by insured
principal, CalHLIF benefits from reinsurance from Genworth
Mortgage Insurance Corp. (GMICO, rated Ba1 with a negative
outlook). The Genworth reinsurance covers 75% of the loss on each
insured loan on a quota-share basis. Risk in force to CalHLIF as
of 12/31/10, after benefit of the Genworth reinsurance, was
approximately $208 million.

PMI claims payments (net of reinsurance) increased to
$43.1 million for the year ended 12/31/10 from $23.6 million for
the year ended 12/31/09. Net PMI claims paid for the six months
ended 6/30/11 were approximately $21.4 million.

In addition, CalHLIF has "gap" insurance outstanding, subject
to a certain level of indemnification for gap claims provided by
CalHFA. CalHFA's primary financing program for single family
mortgage loans is the HMRB program, which provides for mortgage
insurance covering at least 50% of delinquent principal on
mortgage loans (other than loans with FHA insurance) that go to
claim. The gap insurance satisfies this requirement; for mortgage
loans with 35% policies, gap insurance covers an additional 15% of
mortgage principal after recovery on PMI and foreclosure, and for
loans without PMI (primarily loans with loan-to-value ratios below
80%) the gap insurance covers losses of up to 50% of mortgage
principal after foreclosure. CalHFA provides indemnification to
CalHLIF for gap claims; in March, 2010, CalHFA limited the amount
of funds available in support of the indemnification to
$135 million including claims paid.

Gap insurance claims for the year ended 12/31/10 were
approximately $61.5 million, up from $22.9 million for the year
ended 12/31/09. Gap claims have been paid from $135 million CalHFA
fund. Moody's understands that these funds should be depleted in
the third quarter.

Going forward claims are expected to be paid to the extent of
premiums earned. Moody's anticipates losses on future claims at
levels consistent with the rating being assigned.

CalHLIF's declining financial performance reflects the severe
decline in performance of the underlying portfolio of mortgage
loans in CalHFA's single family portfolio. Serious delinquencies
(90 days + and in foreclosure) in the CalHLIF PMI-insured
portfolio increased from 2.86% at 6/30/08 to 16.4% as of 12/31/09.
Such delinquencies have since declined and stood at 11.81% as of
5/31/11. For all CalHFA conventional loans (including both those
with CalHLIF PMI and gap insurance and those with gap insurance
alone) serious delinquencies increased from 1.97% at 6/30/08 to
11.25% as of 12/31/09 and then declined to 8.18% as of 5/31/11.
CalHFA has an active single family asset management function that
has worked to reduce timelines for claims in order to manage
losses. The number of PMI insured loans has declined from 9,116 at
12/31/09 to 6,894 at 5.31/11. The U.S. Treasury's commitment to
provide a total of $1.98 billion of Hardest Hit Funds (HHF) has
the potential to be a significant positive in CalHFA's efforts to
reduce mortgage losses, which may potentially reduce insurance
claims to CalHLIF. Although the size of the award is significant,
implementation has been slow, and the impact of HHF on CalHLIF is
difficult to quantify at this time. The funds are available to
lenders statewide; because CalHFA borrowers may meet the general
eligibility criteria under the HHF initiative, a portion of the
funds could benefit CalHLIF-insured loans.

Based on these trends Moody's believes that insurance claims will
exceed funds available for claims payments by a level consistent
with the rating assigned. Moody's projects potential PMI claims (
net of reinsurance), after the anticipated exhaustion of insurance
reserves to exceed $80 million compared with estimated available
future resources of $17 to $23 million, which would lead to
recoveries of 21% to 29% over time. Inclusion of additional claims
on gap insurance could further increase losses and reduce recovery
levels.

What could change the rating - UP

A significant decrease in insurance claims below Moody's current
expectations, reflecting decreases in loan delinquencies and
foreclosures, and success by CalHFA and CalHLIF in moderating
insurance claims through claims management and application of HHF
funds, decreasing levels of potential losses on insurance claims

What could change the rating - DOWN

N/A

The California Housing Loan Insurance Fund rating was assigned by
evaluating factors believed to be relevant to the credit profile
of the Fund such as i) the business risk and competitive position
of the Fund versus others within its industry or sector, ii) the
capital structure and financial risk of the Fund, iii) the
projected performance of the Fund over the near to intermediate
term, iv) the Fund's history of achieving consistent operating
performance and meeting budget or financial plan goals, v) the
nature of the dedicated revenue stream supporting the Fund, vi)
the legal structure that documents the revenue stream and the
source of payment, and viii) and the Fund's management and
governance structure related to payment.


CALLIDUS DEBT: Moody's Raises Ratings of Class D Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Callidus Debt Partners CLO Fund VII, Ltd.:

US$443,000,000 Class A Senior Secured Floating Rate Notes Due 2021
(current balance of $442,064,922.79), Upgraded to Aa1 (sf);
previously on June 22, 2011 A1 (sf) Placed Under Review for
Possible Upgrade;

US$24,000,000 Class B Senior Secured Floating Rate Notes Due 2021,
Upgraded to A1 (sf); previously on June 22, 2011 Baa1 (sf) Placed
Under Review for Possible Upgrade;

US$33,000,000 Class C Senior Secured Deferrable Floating Rate
Notes Due 2021, Upgraded to Baa2 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$19,500,000 Class D Senior Secured Deferrable Floating Rate
Notes Due 2021, Upgraded to Ba1 (sf); previously on June 22, 2011
B3 (sf) Placed Under Review for Possible Upgrade; and

US$25,500,000 Class E Senior Secured Deferrable Floating Rate
Notes Due 2021 (current balance of $21,461,437.79), 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 and credit improvement
of the underlying portfolio since the rating action in May 2010.
Based on the latest trustee report dated July 11, 2011, the Class
A/B, Class C, Class D, and Class E overcollateralization ratios
are reported at 124.56%, 116.32%, 111.95% and 107.50%,
respectively, versus April 2010 levels of 122.56%, 114.45%,
110.16%, and 105.77%, respectively. Based on the July 2011 trustee
report, the weighted average rating factor is currently 2,464
compared to 2,726 in April 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 $580.5 million,
defaulted par of $2.98 million, a weighted average default
probability of 23.51% (implying a WARF of 2,890), a weighted
average recovery rate upon default of 48.89%, and a diversity
score of 66. The default and recovery properties of the collateral
pool are incorporated in cash flow model analysis where they are
subject to stresses as a function of the target rating of each CLO
liability being reviewed. The default probability is derived from
the credit quality of the collateral pool and Moody's expectation
of the remaining life of the collateral pool. The average recovery
rate to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Callidus Debt Partners CLO Fund VII, 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) 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, weighted average spread, weighted average
   coupon, 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.


CAMBER 3: S&P Affirms Ratings on 5 Classes of Notes at 'CC'
-----------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on six
classes from Camber 3 PLC. "At the same time, we removed our
rating on the class S notes from CreditWatch, where we placed
it with negative implications on May 25, 2011. The transaction
is U.S. collateralized debt obligation transaction backed
substantially by residential mortgage-backed securities," S&P
said.

The affirmations and CreditWatch removal primarily reflect the
availability of sufficient credit support at the current rating
levels.

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 Action

Camber 3 PLC
                   Rating
Class       To                From
S           A (sf)            A (sf)/Watch Neg

Ratings Affirmed

Camber 3 PLC
Class   Rating
A-1      CC (sf)
A-2      CC (sf)
B        CC (sf)
C        CC (sf)
D        CC (sf)


CANADA MORTGAGE: Moody's Withdraws Ratings On Three Transactions
----------------------------------------------------------------
Moody's Investors Service has withdrawn the ratings of nine
tranches from the Canada Mortgage Acceptance Corporation Series
2004-C2, 2005-C3 and 2006-C4 transactions. These tranches are
backed by a pool of mortgage loans with a pool factor less than 5%
and containing fewer than 40 loans.

Complete rating actions are:

Issuer: Canada Mortgage Acceptance Corporation, Series 2004-C2

2004C2-A, Withdrawn (sf); previously on Dec 21, 2004 Assigned Aaa
(sf)

2004C2-IO, Withdrawn (sf); previously on Dec 21, 2004 Assigned Aaa
(sf)

2004C2-B, Withdrawn (sf); previously on Dec 21, 2004 Assigned Aa2
(sf)

2004C2-C, Withdrawn (sf); previously on Dec 21, 2004 Assigned A2
(sf)

2004C2-D, Withdrawn (sf); previously on Dec 21, 2004 Assigned Baa2
(sf)

2004C2-E, Withdrawn (sf); previously on Dec 21, 2004 Assigned Ba2
(sf)

2004C2-F, Withdrawn (sf); previously on Dec 21, 2004 Assigned B2
(sf)

Issuer: Canada Mortgage Acceptance Corporation, Series 2005-C3

2005IO-P, Withdrawn (sf); previously on Aug 1, 2005 Assigned Aaa
(sf)

Issuer: Canada Mortgage Acceptance Corporation, Series 2006-C4

Cl. IO-C, Withdrawn (sf); previously on Mar 6, 2006 Assigned Aaa
(sf)

RATINGS RATIONALE

Moody's current RMBS surveillance methodologies apply to pools
with at least 40 loans and a pool factor of greater than 5%. As a
result, Moody's may withdraw its rating when the pool factor drops
below 5% and the number of loans in the pool declines to 40 loans
or lower unless specific structural features allow for a
monitoring of the transaction (such as a credit enhancement floor
or pool insurance).

Moody's has withdrawn the rating pursuant to published rating
methodologies that allow for the withdrawal of the rating if the
size of the underlying collateral pool at the time of the
withdrawal has fallen below a specified level.


CAPITALSOURCE REAL: Fitch Affirms Junk Rating on 7 Note Classes
---------------------------------------------------------------
Fitch Ratings has affirmed all classes of CapitalSource Real
Estate Loan Trust 2006-A (CapitalSource 2006-A) reflecting Fitch's
base case loss expectation of 27.3%.  Fitch's performance
expectation incorporates prospective views regarding commercial
real estate market value and cash flow declines.

Since last review, classes A-1A and A-2A have been paid down by
$131 million (10% of the original transaction balance).  While
proceeds have also been directed to pay down the A-1R notes, these
payments only serve to increase the amount of available undrawn
capacity.  The revolver class continues to maintain its total
capacity of $200 million. Since last review, the disposal of
multiple assets from the collateralized debt obligation (CDO)
resulted in realized losses to par of greater than $90 million.
However, these losses were offset by par building of approximately
$108 million from the purchase of new assets, predominately whole
loan/A-note positions and commercial mortgage-backed securities
(CMBS).

CapitalSource 2006-A is primarily collateralized by senior
commercial real estate (CRE) debt with 73.6% of the total
collateral consisting of whole loans/A-notes.  As of the July 2011
trustee report and per Fitch categorization, the remaining
collateral consisted of principal cash (10.7%), CMBS (7.2%),
rediscount facilities (3.4%), B-notes (3.2%), and term loan
financing (1.9%).  Additionally, Fitch is generally concerned with
the high percentage of the total collateral secured by non-
traditional property types, including resort/timeshare (15.4%),
hotel (13.3%), land (9.4%), healthcare (7.6%), and casino (4.8%).

Defaulted assets comprise 3.2% of the total collateral and include
five whole loans, three of which are secured by land (1.7%), one
of which is secured by multifamily (1.4%), and one of which is
secured by healthcare (0.1%).  An additional 18 loans (26.8%) were
identified as Loans of Concern.  These Loans of Concern include 16
whole loan/A-notes (25.3%) and two B-notes (1.5%).  Fitch modeled
significant losses on the defaulted assets and Loans of Concern.

CapitalSource 2006-A was initially issued as a $1.3 billion
revolving CRE CDO with a five-year reinvestment period ending in
January 2012.  All overcollateralization and interest coverage
ratios have remained above their covenants as of the July 2011
trustee report.

Under Fitch's surveillance methodology, approximately 80% 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 9.8%.  Fitch estimates that average
recoveries will be at 65.9%.

The largest component of Fitch's base case loss expectation is an
A-note (6.6%) which was initially secured by the construction of a
hotel property located in Atlantic City, NJ.  Construction has
since been completed and the property is fully operational.  Year-
end 2010 property cash flow is insufficient to support debt
service.  Fitch modeled a term default with a significant loss
under its base case scenario.

The second largest component of Fitch's base case loss expectation
is an A-note (2.9%) secured by over 2,000 acres of land located in
the Pocono Mountains of Pennsylvania.  The initial business plan
was to develop the site in multiple phases, but due to economic
downturn, the plan was not realized.  Fitch modeled a term default
with a significant loss under its base case scenario.

The third largest component of Fitch's base case loss expectation
is a whole loan (2.1%) secured by a 64-key beachfront hotel
property located in Cape May, NJ.  The borrower's original
business plan was to demolish the existing structure and construct
luxury condominium units.  However, due to economic downturn, the
borrower has been operating the hotel on a seasonal basis.  Fitch
modeled a term default with a significant loss under 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 default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.
Based on this analysis, the breakeven rates for classes A-1A, A-
1R, A-2A, A-2B, and B are generally consistent with the ratings
assigned below.

The ratings for classes C through J 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 (RRs) in order to provide a forward-looking
estimate of recoveries on currently distressed or defaulted
structured finance securities.

The Rating Outlook on class A-2A was revised to Stable based upon
its senior position in the capital structure.  Classes A-1A, A-1R,
A-2B, and B maintain a Negative Outlook reflecting Fitch's
expectation for further potential negative credit migration of the
underlying collateral.

At issuance, the CDO was managed by CapitalSource Finance, LLC
(CapitalSource), a subsidiary of CapitalSource, Inc. In the fourth
quarter of 2010, NS Advisors II, LLC (NS Advisors II) became the
delegated collateral manager for the CDO under the delegation
provisions of the Indenture.  All collateral manager
responsibilities and fees have been delegated to NS Advisors II.
In addition, an amendment to the servicing agreement replaced the
special servicer of the CDO to NS Servicing, LLC (NS Servicing).
NS Servicing assumed all rights, interests, duties, and
obligations as special servicer under the servicing agreement,
previously held by CapitalSource.

In June 2009, Fitch was notified by the trustee that a tax event
had occurred under the terms of the indenture.  CapitalSource Inc.
revoked its REIT election as of Jan. 1, 2009, causing the issuer
to lose its status as a Qualified REIT Subsidiary for U.S. income
tax purposes.  Consequently, the issuer was treated as a
corporation subject to income taxes for the remaining life of the
deal.  According to discussions with NS Advisors II, it is
expected that the CDO will resume as a non-taxable entity. The CDO
currently has a tax reserve account in place which has a balance
of $24.5 million as of the July 2011 trustee report.

Fitch has affirmed and revised Recovery Ratings (RRs) on the
following classes as indicated:

  -- $49.6 million class A-1A at 'BB'; Outlook Negative;
  -- $200 million class A-1R at 'BB'; Outlook Negative;
  -- $315.6 million class A-2A at 'BB'; Outlook to Stable from
     Negative;
  -- $125 million class A-2B at 'BB'; Outlook Negative;
  -- $82.9 million class B at 'B'; Outlook Negative;
  -- $62.4 million class C at 'CCC/RR4';
  -- $30.2 million class D at 'CCC/RR6';
  -- $30.2 million class E at 'CCC/RR6';
  -- $26.7 million class F at 'CC/RR6';
  -- $33.2 million class G at 'CC/RR6';
  -- $31.2 million class H at 'C/RR6';
  -- $47.5 million class J at 'C/RR6'.


CAVALRY CLO: Moody's Upgrades Class D Notes Rating to Baa3 From B3
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Cavalry CLO I, Ltd.:

US$10,000,000 Class A-2 Senior Secured Floating Rate Notes due
2022, Upgraded to Aaa (sf); previously on June 22, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade;

US$10,250,000 Class B-1 Senior Secured Deferrable Floating Rate
Notes dues 2022, Upgraded to Aa1 (sf); previously on June 22, 2011
Baa3 (sf) Placed Under Review for Possible Upgrade;

US$12,750,000 Class B-2 Senior Secured Deferrable Fixed Rate Notes
dues 2022, Upgraded to Aa1 (sf); previously on June 22, 2011 Baa3
(sf) Placed Under Review for Possible Upgrade;

US$27,000,000 Class C Senior Secured Deferrable Floating Rate
Notes dues 2022, Upgraded to A3 (sf); previously on June 22, 2011
Ba3 (sf) Placed Under Review for Possible Upgrade;

US$12,000,000 Class D Secured Deferrable Floating Rate Notes dues
2022, Upgraded to Baa3 (sf); previously on June 22, 2011 B3 (sf)
Placed Under Review for Possible Upgrade;

US$8,000,000 Type I Composite Notes due 2022 (current rated
balance of $5,746,656), Upgraded to Aaa (sf); previously on
June 22, 2011 Aa3 (sf) Placed Under Review for Possible Upgrade;

US$4,000,000 Type II Composite Notes due 2022 (current rated
balance of $2,348,869), Upgraded to Aa1 (sf); previously on
June 22, 2011 Baa2 (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 July 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2532 compared to 2792 in May 2009.
Additionally, the Class A, Class B, Class C, and Class D
overcollateralization ratios are reported at 135.64%, 125.54%,
115.44%, and 111.46%, respectively, versus May 2009 levels of
128.76%, 119.44%, 110.09%, and 106.39%, 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 $398.8 million, a
weighted average default probability of 20.29% (implying a WARF of
2802), a weighted average recovery rate upon default of 50.6%, and
a diversity score of 59. 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.

Cavalry CLO I, Ltd., issued in March 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) 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.


CEAGO ABS: S&P Lowers Ratings on 5 Classes of Notes to 'D'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 22
classes of notes from five U.S. cash flow collateralized debt
obligations (CDOs) of structured finance assets. "Additionally, we
withdrew our 'AA+ (sf)' rating on one note," S&P related.

"We lowered our ratings because the transactions could not pay the
noteholders in full after the liquidation of the portfolio assets.
Additionally, CEAGO ABS CDO 2007-1 Ltd., IMAC CDO 2006-1 Ltd., and
Maxim High Grade CDO I Ltd. have 13 ratings outstanding, which we
previously lowered to 'D (sf)' to reflect missed interest payments
at an earlier payment date," S&P said.

"We withdrew our rating on the Princ notes from Maxim High Grade
CDO I after the underlying treasury security was transferred to
the noteholder on the liquidation date," S&P related.

Ratings Lowered

CEAGO ABS CDO 2007-1 Ltd.
                Rating
Class       To          From
S           D (sf)      CCC- (sf)
A-1         D (sf)      CC (sf)
A-2         D (sf)      CC (sf)
C           D (sf)      CC (sf)
D           D (sf)      CC (sf)

Hereford Street ABS CDO I Ltd.
                Rating
Class      To          From
A-1        D (sf)      CC (sf)
A-2        D (sf)      CC (sf)
B          D (sf)      CC (sf)
C          D (sf)      CC (sf)
D          D (sf)      CC (sf)

IMAC CDO 2006-1 Ltd.
                Rating
Class      To          From
E          D (sf)      CC (sf)
F          D (sf)      CC (sf)
G          D (sf)      CC (sf)

Kleros Real Estate CDO I Ltd.
                Rating
Class      To          From
A-1A       D (sf)      CC (sf)
A-1B       D (sf)      CC (sf)
A-2        D (sf)      CC (sf)
B          D (sf)      CC (sf)
C          D (sf)      CC (sf)
D          D (sf)      CC (sf)

Maxim High Grade CDO I Ltd.
                Rating
Class      To          From
D          D (sf)      CC (sf)
E1         D (sf)      CC (sf)
E2         D (sf)      CC (sf)

Ratings Withdrawn

Maxim High Grade CDO I Ltd.
                Rating
Class      To         From
Princ Nts  NR         AA+ (sf)

NR -- Not rated.

Other Ratings Outstanding

CEAGO ABS CDO 2007-1 Ltd.
Class            Rating
B                D (sf)

IMAC CDO 2006-1 Ltd.
Class            Rating
A-1              D (sf)
A-2              D (sf)
B                D (sf)
C                D (sf)
D                D (sf)

Maxim High Grade CDO I Ltd.
Class            Rating
A1               D (sf)
A2               D (sf)
A3               D (sf)
A4               D (sf)
A5               D (sf)
B                D (sf)
C                D (sf)


CENT CDO: Moody's Upgrades Class D Notes Rating to 'Ba3'
--------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Cent CDO 15 Limited:

US$61,000,000 Class A-1 Floating Rate Notes Due 2021, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review
for Possible Upgrade;

US$39,000,000 Class A-2b Floating Rate Notes Due 2021, Upgraded to
Aa1 (sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review
for Possible Upgrade;

US$39,500,000 Class A-3 Floating Rate Notes Due 2021, Upgraded to
Aa3 (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$33,500,000 Class B Deferrable Floating Rate Notes Due 2021,
Upgraded to A3 (sf); previously on June 22, 2011 Baa2 (sf) Placed
Under Review for Possible Upgrade;

US$23,000,000 Class C Deferrable Floating Rate Notes Due 2021,
Upgraded to Baa3 (sf); previously on June 22, 2011 Ba2 (sf) Placed
Under Review for Possible Upgrade;

US$19,000,000 Class D Deferrable Floating Rate Notes Due 2021,
Upgraded to Ba3 (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.

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 $594 million,
defaulted par of $5.9 million, a weighted average default
probability of 21.92% (implying a WARF of 2957), a weighted
average recovery rate upon default of 47.96%, 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.

Cent CDO 15 Limited, 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) 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 spread
   levels higher than the covenant levels due to the large
   difference between the reported and covenant levels.


CENT CDO: Moody's Upgrades Rating of Class D Notes to 'Ba2'
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Cent CDO 14 Limited:

US$110,000,000 Class A-1 Senior Term Notes due 2021, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review
for Possible Upgrade;

US$26,250,000 Class A-2b Senior Term Notes due 2021, Upgraded to
Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$33,750,000 Class B Senior Floating Rate Notes due 2021,
Upgraded to A1 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$ 24,375,000 Class C Deferrable Mezzanine Floating Rate Notes
due 2021, Upgraded to Baa2 (sf); previously on June 22, 2011 Ba1
(sf) Placed Under Review for Possible Upgrade;

US$18,750,000 Class D Deferrable Mezzanine Floating Rate Notes due
2021, Upgraded to Ba2 (sf); previously on June 22, 2011 B1 (sf)
Placed Under Review for Possible Upgrade;

US$12,500,000 Class E Deferrable Junior Floating Rate Notes due
2021, 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 September
2009. Based on the July 2011 trustee report, the weighted average
rating factor is currently 2603 compared to 2919 in July 2009.
Additionally, the Class A/B, Class C, Class D, and Class E
overcollateralization ratios are reported at 119.76%, 112.99%,
108.27%, and 105.34%, respectively, versus the July 2009 levels of
117.25%, 110.61%, 106.00%, and 103.13%, 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 $485.3 million,
defaulted par of $3.7 million, a weighted average default
probability of 23.42% (implying a WARF of 2922), a weighted
average recovery rate upon default of 48.2%, 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.

Cent CDO 14 Limited, 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.

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) 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.


CENT CDO: Moody's Upgrades Ratings of Five Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Cent CDO 12 Limited:

US$459,600,000 Class A Floating Rate Senior Notes Due November 18,
2020, Upgraded to Aa1 (sf); previously on June 22, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade;

US$28,800,000 Class B Floating Rate Senior Notes Due November 18,
2020, Upgraded to A1 (sf); previously on June 22, 2011 A3 (sf)
Placed Under Review for Possible Upgrade;

US$32,400,000 Class C Deferrable Floating Rate Mezzanine Notes Due
November 18, 2020, Upgraded to Baa1 (sf); previously on June 22,
2011 Ba1 (sf) Placed Under Review for Possible Upgrade;

US$22,800,000 Class D Deferrable Floating Rate Mezzanine Notes Due
November 18, 2020, Upgraded to Ba1 (sf); previously on June 22,
2011 B1 (sf) Placed Under Review for Possible Upgrade;

US$22,800,000 Class E Deferrable Floating Rate Junior Notes Due
November 18, 2020, 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.

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 2632 compared to 2838
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 $600.0 million,
defaulted par of $4.6 million, a weighted average default
probability of 24.45% (implying a WARF of 2957), a weighted
average recovery rate upon default of 48.77%, and a diversity
score of 85. 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.

Cent CDO 12 Limited, 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) 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.


CENTURION CDO: Moody's Raises Rating of Class C-1 Notes to 'Ba1'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Centurion CDO VII Limited:

US$22,000,000 Class A-1b Floating Rate Notes due 2016, Upgraded to
Aa1 (sf), previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$632,500,000 Class A-2 Floating Rate Notes due 2016 (current
balance of $590,642,291), Upgraded to Aaa (sf), previously on
June 22, 2011 Aa2 (sf) Placed Under Review for Possible Upgrade;

US$22,500,000 Class B-1 Deferrable Fixed Rate Notes due 2016,
Upgraded to Baa1 (sf), previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$76,500,000 Class B-2 Deferrable Floating Rate Notes due 2016,
Upgraded to Baa1 (sf), previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$3,000,000 Class C-1 Deferrable Fixed Rate Notes due 2016,
Upgraded to Ba1 (sf), previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$27,205,000 Class C-2 Deferrable Floating Rate Notes due 2016,
Upgraded to Ba1 (sf), previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$5,000,000 Class D-1 Deferrable Fixed Rate Notes due 2016,
Upgraded to B1 (sf), previously on June 22, 2011 Caa3 (sf) Placed
Under Review for Possible Upgrade;

US$25,300,000 Class D-2 Deferrable Floating Rate Notes due 2016,
Upgraded to B1 (sf), previously on June 22, 2011 Caa3 (sf) Placed
Under Review for Possible Upgrade;

US$6,000,000 Class H Combination Securities due 2016 (current
rated balance of $791,660), Upgraded to Ba1 (sf), previously on
June 22, 2011 B2 (sf) Placed Under Review for Possible Upgrade;

US$8,500,000 Class K Combination Securities due 2016 (current
rated balance of $3,090,590), Upgraded to A2 (sf), previously on
June 22, 2011 Ba1 (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 and credit improvement of the underlying portfolio since the
rating action in September 2009. Moody's notes that the Class A-1a
Notes have been paid down by approximately 7% or $14 million and
the Class A-2 Notes have been paid down by approximately 6% or $40
million since the rating action in September 2009. As a result of
the delevering, the overcollateralization ratios have increased.
Based on the latest trustee report dated July 26, 2011, the Class
A, Class B, Class C and Class D overcollateralization ratios are
reported at 127.55%, 113.69%, 110.04% and 106.61%, respectively,
versus August 2009 levels of 124.54%, 111.55%, 108.11% and
104.87%, respectively. Moody's notes that these reported
overcollateralization ratios do not reflect the impact of the
recent paydown of the Class A-1a Notes and Class A-2 Notes, which
were reduced by $4 million and $12 million, respectively on the
August 2, 2011 payment date.

Moody's also notes that the deal has benefited from 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 2421 compared to
2629 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 $996 million,
defaulted par of $30 million, a weighted average default
probability of 13.43% (implying a WARF of 2609), a weighted
average recovery rate upon default of 47.37%, and a diversity
score of 54. 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.

Centurion CDO VII Limited, issued in May 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.

Another 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) 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.


COAST INVESTMENT: Moody's Raises Class B-1 Rating to Baa3 from B2
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of four classes
of notes issued by Coast Investment Grade 2001-1, Limited. The
classes of notes affected by today's rating actions are:

US$48,700,000 Class B-1 Floating Rate Senior Secured Notes
(current balance of $44,266,676), Upgraded to Baa3 (sf);
previously on Jun 24, 2011 B2 (sf) Placed Under Review for
Possible Upgrade;

US$5,000,000 Class B-2 Fixed Rate Senior Secured Notes (current
balance of $4,544,833), Upgraded to Baa3 (sf); previously on
Jun 24, 2011 B2 (sf) Placed Under Review for Possible Upgrade;

US$11,000,000 Class C-1 Floating Rate Senior Secured Notes,
Upgraded to Caa3 (sf); previously on Jun 24, 2011 C (sf) Placed
Under Review for Possible Upgrade;

US$5,000,000 Class C-2 Fixed Rate Senior Secured Notes, Upgraded
to Caa3 (sf); 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 29, 2011, the Class B
and C overcollateralization ratios are reported at 122.84% and
91.70% respectively, versus April 2011 levels of 109.05% for Class
B and 83.73% for Class C. Also based on the July report the WARF
is reported at 2541 versus an April 2011 reported WARF of 3104.

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).
Today's 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, 33% of the collateral has been upgraded
since June 22nd, and 7% remains on review.

Coast Investment Grade 2001-1, Ltd. 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.


COBALT CMBS: Moody's Affirms Cl. A-JFX Notes Rating at 'Ba3'
------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 22
classes of Cobalt CMBS Commercial Mortgage Trust, Commercial
Mortgage Pass-Through Certificates, Series 2007-C2:

Cl. A-2, Affirmed at Aaa (sf); previously on Apr 19, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-3, Affirmed at Aaa (sf); previously on Dec 2, 2010 Confirmed
at Aaa (sf)

Cl. A-AB, Affirmed at Aaa (sf); previously on Apr 19, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Dec 2, 2010
Confirmed at Aaa (sf)

Cl. A-MFX, Affirmed at A1 (sf); previously on Dec 2, 2010
Downgraded to A1 (sf)

Cl. A-JFX, Affirmed at Ba3 (sf); previously on Dec 2, 2010
Downgraded to Ba3 (sf)

Cl. X, Affirmed at Aaa (sf); previously on Apr 19, 2007 Definitive
Rating Assigned Aaa (sf)

Cl. B, Affirmed at B3 (sf); previously on Dec 2, 2010 Downgraded
to B3 (sf)

Cl. C, Affirmed at Caa2 (sf); previously on Dec 2, 2010 Downgraded
to Caa2 (sf)

Cl. D, Affirmed at Caa3 (sf); previously on Dec 2, 2010 Downgraded
to Caa3 (sf)

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

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

Cl. A-MFL, Affirmed at A1 (sf); previously on Dec 2, 2010
Downgraded to A1 (sf)

Cl. A-JFL, Affirmed at Ba3 (sf); previously on Dec 2, 2010
Downgraded to Ba3 (sf)

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

Cl. H, Affirmed at C (sf); previously on Dec 2, 2010 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)

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
12.1% of the current balance. At last review, Moody's cumulative
base expected loss was 12.0%. Moody's stressed scenario loss is
23.4% of the current balance compared to 26.9% 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 de leveraging, 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.

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 6% to $2.3 billion
from $2.4 billion at securitization. The Certificates are
collateralized by 134 mortgage loans ranging in size from less
than 1% to 11% of the pool, with the top ten loans representing
27% of the pool. The pool includes one loan with an investment
grade credit estimate, representing 4% of the pool.

Fifty loans, representing 22% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
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 since
securitization, resulting in an aggregate $43.1 million loss (46%
loss severity on average). There were $30.5 million in realized
losses from eight loans at last review. Eleven loans, representing
24% of the pool, are currently in special servicing compared to 15
loans representing 17% of the pool at last review.

The largest specially serviced loan is the Peter Cooper Village
and Stuyvesant (PCV/ST) Loan ($250.0 million -- 10.9% 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 $51.3 million appraisal
reduction in November 2010, increasing to an appraisal reduction
totaling $62.3 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 tenant 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 second largest specially serviced loan is the Woodies Building
Loan ($172.1 million -- 7.5% of the pool), which is secured by two
buildings totaling 493,668 SF with street level retail and office
space above. These properties are located in the East End sub-
market of Washington, D.C. The office component represents 73% of
the net rentable area (NRA) and is predominantly leased to
government agencies. The largest office tenants are the Federal
Bureau of Investigation (29% of the NRA; lease expiration in
2015), the National Endowment of Democracy (13% of the NRA; lease
expiration in March 2021) and the Environmental Protection Agency
(10% of the NRA; lease expiration in March 2014). The largest
retail tenants are Forever 21, H&M, Madame Tussauds and Zara. As
of September 2010, the property was 99% leased compared to 91% at
last review. The loan remains current and was transferred to
special servicing March 2011 due to multiple defaults. Discussions
and negotiations between the borrower and special servicer to
resolve matters are underway.

The remaining nine specially serviced loans are secured by a mix
of property types. The master servicer has recognized an aggregate
$104.8 million appraisal reduction for six of the remaining
specially serviced loans. Moody's has estimated an aggregate
$174.4 million loss (32% expected loss on average) for all of the
specially serviced loans.

Moody's has assumed a high default probability for 17 poorly
performing loans representing 8.3% of the pool and has estimated
an aggregate $35.6 million loss (19% expected loss based on a 50%
probability of default) from these troubled loans.

Based on the most recent remittance statement, Classes G through
S have experienced cumulative interest shortfalls totaling
$4.8 million. Interest shortfalls had increased from Class L to
Class H 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, loan modifications, ASERs
and extraordinary trust expenses.

Moody's was provided with full year 2010 operating results for 74%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV for the conduit component is 110%
compared to 119% at Moody's prior review. Moody's net cash flow
reflects a weighted average haircut of 11.0% to the most recently
available net operating income (NOI). Moody's value reflects a
weighted average capitalization rate of 9.2%.

Moody's actual and stressed DSCRs for the performing conduit loans
are 1.43X and 0.96X, respectively, compared to 1.27X and 0.88X 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 27 compared to 28 at Moody's prior review.

The loan with a credit estimate is the GGP-sponsored Ala Moana
Portfolio Loan ($87.2 million -- 3.8%), which is a pari-passu
interest in a first mortgage loan secured by a 2.0 million square
foot (SF) mixed-use portfolio located on the island of Hawaii. The
largest property is the Ala Moana Mall, which is considered the
world's largest open-air shopping center. As of March 2011, the
portfolio was 95% leased, essentially the same as at last two
reviews. The loan was transferred to special servicing in April
2009 when GGP filed for bankruptcy. Since exiting bankruptcy, GGP
paid down the current portfolio loan balance by $150 million.
Additionally, the loan's maturity date was extended to 2018 and
the loan was restructured with a 25-year amortization schedule.
Moody's credit estimate and stressed DSCR are A3 and 0.89X,
respectively, compared to A3 and 0.90X at the prior review.

The top three performing conduit loans represent 16% of the pool
balance. The largest loan is the 75 Broad Street Loan ($243.5
million -- 10.6% of the pool), which is secured by a 648,000 SF
office telecom building located in the Financial District of New
York. The property was 94% leased as of December 2010 compared to
96% at last review. The largest tenants include Internap (13% of
the new rentable area (NRA); lease expiration December 2016) and
the Board of Education (12% of the NRA; lease expiration August
2018). The loan is interest only for its entire ten-year term.
Moody's LTV and stressed DSCR are 115% and 0.87X, respectively,
compared to 117% and 0.85X at last review.

The second largest loan is One Summer Street Loan ($79.4 million -
- 3.5% of the pool), which is secured by a 388,000 SF office
telecom building located in Boston, Massachusetts. The largest
tenants include Qwest Communications Corp (17% of the NRA; lease
expiration June 2015) and WiTel Communications LLC (15% of the
NRA; lease expiration February 2020). The property was 62% leased
as of December 2010, compared to 64% at last review. The loan was
interest only for the first 24 months of its ten-year term and is
now amortizing. Moody's LTV and stressed DSCR are 64% and 1.73X,
respectively, compared to 93% and 1.19X at last review.

The third largest loan is the Argonaut Hotel Loan ($42.0 million -
- 1.8% of the pool), which is secured by a 252-room boutique hotel
located in the Fisherman's Wharf area of San Francisco,
California. The property was 87% occupied as of December 2010,
compared to 93% at last review. The loan is interest only
throughout the five-year term. Moody's LTV and stressed DSCR are
98% and 1.13X, respectively, compared to 99% and 1.12X at last
review.


COMM 2004-LNB2: S&P Lowers Rating on Class K Certs. to 'D'
----------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on eight
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 four of these classes to 'D (sf)'
because we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. These four classes have
had accumulated interest shortfalls outstanding between three and
11 months," S&P said. 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 related.

The servicer implements ARAs and resulting ASER amounts according
to 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 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 eight downgraded classes from the three U.S. CMBS
transactions," S&P said.

                         COMM 2004-LNB2

"We lowered our ratings on the class H, J, and K certificates from
COMM 2004-LNB2. We lowered our rating on class K to 'D (sf)' due
to accumulated interest shortfalls outstanding for 10 consecutive
months resulting from ASER amounts related to two ($16.8 million,
2.7%) of the four assets ($40.8 million, 6.6%) that are currently
with the special servicer, LNR Partners LLC (LNR), as well as
interest not advanced ($116,628) on the 1 Northbrook Corporate
Center and Northbrook real estate owned (REO) assets. The master
servicer, Berkadia Commercial Mortgage LLC (Berkadia), determined
that the two REO assets were nonrecoverable because of the dated
July 2009 appraisal values. These values represented 56.9% and
60.1% of the total exposure of the 1 Northbrook Corporate Center
and Northbrook REO assets, respectively. LNR has informed us that
updated appraisal values have been received. It is our
understanding that Berkadia is currently reviewing the updated
data and reevaluating its nonrecoverable determination," S&P
related.

"We lowered our ratings on classes H and J to 'CCC- (sf)' to
reflect accumulated interest shortfalls outstanding for two
consecutive months. We will lower our ratings on these classes to
'D (sf)' if the interest shortfalls continue. As of the July 11,
2011, trustee remittance report, ARAs totaling $3.1 million were
in effect for two assets and the total reported monthly ASER
amount was $20,579. The reported monthly interest shortfalls
totaled $147,346 and have affected all of the classes subordinate
to and including class H," S&P said.

           GE Commercial Mortgage Corp. Series 2005-C4

"We lowered our ratings on the class E, F, G, and H certificates
from GE Commercial Mortgage Corp.'s series 2005-C4. We lowered our
ratings on classes G and H to 'D (sf)' to reflect accumulated
interest shortfalls outstanding for three and 11 months due to
ASER amounts related to 12 ($273.8 million, 13.0%) of the 18 loans
($584.6 million, 27.8%) that are currently with the special
servicer, Midland Loan Services (Midland), as well as special
servicing fees. We downgraded class F to 'CCC+ (sf)' and class E
to 'B (sf)' due to reduced liquidity support available to these
classes following recurring interest shortfalls and the potential
for these classes to experience interest shortfalls relating to
the specially serviced assets. As of the July 11, 2011, trustee
remittance report, ARAs totaling $131.6 million were in effect for
12 loans and the total reported monthly ASER amount was $580,777.
The reported monthly interest shortfalls totaled $721,899 and have
affected all of the classes subordinate to and including class G,"
S&P said.

          PNC Mortgage Acceptance Corp. Series 1999-CM1

"We lowered our rating on the class B-7 certificate from PNC
Mortgage Acceptance Corp.'s series 1999-CM1 to 'D (sf)' to
reflect interest shortfalls outstanding for 10 months due to
ASER amounts related to four ($7.9 million, 24.6%) of the five
assets ($14.0 million, 43.6%) that are currently with Midland, as
well as special servicing fees. As of the July 11, 2011 trustee
remittance report, ARAs totaling $3.1 million were in effect for
four loans and the total reported monthly ASER amount was $21,140.
The reported monthly interest shortfalls totaled $25,885 and have
affected all of the classes subordinate to and including class B-
7," S&P added.

Ratings Lowered

COMM 2004-LNB2
Commercial mortgage pass-through certificates

                              Credit          Reported
            Rating          enhancement       interest shortfalls
                                                 ($)
Class    To           From            (%)      Current Accumulated
H        CCC- (sf)    CCC+ (sf)      5.64        2,479   8,996
J        CCC- (sf)    CCC (sf)       4.86       20,067  40,134
K        D (sf)       CCC- (sf)      3.88       25,085 146,356

GE Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2005-C4

                               Credit        Reported
            Rating           enhancement     interest shortfalls
                                                 ($)
Class    To           From             (%)   Current  Accumulated
E        B (sf)       BB (sf)         9.44     0           0
F        CCC+ (sf)    BB- (sf)        8.15     0           0
G        D (sf)       B+ (sf)         6.58   131,575     426,189
H        D (sf)       CCC+ (sf)       5.44   106,201     625,565

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 1999-CM1

                                 Credit              Reported
            Rating            enhancement      interest shortfalls
                                                       ($)
Class    To        From               (%)   Current    Accumulated
B-7      D (sf)    CCC- (sf)        5.33     15,519        121,375


CORNERSTONE CLO: Moody's Upgrades Ratings of Four Classes of Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Cornerstone CLO Ltd.:

US$34,500,000 Class A-2 Senior Secured Floating Rate Notes due
2021, Upgraded to Aa3 (sf); previously on June 22, 2011 A1 (sf)
Placed Under Review for Possible Upgrade;

US$34,000,000 Class B Senior Secured Deferrable Floating Rate
Notes due 2021, Upgraded to Baa1 (sf); previously on June 22, 2011
Baa3 (sf) Placed Under Review for Possible Upgrade;

US$24,000,000 Class C Senior Secured Deferrable Floating Rate
Notes due 2021, Upgraded to Ba1 (sf); previously on June 22, 2011
Ba3 (sf) Placed Under Review for Possible Upgrade; and

US$21,500,000 Class D Secured Deferrable Floating Rate Notes due
2021, Upgraded to B1 (sf); previously on June 22, 2011 Caa2 (sf)
Placed Under Review for Possible Upgrade.

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

US$51,500,000 Class A-1-J Senior Secured Floating Rate Notes due
2021, 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.

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 $645.5 million,
defaulted par of $1.9 million, a weighted average default
probability of 22.2% (implying a WARF of 2700), a weighted average
recovery rate upon default of 48.1%, and a diversity score of 75.
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.

Cornerstone CLO Ltd., 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) 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 spread
   levels 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.


CRESS 2008-1: S&P Affirms Ratings on 9 Classes at 'CCC-'
--------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on five
classes from Cress 2008-1 Ltd. (Cress 2008-1), a U.S. commercial
real estate collateralized debt obligation (CRE CDO) transaction.
"At the same time, we affirmed our ratings on 10 other classes
from the same transaction," S&P said.

"The downgrades and affirmations primarily reflect the
transaction's exposure to underlying commercial mortgage-backed
securities (CMBS) collateral that we downgraded. We downgraded six
securities from six transactions totaling $65.0 million (12.3% of
the total asset balance). We lowered our ratings on six
securities to 'D (sf)' or 'CCC- (sf)'," S&P said. Cress 2008-1 has
exposure to these securities that Standard & Poor's has
downgraded:

    Morgan Stanley Capital I Trust 2007-IQ14 (class K;
    $15.0 million, 2.8%);

    Morgan Stanley Capital I Trust 2007-TOP27 (class H;
    $10.0 million, 1.9%);

    Morgan Stanley Capital I Trust 2007-HQ12 (class H;
    $10.0 million, 1.9%); and

    Merrill Lynch Mortgage Trust 2007-C1 (class H; $10.0 million,
    1.9%).

The downgrades and affirmations also reflect the deterioration
in the transaction's collateralization ratio. As of the July 29,
2011 trustee report, the transaction's collateral totaled
$530.2 million while the transaction's liability totaled
$627.8 million, which includes capitalized interest.

According to the July 29, 2011, trustee report, the transaction's
current assets included:

    19 whole loans and senior interest loans ($326.7 million,
    61.6%);

    10 subordinate-interest loans ($89.3 million, 16.8%);

    Seven CMBS tranches from seven distinct transactions issued in
    2007 ($75.0 million, 14.1%);

    Three CMBS tranches from one single borrower mortgage security
    transaction issued in 2010 ($24.8 million, 4.7%); and

    Principal cash ($14.5 million, 2.7%).

The trustee report noted six defaulted loans ($36.4 million, 6.9%)
and seven defaulted securities ($75.0 million, 14.1%) in the
transaction. Standard & Poor's estimated specific recovery rates
for the defaulted loans from 0% to 54%. "We based the recovery
rates on information from the collateral manager, special
servicer, and third-party data providers," S&P said. The defaulted
loan assets are:

    400 South Beverly Whole Loan ($15.8 million, 3.0%);

    Lembi Marina Portfolio 1 whole loan ($9.1 million, 1.7%);

    Wynn Palms B Note ($5.0 million, 0.9%);

    500 Davis Center B Note ($3.0 million, 0.6%);

    Quail Creek B Note ($2.0 million, 0.4%); and

    Rancho Vista B Note ($1.5 million, 0.3%).

According to the trustee report, the deal is failing all four par
value tests but passing the interest coverage tests. Because the
transaction failed its class A/B par value test, all outstanding
interest proceeds after class B are being diverted to pay down the
class A1 outstanding principal balance.

Standard & Poor's analyzed the transaction and its underlying
assets in accordance with its current criteria. "Our analysis is
consistent with the lowered and affirmed ratings," S&P said.

Ratings Lowered

Cress 2008-1 Ltd.
                  Rating
Class     To                   From
A2        B (sf)               BB- (sf)
B         CCC (sf)             B (sf)
C         CCC- (sf)            CCC+ (sf)
D         CCC- (sf)            CCC+ (sf)
E         CCC- (sf)            CCC (sf)

Ratings Affirmed

Cress 2008-1 Ltd.

Class     Rating
A1        BBB- (sf)
F         CCC- (sf)
G         CCC- (sf)
H         CCC- (sf)
J         CCC- (sf)
K         CCC- (sf)
L         CCC- (sf)
M         CCC- (sf)
N         CCC- (sf)
O         CCC- (sf)


CREST 2003-2: Moody's Affirms Ratings of Nine Classes of Notes
--------------------------------------------------------------
Moody's has affirmed nine classes and downgraded two classes of
Notes issued by Crest 2003-2, Ltd. due to the deterioration in the
credit quality of the underlying portfolio as evidenced by an
increase in the weighted average rating factor (WARF) and decrease
in weighted average recovery rate (WARR). The affirmations are due
to key transaction parameters are 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.

Moody's rating action is:

Cl. A-1, Affirmed at Aa2 (sf); previously on Oct 27, 2010
Downgraded to Aa2 (sf)

Cl. A-2, Affirmed at Aa2 (sf); previously on Oct 27, 2010
Downgraded to Aa2 (sf)

Cl. A-3, Affirmed at Aa2 (sf); previously on Oct 27, 2010
Downgraded to Aa2 (sf)

Cl. B-1, Affirmed at Baa2 (sf); previously on Oct 27, 2010
Downgraded to Baa2 (sf)

Cl. B-2, Affirmed at Baa2 (sf); previously on Oct 27, 2010
Downgraded to Baa2 (sf)

Cl. C-1, Affirmed at Ba2 (sf); previously on Oct 27, 2010
Downgraded to Ba2 (sf)

Cl. C-2, Affirmed at Ba2 (sf); previously on Oct 27, 2010
Downgraded to Ba2 (sf)

Cl. D-1, Downgraded to Caa1 (sf); previously on Oct 27, 2010
Downgraded to B2 (sf)

Cl. D-2, Downgraded to Caa1 (sf); previously on Oct 27, 2010
Downgraded to B2 (sf)

Cl. E-1, Affirmed at Caa3 (sf); previously on Oct 27, 2010
Downgraded to Caa3 (sf)

Cl. E-2, Affirmed at Caa3 (sf); previously on Oct 27, 2010
Downgraded to Caa3 (sf)

RATINGS RATIONALE

Crest 2003-2, Ltd. is a static CRE CDO transaction backed by a
portfolio of commercial mortgage backed securities (CMBS) (87.6%
of the pool balance), real estate investment trust (REIT) debt
(7.3%), ten credit tenant leases (CTL) (3.5%) and one CRE CDO
class (1.7%). As of the July 29, 2011 Trustee report, the
aggregate Note balance of the transaction has decreased to
$299.2 million from $325.0 million at issuance, with the paydown
directed to the Class A-1, Class A-2 and Class A-3 Notes.

There are seven assets with a par balance of $27.6 million (9.1%
of the current pool balance) that are considered Credit Risk
Securities and sixteen assets with a par balance of $66.1 million
(21.9% of the current pool balance) that are considered Defaulted
Securities as of the July 29, 2011 Trustee report. While there
have been no realized losses to date, Moody's does expect
significant losses to occur once they are realized.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: 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 3,351 compared to 2,661 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (3.6% compared to 4.7% al last review), A1-A3
(5.8% compared to 6.1% at last review), Baa1-Baa3 (18.8% compared
to 13.9% at last review), Ba1-Ba3 (30.4% compared to 50.2% at last
review), B1-B3 (14.8% compared to 4.8% at last review), and Caa1-C
(26.7% compared to 20.3% 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 2.8 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
14.7% compared to 19.4% 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 8.9% compared to 14.0% 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
14.7% to 9.7% or up to 19.7% would result in average rating
movement on the rated tranches of 0 to 1 notches downward or 0 to
1 notches upward, respectively.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of assumption uncertainty
are the current sluggish macroeconomic environment and performance
in the commercial real estate property markets. While commercial
real estate property markets are gaining momentum, a consistent
upward trend will not be evident until the volume of transactions
increases, distressed properties are cleared from the pipeline and
job creation rebounds. The hotel and multifamily sectors are
continuing to show signs of recovery through the first half of
2011, while recovery in the non-core office and retail sectors are
tied to pace of recovery of the broader economy. Core office
markets are showing signs of recovery through lending and leasing
activity. 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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

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

The other methodology used in these ratings was "Moody's Approach
to Rating Commercial Real Estate CDOs" published in July 2011.


CS FIRST: Moody's Affirms Class J Notes Rating at 'C'
-----------------------------------------------------
Moody's Investors Service (Moody's) upgraded the rating of four
classes and affirmed three classes of Credit Suisse First Boston
Mortgage Securities Corp., Commercial Mortgage Pass-Through
Certificates, Series 2001-CK3:

Cl. F, Upgraded to Aaa (sf); previously on Apr 15, 2010 Downgraded
to Aa3 (sf)

Cl. G-1, Upgraded to Baa3 (sf); previously on Mar 30, 2011
Downgraded to Ba1 (sf)

Cl. G-2, Upgraded to Baa3 (sf); previously on Mar 30, 2011
Downgraded to Ba1 (sf)

Cl. H, Upgraded to B3 (sf); previously on Mar 30, 2011 Downgraded
to Caa1 (sf)

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

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

Cl. J, Affirmed at C (sf); previously on Mar 30, 2011 Downgraded
to C (sf).

RATINGS RATIONALE

The upgrades are due to increased credit support due to loan
payoffs and amortization and overall improved pool financial
performance . The pool has paid down 65% since Moody's last full
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
14.5% of the current balance. At last review, Moody's cumulative
base expected loss was 10.5%. The current cumulative base expected
loss represents a higher percentage of the pool than at last
review due to significant pay downs since last review, even though
the dollar amount of expected loss is less. Moody's stressed
scenario loss is 23.8% 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 in September
2000. Please see the Credit Policy page on www.moodys.com for a
copy of this methodology.

Moody's also consider another methodology in this rating - "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 2.60 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 4 compared to 33 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 8.1 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 March 30, 2011. 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 92% to $87 million
from $1.13 billion at securitization. The Certificates are
collateralized by 22 mortgage loans ranging in size from less than
1% to 49% of the pool, with the top ten loans representing 76% of
the pool. One loan, representing less than 1% of the pool, has
defeased and is secured by U.S. Government securities. The pool
previously contained one loan with an investment grade credit
estimate, representing 49% of the pool, but due to declines in
performance this loan is now analyzed as part of the conduit pool.

Five loans, representing 54% 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.

Twenty-seven loans have been liquidated from the pool, resulting
in a realized loss of $58.6 million (36% loss severity). Currently
nine loans, representing 30% of the pool, are in special
servicing. Moody's estimates an aggregate $10.9 million loss for
the specially serviced loans (60.7% expected loss on average).

Moody's has assumed a high default probability for one poorly
performing loan representing 2% of the pool and has estimated an
aggregate $300,000 loss (15% expected loss based on a 50%
probability default) from this troubled loan.

Moody's was provided with full year 2010 operating results for 86%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 78% compared to 72% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 10.8% 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 1.21X and 1.40X, respectively, compared to
1.31X and 1.59X 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 that previously had a credit estimate is the Atrium Mall
Loan ($42.4 million -- 48.7% of the pool), which is secured by a
214,800 SF unanchored enclosed shopping center located
approximately nine miles west of Downtown Boston in Chestnut Hill,
Massachusetts. Financial performance has declined since last
review in concert with declining occupancy. The mall is presently
63% leased, compared to 77% at June 2010, with Borders, William
Sonoma and Abercrombie and Fitch each recently leaving the
property. As of June 2009 the property was 89% leased, and in 2006
the property was 95% leased. The borrower, Simon Property Group
(SPG), has announced a remerchandising program beginning in 2011
to improve occupancy and tenant sales. The loan remains current
after having passed the recent March 15, 2011 anticipated
repayment date (ARD). Simon has requested that the master servicer
consider a modification of the loan's ARD payment terms. Moody's
current LTV and stressed DSCR are 79% and 1.23X, respectively,
compared to 72% and 1.24X at last review.

The second largest conduit loan is the Best Buy #185 Loan
($5.7 million -- 6.6% of the pool), which is secured by a
50,000 SF single tenant Best Buy store, located in East Palo
Alto California. Best Buy's lease expires in 2020. Moody's LTV
and stressed DSCR are 79% and 1.26X, respectively, compared to
82% and 1.22X at last review.


CSFB 2001-CP4: Modeled Losses Cue Fitch to Downgrade Ratings
------------------------------------------------------------
Fitch Ratings has downgraded two classes of Credit Suisse First
Boston Mortgage Securities Corp., series 2001-CP4 (CSFB 2001-CP4).

The downgrades reflect Fitch modeled losses of 18.75% of the
remaining pool.  Fitch has designated 26 loans (85.4%) as Fitch
Loans of Concern, which includes 19 specially-serviced loans
(66.7%).  Fitch expects classes J through O to be fully depleted
and class H 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 86.7% to $157.4 million from
$1.18 billion at issuance.  In addition, one loan (.4%) has been
fully defeased.  Interest shortfalls totaling $7,808,151 are
currently affecting classes H through O.

The largest contributor to modeled losses is a specially serviced
loan (10%) secured by a 156,776 square feet (SF) of office space
located in Shelton, CT.  The loan transferred to special servicing
in June 2008 due to monetary default.  The borrower has been under
bankruptcy protection since August 2009 and the judge ordered
conversion to Chapter 7 Bankruptcy in August 2010.

The second largest contributor to modeled losses is a specially
serviced (7.6%) real estate owned (REO) 121,409 square foot office
building located in Rockville, MD.  The loan transferred to
special servicing in October 2009 due to monetary default and the
property was foreclosed on in May 2010.  Lincoln Property Company
has been appointed as the property manager and leasing agent while
Cassidy Turley is marketing the property for sale.

The third largest contributor to modeled losses is a specially
serviced loan (8.7%) secured by a 166,594 sf of office space
located in Raleigh, NC.  The loan transferred to special servicing
in December 2009 due to monetary default.  A foreclosure sale was
originally scheduled for November 2010 until the borrower filed
for bankruptcy which stayed the foreclosure sale.  The court has
postponed a confirmation of the borrower proposed reorganization
plan until the value of the property is determined.


Fitch has downgraded, assigned Recovery Ratings (RRs), and revised
Outlooks on the following classes as indicated:

  -- $11.8 million class G to 'B-sf' from 'Bsf'; Outlook to Stable
     from Negative;
  -- $22.1 million class H to 'CCsf/RR5' from 'B-'.

Fitch has also affirmed the following classes:

  -- $10.1 million class B at 'AAAsf'; Outlook Stable;
  -- $45.7 million class C at 'AAAsf'; Outlook Stable;
  -- $22.1 million class D at 'AAAsf'; Outlook Stable;
  -- $16.2 million class E at 'Asf'; Outlook Stable;
  -- $16.2 million class F at 'BBsf'; Outlook Stable;
  -- $13.2 million class J to 'Dsf/RR6' from 'Dsf/RR3'.

Class K, L, M, and N remain at 'Dsf/RR6'. Class O, which is not
rated by Fitch has been reduced to zero from 20.6 million at
issuance due to realized losses.

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


DENALI CAPITAL: Moody's Raises Class C Rating to Baa1 From B1
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Denali Capital CLO IV, Ltd.:

$312,000,000 Class A Senior Secured Notes Due 2016 (current
outstanding balance of $126,501,873.02), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

$26,000,000 Class B Senior Secured Deferrable Interest Notes Due
2016, Upgraded to Aa1 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

$22,000,000 Class C Senior Secured Deferrable Interest Notes Due
2016, Upgraded to Baa1 (sf); previously on June 22, 2011 B1 (sf)
Placed Under Review for Possible Upgrade;

$8,000,000 Class D Subordinated Secured Deferrable Interest Notes
Due 2016 (current outstanding balance of $2,280,436.45), Upgraded
to Baa3 (sf); previously on June 22, 2011 Caa2 (sf) Placed Under
Review for Possible Upgrade;

$7,500,000 Class 1 Composite Securities Due 2016 (current
outstanding Composite Security Rated Balance of $4,080,189.90),
Upgraded to Baa2 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

$11,000,000 Class 2 Composite Securities Due 2016 (current
outstanding Composite Security Rated Balance of $5,863,457.97),
Upgraded to Aa3 (sf); previously on June 22, 2011 Ba2 (sf) Placed
Under Review for Possible Upgrade;

$1,850,000 Class 3 Composite Securities Due 2016 (current
outstanding Composite Security Rated Balance of $79,829.47),
Upgraded to A1 (sf); previously on June 22, 2011 Caa2 (sf) Placed
Under Review for Possible Upgrade;

$3,250,000 Class 4 Composite Securities Due 2016 (current
outstanding Composite Security Rated Balance of $2,040,583.10),
Upgraded to A1 (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.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios and deleveraging of the
senior notes since the rating action in May 2010. Moody's notes
that the Class A Notes have been paid down by approximately 54% or
$150 million since the rating action in May 2010. As a result of
the deleveraging, the overcollateralization ratios have increased
since the rating action in May 2010. 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 154.61%,
128.25%, 112.08% and 110.63%, respectively, versus April 2010
levels of 123.57%, 112.97%, 105.32% and 103.91%, respectively. In
particular, the Class D overcollateralization ratio has increased
in part due to the diversion of excess interest to delever the
Class D. Since the rating action in May 2010, $2.1 million of
interest proceeds have reduced the outstanding balance of the
Class D Notes by 48.2%.

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 $195.6 million,
defaulted par of $8.1 million, a weighted average default
probability of 16.30% (implying a WARF of 2855), a weighted
average recovery rate upon default of 50.40%, and a diversity
score of 59. 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.

Denali Capital CLO IV, Ltd., 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.

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 delevering from unscheduled principal
   proceeds will continue and at what pace. Deleveraging may
   accelerate due to high prepayment levels in the loan market
   and/or collateral sales by the manager, which may have
   significant impact on the notes' ratings.

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


DRYDEN XI-LEVERAGED: Moody's Upgrades Ratings of CLO Notes
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Dryden-XI Leveraged Loan CDO 2006:

US$325,000,000 Class A-1 First Priority Senior Secured Floating
Rate Notes due April 12, 2020 (current outstanding balance of
$316,381,137.11), Upgraded to Aaa (sf); previously on June 22,
2011 Aa2 (sf) Placed Under Review for Possible Upgrade;

US$25,000,000 Class A-2B First Priority Senior Secured Floating
Rate Notes due April 12, 2020, Upgraded to Aaa (sf); previously on
June 22, 2011 Aa3 (sf) Placed Under Review for Possible Upgrade;

US$25,300,000 Class A-3 Second Priority Senior Secured Floating
Rate Notes due April 12, 2020, Upgraded to Aa1 (sf); previously on
June 22, 2011 A2 (sf) Placed Under Review for Possible Upgrade;

US$47,200,000 Class B Third Priority Mezzanine Secured Deferrable
Floating Rate Notes due April 12, 2020, Upgraded to Baa1 (sf);
previously on June 22, 2011 Baa3 (sf) Placed Under Review for
Possible Upgrade;

US$24,800,000 Class C-1 Fourth Priority Mezzanine Secured
Deferrable Floating Rate Notes due April 12, 2020, Upgraded to Ba2
(sf); previously on June 22, 2011 B1 (sf) Placed Under Review for
Possible Upgrade;

US$12,700,000 Class C-2 Fourth Priority Mezzanine Secured
Deferrable Floating Rate Notes due April 12, 2020, Upgraded to Ba2
(sf); previously on June 22, 2011 B1 (sf) Placed Under Review for
Possible Upgrade;

US$23,600,000 Class D Fifth Priority Mezzanine Secured Deferrable
Floating Rate Notes due April 12, 2020 (current outstanding
balance of $20,143,416), Upgraded to B1 (sf); previously on
June 22, 2011 Caa3 (sf) Placed Under Review for Possible Upgrade;

US$20,000,000 Class Q-2 Securities (current outstanding balance of
$9,301,546.94), Upgraded to Baa2 (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 $726.7 million,
defaulted par of $10.9 million, a weighted average default
probability of 19.6% (implying a WARF of 2615), a weighted average
recovery rate upon default of 49.9%, 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.

Dryden-XI Leveraged Loan CDO 2006, 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.

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. 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) 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 and diversity levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.


DUANE STREET: Moody's Upgrades Rating of Class D Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Duane Street CLO III, Ltd.:

US$262,100,000 Class A-1 Senior Floating Rate Notes Due 2021
(current outstanding balance of $260,947,789), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$137,500,000 Class A-2a Senior Revolving Floating Rate Notes Due
20211 (current outstanding balance of $136,862,569), Upgraded to
Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review
for Possible Upgrade;

US$7,500,000 Class A-2b Senior Floating Rate Notes Due 2021,
Upgraded to Aa1 (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

US$33,000,000 Class B Senior Floating Rate Notes Due 2021,
Upgraded to Aa3 (sf); previously on June 22, 2011 Baa1 (sf) Placed
Under Review for Possible Upgrade;

US$28,500,000 Class C Deferrable Mezzanine Floating Rate Notes Due
2021, Upgraded to Baa1 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$27,500,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2021, Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf)
Placed Under Review for Possible Upgrade;

US$14,000,000 Class E Deferrable Junior Floating Rate Notes Due
2021, 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.

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 $545 million,
defaulted par of $2 million, a weighted average default
probability of 20.25% (implying a WARF of 2813), a weighted
average recovery rate upon default of 48.13%, 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.

Duane Street 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 weighted average coupon. 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.


DUANE STREET: Moody's Upgrades Rating of Class D Notes to 'Ba3'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Duane Street CLO II, Ltd.:

$238,000,000 Class A-1 Senior Floating Rate Notes Due 2018
(current outstanding balance of $230,707,940), Upgraded to Aaa
(sf); previously on June 22, 2011 A1 (sf) Placed Under Review for
Possible Upgrade;

$75,000,000 Class A-2 Senior Revolving Floating Rate Notes Due
2018 (current outstanding balance of $72,702,082), Upgraded to Aaa
(sf); previously on June 22, 2011 A1 (sf) Placed Under Review for
Possible Upgrade;

$25,500,000 Class B Senior Floating Rate Notes Due 2018, Upgraded
to A1 (sf); previously on June 22, 2011 Baa2 (sf) Placed Under
Review for Possible Upgrade;

$23,000,000 Class C Deferrable Mezzanine Floating Rate Notes Due
2018, Upgraded to Baa3 (sf); previously on June 22, 2011 Ba2 (sf)
Placed Under Review for Possible Upgrade;

$18,500,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2018, Upgraded to Ba3 (sf); previously on June 22, 2011 Caa1 (sf)
Placed Under Review for Possible Upgrade;

$11,750,000 Class E Deferrable Junior Floating Rate Notes Due
2018, 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.

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 $403 million,
defaulted par of $2 million, a weighted average default
probability of 20.25% (implying a WARF of 2850), a weighted
average recovery rate upon default of 48.57%, and a diversity
score of 50. 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.

Duane Street CLO II, Ltd., issued in July 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) 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 coupon and diversity
   score. However, as part of the base case, Moody's considered a
   weighted average rating factor level lower than the covenant
   level and a weighted average spread levels higher than the
   covenant level due to the large difference between the reported
   and covenant levels.


FLAGSHIP CLO: Moody's Raises Rating of Class C to Baa3 from Ba3
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Flagship CLO III.

US$234,000,000 Class A Senior Secured Floating Rate Funded Notes
(current outstanding balance of $169,632,115.62), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$35,400,000 Class A Senior Secured Floating Rate Revolving Notes
(current outstanding balance of $25,662,294.41), Upgraded to Aaa
(sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$29,400,000 Class B Second Priority Deferrable 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 Third Priority Deferrable Floating Rate
Notes, Upgraded to Baa3 (sf); previously on June 22, 2011 Ba3 (sf)
Placed Under Review for Possible Upgrade;

US$10,600,000 Class D Fourth Priority Deferrable Floating Rate
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 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 amortization 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
28% or $69 million since the rating action in December 2010. As a
result of the deleveraging, the overcollateralization ratios of
the rated notes have increased. Based on the latest trustee report
dated July 5, 2011, the Class A, Class B, Class C, and Class D
overcollateralization ratios are reported at 134.7%, 117.1%, 110.7
and 105.9%, respectively, versus November 2010 levels of 125.2%,
112.7%, 107.9%, and 104.3%, 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 $262 million,
defaulted par of $4.9 million, a weighted average default
probability of 17.4% (implying a WARF of 2862), a weighted average
recovery rate upon default of 50.3%, 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.

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

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

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


FLAGSHIP CLO: Moody's Upgrades Ratings of Class D Notes to 'Ba1'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Flagship CLO V:

US$365,000,000 Class A Floating Rate Notes, Due 2019, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review
for Possible Upgrade;

US$33,750,000 Class B Floating Rate Notes, Due 2019, Upgraded to
Aa3 (sf); previously on June 22, 2011 Baa1 (sf) Placed Under
Review for Possible Upgrade;

US$22,500,000 Class C Deferrable Floating Rate Notes, Due 2019,
Upgraded to Baa1 (sf); previously on June 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$17,500,000 Class D Deferrable Floating Rate Notes, Due 2019,
Upgraded to Ba1 (sf); previously on June 22, 2011 B2 (sf) Placed
Under Review for Possible Upgrade;

US$22,500,000 Class E Deferrable Floating Rate Notes, Due 2019,
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 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 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 trustee report dated July 8, 2011 the weighted
average rating factor is 2269 compared to 2604 in July 2009. The
Class A/B, Class C, Class D and Class E overcollateralization
ratios are reported at 118.2%, 111.9%, 107.4%, and 102.2%
respectively, versus May 2009 levels of 116.9%, 110.7%, 106.3% and
101.1%, 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 $469 million,
defaulted par of $6.7 million, a weighted average default
probability of 20.3% (implying a WARF of 2747), a weighted average
recovery rate upon default of 50.5%, 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.

Flagship CLO V, 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 and coupon levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.


FLAGSHIP CLO: Moody's Upgrades Ratings of Five Classes of Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Flagship CLO IV:

US$40,400,000 Class A Senior Secured Floating Rate Revolving Notes
Due 2017, Upgraded to Aa1 (sf); previously on June 22, 2011 A1
(sf) Placed Under Review for Possible Upgrade;

US$269,600,000 Class A Senior Secured Floating Rate Funded Notes
Due 2017, Upgraded to Aa1 (sf); previously on June 22, 2011 A1
(sf) Placed Under Review for Possible Upgrade;

US$27,900,000 Class B Second Priority Deferrable Floating Rate
Notes Due 2017, Upgraded to A3 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$17,900,000 Class C Third Priority Deferrable Floating Rate
Notes Due 2017, Upgraded to Ba2 (sf); previously on June 22, 2011
B3 (sf) Placed Under Review for Possible Upgrade;

US$13,200,000 (current outstanding balance of $11,497,148) Class D
Fourth Priority Deferrable Floating Rate Notes Due 2017, 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 since the rating action in September
2009. Based on the latest trustee report dated June 17, 2011, the
weighted average rating factor is currently 2368 compared to 2789
in the August 2009 report. 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 123.10%, 112.93%,
107.25% and 103.89%, respectively, versus August 2009 levels of
120.02%, 110.11%, 104.57% and 101.30%, 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 $379.7 million,
defaulted par of $4.6 million, a weighted average default
probability of 17.4% (implying a WARF of 2659), a weighted average
recovery rate upon default of 49.57%, 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.

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

The principal methodology used in this rating was "Moody's
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) 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.


FOOTHILL CLO: Moody's Upgrades Ratings of Five Classes of Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Foothill CLO I, Ltd.:

US$30,000,000 Class B Senior Secured Floating Rate Notes, Due
2021, Upgraded to Aa3 (sf); previously on June 22, 2011 A2 (sf)
Placed Under Review for Possible Upgrade;

US$28,000,000 Class C Senior Secured Deferrable Floating Rate
Notes, Due 2021, Upgraded to A3 (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
2021, Upgraded to Baa3 (sf); previously on June 22, 2011 B1 (sf)
Placed Under Review for Possible Upgrade;

US$19,000,000 Class E Secured Deferrable Floating Rate Notes, Due
2021, Upgraded to Ba3 (sf); previously on June 22, 2011 Caa2 (sf)
Placed Under Review for Possible Upgrade;

US$6,000,000 Class Type I Class Q Notes, Due 2021 (current
outstanding rated balance of $5,366,835), Upgraded to Ba1 (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 July 2009.
Based on the June 2011 trustee report, the weighted average rating
factor is currently 2754 compared to 3104 in June 2009. The Class
A/B, Class C, Class D, and Class E overcollateralization ratios
are reported at 128.53%, 119.82%, 112.98%, and 108.29%,
respectively, versus June 2009 levels of 120.83%, 112.63%,
106.21%, and 101.80%, 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
$496 million, defaulted par of $0.9 million, a weighted average
default probability of 23.3% (implying a WARF of 2897), a weighted
average recovery rate upon default of 50.8%, and a diversity score
of 54. 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.

Foothill CLO I, Ltd., issued in February 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
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 weighted average rating
   factor, weighted average coupon, and diversity score. As part
   of the base case, Moody's considered weighted average spread
   levels higher than the covenant levels due to the large
   difference between the reported and covenant levels.


FRANKLIN CLO: Moody's Upgrades Class D Notes Rating to Ba1 From B2
------------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Franklin CLO V, Limited:

US$49,000,000 Class B Senior Floating Rate Notes due 2018,
Upgraded to Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed
Under Review for Possible Upgrade;

US$23,500,000 Class C Deferrable Mezzanine Floating Rate Notes due
2018, Upgraded to Baa1 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$21,500,000 Class D Deferrable Mezzanine Floating Rate Notes due
2018, Upgraded to Ba1 (sf); previously on June 22, 2011 B2 (sf)
Placed Under Review for Possible Upgrade;

US$13,000,000 Class E Deferrable Mezzanine Floating Rate Notes due
2018, 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.

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 465 million,
defaulted par of $8.9 million, a weighted average default
probability of 22.62% (implying a WARF of 2700), a weighted
average recovery rate upon default of 50.45%, and a diversity
score of 55. 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.

Franklin CLO V, Limited, 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. 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) 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.

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.

4) 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 collateral quality metrics' levels better
   than the covenant levels given the limited time remaining in
   the deal's reinvestment period.


GALAXY VI: Moody's Upgrades Ratings of Seven Classes of Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Galaxy VI CLO, Ltd.

US$321,400,000 Class A-1 Senior Term Notes Due 2018 (current
outstanding balance of $321,358,654.61), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$ 50,000,000 Class A-2 Senior Revolving Notes Due 2018 (current
outstanding balance of $49,993,567.92), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$ 35,000,000 Class B Senior Floating Rate Notes Due 2018,
Upgraded to A2 (sf); previously on June 22, 2011 Baa1 (sf) Placed
Under Review for Possible Upgrade;

US$ 13,700,000 Class C-1 Deferrable Mezzanine Floating Rate Notes
Due 2018, Upgraded to Baa3 (sf); previously on June 22, 2011 Ba1
(sf) Placed Under Review for Possible Upgrade;

US$ 7,000,000 Class C-2 Deferrable Mezzanine Fixed Rate Notes Due
2018, Upgraded to Baa3 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$ 26,250,000 Class D Deferrable Mezzanine Floating Notes Due
2018 (current outstanding balance of $21,407,164.45), Upgraded to
Ba2 (sf); previously on June 22, 2011 B2 (sf) Placed Under Review
for Possible Upgrade;

US$10,000,000 Class Z Combination Notes Due 2018 (current rated
balance of $6,237,507.06), Upgraded to Baa1 (sf); previously on
June 22, 2011 Ba1 (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 credit improvement of
the underlying portfolio since the rating action in July 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2575 compared to 3021 in June 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 $473 million, a
weighted average default probability of 20.6% (implying a WARF of
2805), a weighted average recovery rate upon default of 50.7%, 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.

Galaxy VI CLO, 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. Please see the Credit Policy page on www.moodys.com for
a copy of this methodology.

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. 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 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.


GALAXY X CLO: Moody's Upgrades Class C Notes to 'A2' From 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Galaxy X CLO Ltd.:

US$21,000,000 Class B Senior Floating Rate Notes Due 2020,
Upgraded to Aa2 (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

US$22,225,000 Class C Deferrable Mezzanine Floating Rate Notes Due
2020, Upgraded to A2 (sf); previously on June 22, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$12,775,000 Class D Deferrable Mezzanine Floating Rate Notes Due
2020, Upgraded to Baa2 (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 credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in July 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2614 compared to 3025 in May 2009.
Additionally, the Senior, Class C, and Class D
overcollateralization ratios are reported at 134.75%, 124.84%,
119.78%, respectively, versus May 2009 levels of 129.13%, 119.63%,
114.78%, 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 $377 million, no
defaulted par, a weighted average default probability of 23.9%
(implying a WARF of 3016), a weighted average recovery rate upon
default of 51.8%, and a diversity score of 66. The default and
recovery properties of the collateral pool are incorporated in
cash flow model analysis where they are subject to stresses as a
function of the target rating of each CLO liability being
reviewed. The default probability is derived from the credit
quality of the collateral pool and Moody's expectation of the
remaining life of the collateral pool. The average recovery rate
to be realized on future defaults is based primarily on the
seniority of the assets in the collateral pool. In each case,
historical and market performance trends and collateral manager
latitude for trading the collateral are also factors.

Galaxy X CLO Ltd., issued in February 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/diversity levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.


GANNETT PEAK: Moody's Upgrades Ratings of 8 Classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Gannett Peak CLO I, Ltd.:

US$369,100,000 Class A-1a Senior Secured Floating Rate Notes, Due
2020, Upgraded to Aa1 (sf); previously on June 22, 2011 Aa2 (sf)
Placed Under Review for Possible Upgrade;

US$60,000,000 Class A-1b Senior Secured Revolving Floating Rate
Notes, Due 2020, Upgraded to Aa1 (sf); previously on June 22, 2011
Aa2 (sf) Placed Under Review for Possible Upgrade;

US$26,000,000 Class B-1 Senior Secured Floating Rate Notes, Due
2020, Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$9,000,000 Class B-2 Senior Secured Fixed Rate Notes, Due 2020,
Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$33,500,000 Class C Senior Secured Deferrable Floating Rate
Notes, Due 2020, Upgraded to Ba2 (sf); previously on June 22, 2011
B1 (sf) Placed Under Review for Possible Upgrade;

US$19,000,000 Class D-1 Senior Secured Deferrable Floating Rate
Notes, Due 2020, Upgraded to B2 (sf); previously on June 22, 2011
Caa3 (sf) Placed Under Review for Possible Upgrade;

US$5,000,000 Class D-2 Senior Secured Deferrable Fixed Rate Notes,
Due 2020, Upgraded to B2 (sf); previously on June 22, 2011 Caa3
(sf) Placed Under Review for Possible Upgrade;

US$14,000,000 Type I Composite Obligations, Due 2020 (current
rated balance of $10,393,981.12), Upgraded to Baa1 (sf);
previously on June 22, 2011 Ba1 (sf) Placed Under Review for
Possible Upgrade.

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

US$41,000,000 Class A-2 Senior Secured Floating Rate Notes, Due
2020, Confirmed at A2 (sf); previously on June 22, 2011 A2 (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 2009. The Class A, Class B, Class C and Class D
overcollateralization ratios are reported at 125.9%, 117.2%,
109.9% and 105.2%, respectively, versus July 2009 levels of
121.0%, 112.7%, 105.6% and 101.1%, 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 $593.4 million,
defaulted par of $4.2 million, a weighted average default
probability of 25.16% (implying a WARF of 3228), a weighted
average recovery rate upon default of 45.37%, 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.

Gannett Peak CLO I, Ltd., 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.

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) 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.


GCO ELF: Fitch Lowers Rating on Four Classes of Notes to 'Bsf'
--------------------------------------------------------------
Fitch Ratings affirms the senior student loan notes at 'AAAsf' and
downgrades the subordinate and junior subordinate student loan
notes to 'Bsf' from 'BBsf' issued by GCO Education Loan Funding
Master Trust II.  The Rating Outlook remains Stable. Fitch used
its 'Global Structured Finance Rating Criteria', and 'U.S. FFELP
Student Loan ABS Surveillance Criteria', as well as 'Rating U.S.
Federal Family Education Loan Program Student Loan ABS' to review
the ratings.

The ratings on the senior notes are affirmed based on the
sufficient level of credit enhancement (consisting of
subordination and the projected minimum excess spread) to cover
the applicable risk factor stresses.

The ratings on the subordinate and junior subordinate notes are
downgraded to 'Bsf' from 'BBsf' because the trust remains
undercollateralized.  The Fitch calculated total parity, which
includes the junior subordinate notes, is 97.34%.  The reported
subordinate parity, which excludes the junior subordinate notes,
is 99.75%.

Fitch has taken the following rating actions:

GCO Education Loan Funding Master Trust II:

  -- 2006-2 A-1AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-1L PIF;
  -- 2006-2 A-1RRN affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-2AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-2L affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-3AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-3L affirmed at 'AAAsf'; Outlook Stable;
  -- 2006-2 A-4AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-4L PIF;
  -- 2007-1 A-5AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-5L affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-6AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-6L affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-7AR affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-7L affirmed at 'AAAsf'; Outlook Stable;
  -- 2007-1 A-8AR PIF;
  -- 2006-2 B-1AR downgraded to 'Bsf' from 'BBsf'; Outlook Stable;
  -- 2006-2 B-2AR downgraded to 'Bsf' from 'BBsf'; Outlook Stable;
  -- 2006-2 B-3AR downgraded to 'Bsf' from 'BBsf'; Outlook Stable;
  -- 2007-1 C-1L downgraded to 'Bsf' from 'BBsf'; Outlook Stable.


GE COMMERCIAL: Fitch Affirms GECMC 2003-C2 Ratings
--------------------------------------------------
Fitch Ratings affirms GE Commercial Mortgage Corporation (GECMC
2003-C2) commercial mortgage pass-through certificates.

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.

Fitch has affirmed these classes and revised Rating Outlooks and
Recovery Ratings (RRs):

   -- $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.

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.


GENERAL ELECTRIC: Fitch Affirm Rating on $1.8MM Notes at 'Dsf'
--------------------------------------------------------------
Fitch Ratings affirms all classes of General Electric Capital
Assurance Company, series GFCM 2001-1 commercial mortgage pass-
through certificates.

The affirmations are the result of stable performance, scheduled
amortization and sufficient credit enhancement to offset Fitch
expected losses.  Fitch modeled losses of 2.6% of the remaining
pool.

As of the July 2011 distribution date, the pool's certificate
balance has paid down 52.3% to $351.3 million from $419.7 million.
Fitch has identified 38 (23.4%) Fitch Loans of Concern (LOC), of
which one (0.5%) is specially serviced.

The only specially serviced loan in the pool is collateralized by
a 24,612 square foot (sf) office building located in Rocklin, CA,
a suburb of Sacramento.  The property has been vacant since the
loss of a single tenant at lease expiration in December 2009.  The
loan was modified in September 2010 to make interest only a
payment however has since become delinquent.

The largest contributor to Fitch expected losses is a loan (0.46%)
collateralized by an 81,900 sf warehouse building located in
Rancho Cordova, CA, a submarket of Sacramento.  Currently there is
one tenant, CA Home Furnishings (29%), on a month-to-month lease.
The remaining 71% of the space has been vacant since 2008 when
Room Source filed for bankruptcy.  Master servicer reports the
borrower is marketing the property.

Fitch affirms the following classes and revises Outlooks as
indicated:

  -- $270 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $112.7 million class A-5 at 'AAAsf'; Outlook Stable;
  -- $11.3 million class B at 'AA+sf'; Outlook to Positive from
     Stable;
  -- $13.3.1 million class C at 'A+sf'; Outlook to Positive from
     Stable;
  -- $11.3 million class D at 'BBBsf'; Outlook Stable;
  -- $10.2 million class E at 'BBB-sf'; Outlook Stable;
  -- $12.3 million class F at 'B-sf'; Outlook Negative;
  -- $7.1 million class G at 'CCsf/RR3';
  -- $1.8 million class H at 'Dsf/RR6'.

Classes A-1, A-2 and A-3, have paid in full.  The total loss to
class J has reduced it to zero and will remain at 'Dsf/RR6'.

Fitch withdrawals the rating on interest-only (IO) class X.


GMAC COMMERCIAL: Fitch Affirms Rating on $3.3-Mil. Notes at 'D'
---------------------------------------------------------------
Fitch Ratings upgrades three classes of GMAC Commercial Mortgage
Securities, Inc., series 2004-C3, commercial mortgage pass-through
certificates.

The upgrades are the result of increased credit enhancement due to
paydown which is sufficient to offset Fitch expected losses.
Fitch modeled losses of 9% of the remaining pool.

As of the July 2011 distribution date, the pool's collateral
balance has paid down 29% to $889.5 million from $1.25 billion at
issuance.  Four loans (4%) have defeased.  Fitch has identified 26
Loans of Concern (35%), including 10 assets in special servicing
(19%).

The largest contributor to loss (3.7%) is secured by a 302,992
square foot (sf), 11 story office building located in Chicago, IL
(approximately 15 miles NW of the CBD). T he loan was transferred
to special servicing in April 2009 due to a technical default.  A
major tenant vacated at lease expiration in May 2007 which
triggered a monthly rollover reserve escrow payment.  The
triggered payment was not implemented until February 2009.  Loan
modification discussions failed and a receiver was appointed in
August 2010.  The special servicer took title through foreclosure
on Jan. 13, 2011.  The property was 60% occupied as of April 2011
which includes two new leases totaling 23,500 sf signed during the
1st quarter of 2011.  There is an additional lease totaling 54,968
sf under negotiation.  The special servicer's strategy is to hold,
reposition, and stabilize the asset.

The second largest contributor to loss (1.7%) is secured by two
four-story buildings which are part of a three building student
housing property located near Winthrop University in Rock Hill,
SC. The two buildings are comprised of 124 units with a total of
432 beds.  The loan was transferred to special servicing in
September 2009 due to monetary default.  A receiver was appointed
by the court in February 2010 and the property remains in
receivership.  As of June 2011, the property was 75% pre-leased
for the fall 2011 school year.

The third largest contributor to loss (1.8%) is secured by a 268
unit apartment building located in Pensacola, FL.  The loan was
transferred to special servicing in October 2009 for imminent
maturity default prior to the November 2009 maturity.  A receiver
was assigned to the property in November 2010.  The receiver is
currently leasing up the property to market occupancy and the
property is currently 71% occupied.

Fitch upgrades and revises Outlooks on the following classes as
indicated:

  -- $82.9 million class A-J to 'BBBsf' from 'BBB-'; Outlook
     revised to Stable from Negative;
  -- $31.3 million class B to 'BBsf' from 'B-'; Outlook revised to
     Stable from Negative;
  -- $14.1 million class C to 'Bsf' from 'B-'; Outlook revised to
     Stable from Negative.

Fitch also affirms the following classes as indicated:

  -- $263.3 million class A-1A at 'AAAsf'; Outlook Stable;
  -- $226.1 million class A-4 at 'AAAsf'; Outlook Stable;
  -- $47 million class A-AB at 'AAAsf'; Outlook Stable;
  -- $138.6 million class A-5 at 'AAAsf'; Outlook Stable;
  -- $20.3 million class D at 'CCCsf/RR1';
  -- $12.5 million class E at 'CCsf/RR3';
  -- $15.6 million class F at 'Csf/RR6';
  -- $10.9 million class G at 'Csf/RR6'';
  -- $20.3 million class H at 'Csf/RR6';
  -- $3.1 million class J at 'Csf/RR6';
  -- $3.3 million class K at 'Dsf/RR6.

Classes L, M, N, and O remain at 'D/RR6' due to principal losses
incurred. Classes A-1, A-2, and A-3 have been paid in full.  Class
P is not rated by Fitch. Fitch had previously withdrawn the
ratings of the interest only classes X-1 and X-2.


GREEN LANE: Moody's Raises Class Notes Rating to A2(sf) From Ba2
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Green Lane CLO Ltd.:

US$360,000,000 Class A-1 Senior Secured Floating Rate Notes due
2017 (current outstanding balance of $270,713,495), Upgraded to
Aaa (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$40,000,000 Class A-2 Revolving Senior Secured Floating Rate
Notes due 2017 (current outstanding balance of $30,079,277),
Upgraded to Aaa (sf); previously on June 22, 2011 Aa3 (sf) Placed
Under Review for Possible Upgrade;

US$23,000,000 Class B Senior Secured Deferrable Floating Rate
Notes due 2017, Upgraded to Aa1 (sf); previously on June 22, 2011
Baa2 (sf) Placed Under Review for Possible Upgrade;

US$33,750,000 Class C Secured Floating Rate Notes due 2017,
Upgraded to A2(sf); previously on June 22, 2011 Ba2 (sf) Placed
Under Review for Possible Upgrade;

US$5,000,000 Combination Notes Due 2017, Upgraded to Aaa (sf);
previously on June 22, 2011 Ba2 (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 October 2009.
Moody's notes that as of August 1, 2011 the Class A Notes have
been paid down by approximately 23.45% or $99.2 million since the
rating action in October 2009. As a result of the delevering, the
overcollateralization ratios have increased since the rating
action in October 2009. Based on the latest trustee report dated
July 21 2011, the Class A overcollateralization ratios are
reported at 131.43%, versus September 2009 levels of 123.46% .

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 $370.7 million,
defaulted par of $4.3 million, a weighted average default
probability of 21.58% (implying a WARF of 3571), a weighted
average recovery rate upon default of 49.01%, and a diversity
score of 44. 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.

Green Lane CLO Ltd., issued in December of 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. 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.


GULF STREAM: Moody's Upgrades Ratings of 4 Classes of CLO Notes
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Gulf Stream - Sextant CLO 2007-1, Ltd.:

US$76,500,000 Class A-1-B Floating Rate Notes Due 2021, Upgraded
to Aaa (sf); previously on June 22, 2011 Aa2 (sf) Placed Under
Review for Possible Upgrade;

US$17,500,000 Class B Floating Rate Notes Due 2021, Upgraded to
Aa2 (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$33,750,000 Class C Floating Rate Deferrable Notes Due 2021,
Upgraded to A3 (sf); previously on June 22, 2011 Baa3 (sf) Placed
Under Review for Possible Upgrade;

US$31,250,000 Class D Floating Rate Deferrable Notes Due 2021,
Upgraded to Baa3 (sf); previously on June 22, 2011 Ba2 (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 $492 million,
defaulted par of $1 million, a weighted average default
probability of 22.22% (implying a WARF of 2767), a weighted
average recovery rate upon default of 48.93%, and a diversity
score of 81. 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 - Sextant CLO 2007-1, Ltd., issued in May 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. 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) 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 weighted average coupon. 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.


HALCYON STRUCTURED: Moody's Raises Ratings of CLO Notes
-------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Halcyon Structured Asset Management Long Secured/Short
Unsecured 2007-1 Ltd.:

US$35,000,000 Class A-2 Senior Secured Floating Rate Notes, Due
2021, Upgraded to Aaa (sf); previously on June 22, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade;

US$32,000,000 Class B Senior Secured Floating Rate Notes, Due
2021, Upgraded to Aa3 (sf); previously on June 22, 2011 A3 (sf)
Placed Under Review for Possible Upgrade;

US$28,000,000 Class C Senior Secured Deferrable Floating Rate
Notes, Due 2021, Upgraded to A3 (sf); previously on June 22, 2011
Baa3 (sf) Placed Under Review for Possible Upgrade;

US$27,500,000 Class D Secured Deferrable Floating Rate Notes, Due
2021, Upgraded to Ba1 (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.

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 July 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2638 compared to 2866 in July 2009. The Class
A/B, Class C and Class D overcollateralization ratios are reported
at 129.51%, 120.66% and 113.08%, respectively, versus July 2009
levels of 117.24%, 109.23% and 102.37%, 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 $495.5 million,
no defaulted par, a weighted average default probability of 18.50%
(implying a WARF of 2705), a weighted average recovery rate upon
default of 46.91%, 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.

Halcyon Structured Asset Management Long Secured/Short Unsecured
2007-1 Ltd., 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) 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 levels higher than the covenant
   levels due to the large difference between the reported and
   covenant levels.

3) Exposure to credit estimates: The deal is exposed to a large
   number of securities whose default probabilities are assessed
   through credit estimates. In the event that Moody's is not
   provided the necessary information to update the credit
   estimates in a timely fashion, the transaction may be impacted
   by any default probability stresses Moody's may assume in lieu
   of updated credit estimates.


HALCYON STRUCTURED: Moody's Upgrades Ratings of CLO Notes Due 2021
------------------------------------------------------------------
Moody's Investors Service announced that it has upgraded the
ratings of the following notes issued by Halcyon Structured Asset
Management Long Secured/Short Unsecured 2007-2 Ltd.:

US$350,000,000 Class A-1a Senior Secured Floating Rate Notes Due
2021 (current outstanding balance of $339,924,881.37), Upgraded to
Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed Under Review
for Possible Upgrade;

US$22,750,000 Class A-1b Senior Secured Floating Rate Notes Due
2021, Upgraded to Aa1 (sf); previously on June 22, 2011 A1 (sf)
Placed Under Review for Possible Upgrade;

US$30,000,000 Class A-2 Senior Secured Floating Rate Notes Due
2021, Upgraded to Aa3 (sf); previously on June 22, 2011 A3 (sf)
Placed Under Review for Possible Upgrade;

US$28,250,000 Class B Senior Secured Deferrable Floating Rate
Notes Due 2021, Upgraded to Baa1 (sf); previously on June 22, 2011
Ba1 (sf) Placed Under Review for Possible Upgrade;

US$24,000,000 Class C Secured Deferrable Floating Rate Notes Due
2021, Upgraded to Ba1 (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 an increase in the
transaction's overcollateralization ratios since the rating action
in July 2009. Based on the latest trustee report dated July 19,
2011, the Class A, Class B and Class C overcollateralization
ratios are reported at 125.29%, 116.88% and 110.58%, respectively,
versus June 2009 levels of 114.58%, 106.96% and 101.21%,
respectively, and all related overcollateralization tests are
currently in compliance. Moody's also notes that the Class B and
Class C 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 $492 million, no
defaulted par, a weighted average default probability of 21.88%
(implying a WARF of 2822), a weighted average recovery rate upon
default of 45.08%, 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.

Halcyon Structured Asset Management Long Secured/Short Unsecured
2007-2 Ltd., issued in August 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 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) Exposure to credit estimates: The deal is exposed to a large
   number of securities whose default probabilities are assessed
   through credit estimates. In the event that Moody's is not
   provided the necessary information to update the credit
   estimates in a timely fashion, the transaction may be impacted
   by any default probability stresses Moody's may assume in lieu
   of updated credit estimates.


IXIS ABS: S&P Lowers Ratings on 2 Classes of Notes to 'D'
---------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes of notes from five U.S. collateralized debt obligation
(CDO) transactions. "In addition, we affirmed seven ratings on
three U.S. CDO transactions," S&P related.

The downgrades follow a default in the payment of interest or
ultimate principal to the notes on their most recent payment
dates. "This is consistent with our criteria, 'Surveillance
Methodology For Global Cash Flow And Hybrid CDOs Subject To
Acceleration Or Liquidation After An EOD,' published on Sept.
2, 2009," S&P said.

IXIS ABS CDO 1 Ltd. is a hybrid CDO backed by mezzanine structured
finance assets, and managed by IXIS Securities North America. "We
downgraded classes X and A-1LB to 'D (sf)' due to a default in the
payment of the interest due to these tranches on their most recent
payment date," S&P said.

Millerton II High Grade ABS CDO Ltd. is a cash flow CDO backed by
high-grade structured finance assets and managed by Hyperion
Capital Management. "We downgraded classes A-1, A-2, B, and C to
'D (sf)' following a notice of acceleration, liquidation, and
suspension of payments. We received this notice on Aug. 4, 2011,
which indicated that the appropriate voting noteholders had
declared to accelerate and liquidate the transaction. The notice
further indicated that due to the declaration of liquidation, the
transaction made no distributions on the Aug. 8, 2011, payment
date. Therefore, we downgraded classes A-1, A-2, B, and C to 'D
(sf)' due to missed interest on these tranches on the Aug. 8,
2011, payment date," S&P related.

Silver Marlin CDO I Ltd. is a cash flow CDO backed by high-grade
structured finance assets, and managed by Sailfish Capital
Partners LLC. "We downgraded classes D, E, and F to 'D (sf)'
following a notice we received on July 22, 2011. This notice
indicated that the transaction had completely liquidated,
and that the application of the proceeds from liquidation were
insufficient to pay the class A-1 notes, or any other note, in
full on the Aug. 1, 2011, distribution date. Therefore, we
downgraded classes D, E, and F to 'D (sf)' as a result of a
default in the payment of the principal amount due to these
notes on the final payment date," S&P said.

Summer Street 2005-1 Ltd. is a cash flow CDO backed by mezzanine
structured finance assets and managed by GE Asset Management Inc.
"We downgraded classes A-2 and A-3 to 'D (sf)' as a result of a
default in the payment of the interest due to these tranches on
their most recent payment date," S&P said.

Tazlina Funding CDO II Ltd. is a cash flow CDO backed by high-
grade structured finance assets and managed by Terwin Money
Management. "We downgraded classes A-1, A-2, D, and E to 'D (sf)'
following a notice we received on July 28, 2011. This notice
indicated that the transaction had completely liquidated, and that
the application of the proceeds from liquidation were insufficient
to pay the class A-1 notes, or any other note, in full on the Aug.
5, 2011, distribution date. Therefore, we downgraded classes A-1,
A-2, D, and E to 'D (sf)' as a result of a default in the payment
of the principal amount due to these notes on the final payment
date," S&P related.

"The affirmations of the class A-3L, B-1L, and B-2L notes from
IXIS ABS CDO 1 Ltd., the rating on the class D notes from
Millerton II High Grade ABS CDO Ltd., and the ratings on the class
A-1, B, and C notes from Summer Street 2005-1 Ltd. reflect our
belief that the credit support available is commensurate with the
current rating levels," S&P said.

Rating Actions

IXIS ABS CDO 1 Ltd.
                        Rating
Class              To           From
X                  D (sf)       CCC- (sf)
A-1LB              D (sf)       CC (sf)

Millerton II High Grade ABS CDO Ltd.
                        Rating
Class              To           From
A-1                D (sf)       CCC- (sf)
A-2                D (sf)       CC (sf)
B                  D (sf)       CC (sf)
C                  D (sf)       CC (sf)

Silver Marlin CDO I Ltd.
                        Rating
Class              To           From
D                  D (sf)       CC (sf)
E                  D (sf)       CC (sf)
F                  D (sf)       CC (sf)

Summer Street 2005-1 Ltd.
                        Rating
Class              To           From
A-2                D (sf)       CC (sf)
A-3                D (sf)       CC (sf)

Tazlina Funding CDO II Ltd.
                        Rating
Class              To           From
A-1                D (sf)       CC (sf)
A-2                D (sf)       CC (sf)
D                  D (sf)       CC (sf)
E                  D (sf)       CC (sf)

Ratings Affirmed

IXIS ABS CDO 1 Ltd.

Class              Rating
A-3L               CC (sf)
B-1L               CC (sf)
B-2L               CC (sf)

Millerton II High Grade ABS CDO Ltd.

Class              Rating
D                  CC (sf)

Summer Street 2005-1, Ltd.

Class              Rating
A-1                CC (sf)
B                  CC (sf)
C                  CC (sf)

OTHER RATINGS OUTSTANDING

IXIS ABS CDO 1 Ltd.

Class              Rating
A-2L               D (sf)

Silver Marlin CDO I Ltd.

Class              Rating
A-1                D (sf)
A-2                D (sf)
A-3                D (sf)
A-4                D (sf)
B                  D (sf)
C                  D (sf)

Tazlina Funding CDO II Ltd.

Class              Rating
A-3                D (sf)
B                  D (sf)
C                  D (sf)


JASPER CLO: Moody's Upgrades Class C Notes Rating to 'Ba1'
----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Jasper CLO Ltd.:

US$521,500,000 Class A Floating Rate Senior Secured Extendable
Notes Due 2017 (current balance of $487,826,407.95), Upgraded to
Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$35,000,000 Class B Floating Rate Senior Secured Extendable
Notes Due 2017, Upgraded to A1 (sf); previously on June 22, 2011
Baa1 (sf) Placed Under Review for Possible Upgrade;

US$35,000,000 Class C Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due 2017, Upgraded to Ba1 (sf);
previously on June 22, 2011 Ba3 (sf) Placed Under Review for
Possible Upgrade;

US$33,500,000 Class D-1 Floating Rate Senior Secured Deferrable
Interest Extendable Notes Due 2017 (current balance of
$17,984,317.58), Upgraded to Ba2 (sf); previously on June 22, 2011
Caa1 (sf) Placed Under Review for Possible Upgrade;

US$5,000,000 Class D-2 Fixed Rate Senior Secured Deferrable
Interest Extendable Notes Due 2017 (current balance of
$2,673,147.04), Upgraded to Ba2 (sf); previously on June 22, 2011
Caa1 (sf) Placed Under Review for Possible Upgrade;

US$10,000,000 Class 1 Extendable Composite Securities Due 2017
(current rated balance of $2,440,745.03), Upgraded to Ba1 (sf);
previously on June 22, 2011 Caa1 (sf) Placed Under Review for
Possible Upgrade; and

US$5,000,000 Class 2 Extendable Composite Securities Due 2017
(current rated balance of $3,411,502.11), Upgraded to Baa3 (sf);
previously on June 22, 2011 Ba2 (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 and credit improvement
of the underlying portfolio since the rating action in October
2009. Based on the latest trustee report dated July 20, 2011, the
Class A/B, Class C and Class D overcollateralization ratios are
reported at 116.46%, 109.16% and 105.26%, respectively, versus
August 2009 levels of 112.09%, 105.36% and 99.26%, respectively.
In particular, the Class D overcollateralization ratio has
increased in part due to the diversion of excess interest to
delever the Class D-1 Notes and Class D-2 Notes in the event of a
Class D Coverage Tests failure. Since the rating action in October
2009, $15.7 million of interest proceeds have reduced the
outstanding balance of the Class D-1 Notes and Class D-2 Notes by
43%. The Class D-1 Notes and Class D-2 Notes are no longer
deferring interest and all previously deferred interest has been
paid in full. Moody's also notes that the deal has benefited from
improvement in the credit quality of the underlying portfolio
since the rating action in October 2009. Based on the July 2011
trustee report, the weighted average rating factor is currently
2,625 compared to 3,009 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 9.49% 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 $602.2 million,
defaulted par of $52.5 million, a weighted average default
probability of 18.04% (implying a WARF of 2,785), a weighted
average recovery rate upon default of 48.35%, and a diversity
score of 59. 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.

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

The principal methodology used in this rating was "Moody's
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) 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) 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.

3) 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.


JP MORGAN: Fitch Affirm Junk Rating on Eight Note Classes
---------------------------------------------------------
Fitch Ratings has affirmed J.P. Morgan Chase Commercial Mortgage
Securities Corp.'s commercial mortgage pass-through certificates,
series 2004-CIBC9.

The affirmations reflect stable portfolio performance and
sufficient credit enhancement to offset Fitch expected losses.
Fitch modeled losses of 9.12% of the remaining pool.  Fitch
designated 21 loans (24%) as Fitch Loans of Concern, which include
seven specially serviced loans (11.95%).

As of the July 2011 distribution date, the pool's aggregate
principal balance has been reduced by 28.85% (including 1.56% of
realized losses) to $784 million from $1.1 billion at issuance.
Interest shortfalls are affecting classes G through NR. Five loans
in the pool (5.99%) are currently defeased.

The largest specially-serviced loan in the pool (5.47%) is secured
by 433,829 square feet (sf) of owned space at a 603,207 sf retail
property located in Sacramento, CA.  The loan transferred to
special servicing in March 2008 due to imminent default. In
January 2009, the anchor tenant (44.8%) filed for bankruptcy and
vacated the property in July 2009.  The special servicer continues
to work with the borrower cure the default while simultaneously
pursuing foreclosure.

The second largest specially-serviced loan in the pool (1.96%) is
secured by two multifamily properties located in Chattanooga, TN
and Red Bank, TN.  The loan was transferred to special servicing
in January 2010 due to monetary default and the special servicer
is pursuing foreclosure.

Fitch affirms the following classes and revises the Outlooks and
Recovery Ratings (RR) as indicated:

  -- $46.8 million class A-3 at 'AAAsf'; Outlook to Stable from
     Negative;
  -- $466.4 million class A-4 at 'AAAsf'; Outlook to Stable from
     Negative;
  -- $135.1 million class A1-A at 'AAAsf'; Outlook to Stable from
     Negative;
  -- $27.5 million class B at 'BBB-sf'; Outlook Negative;
  -- $13.8 million class C at 'BBsf'; Outlook Negative;
  -- $20.7 million class D at 'B-sf'; Outlook Negative;
  -- $11 million class E at 'CCCsf'; RR to 'RR2' from 'RR1';
  -- $15.15 million class F at 'CCCsf'; RR to 'RR2' from 'RR1';
  -- $9.6 million class G at 'CCsf'; RR to 'RR6' from 'RR2';
  -- $17.9 million class H at 'Csf'; RR to 'RR6' from 'RR3';
  -- $2.8 million class J at 'Csf'; RR to 'RR6' from 'RR4';
  -- $4.1 million class K at 'Csf/RR6';
  -- $5.5 million class L at 'Csf/RR6';
  -- $5.5 million class M at 'Csf/RR6';
  -- $2.8 million class N at 'Dsf/RR6';
  -- Class P at 'Dsf/RR6'.

Classes A-1 and A-2 have repaid in full. Classes P and NR have
been reduced to zero due to realized losses.  Fitch does not rate
class NR.  The rating on class X was previously withdrawn.


JP MORGAN: Moody's Affirms 17 CMBS Classes of JPMCC 2007-CIBC18
---------------------------------------------------------------
Moody's Investors Service affirmed 17 classes of J.P. Morgan Chase
Commercial Mortgage Securities Trust 2007-CIBC18, Commercial
Mortgage Pass-Through Certificates, Series 2007-CIBC18:

Cl. A-1, 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-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-M, Affirmed at Aa3 (sf); previously on Nov 17, 2010
Downgraded to Aa3 (sf)

Cl. A-MFL, Affirmed at Aa3 (sf); previously on Nov 17, 2010
Downgraded to Aa3 (sf)

Cl. A-J, Affirmed at Ba1 (sf); previously on Nov 17, 2010
Downgraded to Ba1 (sf)

Cl. B, Affirmed at Ba3 (sf); previously on Nov 17, 2010 Downgraded
to Ba3 (sf)

Cl. C, Affirmed at B1 (sf); previously on Nov 17, 2010 Downgraded
to B1 (sf)

Cl. D, Affirmed at B3 (sf); previously on Nov 17, 2010 Downgraded
to B3 (sf)

Cl. E, Affirmed at Caa2 (sf); previously on Nov 17, 2010
Downgraded to Caa2 (sf)

Cl. F, Affirmed at Ca (sf); previously on Nov 17, 2010 Downgraded
to Ca (sf)

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

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

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

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

Cl. X, 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 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
7.6% of the current balance. At last full review, Moody's
cumulative base expected loss was 7.9%. Moody's stressed scenario
loss is 20.9% 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.

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 performance in the commercial real
estate property markets. While commercial real estate property
markets are gaining momentum, a consistent upward trend will not
be evident until the volume of transactions increases, distressed
properties are cleared from the pipeline and job creation
rebounds. The hotel and multifamily sectors are continuing to show
signs of recovery through the first half of 2011, while recovery
in the non-core office and retail sectors are tied to pace of
recovery of the broader economy. Core office markets are showing
signs of recovery through lending and leasing activity. 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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

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

Moody's review incorporated the use of the Excel-based CMBS
Conduit Model v 2.60 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 57, compared to 60 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 17, 2010.

DEAL PERFORMANCE

As of the August 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 6% to $3.69 billion
from $3.90 billion at securitization. The Certificates are
collateralized by 209 mortgage loans ranging in size from less
than 1% to 6% of the pool, with the top ten loans representing 32%
of the pool. No loans have defeased or have investment grade
credit estimates.

Fifty-eight loans, representing 32% 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.

Nineteen loans have been liquidated from the pool since
securitization, resulting in an aggregate $87.3 million loss (53%
loss severity on average). Due to realized losses, classes L, M,
N, P and NR have been eliminated entirely and Class K has
experienced a 29% principal loss. Currently, fifteen loans,
representing 6% of the pool, are in special servicing. The master
servicer has recognized appraisal reductions totaling $71.5
million for the specially serviced loans. Moody's has estimated a
$78.2 million loss (36% expected loss) for the specially serviced
loans.

Moody's has assumed a high default probability for twenty-nine
poorly performing loans representing 21.6% of the pool. Moody's
has estimated a $119.7 million loss (15% expected loss based on a
30% probability default) from these troubled loans.

Moody's was provided with full year 2010 and partial year 2011
operating results for 86% and 12%, respectively, of the performing
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV for the conduit component is 105% compared to
115% 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 9.0%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs for the conduit component are 1.60X and 1.08X,
respectively, compared to 1.29X and 0.91X at last review. Moody's
actual DSCR is based on Moody's net cash flow (NCF) and the loan's
actual debt service. Moody's stressed DSCR is based on Moody's NCF
and a 9.25% stressed rate applied to the loan balance.

The top three performing conduit loans represent 16% of
the pool. The largest loan is the 131 South Dearborn Loan
($236.0 million -- 6.4%), which represents a participation
interest in a $472.0 million mortgage loan. The loan is secured
by a 1.5 million square foot (SF) Class A office property located
in downtown Chicago, Illinois. The property was 95% leased as of
March 2011, the same as at last review. Performance remains
stable. Moody's LTV and stressed DSCR are 117% and 0.79X,
respectively, compared to 118% and 0.78X at last review.

The second largest loan is the Centro Heritage Portfolio 4 Loan
($226.1 million -- 6.1%), which is secured by a diverse portfolio
of 16 retail properties located in ten states. As of December 2010
the portfolio was 89% leased, the same as at last review.
Performance has slightly declined due to a drop in base rent and
expense reimbursements. Moody's LTV and stressed DSCR are 80% and
1.16X, respectively, compared to 77% and 1.20X at last review.

The third largest loan is the Quantico Property Trust Portfolio
Loan ($131.2 million -- 3.6%), which is secured by a portfolio of
14 properties (938,769 SF), comprised of office, warehouse and
flex space. Thirteen of the properties are located in Sterling,
Virginia. As of December 2010, the portfolio was 92% occupied,
compared to 97% at last review. Despite the decline in occupancy,
performance has been stable. Moody's LTV and stressed DSCR are
119% and 0.82X, respectively, compared to 120% and 0.81X at last
review.


JP MORGAN: Moody's Affirms 18 CMBS Classes of JPMCC 2006-CIBC14
---------------------------------------------------------------
Moody's Investors Service affirmed the ratings of 18 CMBS classes
of J.P. Morgan Chase Commercial Mortgage Securities Corp.,
Commercial Mortgage Pass-Through Certificates, Series 2006-CIBC14:

Cl. A-3A, Affirmed at Aaa (sf); previously on Mar 28, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-3B, Affirmed at Aaa (sf); previously on Mar 28, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Mar 28, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-SB, Affirmed at Aaa (sf); previously on Mar 28, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Mar 28, 2006
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at Aa3 (sf); previously on Dec 2, 2010
Downgraded to Aa3 (sf)

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

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

Cl. C, Affirmed at Caa2 (sf); previously on Dec 2, 2010 Downgraded
to Caa2 (sf)

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

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

Cl. X-1, Affirmed at Aaa (sf); previously on Mar 28, 2006
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on Mar 28, 2006
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
8.8% of the current pooled balance as compared to 11.4% at last
review. The pool's cumulative realized losses have increased by
$56 million since last review. Moody's current base expected loss
plus cumulative realized losses is 10.1% of the original pool
balance as compared to 11.4% at last review. Moody's stressed
scenario loss is 16.7% of the current pooled 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.

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 performance in the commercial real
estate property markets. While commercial real estate property
markets are gaining momentum, a consistent upward trend will not
be evident until the volume of transactions increases, distressed
properties are cleared from the pipeline and job creation
rebounds. The hotel and multifamily sectors are continuing to show
signs of recovery through the first half of 2011, while recovery
in the non-core office and retail sectors are tied to the pace of
the recovery of the broader economy. Core office markets are
showing signs of recovery through lending and leasing activity.
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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

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

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.60 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 pool has a Herf of 28 as compared to 39
at last 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 2, 2010.

DEAL PERFORMANCE

As of the July 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 10% to $2.4 billion
from $2.7 billion at securitization. The Certificates are
collateralized by 182 mortgage loans ranging in size from less
than 1% to 12% of the pool, with the top ten loans representing
44% of the pool. The pool contains two loans with investment grade
credit estimates. The pool does not have any defeased loans.

Forty-eight loans, representing 17% 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 an
aggregate realized loss of $66 million (45% average loss
severity). Thirty-one loans, representing 17% of the pool, are
currently in special servicing. The largest specially serviced
loan is the Avion Business Park Portfolio Loan ($94 million --
3.9%) which is secured by seven suburban office properties located
in Chantilly, Virginia. The loan was transferred into special
servicing October 2010 and is now over 90 days delinquent. The
portfolio's occupancy declined to 59% as of March 8, 2011 from 78%
as of June 30, 2010. The servicer has recognized a $30.6 million
appraisal reduction for this loan, while Moody's expected loss is
$24 million.

The remaining specially serviced loans are secured by a mix of
commercial and multifamily property types. The master servicer has
recognized an aggregate $161 million appraisal reduction for 28 of
the 31 specially serviced loans and two loans that had previously
been in special servicing. Moody's has estimated an aggregate $150
million loss (38% expected loss based on an 87% probability of
default) for the specially serviced loans.

Moody's has assumed a high default probability for 18 poorly
performing loans representing 7% of the pool and has estimated a
$32 million loss (20% expected loss based on a 50% probability
default) from these troubled loans.

Based on the most recent remittance statement, Classes D through
NR have experienced cumulative interest shortfalls totaling
$10.9 million. Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced and troubled loans. 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 full year 2010 operating results for 95%
conduit's loans. The conduit portion of the pool excludes
specially serviced, troubled and defeased loans as well as loans
with credit estimates. Moody's weighted average conduit LTV is 98%
compared to 103% at Moody's prior 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 9.2%.

Moody's actual and stressed conduit DSCRs are 1.42 and 1.07X,
respectively, compared to 1.41X and 1.04X 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 Houston Galleria
Loan ($290 million -- 12.1%), which represents a 50% pari-passu
interest in a $580 million first mortgage secured by a 2.3 million
square foot (SF) super-regional mall located in Houston, Texas.
The center is anchored by Macy's, Neiman Marcus, Nordstrom and
Saks Fifth Avenue. The property was 92% leased as of March 2011,
which is similar to last review and securitization. 2010 in-line
tenant sales are $959 per SF, which is considered strong. The loan
is interest only for the entire term. Moody's current credit
estimate and stressed DSCR are Baa2 and 1.29X, respectively,
compared to Baa2 and 1.28X at last review.

The second loan with a credit estimate is the Patrick Henry
Building Loan ($120 million --5.0%), which is secured by a 520,000
SF office building located in Washington, DC. The property is 100%
leased to the U.S. Department of Justice until August 2015. The
loan is interest only for the entire term. Moody's current credit
estimate and stressed DSCR are Baa3 and 1.35X, respectively,
compared to Baa3 and 1.34X at last review.

The top three conduit loans represent 18.4% of the pool
balance. The largest loan is the Ballantyne Corporate Park
Loan ($217 million -- 9.1%). The loan is secured by 20 cross-
collateralized and cross-defaulted properties located in
Charlotte, North Carolina. Two of the properties are hotels
with a total of 208 rooms and the remaining 18 properties are
offices with a total of 1.65 million SF. The offices' weighted
average occupancy was 89% as of June 2011 compared to 90% in June
2010. The hotels' 2011 Revenue per available room (RevPAR) through
May increased to $90 from $81 in 2010. Moody's LTV and stressed
DSCR are 96% and 1.07X, respectively, compared to 97% and 1.06X at
last review.

The second largest loan is the Colony Line II Loan ($159 million -
- 6.6%), which is secured by eight cross-defaulted and cross-
collateralized loans secured by eight properties located in
Georgia, Illinois, Texas and Virginia. The collateral consists of
four industrial properties, two multifamily properties and two
office properties. The portfolio is 87% leased as of December 2010
compared to 87% at last review. The loan is interest only for the
entire term. Moody's LTV and stressed DSCR are 115% and 0.87X,
respectively, compared to 108% and 0.93X at last review.

The third largest conduit loan is the Chartwell II Portfolio Loan
($66 million -- 2.8%), which is secured by three senior housing
properties totaling 499 units. Two of the properties are located
in Colorado, while the third is located in Temple, Texas. The
portfolio's occupancy has declined to 84% as of June 2011 from 92%
at last review and 96% at securitization. The decline in occupancy
is attributed to the Texas property, which is only 73% occupied.
Moody's LTV and stressed DSCR are 94% and 1.26X, respectively,
compared to 92% and 1.29X at last review.


JP MORGAN: Moody's Affirms Cl. A-J Notes Rating at 'B1'
-------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 24
classes of J.P. Morgan Chase Commercial Mortgage Securities Corp.,
Commercial Mortgage Pass-Through Certificates, Series 2005-CIBC13:

Cl. A-1A, Affirmed at Aaa (sf); previously on Dec 17, 2010
Confirmed at Aaa (sf)

Cl. A-2, Affirmed at Aaa (sf); previously on Dec 7, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-2FX, Affirmed at Aaa (sf); previously on Aug 3, 2010
Assigned Aaa (sf)

Cl. A-2FL, Affirmed at Aaa (sf); previously on Dec 7, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-3A1, Affirmed at Aaa (sf); previously on Dec 7, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Dec 17, 2010
Confirmed at Aaa (sf)

Cl. A-SB, Affirmed at Aaa (sf); previously on Dec 7, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-M, Affirmed at A1 (sf); previously on Dec 17, 2010
Downgraded to A1 (sf)

Cl. A-3A2, Affirmed at Aaa (sf); previously on Dec 7, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-J, Affirmed at B1 (sf); previously on Dec 17, 2010
Downgraded to B1 (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on Dec 7, 2005
Definitive Rating Assigned Aaa (sf)

Cl. X-2, Affirmed at Aaa (sf); previously on Dec 7, 2005
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Caa2 (sf); previously on Dec 17, 2010
Downgraded to Caa2 (sf)

Cl. C, Affirmed at Caa3 (sf); previously on Dec 17, 2010
Downgraded to Caa3 (sf)

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

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

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

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

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

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

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

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

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

Cl. N, Affirmed at C (sf); previously on Jan 28, 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
11.9% of the current pooled balance, which is the same as at last
review. Moody's stressed scenario loss is 24.1% of the current
pooled 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 U.S. CMBS Conduit Transactions," published 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 pool has a Herf of 51, which is above
the credit neutral Herf score of 40.

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 17, 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 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 9% to $2.5 billion
from $2.7 billion at securitization. The Certificates are
collateralized by 216 mortgage loans ranging in size from less
than 1% to 7% of the pool, with the top ten loans representing 35%
of the pool. The pool does not contain any defeased loans or loans
with credit estimates.

Fifty loans, representing 20% 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 $53 million loss (61% average loss
severity). Twenty-six loans, representing 24% of the pool, are
currently in special servicing. The largest specially serviced
loan is the Southeast Office Portfolio Loan ($181 million -- 7.3%
of the pool), which is secured by a portfolio of 16 suburban
office properties containing a total of 1.5 million SF. The
properties are located in Florida (12), North Carolina (2) and
Maryland (2). The loan was transferred to special servicing in
November 2009 and the entire portfolio is now REO. The master
servicer has recognized a $95 million appraisal reduction for this
portfolio.

The second largest specially serviced loan is the Shore Club A-
Note Loan ($107.8 million -- 4.3% of the pool), which is secured
by a 322-room full-service boutique hotel located in Miami Beach,
Florida. The Shore Club also has an $11.5 million B-Note that is
held outside of the Trust, which brings the property's total debt
to $119.3 million. The Shore Club A-Note Loan was transferred to
special servicing in September 2009 and is currently in the
foreclosure process. Although the loan is over 90 days delinquent,
occupancy and revenue per available room (RevPAR) have increased.
Occupancy and RevPar for 1H2011 are up 4% and 7%, respectively.
The master servicer recognized a $39 million appraisal reduction
for this loan.

The remaining specially serviced loans are secured by a mix of
commercial and multifamily property types. The master servicer has
recognized an aggregate $237 million appraisal reduction for 19 of
the 26 specially serviced loans and one loan that is not being
specially serviced. Moody's has estimated an aggregate $227
million loss (38% expected loss based on an 88% probability of
default) for the specially serviced loans.

Moody's has assumed a high default probability for 21 poorly
performing loans representing 7% of the pool and has estimated a
$26 million loss (15% expected loss based on a 50% probability
default) from these troubled loans.

Based on the most recent remittance statement, Classes C through
NR have experienced cumulative interest shortfalls totaling
$21.5 million. Moody's anticipates that the pool will continue to
experience interest shortfalls because of the high exposure to
specially serviced and troubled loans. 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 full year 2010 operating results for 86%
conduit's loans. The conduit portion of the pool excludes
specially serviced and troubled loans. Moody's weighted average
conduit LTV is 103% compared to 104% 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%.

Moody's actual and stressed conduit DSCRs are 1.33X and 1.0X,
respectively, compared to 1.33X and .98X 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 13% of the
pool balance. The largest loan is the Mellon Bank Center Loan
($172 million -- 6.9% of the pool), which is secured by a
703,000 SF office property located in Los Angeles, California.
The property was 76% leased as of December 2010 compared to 92% at
last review. The decline in occupancy is mainly attributed to one
large tenant, McKinsey & Co. (11% of net rentable area or NRA),
vacating and another large tenant, O'Melveny & Myers, LLP (33% of
NRA), contracting. The loan is interest only for its entire term.
The loan is on the watchlist due to low DSCR. The loan's maturity
is October 2012. Moody's anticipates that the borrower will seek a
loan extension to provide additional time to stabilize the
property prior to seeking refinancing. Moody's LTV and stressed
DSCR are 140% and 0.66X, respectively, compared to 119% and 0.77X
at last review.

The second largest loan is Marriott Myrtle Beach Loan ($73 million
-- 2.9% of the pool), which is secured by a 405 room full service
hotel located in Myrtle Beach, South Carolina. The collateral's
2010 occupancy (65%) and RevPAR ($101) remained stable since last
review. Moody's LTV and stressed DSCR are 82% and 1.45X,
respectively, compared to 79% and 1.50X at last review.

The third largest loan is the 270 Madison Avenue Loan
($65.0 million -- 2.6% of the pool), which is secured by 19-story
Class B office building located in Manhattan, New York. The
property was 99% leased as of March 2011, similar to last review.
However, Taylor & Francis (13% of NRA) vacated the property at its
April 2011 lease expiration. Moody's stressed the property's cash
flow to account for the costs associated with leasing the vacant
space. The loan is interest only for its entire term. Moody's LTV
and stressed DSCR are 124% and 0.76X, respectively, compared to
113% and 0.84X at last review.


JP MORGAN: Moody's Upgrades Class G Notes Rating to 'B1'
--------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the rating of two
classes and affirmed two classes of J.P. Morgan Commercial
Mortgage Finance Corp., Mortgage Pass-Through Certificates, Series
1999-C8:

Cl, F, Upgraded to Aaa (sf); previously on Dec 17, 2010 Downgraded
to B1 (sf)

Cl. G, Upgraded to B1 (sf); previously on Dec 17, 2010 Downgraded
to Caa1 (sf)

Cl. X, Affirmed at Aaa (sf); previously on Aug 17, 1999 Definitive
Rating Assigned Aaa (sf)

Cl. H, Affirmed at C (sf); previously on May 12, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

The upgrades are due to increased credit support due to loan
payoffs and amortization. The pool has paid down by 44% since last
review. At last review Classes F and G were downgraded due to
interest shortfalls. These shortfalls have been paid back and
currently only Class J has interest shortfalls.

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
1.4% of the current balance compared to 29.8% at last review. The
variance from the prior review is largely attributed to
liquidations of specially serviced loans, which has resulted in
higher realized losses. Realized losses are currently $55.9
million compared to $45.5 million at last review. Moody's stressed
scenario loss is 13.0% 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 Conduit Transactions" published in September
2000.

Moody's also considered another methodology - "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 2.60 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 10 compared to 13 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 8.1 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 17, 2010.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 96% to $26.8
million from $731.5 million at securitization. The Certificates
are collateralized by 15 mortgage loans ranging in size from less
than 2% to 19% of the pool, with the top ten loans representing
87% of the pool. One loan, representing less than 2% of the pool,
has defeased and is secured by U.S. Government securities.

Four 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.

Nineteen loans have been liquidated from the pool, resulting in a
realized loss of $55.9 million (51% loss severity). Currently two
loans, representing 13% of the pool, are in special servicing. One
of the specially serviced loans was transferred to special
serviding due to maturity default but is performing and is
current. The borrower and special servicer are negotiating a one
year extension for this loan. The other specially serviced loan
transferred due to payment default but has repaid all outstanding
payments. the loan is performing and current and is expected to
return to the master servicer in September. Moody's does not
estimate any losses for the specially serviced loans at this time.

Moody's was provided with full year 2010 operating results for 83%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 59% compared to 57% 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 10.2%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.27X and 2.23X, respectively, compared to
1.33X and 2.08X 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 conduit loan is the Quail Park III Loan ($5.0 million
-- 18.6% of the pool), which is secured by a 71,296 square foot
office property located in Las Vegas, Nevada. As of December 2010
the property was 74% leased compared to 79% at last review. The
loan has amortized 21% since securitization. Moody's LTV and
stressed DSCR are 77% and 1.44X, respectively, the same as at last
review.


JPMORGAN CHASE: Fitch Downgrades Ratings on 3 Classes
-----------------------------------------------------
Fitch Ratings has downgraded three classes of J.P. Morgan Chase
Commercial Mortgage Securities Corp. 2001-CIBC3.

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 downgrades these classes and assigns Recovery Ratings (RRs):

   -- $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:

   -- $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.

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.


JPMORGAN CHASE: Fitch Places 5 Classes on Positive Watch
--------------------------------------------------------
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.

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.

Fitch affirms these classes, places classes on Rating Watch
Positive, and revises Recovery Ratings (RRs):

   -- $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'.

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 CHASE: S&P Lowers Rating on Class J Certificates to 'D'
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its rating to 'D (sf)'
from 'CCC- (sf)' on the class J commercial mortgage pass-through
certificates from JPMorgan Chase Commercial Mortgage Securities
Corp.'s series 2005-LDP3, a U.S. commercial mortgage-backed
securities (CMBS) transaction.

The downgrade follows a principal loss to the class J
certificates, which the July 15, 2011, trustee remittance report
detailed. Class J experienced a 0.61% loss of its $10.1 million
original certificate balance. The class K, L, and M certificates,
which Standard & Poor's previously lowered to 'D (sf)', have
lost 100% of their respective opening balances.

According to the July 15, 2011, trustee remittance report,
the trust experienced a $1.3 million principal loss upon the
liquidation of the ProMed Center loan (which was secured by a
15,145-sq.-ft. office building in Longwood, Fla.), and a $0.8
million principal loss upon the liquidation of the Libby Aurora
MHC loan (which was secured by a 93-pad manufactured housing
complex in Bedford Heights, Ohio). The ProMed Center loan had a
beginning scheduled balance of $2.5 million and the Libby Aurora
MHC loan had a beginning scheduled balance of $1.0 million at the
time of liquidation.


KENNECOTT FUNDING: Moody's Upgrades Ratings of CLO Notes
--------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Kennecott Funding Ltd.:

US$100,000,000 Class A-1 Notes Due January 13, 2018, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$253,175,000 Class A-2A Notes Due January 13, 2018, Upgraded to
Aaa (sf); previously on June 22, 2011 Aa2 (sf) Placed Under Review
for Possible Upgrade;

US$13,325,000 Class A-2B Notes Due January 13, 2018, Upgraded to
Aa1 (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$30,000,000 Class B Notes Due January 13, 2018, Upgraded to Aa3
(sf); previously on June 22, 2011 A3 (sf) Placed Under Review for
Possible Upgrade;

US$35,000,000 Class C Notes Due January 13, 2018, Upgraded to Baa1
(sf); previously on June 22, 2011 Baa3 (sf) Placed Under Review
for Possible Upgrade;

US$23,000,000 Class D-1 Notes Due January 13, 2018, Upgraded to
Ba1 (sf); previously on June 22, 2011 Ba3 (sf) Placed Under Review
for Possible Upgrade;

US$7,000,000 Class D-2 Notes Due January 13, 2018, Upgraded to Ba1
(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.

The actions also reflect consideration of an increase in the
transaction's overcollateralization ratios since the rating action
in September 2009. Based on the latest trustee report dated July
1, 2011, the Class A/B, Class C, and Class D overcollateralization
ratios are reported at 129.13%, 118.66%, and 110.94%,
respectively, versus August 2009 levels of 122.78%, 112.82%, and
105.48%, 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 $523.6 million,
defaulted par of $4.9 million, a weighted average default
probability of 23% (implying a WARF of 3541), a weighted average
recovery rate upon default of 48%, and a diversity score of 50.
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.

Kennecott Funding 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.

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) 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.

3) Exposure to credit estimates: The deal is exposed to a number
   of securities whose default probabilities are assessed through
   credit estimates. In the event that Moody's is not provided the
   necessary information to update the credit estimates in a
   timely fashion, the transaction may be impacted by any default
   probability stresses Moody's may assume in lieu of updated
   credit estimates.


KNOWLEDGEFUNDING OHIO: Moody's Lowers Bond Ratings to 'Caa3'
------------------------------------------------------------
Moody's Investors Service downgraded six classes of senior tax-
exempt student loan-backed bonds issued by KnowledgeFunding Ohio,
Inc. under a Master Indenture established as of December 1st 2005.
The underlying collateral includes a pool of Federal Family
Education Loan Program (FFELP) student loans that are guaranteed
by the Department of Education.

RATINGS:

The complete actions are:

Issuer: KnowledgeFunding Ohio, Inc. (2005 Indenture):

2005A-1, Downgraded to Caa3; previously on July 9, 2010 Baa1 (sf)
Placed Under Review for Possible Downgrade

2005A-2, Downgraded to Caa3; previously on July 9, 2010 Baa1 (sf)
Placed Under Review for Possible Downgrade

2005A-3, Downgraded to Caa3; previously on July 9, 2010 Baa1 (sf)
Placed Under Review for Possible Downgrade

2006A-1, Downgraded to Caa3; previously on July 9, 2010 Baa1 (sf)
Placed Under Review for Possible Downgrade

2006A-2, Downgraded to Caa3; previously on July 9, 2010 Baa1 (sf)
Placed Under Review for Possible Downgrade

2006A-3, Downgraded to Caa3; previously on July 9, 2010 Baa1 (sf)
Placed Under Review for Possible Downgrade

RATINGS RATIONALE

The downgrades are caused by an erosion of excess spread due to
the failed auction rate market. Since the collapse of the auction
rate market in the beginning 2008, the coupon rates on these bonds
have been reset to a "failed-auction" rate, which increases (among
other things) if the ratings of the bonds fall below Baa. Because
Moody's is downgrading the bonds below the trigger levels, their
coupon rates increase to 265% times the higher of the after-tax
equivalent rate (defined as a product of (i) the financial
commercial paper rate, and (ii) one minus the corporate tax rate),
the BMA index, and 14%. The higher coupon rates will further erode
excess spread in the future, which will, in turn, have a
significant negative effect on the parity levels and expose the
deal to a default risk. Moody's expects the deal to continue
generating negative excess spread, which indicates that the
interest paid on the student loan collateral does not cover the
interest on the bonds plus the fees.

The current total parity (a ratio of total assets plus escrow fund
to total liabilities) has remained at approximately 97% over the
past year. Moody's expects the deal to continue experiencing
difficulty in building up parity due to the negative excess spread
discussed above.

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 uncertainty with
regard to excess spread are increased basis risk. Ratings on Class
A would not be upgraded if spread between LIBOR and the financial
CP is 10 bps lower, or downgraded if the spread is 10 bps higher.

To assess rating implications of the higher expected losses, each
individual transaction was run through a variety of stress
scenarios using the Structured Finance Workstation(R) (SFW), a
cash flow model developed by Moody's Wall Street Analytics.

In monitoring securitizations backed by student loans Moody's
evaluates operational and transaction governance risks introduced
by nonperformance of various transaction parties, in addition to
assessing liquidity and credit risks. The adherence of the
transaction parties to legal agreements governing securitization
transactions is the essential element of assuring that noteholders
receive the timely payments of interest and ultimate repayment of
their principal investments. Moody's monitors compliance with
covenants and other legal provisions of the transaction documents.

In addition, Moody's assesses both liquidity and credit risks of
the student loan transactions. The factors affecting liquidity and
credit performance of a transaction include defaults, guarantor
reject rates, voluntary prepayments, basis risk, borrower benefit
utilization, and the number of borrowers in non-repayment status,
such as deferment and forbearance. As a part of Moody's analysis,
Moody's examines historical FFELP static pool performance data. To
the extent that performance data is available from a specific
issuer, that information is used to arrive at Moody's cash flow
assumptions for that particular issuer. If an issuer's data are
either limited or unavailable, Moody's assumptions are based on
FFELP performance data received from other participants.

Historical interest rates and spreads are also analyzed to
evaluate the basis risk between the interest rate to which the
notes are indexed and the interest rate to which the FFELP loans
are indexed. This historical data is used to derive at expected,
or most likely, outcome for each variable. These expected
defaults, prepayments, interest rates, and other assumptions are
then stressed in accordance with the rating categories requested
by the issuer. Factors that influence the stress levels include
the availability of relevant issuer-specific performance data, the
seasoning of the loans, collateral concentrations (school types,
loan programs), the financial strength and stability of the
servicer, and the general economic environment.

These stressed assumptions are then incorporated into a cash flow
model that takes into account the FFELP loan characteristics as
well as structural (e.g., starting parity, cash flow waterfall,
bond tranching, etc.) and pricing features of the transaction. The
cash flow model outputs are analyzed to determine whether the
transaction as structured by the issuer has sufficient credit
protection to pay off the notes by their legal final maturity
dates. In certain circumstances where cash flow runs are not
available, Moody's relies on model results from similar
transactions. Moody's also analyzes the liquidity risk of the
transaction given that borrowers can be in non-repayment status
while in school, grace, deferment or forbearance status, and the
transaction can experience delays in default reimbursement and
other payments. Basis risk is the primary credit risk in FFELP
student loan ABS. Moody's Aaa stressed basis risk assumption
between LIBOR and the CP Rate is 25 basis points with certain
periods in which the spread increases to 150 basis points. This is
based on an analysis of historical spreads between the two
indices. For additional information, please see "Methodology
Update on Basis Risk in FFELP Student Loan-Backed Securitization,"
on moodys.com. Other methodologies and factors that may have been
considered in the process of rating this issue can also be found
in the Rating Methodologies sub-directory on Moody's website. In
addition, Moody's publishes a weekly summary of structured finance
credit, ratings and methodologies, available to all registered
users of Moody's website, at www.moodys.com/SFQuickCheck.

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 6 months.


LAGUNA ABS: S&P Lowers Ratings on 3 Classes of Notes to 'CC'
------------------------------------------------------------
The downgrades reflect Standard & Poor's opinion that the
transaction has insufficient collateral to return the rated
principal amount currently due on the class A1SB-1, A1SB-2,
and A1ST notes. As of Aug. 3, 2011, the transaction's A1SB-1,
A1SB-2, and A1ST notes had a total of $737.8 million in principal
outstanding, backed by approximately $726.3 million in outstanding
assets.

Rating Actions

Laguna ABS CDO Ltd.
                        Rating
Class              To           From
A1SB-1             CC (sf)      CCC- (sf)/Watch Neg
A1SB-2             CC (sf)      CCC- (sf)/Watch Neg
A1ST               CC (sf)      CCC- (sf)/Watch Neg

Other Ratings Outstanding

Laguna ABS CDO Ltd.
Class                 Rating
A1J                   CC (sf)
A2                    CC (sf)
A3                    CC (sf)
Preference shares     CC (sf)
Class I combo notes   CC (sf)
Class II combo notes  AA+ (sf)


LANDMARK V CDO: Moody's Raises Ratings of Class B-1L Notes to Ba1
-----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Landmark V CDO, Ltd.

US$23,000,000 Class A-2L Floating Rate Notes Due June 2017,
Upgraded to Aa1 (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

US$22,500,000 Class A-3L Floating Rate Notes Due June 2017,
Upgraded to A2 (sf); previously on June 22, 2011 Baa3 (sf) Placed
Under Review for Possible Upgrade;

US$18,000,000 Class B-1L Floating Rate Notes Due June 2017,
Upgraded to Ba1 (sf); previously on June 22, 2011 Ba3 (sf) Placed
Under Review for Possible Upgrade;

US$12,000,000 Class B-2L Floating Rate Notes Due June 2017
(current outstanding balance of $10,940,005.84), 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 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 credit improvement of
the underlying portfolio since the rating action in August 2009.
Based on the trustee report dated July 22, 2011 the weighted
average rating factor is 2688 compared to 2947 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 $326 million,
defaulted par of $11.9 million, a weighted average default
probability of 19.7% (implying a WARF of 2852), a weighted average
recovery rate upon default of 48.5%, 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.

Landmark V CDO, 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. Deleveraging: The main source of uncertainty in this
   transaction is the extent of deleveraging from unscheduled
   principal proceeds. Deleveraging may accelerate due to high
   prepayment levels in the loan market and/or collateral sales by
   the manager, which may have significant impact on the notes'
   ratings.

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

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


LANDMARK VIII: Moody's Upgrades Class D Notes Rating to 'Ba1'
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Landmark VIII CLO Ltd.

US$35,500,000 Class A-2 Senior Secured Floating Rate Notes Due
2020 Notes, Upgraded to Aaa (sf); previously on Jun 22, 2011 Aa1
(sf) Placed Under Review for Possible Upgrade

US$36,000,000 Class B Senior Secured Floating Rate Notes Due 2020
Notes, Upgraded to Aa1 (sf); previously on Jun 22, 2011 Aa3 (sf)
Placed Under Review for Possible Upgrade

US$34,000,000 Class C Secured Deferrable Floating Rate Notes Due
2020 Notes, Upgraded to A3 (sf); previously on Jun 22, 2011 Baa3
(sf) Placed Under Review for Possible Upgrade

US$26,000,000 Class D Secured Deferrable Floating Rate Notes Due
2020 Notes, Upgraded to Ba1 (sf); previously on Jun 22, 2011 Ba3
(sf) Placed Under Review for Possible Upgrade

US$8,000,000 Composite Obligations Due 2020 Notes, Upgraded to
Baa3 (sf); previously on Jun 22, 2011 B1 (sf) Placed Under Review
for Possible Upgrade

US$20,000,000 Class E Secured Deferrable Floating Rate Notes Due
2020 Notes, Upgraded to Ba3 (sf); previously on Jun 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 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 latest trustee report dated July
8, 2011 the weighted average rating factor is currently 2700
compared to 3061 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 126.73%, 116.30%,
109.41 and 104.64%, respectively, versus July 2009 levels of
119.95%, 110.2%, 103.76% and 99.24%, 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 $482.5 million,
defaulted par of $ 9.8million, a weighted average default
probability of 23.24% (implying a WARF of 2992, a weighted average
recovery rate upon default of 21.91%, and a diversity score of 90.
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 VIII CLO Ltd., 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.

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) 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.

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.

4) 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/diversity levels higher than
   the covenant levels due to the large difference between the
   reported and covenant levels.


LB-UBS COMMERCIAL: Fitch Takes Various Rating Actions
-----------------------------------------------------
Fitch Ratings has downgraded three classes and upgraded two
classes of LB-UBS Commercial Mortgage, series 2002-C4, commercial
mortgage pass-through certificates.

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 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'.

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.


LB-UBS COMMERCIAL: Moody's Affirms Class J Notes Rating at 'Caa2'
-----------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 19
classes of LB-UBS Commercial Mortgage Pass-Through Certificates,
Series 2004-C4:

Cl. A-3, Affirmed at Aaa (sf); previously on Jun 11, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Jun 11, 2004
Definitive Rating Assigned Aaa (sf)

Cl. A-1b, Affirmed at Aaa (sf); previously on Jun 11, 2004
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Dec 10, 2010 Confirmed
at Aaa (sf)

Cl. C, Affirmed at Aa1 (sf); previously on Dec 10, 2010 Confirmed
at Aa1 (sf)

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

Cl. D, Affirmed at Aa2 (sf); previously on Dec 10, 2010 Confirmed
at Aa2 (sf)

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

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

Cl. H, Affirmed at Ba2 (sf); previously on Dec 10, 2010 Downgraded
to Ba2 (sf)

Cl. J, Affirmed at Caa2 (sf); previously on Dec 10, 2010
Downgraded to Caa2 (sf)

Cl. K, Affirmed at Ca (sf); previously on Dec 10, 2010 Downgraded
to Ca (sf)

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

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

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

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

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

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

Cl. X, Affirmed at Aaa (sf); previously on Jun 11, 2004 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
4.9% of the current balance. At last review, Moody's cumulative
base expected loss was 4.4%. 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 "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 Large Loan/Single Borrower Transactions",
published in July 2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.60 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 7 compared to 8 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 8.1 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 10, 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 42% to $815.7
million from $1.4 billion at securitization. The Certificates are
collateralized by 77 mortgage loans ranging in size from less than
1% to 32% of the pool, with the top ten loans representing 58% of
the pool. The pool contains two loans with investment grade credit
estimates that represent 52% of the pool. Seven loans,
representing 6% of the pool, have defeased and are collateralized
with U.S. Government securities.

Fifteen loans, representing 27% 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, resulting in an
aggregate realized loss of $8.1 million (14% loss severity
overall). Two loans, representing 5% of the pool, are currently in
special servicing. The master servicer has recognized an aggregate
$20.8 million appraisal reduction for the specially serviced
loans. Moody's has estimated an aggregate $21.4 million loss (57%
expected loss on average) for the specially serviced loans.

Moody's has assumed a high default probability for 12 poorly
performing loans representing 11% of the pool and has estimated a
$13.9 million aggregate loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full and partial year 2010 and partial
year 2011 operating results for 87% and 29% of the pool's non-
defeased loans, respectively. Excluding specially serviced and
troubled loans, Moody's weighted average LTV is 84% compared to
88% 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 9.4%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.33X and 1.24X, respectively, compared to
1.52X and 1.21X 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 Westfield
Shoppingtown Garden State Plaza Loan ($260 million -- 31.9% of the
pool), which represents a 50% pari-passu interest in a first
mortgage loan. The loan is secured by the borrower's interest in
an enclosed 2.0 million square foot (SF) super-regional shopping
mall located in Paramus, New Jersey. The mall is anchored by
Macy's, Nordstrom, J.C. Penney, Neiman Marcus and Lord & Taylor.
As of December 2010, the property was 98% leased compared to 99%
as of December 2009 and December 2008. Westfield is the loan
sponsor. The loan is interest-only for its entire 10-year term.
Moody's current credit estimate and stressed DSCR are A1 and
1.52X, respectively, compared to A1 and 1.47X at last review.

The second loan with a credit estimate is the Town East Mall
Loan ($99.1 million -- 12.2% of the pool) which is secured by a
1.2 million SF regional shopping mall located in Mesquite, Texas.
The mall is anchored by Macy's, Sears, Dillard's and J.C. Penney.
Property performance is stable. As of March 2011, the property was
97% leased compared to 98% as of December 2009 and December 2008.
GGP is the loan sponsor. Moody's current credit estimate and
stressed DSCR are Baa2 and 1.52X, respectively, compared to Baa2
and 1.59X at last review.

The top three performing conduit loans represent 7% of the pool
balance. The largest loan is the Park Parthenia Apartments Loan
($21.7 million -- 2.7% of the pool), which is secured by a 399-
unit apartment property in Northridge, California. The property's
financial performance has improved due to an increase in revenues.
As of March 2011, the property was 92% leased compared to the same
level as of December 2010 and 95% as of December 2009. Moody's LTV
and stressed DSCR are 87% and 1.09X, respectively, essentially the
same at last review.

The second largest loan is the Sirata Beach Resort and Conference
Center Loan ($21.4 million -- 2.6% of the pool), which is secured
by a 380-room hotel and conference center in St. Pete Beach,
Florida. Property performance has declined since the last review
due to a decline in occupancy and the average daily rate.
Occupancy for the trailing twelve months ending December 2010 was
66% compared to 71% in December 2009. Moody's LTV and stressed
DSCR are 84% and 1.48X, respectively, compared to 63% and 1.98X at
last review.

The third largest loan is the 325-329 North Rodeo Drive Loan
($14.9 million -- 1.8% of the pool), which is secured by a 7,100
square foot upscale retail property located in a prominent retail
corridor of Beverly Hills, California. Property performance has
improved due to an increase in effective gross income. As of March
2011, the property was 100% leased to Coach, Inc. (62% of the NRA;
lease expiration in March 2015) and The Swatch Group (38% of the
NRA; lease expiration in March 2015). Moody's LTV and stressed
DSCR are 95% and 1.03X, respectively, compared to 98% and 0.99X at
last review.


LCM IX: S&P Gives 'BB' Rating on Class E Deferrable Notes
---------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on LCM IX
L.P./LCM IX LLC's $602.75 million floating-rate notes following
the transaction's effective date as of July 15, 2011.

Most U.S. cash flow collateralized loan obligations (CLOs) close
before purchasing the full amount of their targeted level of
portfolio collateral.

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

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

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

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

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

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

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

Ratings Affirmed
LCM IX L.P./LCM IX LLC

Class                Rating      Amount (mil. $)
A                    AAA (sf)             429.00
B                    AA (sf)               61.75
C (deferrable)       A (sf)                53.50
D (deferrable)       BBB (sf)              32.50
E (deferrable)       BB (sf)               26.00
Subordinated         NR                    63.50

NR -- Not rated.


LNR CDO: Fitch Withdraw 'Dsf' Rating on 10 Note Classes
-------------------------------------------------------
Fitch Ratings has downgraded 10 classes to 'Dsf' and withdrawn the
ratings on the notes issued by LNR CDO 2007-2, Ltd./LLC (VI).

On Dec. 2, 2010, the trustee notified noteholders of an event of
default (EOD) due to the failure to pay the full and timely
interest on the class B notes.  On June 28, 2011, the controlling
party declared all notes due and payable.  On August 3, 2011 all
liquidation proceeds were distributed according to the transaction
documents.

The class A-1 notes received 100% of their outstanding balance and
the class B notes received 99% of their outstanding balance. The
remaining classes have been completely written off due to
insufficient liquidation proceeds.

Fitch has taken the following actions:

  -- $0 class A-1 marked 'PIF';
  -- $0 class B downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class C downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class D downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class E downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class F downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class G downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class H downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class J downgraded to 'Dsf' from 'Csf' and withdrawn;
  -- $0 class K Preferred Shares downgraded to 'Dsf' from 'Csf'
        and withdrawn;
  -- $0 class L Preferred Shares downgraded to 'Dsf' from 'Csf'
        and withdrawn.


LNR CDO: S&P Lowers Ratings on 9 Classes to 'D' Foll. Liquidation
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings to 'D (sf)'
on nine classes from LNR CDO VI Ltd., a commercial real estate
collateralized debt obligation (CRE CDO) transaction, following
the liquidation of the underlying commercial mortgage-backed
securities (CMBS) collateral. "We subsequently withdrew our
ratings on all outstanding classes," S&P said.

The transaction experienced an event of default (EOD) prior to the
rating actions, and the controlling noteholders subsequently voted
to accelerate the maturity of the notes and liquidate the
collateral.

The downgrades follow notice from the trustee that the liquidation
of the portfolio assets is complete and resulted in nonpayment of
principal to classes C through L. "We previously lowered our
rating on the nondeferrable class B notes to 'D (sf)'," S&P
related.

The withdrawal of the ratings on the class A-1 and A-2 notes
reflect the successful credit bid for the portfolio collateral by
the noteholders, which reduced the principal balance to zero. The
withdrawal of the ratings on classes B through L reflects the
write-down of the principal balances to zero.

Standard & Poor's analyzed the transaction in accordance with its
current criteria. "Our analysis is consistent with the lowered and
withdrawn ratings," S&P said.

Ratings Lowered And Withdrawn

LNR CDO VI Ltd.
                   Rating
Class     To       Interim     From
C         NR       D (sf)      CC (sf)
D         NR       D (sf)      CC (sf)
E         NR       D (sf)      CC (sf)
F         NR       D (sf)      CC (sf)
G         NR       D (sf)      CC (sf)
H         NR       D (sf)      CC (sf)
J         NR       D (sf)      CC (sf)
K         NR       D (sf)      CC (sf)
L         NR       D (sf)      CC (sf)

Ratings Withdrawn

LNR CDO VI Ltd.
               Rating
Class     To             From
A1        NR             CCC- (sf)
A2        NR             CCC- (sf)
B         NR             D (sf)

NR -- not rated.


MADISON PARK: Moody's Upgrades Ratings of 8 Classes of CLO Notes
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Madison Park Funding II, Ltd.:

US$509,750,000 Class A-1 Floating Rate Notes Due 2020 (current
outstanding balance of $502,457,224), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$11,250,000 Class A-2b Floating Rate Notes Due 2020, Upgraded to
Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed Under Review
for Possible Upgrade;

US$38,000,000 Class A-3 Floating Rate Notes Due 2020, Upgraded to
Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed Under Review
for Possible Upgrade;

US$25,000,000 Class B-1 Deferrable Floating Rate Notes Due 2020,
Upgraded to Baa2 (sf); previously on June 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$25, 000,000 Class B-2 Deferrable Fixed Rate Notes Due 2020,
Upgraded to Baa2 (sf); previously on June 22, 2011 Ba1 (sf) Placed
Under Review for Possible Upgrade;

US$25,000,000 Class C-1 Deferrable Floating Rate Notes Due 2020,
Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

US$5,000,000 Class C-2 Deferrable Fixed Rate Notes Due 2020,
Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf) Placed
Under Review for Possible Upgrade;

US$22,500,000 Class D Deferrable Floating Rate Notes Due 2020,
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 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 July 2009.
Based on the July 2011 trustee report, the weighted average rating
factor is currently 2691 compared to 2929 in June 2009.

The overcollateralization ratios of the rated notes have also
improved since the rating action in July 2009. The Class A, Class
B, Class C and Class D overcollateralization ratios are reported
125.62%, 116.65%, 111.86% and 108.51%, respectively, versus June
2009 levels of 116.18%, 107.19%, 103.52% and 100.97%,
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 $815 million,
defaulted par of $6 million, a weighted average default
probability of 20.73% (implying a WARF of 2836), a weighted
average recovery rate upon default of 47.44%, and a diversity
score of 90. 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.

Madison Park Funding II, Ltd., issued in February 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) 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.


MADISON PARK: S&P Affirms 'BB' Rating on Class E Deferrable Notes
-----------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on
Madison Park Funding VII Ltd./Madison Park Funding VII LLC's
$368.5 million floating-rate notes following the transaction's
effective date as of June 30, 2011.

Most U.S. cash flow collateralized loan obligations (CLOs) close
before purchasing the full amount of their targeted level of
portfolio collateral.

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

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

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

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

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

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

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

Ratings Affirmed
Madison Park Funding VII Ltd./Madison Park Funding VII LLC

Class                Rating      Amount (mil. $)
A                    AAA (sf)             255.00
B                    AA (sf)               37.50
C (deferrable)       A (sf)                36.00
D (deferrable)       BBB (sf)              22.00
E (deferrable)       BB (sf)               18.00
Subordinated         NR                    41.50

NR -- Not rated.


MARATHON REAL: Fitch Affirms Junk Ratings on Four Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed all classes of Marathon Real Estate CDO
2006-1, Ltd./LLC (Marathon 2006-1) reflecting Fitch's base case
loss expectation of 26.8%, which is slightly improved from 30.9%
at last review.  Fitch's performance expectation incorporates
prospective views regarding commercial real estate market value
and cash flow declines.

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

  -- $518,080,048 class A-1 at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $50,000,000 class A-2 at 'BBBsf'; Outlook to Stable from
     Negative;
  -- $99,000,000 class B at 'BBsf'; Outlook Negative;
  -- $51,500,000 class C at 'Bsf'; Outlook Negative;
  -- $16,000,000 class D at 'Bsf'; Outlook Negative;
  -- $14,000,000 class E at 'Bsf'; Outlook Negative;
  -- $23,500,000 class F at 'CCCsf/RR5';
  -- $15,500,000 class G at 'CCCsf/RR6';
  -- $26,000,000 class H at 'CCCsf/RR6';
  -- $56,300,000 class J at 'CCCsf/RR6';
  -- $26,700,000 class K at 'CCCsf/RR6'.

The CDO exited its reinvestment period in May 2011.  Prior to that
date, the asset manager made significant changes to the pool
composition, with approximately 45 assets removed from the pool,
and a large addition of rated securities, which increased the
securities component of the pool to 39.9% from 24.8%.  Of the
collateral removed from the pool, losses to par exceeded $100
million.

The transaction is collateralized by both senior and subordinate
commercial real estate (CRE) debt: 42% are either whole loans or
A-notes, 17.8% are either B-notes or mezzanine loans, and as
mentioned, approximately 40% are rated securities.  Since last
review, the average Fitch derived rating for the underlying CMBS
collateral improved slightly to 'BB+/BB' from 'BB-'.  Furthermore,
four loans (5.2%) are currently defaulted while two loans (9.5%)
are considered Fitch Loans of Concern. Fitch expects significant
losses on the delinquent assets and Loans of Concern.

Under Fitch's updated methodology, approximately 45% of the
portfolio is modeled to default in the base case stress scenario,
defined as the 'B' stress. In this scenario, the modeled average
cash flow decline is 7.8% from the most recent available cash
flows (generally year-end 2010).  Fitch estimates that recoveries
will average 40.5% in the base case.

The largest component of Fitch's base case loss expectation is a
whole loan (6.1%) secured by a 363-key limited service hotel
located on Manhattan's Upper West Side.  The sponsor has been
converting the property's single-occupancy rooms into traditional
rooms on an ongoing basis, and further planned an extensive
property improvement plan in order to convert the hotel into a
full-service hotel to be operated under a major flag.  The
renovations fell behind schedule during the recession, and the
property continues to struggle, with cash flow declining an
additional 30% from 2009 to 2010.

The next largest component of Fitch's base case loss expectation
is a B-note secured by a 190-key hotel in Boston, MA, located
between Boston's Financial District and the Beacon Hill/Back Bay
areas.  The property experienced a significant decline in cash
flow through the recession. Performance has since improved, but
remains below expectations from issuance.  The loan was recently
modified, which included an extension to May 2014, and a borrower
contribution of equity, which delevered the A-note slightly.  The
special servicer will continue to monitor the progress of the
asset.

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 E 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. T he Rating Outlooks for classes A-1 and A-2 are
revised to Stable from Negative reflecting the slight improvement
in modeled expected losses and the senior position of the classes
within the capital structure, which will continue to pay down as
assets payoff going forward.

The 'CCC' and below ratings for classes F 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.


MAXIM HIGH: Fitch Withdraws 'Dsf' Rating on 10 Note Classes
-----------------------------------------------------------
Fitch Ratings has affirmed seven, downgraded three, and
subsequently withdrawn the ratings on all classes of notes issued
by Maxim High Grade CDO I, Ltd. (Maxim HG I) as follows:

  -- $858,225,336 class A-1 notes affirmed at 'Dsf' and withdrawn;
  -- $249,928,543 class A-2 notes affirmed at 'Dsf' and withdrawn;
  -- $249,928,543 class A-3 notes affirmed at 'Dsf' and withdrawn;
  -- $99,971,417 class A-4 notes affirmed at 'Dsf' and withdrawn;
  -- $99,971,417 class A-5notes affirmed at 'Dsf' and withdrawn;
  -- $33,990,282 class B notes affirmed at 'Dsf' and withdrawn;
  -- $20,380,676 class C notes affirmed at 'Dsf' and withdrawn;
  -- $15,739,001 class D notes downgraded to 'Dsf' from 'Csf' and
     withdrawn;
  -- $23,763,040 class E-1 notes downgraded to 'Dsf' from 'Csf'
     and withdrawn;
  -- $1,938,096 class E-2 notes downgraded to 'Dsf' from 'Csf' and
     withdrawn.

Maxim HG I entered an event of default in April 2008 and its
maturity was accelerated in December 2008.  On June 2, 2011, the
trustee was directed by the hedge counterparty and the requisite
majority of the aggregate outstanding amount of each class to
liquidate the portfolio.

The final distribution occurred on Aug. 5, 2011.  The trustee
reports showed that the proceeds available for distribution were
enough to pay accrued and defaulted interest to the class A-4
through class C notes and a portion of the outstanding class A-1
note balance.  None of the notes were paid in full.

Maxim HG I was a static cash flow structured finance (SF)
collateralized debt obligation (CDO) invested in residential
mortgage-backed securities and SF CDOs.


MERCATOR CLO: Moody's Upgrades Ratings of EUR277.9-Mil. CLO Notes
-----------------------------------------------------------------
Moody's Investors Service said that Knology, Inc.'s announced
authorization of a repurchase program of 2,000,000 shares of the
company's common stock will have no impact on the company's
ratings, including the company's B1 Corporate Family Rating, B2
Probability of Default Rating, B1 senior secured bank debt ratings
and SGL-2 Speculative Grade Liquidity Rating. The rating outlook
remains stable. Moody's expects that the company will fund the
share repurchase with available cash on hand and free cash flow.

The principal methodology used in rating Knology was Moody's
Global Cable Television Industry Methodology, published in July
2009 and available on www.moodys.com in the Rating Methodologies
sub-directory under the Research & Ratings tab. Other
methodologies and factors that may have been considered in the
process of rating this issuer can also be found in the Rating
Methodologies sub-directory on Moody's website.

Headquartered in West Point, Georgia, Knology, Inc. is principally
an "overbuild" provider of video, high speed data and telephony
services primarily in the Southeast and portions of the Midwest.
The company generated revenue of approximately $496 million for
the twelve month period ended June 2011.


MERRILL LYNCH: Moody's Affirms Cl. F Notes Rating at 'Ba2'
----------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 29
classes of Merrill Lynch Mortgage Trust Commercial Mortgage Pass-
Through Certificates, Series 2008-C1:

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

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

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

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

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

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

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

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

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

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

Cl. AJ-AF, Affirmed at A2 (sf); previously on Nov 18, 2010
Downgraded to A2 (sf)

Cl. AJ, Affirmed at A2 (sf); previously on Nov 18, 2010 Downgraded
to A2 (sf)

Cl. AJ-A, Affirmed at A2 (sf); previously on Nov 18, 2010
Downgraded to A2 (sf)

Cl. B, Affirmed at A3 (sf); previously on Nov 18, 2010 Downgraded
to A3 (sf)

Cl. C, Affirmed at Baa1 (sf); previously on Nov 18, 2010
Downgraded to Baa1 (sf)

Cl. D, Affirmed at Baa2 (sf); previously on Nov 18, 2010
Downgraded to Baa2 (sf)

Cl. E, Affirmed at Baa3 (sf); previously on Nov 18, 2010
Downgraded to Baa3 (sf)

Cl. F, Affirmed at Ba2 (sf); previously on Nov 18, 2010 Downgraded
to Ba2 (sf)

Cl. G, Affirmed at Ba3 (sf); previously on Nov 18, 2010 Downgraded
to Ba3 (sf)

Cl. H, Affirmed at B2 (sf); previously on Nov 18, 2010 Downgraded
to B2 (sf)

Cl. J, Affirmed at B3 (sf); previously on Nov 18, 2010 Downgraded
to B3 (sf)

Cl. K, Affirmed at Caa2 (sf); previously on Nov 18, 2010
Downgraded to Caa2 (sf)

Cl. L, Affirmed at Caa3 (sf); previously on Nov 18, 2010
Downgraded to Caa3 (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. P, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (sf)

Cl. Q, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (sf)

Cl. S, Affirmed at C (sf); previously on Nov 18, 2010 Downgraded
to C (sf)

Cl. X, Affirmed at Aaa (sf); previously on Mar 9, 2011 Confirmed
at 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
6.6% of the current balance compared to 6.1% at last review.
Moody's stressed scenario loss is 16.6% 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 was CMBS" Moody's Approach to Rating
U.S. CMBS Conduit Transaction" 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 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 20 compared to 21 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 18, 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 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by less than 3% to
$922.5 million from $948.8 million at securitization. The
Certificates are collateralized by 90 mortgage loans ranging in
size from less than 1% to 16% of the pool, with the top ten loans
representing 53% of the pool. The pool does not contain any
defeased loans or loans with credit estimates.

Moody's was provided with full year 2009 and full year 2010
operating results for 94% and 93% of the performing pool,
respectively. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 105% compared to 111% at last
review. Moody's net cash flow reflects a weighted average haircut
of 14% to the most recently available net operating income.
Moody's value reflects a weighted average capitalization rate of
9.78%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.38X and 1.05X, respectively, compared to
1.31X and 0.99X 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.

Twenty-five 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.

Seven loans, representing 21% of the pool, are currently in
special servicing. The largest specially serviced loan is the
Farallon Portfolio Loan ($149.8 million -- 16.2% of the pool),
which is secured by 273 cross-collateralized and cross-defaulted
mobile home communities located throughout 23 states. The loan
represents a 16.5% pari-passu interest in a $909.8 million loan.
There is subordinate debt of approximately $575 million held
outside the trust. The loan was transferred to special servicing
in June 2010 for imminent default due to the scheduled August 2010
maturity of the floating-rate portion of the debt, which is held
outside the trust in BALL 2007-BMB. A loan modification was
completed in April 2011; the maturities on the floating-rate and
fixed-rate portions of the loan were extended to August 2015 and a
2-year extension option was granted. Other key modification terms
include capture of all excess cash above debt-service on a
quarterly basis and the remittance of net proceeds from home and
note sales to the lender. The loan remains current and Moody's
does not estimate any losses at the moment. Moody's LTV and
stressed DSCR are 76% and l.32X, respectively.

The remaining six specially serviced loans are secured by a mix of
property types. The Master Servicer has recognized an aggregate
$14.4 million in appraisal reductions for these loans. Moody's has
estimated $19.8 million loss (50% expected loss on average) for
these six loans.

Moody's has assumed a high default probability for 16 poorly
performing loans representing 13% of the pool and has estimated an
aggregate $22.8 million loss (20% expected loss based on a 50%
probability of default) from these troubled loans.

Based on the most recent remittance statement, Classes K through
T have experienced cumulative interest shortfalls totaling
$1.78 million. At last review, interest shortfalls totaled
$934,000 million and affected Class T. 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),
modifications and extraordinary trust expenses.

The top three conduit loans represent 20% of the pool balance. The
largest loan is the Arundel Mills Loan ($63.5 million -- 6.9% of
the pool), which is secured by a 1.3 million square foot retail
center located in Hanover, Maryland. The loan represents a 16.7%
pari-passu interest in a $381.1 million loan. As of December 2010,
the in-line mall space was 95% leased compared to 98% at
securitization. In-line sales for comparable stores less than
10,000 square feet were $351 in 2010 compared to $348 in 2009. Net
operating income (NOI) increased by 3% in 2010. The sponsors are
Simon Property Group and Farallon Capital. Moody's LTV and
stressed DSCR are 117% and 0.84X, respectively, compared to 123%
and 0.79X at last review.

The second largest loan is the Apple Hotel Portfolio Loan
($63.1 million -- 6.8% of the pool), which is secured by a
portfolio of 27 limited service and extended stay hotels located
across 14 states. The loan represents a 18.3% pari-passu interest
in a $344.8 million loan. Performance has improved since last
review due to an approximate 4% increase in NOI. In 2010, the
pool's revenue per available room (RevPAR) was $75.29 compared to
$73.83 at last review. The loan is on the watchlist due to net
cash flow DSCR dropping below a 1.4X threshold; however, in 2010
the DSCR improved to 1.30X from 1.24X in 2009. Moody's LTV and
stressed DSCR are 130% and 0.93X, respectively, compared to 135%
and 0.90X at last review.

The third largest loan is the Fort Office Portfolio Loan
($49.8 million -- 5.4% of the pool), which is secured by three
office buildings, totaling 341,000 square feet, located in
Arizona, Texas and Nebraska. In 2010, the portfolio's occupancy as
97% compared to 100% at securitization. The largest tenant is
ConAgra Foods, which leases 26% of the net rentable area through
2016. In 2010, NOI increased by 4% due to rent escalations and the
renewal of the Global Crossing lease. Moody's LTV and stressed
DSCR are 117% and 0.90X, respectively, compared to 122% and 0.87X
at last review.


MERRILL LYNCH: Moody's Affirms Ratings of Six CMBS Classes
----------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of four
classes and affirmed the ratings of six classes of Merrill Lynch
Financial Assets, Inc., Commercial Mortgage Pass-Through
Certificates, Series 2001-Canada 6:

Cl. A-2, Affirmed at Aaa (sf); previously on Mar 14, 2002
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on Aug 23, 2006 Upgraded
to Aaa (sf)

Cl. C, Affirmed at Aaa (sf); previously on Dec 17, 2010 Upgraded
to Aaa (sf)

Cl. D, Upgraded to Aa2 (sf); previously on Dec 17, 2010 Upgraded
to A2 (sf)

Cl. E, Upgraded to A1 (sf); previously on Dec 17, 2010 Upgraded to
A3 (sf)

Cl. F, Upgraded to Baa3 (sf); previously on Mar 14, 2002
Definitive Rating Assigned Ba2 (sf)

Cl. G, Upgraded to Ba2 (sf); previously on Mar 14, 2002 Definitive
Rating Assigned Ba3 (sf)

Cl. H, Affirmed at B2 (sf); previously on Mar 14, 2002 Definitive
Rating Assigned B2 (sf)

Cl. J, Affirmed at B3 (sf); previously on Mar 14, 2002 Definitive
Rating Assigned B3 (sf)

Cl. X, Affirmed at Aaa (sf); previously on Mar 14, 2002 Definitive
Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrades are due to overall improved pool financial
performance and increased credit support due to expected loan
payoffs and amortization.

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
2% of the current balance. At last review, Moody's cumulative base
expected loss was 1.6%. Moody's stressed scenario loss is 7.5% 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.

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 performance in the commercial real
estate property markets. While commercial real estate property
markets are gaining momentum, a consistent upward trend will not
be evident until the volume of transactions increases, distressed
properties are cleared from the pipeline and job creation
rebounds. The hotel and multifamily sectors are continuing to show
signs of recovery through the first half of 2011, while recovery
in the non-core office and retail sectors are tied to pace of
recovery of the broader economy. Core office markets are showing
signs of recovery through lending and leasing activity. 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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

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

Other methodologies used in this rating were: "Moody's Approach to
Rating Large Loan/Single Borrower Transactions" published in July
2000 and "Moody's Approach to Rating Canadian CMBS" published in
May 2000.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.60 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 8 compared to 11 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 8.1 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 17, 2010.

DEAL PERFORMANCE

As of the August 12, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 63% to
$98.9 million from $265.5 million at securitization. The
Certificates are collateralized by 16 mortgage loans ranging
in size from less than 1% to 23% of the pool, with the top ten
non-defeased loans representing 87% of the pool. Two loans,
representing 6% of the pool, have defeased and are secured by
Canadian Government securities.

Six 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) 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.

There are currently no loans in special servicing, and there are
no realized losses. Twelve loans, representing 83% of the pool are
expected to mature within six months. Of these 12 loans, one loan
representing 1% of the pool fails Moody's refinance test. Loans
that fail this test have a DSCR that falls below the threshold of
1.0X, using a stressed interest rate of 9.25%.

Moody's was provided with full year 2010 operating results for 61%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 64% compared to 66% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 11.4% 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 1.53X and 1.85X, respectively, compared to
1.49X 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 top three conduit loans represent 47% of the pool. The largest
loan is the Westbridge Shopping Center Loan ($22.4 million -- 23%
of the pool), which is secured by a 213,000 square foot retail
center located in Vaughan, Ontario, approximately 20 miles north
of Toronto. Currently, the center's largest tenants are Toys 'R'
Us (14% of the net rentable area (NRA); lease expiration November
2014) and Mark's Work Warehouse (6% of the NRA; lease expiration
March 2011). Linens 'N Things, which was the center's largest
tenant at securitization (17% of the NRA), vacated its space in
early 2009. As of December 2010, the property was 80% leased. The
loan matures in November 2011. Moody's LTV and stressed DSCR are
84% and 1.22X, respectively, compared to 89% and 1.15X at last
review.

The second largest loan is the Chateau Janville Loan
($12.0 million -- 12% of the pool), which is secured by a 271-unit
apartment complex located in Ottawa, Ontario. As of January 2011,
the property was 98% leased, essentially the same as at last
review. Moody's LTV ratio and stressed DSCR are 86% and 1.06X,
respectively, compared to 79% and 1.16X at last review.

The third largest loan is the Zellers Centre Bridgeport Loan
($11.7 million -- 12% of the pool), which is secured by a 211,100
square foot retail center located in Waterloo, Ontario. The center
is anchored by Zellers (50% of the NRA; lease expiration September
2018) and Sobeys (23% of the NRA; lease expiration July 2018). As
of December 2010, the property was 100% leased, essentially the
same as at last review. Moody's LTV and stressed DSCR are 54% and
2.02X, respectively, compared to 55% and 1.96X at last review.


MM COMMUNITY: Moody's Lowers Rating of Class A-2 Notes to 'Ba1'
---------------------------------------------------------------
Moody's Investors Service has downgraded the ratings on these
three notes issued by MM Community Funding IX, Ltd.

US$45,000,000 Class A-2 Floating Rate Senior Notes due 2033,
Downgraded to Ba1 (sf); previously on August 18, 2009 Downgraded
to Baa3 (sf);

US$50,000,000 Class B-1 Floating Rate Senior Subordinate Notes due
2033, Downgraded to Ca (sf); previously on March 27, 2009

Downgraded to Caa3 (sf);

US$60,000,000 Class B-2 Fixed/Floating Rate Senior Subordinate
Notes due 2033, Downgraded to Ca (sf); previously on March 27,
2009 Downgraded to Caa3 (sf).

RATINGS RATIONALE

According to Moody's, the rating downgrade actions taken are
primarily the result of the declaration of an Event of Default
(EOD) on August 8, 2011, and the increase in the assumed defaulted
amount in the underlying portfolio. The EOD was triggered as a
result of a default in the payment of interest due on the Class B-
1 Notes and the Class B-2 Notes. The assumed defaulted amount
increased by $73.8 million since the last rating action in August
2009. Assumed defaults now total $121.25 million (50.7% of the
current portfolio). The credit metrics of the remaining portfolio
have shown a slight improvement due to the removal of the assumed
defaulted assets from the collateral pool, as indicated by a
weighted average weighting factor (WARF) decrease to 1327, from
1608, as of the last rating action date.

The par loss due to the increase in the assumed defaulted amount
has resulted in loss of overcollateralization for the tranches
affected and an increase of their expected losses since the last
rating action. As of the latest trustee report dated June 26,
2011, the Senior Principal Coverage Test is at 110.74% (limit
125.00%), and the Senior Subordinate Principal Coverage Test is at
55.85% (limit 104.85%), versus trustee reported levels from the
report dated April 27, 2009 of 157.56% and 81.61% respectively,
which were used during the last rating action.

MM Community Funding IX, Ltd., issued on April 10, 2003, is a
collateral debt obligation backed by a portfolio of bank trust
preferred securities (the 'TRUP CDO'). On August 18, 2009, the
last rating action date, Moody's downgraded two classes of notes
as a result of the deterioration in the credit quality of the
transaction's underlying portfolio.

The credit deterioration exhibited by the TRUP CDO portfolio is a
reflection of the continued pressure in the banking sector. In
Moody's opinion, the banking sector outlook continues to remain
negative although there have been some recent signs of
stabilization. The pace of bank failures in 2011 has declined
compared to 2009 and 2010, and a handful of previously deferring
banks have resumed interest payment on their trust preferred
securities.

The portfolio of this CDO is mainly composed of trust preferred
securities issued by small to medium sized U.S. community banks
that are generally not publicly rated by Moody's. To evaluate
their credit quality, Moody's uses RiskCalc model, an econometric
model developed by Moody's KMV, to derive credit scores for these
non-publicly rated bank trust preferred securities. Moody's
evaluation of the credit risk for a majority of bank obligors in
the pool relies on FDIC financial data received as of Q1-2011.
Moody's also evaluates the sensitivity of the rated transactions
to the volatility of the credit estimates, as described in Moody's
Rating Implementation Guidance "Updated Approach to the Usage of
Credit Estimates in Rated Transactions," October 2009.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations. Moody's considers as well the structural
protections in each transaction, the impact of the declaration of
the Event of Default and the potential post-EOD cure, the recent
deal performance in the current market conditions, 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 rating MM Community Funding IX,
Ltd. was "Moody's Approach to Rating TRUP CDOs" published in May
2011.

Due to the impact of revised and updated key assumptions
referenced in these rating methodologies, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers. The
transaction's portfolio was modeled, according to Moody's rating
approach, using CDOROM v.2.8 to develop the default distribution
from which the Moody's Asset Correlation parameter was obtained.
This parameter was then used as an input in a cash flow model
using CDOEdge. CDOROM v.2.8 is available on moodys.com under
Products and Solutions -- Analytical models, upon return of a
signed free license agreement.


MONTANA HIGHER: Fitch Affirms 'B' Rating on Seven Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed the senior student loan notes and the
subordinate notes issued by Montana Higher Education Assistance
Corp, 1993 Master Trust.  The Rating Outlook is Stable.

The ratings on the senior and subordinate notes are affirmed based
on the sufficient level of credit enhancement (combination of
overcollateralization, projected minimum excess spread, and
subordination) to cover the applicable risk factor stresses.

Fitch has taken the following rating actions:

MHESAC 1993 Master Trust

  -- Class 1995-A affirmed at 'AAA'; Outlook Stable;
  -- Class 1995-B affirmed at 'AAA'; Outlook Stable;
  -- Class 1995-C affirmed at 'AAA'; Outlook Stable;
  -- Class 1998-A affirmed at 'AAA'; Outlook Stable;
  -- Class 1999-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2000-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2000-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2000-C affirmed at 'AAA'; Outlook Stable;
  -- Class 2001-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2001-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2001-C affirmed at 'AAA'; Outlook Stable;
  -- Class 2002-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2002-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2002-D affirmed at 'AAA'; Outlook Stable;
  -- Class 2003-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2003-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2003-C affirmed at 'AAA'; Outlook Stable;
  -- Class 2004-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2004-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2005-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-A affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-B affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-D affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-E affirmed at 'AAA'; Outlook Stable;
  -- Class 2006-F affirmed at 'AAA'; Outlook Stable;
  -- Class 1998-B affirmed at 'B'; Outlook stable;
  -- Class 1999-B affirmed at 'B'; Outlook stable;
  -- Class 2002-E affirmed at 'B'; Outlook stable;
  -- Class 2003-D affirmed at 'B'; Outlook stable;
  -- Class 2004-C affirmed at 'B'; Outlook stable;
  -- Class 2006-C affirmed at 'B'; Outlook stable.
  -- Class 2006-G affirmed at 'B'; Outlook stable.


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

US$847,000,000 Class A-1 Floating Rate Senior Delayed Funding
Notes Due 2016 (current outstanding balance of $275,216,724),
Upgraded to Aaa (sf); previously on June 22, 2011 Aa2 (sf) Placed
Under Review for Possible Upgrade;

US$60,000,000 Class A-2 Floating Rate Senior Revolving Notes Due
2016 (current outstanding balance of $0), Upgraded to Aaa (sf);
previously on June 22, 2011 Aa2 (sf) Placed Under Review for
Possible Upgrade;

US$50,000,000 Class B Floating Rate Subordinated Delayed Funding
Deferrable Notes Due 2016, Upgraded to A3 (sf); previously on
June 22, 2011 Ba1 (sf) Placed Under Review for Possible Upgrade;

US$10,000,000 Combination Securities Due 2016 (current outstanding
rated balance of $6,955,799), Upgraded to Baa1 (sf); previously on
June 22, 2011 Ba1 (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. The Class A-1 Notes have been paid down from
approximately $353 million to approximately $275 million since the
last rating action in May 2011. As a result of the delevering, the
overcollateralization ratios of the rated notes have improved. The
Class A and Class B overcollateralization ratios are reported at
129.83% and 113.70%, respectively, versus April 2011 levels of
124.50% and 111.38%, 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 $390
million, defaulted par of $2.7 million, a weighted average default
probability of 16.6% (implying a WARF of 2981), a weighted average
recovery rate upon default of 49.7%, and a diversity score of 47.
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.

Monument Park CDO Ltd., issued in January 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
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) 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 selling 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.


MORGAN STANLEY: Moody's Affirms Class G Notes Rating at 'Ba2'
-------------------------------------------------------------
Moody's Investors Service (Moody's) affirmed the ratings of 16
classes of Morgan Stanley Capital I Inc., Commercial Mortgage
Pass-Through Certificates, Series 2003-IQ4:

Cl. A-2, Affirmed at Aaa (sf); previously on Jun 17, 2003
Definitive Rating Assigned Aaa (sf)

Cl. B, Affirmed at Aaa (sf); previously on May 8, 2006 Upgraded to
Aaa (sf)

Cl. C, Affirmed at A1 (sf); previously on Nov 13, 2007 Upgraded to
A1 (sf)

Cl. D, Affirmed at A2 (sf); previously on Nov 13, 2007 Upgraded to
A2 (sf)

Cl. E, Affirmed at Baa1 (sf); previously on Jun 17, 2003
Definitive Rating Assigned Baa1 (sf)

Cl. F, Affirmed at Baa2 (sf); previously on Jun 17, 2003
Definitive Rating Assigned Baa2 (sf)

Cl. G, Affirmed at Ba2 (sf); previously on Nov 18, 2010 Downgraded
to Ba2 (sf)

Cl. H, Affirmed at B2 (sf); previously on Nov 18, 2010 Downgraded
to B2 (sf)

Cl. J, Affirmed at Caa1 (sf); previously on Nov 18, 2010
Downgraded to Caa1 (sf)

Cl. K, Affirmed at Caa2 (sf); previously on Nov 18, 2010
Downgraded to Caa2 (sf)

Cl. L, Affirmed at Caa3 (sf); previously on Nov 18, 2010
Downgraded to Caa3 (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-1, Affirmed at Aaa (sf); previously on Jun 17, 2003
Definitive Rating Assigned Aaa (sf)

Cl. MM-A, Affirmed at Baa2 (sf); previously on Jul 9, 2009
Upgraded to Baa2 (sf)

Cl. MM-B, Affirmed at Baa3 (sf); previously on Jul 9, 2009
Upgraded to Baa3 (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
3.1% of the current balance. At last review, Moody's cumulative
base expected loss was 3.0%. Moody's stressed scenario loss is
6.1% 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 Transactions" published in April 2005.
Moody's also considered another methodology in this rating -
"CMBS: Moody's Approach to Rating Large Loan/Single Borrower
Transactions" published in July 2000. Please see the Credit Policy
page on www.moodys.com for a copy of these methodologies.

Moody's review incorporated the use of the excel-based CMBS
Conduit Model v 2.60 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 19 compared to 22 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 8.1 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.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 28% to $525.6
million from $727.7 million at securitization. The Certificates
are collateralized by 99 mortgage loans ranging in size from less
than 1% to 13% of the pool, with the top ten non-defeased loans
representing 53% of the pool. Seven loans, representing 11% of the
pool, have defeased and are secured by U.S. Government securities.
The pool contains three loans with investment grade credit
estimates, representing 29% of the pool.

Twenty-five loans, representing 15% of the pool, are on the master
servicer's watchlist. The watchlist includes loans which meet
certain portfolio review guidelines established as part of the CRE
Finance Council (CREFC) monthly reporting package. As part of
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 a
realized loss of $1.8 million (34% loss severity). Currently four
loans, representing 4% of the pool, are in special servicing.
Moody's estimates an aggregate $4.3 million loss for the specially
serviced loans (31% expected loss on average).

Moody's has assumed a high default probability for three poorly
performing loans representing 4.4% of the pool and has estimated
an aggregate $4.5 million loss (20% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full year 2010 operating results for 83%
of the pool. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 75% compared to 72% at Moody's
prior review. Moody's net cash flow reflects a weighted average
haircut of 13.4% 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 1.56X and 1.69X, respectively, compared to
1.62X and 1.75X 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 Mall at Millenia
Loan ($66.8 million -- 12.7%), which represents a participation
interest in the senior component of a $186.3 million mortgage
loan. The loan is secured by the borrower's interest in a
1.1 million square foot high-in mall located in Orlando, Florida.
The mall is anchored by Bloomingdale's, Macy's and Neiman Marcus.
Property performance has improved since last review due to an
increase in percentage rents. The property is 99% occupied,
essentially the same as last review. The property is also
encumbered by a $15.0 million non-pooled junior loan that serves
as the security for non-pooled Classes MM-A and MM-B. Moody's
current credit estimate and stressed DSCR for the senior loan are
Baa1 and 1.52X, respectively, compared to Baa1 and 1.46X at last
review. Moody's current credit estimate for the junior loan is
Baa3, the same as at last review.

The second largest loan with a credit estimate is the Federal
Center Plaza Loan ($64.4 million -- 12.3%), which represents a
participation interest in a $128.8 million mortgage loan. The loan
is secured by two adjacent Class B office buildings located in
Washington D.C. The buildings total 722,000 square feet. General
Services Agency (GSA) is the largest tenant, occupying
approximately 87% of the space under two leases expiring in August
2019 (38% NRA) and January 2013 (49% NRA). The GSA has leased
space at the property since 1981 and has previously renewed leases
on a long-term basis in 1991, 1992, 2001 and 2009. Total property
occupancy was 99% as of December 2010, the same as at last review.
Moody's current credit estimate and stressed DSCR are Baa3 and
1.46X, respectively, compared to Baa3 and 1.36X at last review.

The third loan with a credit estimate is the Oakbrook Center Loan
($21.1 million -- 4%), which represents a participation interest
in a $215.7 million mortgage loan. The loan is secured by a mixed-
use property located west of Chicago in Oak Brook, Illinois that
consists of an open-air regional mall, three office buildings and
a ground lease to a hotel and a theater. The center totals
approximately 2.4 million square feet, of which 1.6 million square
feet serves as collateral for the loan. The mall is anchored by
Macy's, Lord & Taylor, Neiman Marcus, Nordstrom and Sears. Total
property occupancy was 98% as of December 2009, the same as at
last review. Performance has been stable since last review.
Moody's current credit estimate and stressed DSCR are Aa2 and
1.77X, respectively, compared to Aa2 and 1.84X at last review.

The top three performing conduit loans represent 15% of the pool
balance. The largest loan is the Katy Mills Loan ($51.8 million --
10% of the pool), which represents a participation interest in a
$139.3 million mortgage loan. The loan is secured by the
borrower's interest in a 1.2 million square foot outlet mall
located near Houston in Katy, Texas. The mall is anchored by Bass
Pro Shops, Burlington Coat Factory, Marshall's, and AMC Theaters.
Total property occupancy was 84% as of December 2010, compared to
83% last review. Moody's LTV and stressed DSCR are 94% and 1.07X,
respectively, compared to 100% and 1.00X at last review.

The second largest loan is the Encino Place Loan ($17.1 million --
3.3%), which is secured by an 84,000 square foot mixed-use retail
and office property located in Encino, California. Property
performance has declined since securitization. Total property
occupancy was 93% as of January 2011, compared with 88% as of
December 2010. Moody's LTV and stressed DSCR are 128% and 0.8X,
respectively, compared to 125% and 0.82X at last review.

The third largest loan is the Indian Creek Phase IV Loan
($14.8 million -- 2.7%), which is secured by a 248-unit
multifamily property located in Cincinnati Ohio. The property
was 96% occupied as of December 2010 compared to 94% at last
review. Property performance has been stable over the life of
the loan. Moody's LTV and stressed DSCR are 52% and 1.97X,
respectively, compared to 54% and 1.92X at last review.


MORGAN STANLEY: Moody's Upgrades Class H Notes Rating to 'Ba2'
--------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of four
classes and affirmed nine classes of Morgan Stanley Dean Witter
Capital I Trust 2001-TOP 5, Commercial Mortgage Pass-Through
Certificates, Series 2001-TOP5:

Cl. D, Upgraded to Aaa (sf); previously on Mar 30, 2011 Upgraded
to Aa1 (sf)

Cl. E, Upgraded to A2 (sf); previously on Mar 30, 2011 Upgraded to
A3 (sf)

Cl. F, Upgraded to Baa2 (sf); previously on Dec 27, 2001
Definitive Rating Assigned Baa3 (sf)

Cl. G, Upgraded to Baa3 (sf); previously on Dec 27, 2001 Assigned
Ba1 (sf)

Cl. B, Affirmed at Aaa (sf); previously on Aug 16, 2005 Upgraded
to Aaa (sf)

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

Cl. H, Affirmed at Ba2 (sf); previously on Dec 27, 2001 Assigned
Ba2 (sf)

Cl. J, Affirmed at Ba3 (sf); previously on Dec 27, 2001 Assigned
Ba3 (sf)

Cl. K, Affirmed at B1 (sf); previously on Dec 27, 2001 Assigned B1
(sf)

Cl. L, Affirmed at B2 (sf); previously on Dec 27, 2001 Assigned B2
(sf)

Cl. M, Affirmed at B3 (sf); previously on Dec 27, 2001 Assigned B3
(sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Dec 27, 2001
Definitive Rating Assigned Aaa (sf)

Cl. X-1, Affirmed at Aaa (sf); previously on Dec 27, 2001
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrades are due to the significant increase in subordination
due to loan payoffs and amortization. The pool has paid down by
32% 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
3.0% of the current balance. At last review, Moody's cumulative
base expected loss was 1.9%. 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 "Moody's Approach
to Rating Fusion U.S. CMBS Transactions", published in April 2005.
The other methodology used in this rating was "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 2.60 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 19 compared to 28 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 8.1 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 March 30, 2011.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 62% to $399.9
million from $1.0 billion at securitization. The Certificates are
collateralized by 63 mortgage loans ranging in size from less than
1% to 8% of the pool, with the top ten loans representing 38% of
the pool. Sixteen loans, representing 34% of the pool, have
defeased and are collateralized with U.S. Government securities.

Twenty-three 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.

Four loans have been liquidated from the pool, resulting in an
aggregate realized loss of $563.6 thousand (4% loss severity
overall). Four loans, representing 3% of the pool, are currently
in special servicing. The master servicer has recognized an
aggregate $1.5 million appraisal reduction for two of the
specially serviced loans. Moody's has estimated an aggregate
$3.4 million loss (32% expected loss on average) for the specially
serviced loans.

Moody's has assumed a high default probability for four poorly
performing loans representing 8% of the pool and has estimated a
$4.4 million aggregate loss (15% expected loss based on a 50%
probability default) from these troubled loans.

Moody's was provided with full and partial year 2010 and partial
year 2011 operating results for 98% and 36% of the pool's non-
defeased loans. Excluding specially serviced and troubled loans,
Moody's weighted average LTV is 67% compared to 65% 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 9.9%.

Excluding specially serviced and troubled loans, Moody's actual
and stressed DSCRs are 1.52X and 1.78X, respectively, compared to
1.66X and 1.85X 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 top three performing conduit loans represent 18% of the pool
balance. The largest loan is the Great American Technical Center
Loan ($30.5 million -- 7.6%), which is secured by two office/R&D
buildings totaling 237,000 square feet (SF) located in Santa
Clara, California. The property is part of the 5.5 million SF
Marriott Business Park. The properties are 100% leased to two
tenants: Broadcom (58% of the net rentable area (NRA); lease
expiration November 2012) and Data Domain (42% of the NRA; lease
expiration June 2018). Although the property has maintained a 100%
occupancy level since last review, financial performance has
declined due to Broadcom's rent being lowered to the current
market level. The loan matures in November 2011. Moody's LTV and
stressed DSCR are 100% and 1.13X, respectively, compared to 56%
and 2.04X at last full review.

The second largest loan is the Lake Mary Centre Loan
($22.1 million -- 5.5%), which is secured by a 339,000 SF
community retail center located near Orlando in Lake Mary,
Florida. The property is anchored by K-Mart, which leases 26% of
the property's NRA through August 2012, and Albertson's, which
leases 19% of the NRA through June 2012. The center was 96% leased
as of March 2011, similar to at last full review. Moody's LTV and
stressed DSCR are 61% and 1.65X, respectively, compared to 62% and
1.62X at last full review.

The third largest loan is the Ryders Crossing Shopping Center Loan
($19.3 million -- 4.8%), which is secured by a 161,000 SF grocery-
anchored shopping center located in Milltown, New Jersey. As of
December 2010, the property was 98% leased compared to 97% as of
December 2009. Major tenants include ACME Supermarket (33% of the
NRA; lease expiration February 2021) and Staples (15% of the NRA;
lease expiration August 2015). Financial performance is stable.
Moody's LTV and stressed DSCR are 77% and 1.41X, respectively,
compared to 79% and 1.38X at last full review.


NAVIGATOR CDO: Moody's Assigns Ba3 Rating to Class B Certificates
-----------------------------------------------------------------
Moody's Investors Service assigned a Ba3 rating to the Class B
Pass Through Certificates, Series 2011-1B of the 2011-1B Pass
Through Trust (the "Certificates") to be issued by Delta Air
Lines, Inc. ("Delta"). The Baa2 rating assigned by Moody's to the
Class A Pass Through Certificates, Series 2011-1A, which Delta
issued on April 5, 2011, and all of Moody's other debt ratings
assigned to Delta are affirmed and remain in force.

The Certificates' proceeds will fund the purchase of the Class B
equipment notes to be issued by Delta, which will use the Notes
proceeds for general corporate purposes, including the refinancing
of certain indebtedness. Please refer to Moody's press release
dated March 30, 2011 for a description of the aircraft that
comprise the collateral for the 2011-1 Certificates. The Class B
Certificates will generally be subordinated to the Class A
Certificates for the distribution of scheduled principal and
interest payments on the Notes, as well as for non-scheduled
distributions. Scheduled interest payments on the Class B
Certificates are supported by the Class B Liquidity Facility,
sized to pay up to three respective consecutive semi-annual
interest payments in the event Delta defaults on its obligations
under the Notes.

Assignments:

   Issuer: Delta Air Lines, Inc.

   -- Series 2011-1B Senior Secured Enhanced Equipment Trust,
      Class B, Assigned Ba3

RATINGS RATIONALE

The ratings of the Certificates reflect:: 1) the credit quality of
Delta (Corporate Family Rating of B2, stable outlook) as obligor
under the Notes; 2) Moody's assessment of the collateral
protection of the Notes; 3) the credit support provided by the
liquidity facility; 4) the cross-subordination provisions of the
inter-creditor agreement and certain structural characteristics of
the Notes such as the applicability of Section 1110 of Title 11 of
the United States Code (the "Code"); and 5) the cross-
collateralization and cross-default provisions of the Notes.

Three aircraft models comprise the collateral, with average and
median ages of about 11.8 and 12.6 years, respectively. These are
approximately four years older than the average age of aircraft in
Delta's other recent EETC issues. Moody's believes that under a
reorganization scenario, the older age of the aircraft in this
financing increases the risk of Delta disaffirming its obligations
under the Notes. Nevertheless, Moody's concluded that a loan-to-
value of about seventy-six percent provides sufficient cushion to
support a Ba3 rating. The cross-collateralization of the equipment
notes should enhance the recovery for investors in the event of
the rejection of the aircraft by Delta in the event of a
bankruptcy filing by it and pursuant to the provisions of the Code
or in the event of a default on the Certificates.

Any combination of future changes in the underlying credit quality
or ratings of Delta, unexpected material changes in the value of
the aircraft pledged as collateral, and/or changes in the status
or terms of the liquidity facility could cause Moody's' to change
its ratings of the Certificates.

The principal methodology used in rating Delta Air Lines, Inc. was
the Global Passenger Airlines Industry Methodology published in
March 2009.

Delta Air Lines, Inc., headquartered in Atlanta, Georgia, is one
of the world's largest airlines, providing scheduled air
transportation for passengers and cargo throughout the U.S. and
around the world.


NAVIGATOR CDO: Moody's Updgrades Class C-1 Notes Rating to Ba1
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Navigator CDO 2005, Ltd.:

US$26,000,000 Class A-2 Floating Rate Senior Secured Term Notes
due 2017, Upgraded to Aa1 (sf); previously on June 22, 2011 Aa3
(sf) Place Under Review for Upgrade;

US$15,500,000 Class B-1 Floating Rate Secured Deferrable Term
Notes due 2017, Upgraded to A3 (sf); previously on June 22, 2011
Baa3 (sf) Place Under Review for Upgrade;

US$15,000,000 Class B-2 Fixed Rate Secured Deferrable Term Notes
due 2017, Upgraded to A3 (sf); previously on June 22, 2011 Baa3
(sf) Place Under Review for Upgrade

US$21,500,000 Class C-1 Floating Rate Subordinate Secured
Deferrable Term Notes due 2017 (current balance of $14,786,662),
Upgraded to Ba1 (sf); previously on June 22, 2011 B1 (sf) Place
Under Review for Upgrade;

US$8,000,000 Class C-2 Fixed Rate Subordinate Secured Deferrable
Term Notes due 2017 (current balance of $5,502,013), Upgraded to
Ba1 (sf); previously on June 22, 2011 B1 (sf) Place Under Review
for Upgrade;

US$20,000,000 Class Q-2 Notes due 2017 (current rated balance of
$14,532,222), Upgraded to A2 (sf); previously on June 22, 2011
Baa3 (sf) Place Under Review for Upgrade;

US$8,000,000 Class Q-3 Notes due 2017 (current rated balance of
$3,266,093), Upgraded to Baa3 (sf); previously on June 22, 2011 B2
(sf) Place Under Review for Upgrade;

US$5,000,000 Class Q-4 Notes due 2017 (current rated balance of
$3,754,684), Upgraded to A2 (sf); previously on June 22, 2011 Baa3
(sf) Place Under Review for Upgrade;

US$14,000,000 Class Q-5 Notes due 2017 (current rated balance of
$9,660,698), Upgraded to A3 (sf); previously on June 22, 2011 Ba1
(sf) Place Under Review for 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 11, 2011 trustee report, the weighted
average rating factor is currently 2589 compared to 2911 in August
2009. As a result of the pay down of the Class A-1A Notes, the
overcollateralization ratios have increased since the rating
action in September 2009. Based on the latest trustee report dated
July 11, 2011 the Class A, Class B and Class C
overcollateralization ratios are reported at 126.66%, 115.59% and
109.23%, respectively, versus August 2009 levels of 117.87%,
108.86% and 102.11%, 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 $434 million,
defaulted par of $11 million, a weighted average default
probability of 15.81% (implying a WARF of 2775), a weighted
average recovery rate upon default of 49.29%, and a diversity
score of 59. 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.

Navigator CDO 2005, Ltd., issued in July 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.

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) 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) Exposure to credit estimates: The deal is exposed to a large
   number of securities whose default probabilities are assessed
   through credit estimates. In the event that Moody's is not
   provided the necessary information to update the credit
   estimates in a timely fashion, the transaction may be impacted
   by any default probability stresses Moody's may assume in lieu
   of updated credit estimates.


NORTHWESTERN INVESTMENTS: Fitch Holds Junk Rating on Two Notes
--------------------------------------------------------------
Fitch Ratings has affirmed two classes of notes issued by
Northwestern Investment Management Company CBO I Fund Ltd./Corp.
(Northwestern CBO I) as follows:

  -- $15,000,000 class B-1 notes at 'Csf/RR6';
  -- $11,000,000 class B-2 notes at 'Csf/RR6'.

As of the Aug. 26, 2011 trustee report there was one performing
bond remaining in the portfolio with a par balance of $3 million.
There are also several defaulted bonds and equity positions that
Fitch expects to have minimal recovery value.  The class A
overcollateralization test, currently reported at 27.3%, has been
failing since 2002.  As a result, the classes B-1 and B-2 notes
have not received any distributions since this time.  With over
$11.6 million of class A notes remaining, Fitch expects that the
class B notes will not receive any distributions at the next and
final payment date in January 2012.

Northwestern CBO I is a collateralized debt obligation (CDO) that
closed Dec. 15, 1999.  The proceeds of the issuance were invested
in a static portfolio consisting primarily of high yield corporate
bonds.  Fitch withdrew its rating on the class A notes in February
2010 as a result of its withdrawal of the rating of the wrap
provider, Financial Security Assurance.

This review did not utilize Fitch's Global Cash Flow model given
that the remaining portfolio contains just one performing bond.
Fitch determined, based on the remaining balance of the class A
notes, that there will not be sufficient proceeds to make any
future payments to the class B-1 and B-2 notes.


NORTHWOODS CAPITAL: Moody's Raises & Confirms Ratings of CLO Notes
------------------------------------------------------------------
Moody's Investors Service has upgraded the rating of these notes
issued by Northwoods Capital VI:

US$43,250,000 Class C Senior Secured Deferrable Floating Rate
Notes Due 2021, Upgraded to Ba3 (sf); previously on June 22, 2011
B3 (sf), Placed on Review for Possible Upgrade;

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

US$402,000,000 Class A-1 Senior Secured Floating Rate Notes Due
2021, Confirmed at Aa1 (sf); previously on June 22, 2011 Aa1 (sf),
Placed on Review for Possible Upgrade;

US$30,000,000 Class A-2 Senior Secured Floating Rate Notes Due
2021, Confirmed at A2 (sf); previously on June 22, 2011 A2 (sf),
Placed on Review for Possible Upgrade;

US$49,000,000 Class B Senior Secured Deferrable Floating Rate
Notes Due 2021, Confirmed at Baa3 (sf); previously on June 22,
2011 Baa3 (sf) Placed on 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 2009. Based on the latest trustee report dated July
8, 2011, the Class A, Class B and Class C overcollateralization
ratios are reported at 137.026%, 123.067%, and 112.914%
respectively, versus August 2009 levels of 128.338%, 115.264%, and
105.755%, respectively.

Moody's notes that the expected losses on the Class A-1, Class A-
2, and Class B notes are consistent with their current ratings. As
a result, Moody's confirmed their ratings.

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 $583 million,
defaulted par of $28.2 million, a weighted average default
probability of 28.7% (implying a WARF of 3529), a weighted average
recovery rate upon default of 46.52%, 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.

Northwoods Capital VI , issued in March 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.

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. However, as part of the base case, Moody's
   considered spread, coupon and diversity levels higher than the
   covenant levels due to the large difference between the
   reported and covenant levels.


OCEAN TRAILS: Moody's Upgrades Class C Notes Rating to 'Ba2'
------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Ocean Trails CLO II:

US$12,500,000 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$15,000,000 Class A-3 Floating Rate Notes Due 2022, Upgraded to
Aa3 (sf); previously on June 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$24,000,000 Class B Deferrable Floating Rate Notes Due 2022,
Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$14,000,000 Class C Floating Rate Notes Due 2022, Upgraded to
Ba2 (sf); previously on June 22, 2011 Ba3 (sf) Placed Under Review
for Possible Upgrade;

US$15,000,000 Class D Floating Rate Notes Due 2022 (current
outstanding balance of $12,165,667), 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 credit improvement of
the underlying portfolio and an increase in the transaction's
overcollateralization ratios since the rating action in September
2009. The weighted average rating factor is currently 2500
compared to 2762 in August 2009. The Class A, Class B, Class C,
and Class D overcollateralization ratios are reported at 119.15%,
110.78%, 106.41%, and 102.89%, respectively, versus August 2009
levels of 116.30%, 108.10%, 103.90%, and 100.11%, 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 balance, including principal proceeds, of
$378 million, defaulted par of $4.1 million, a weighted average
default probability of 20.4% (implying a WARF of 2571), a weighted
average recovery rate upon default of 48.6%, 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.

Ocean Trails CLO II, 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. 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. 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. 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 selling 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 worse
   of reported and covenanted values for weighted average rating
   factor and weighted average coupon. 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.


PARTS STUDENT: Moody's Reviews Ratings for Possible Downgrade
-------------------------------------------------------------
Moody's Investors Service has placed under review for possible
downgrade three classes of notes issued by PARTS Student Loan
Trust 2007-CT1, administered by Deutsche International Corporate
Services (Delaware) LLC and serviced by the Pennsylvania Higher
Education Assistance Agency. Access Group, Inc. is the servicing
administrator. The underlying collateral consists of private
credit student loans that are not guaranteed or reinsured under
the Federal Family Education Loan Program (FFELP) or any other
federal student loan program.

The review was prompted by deterioration in the collateral
performance as demonstrated by higher than expected defaults and
declining parity levels (i.e. the ratio of total assets to total
liabilities). As of the latest reporting date of April 30, 2011,
the cumulative defaults were approximately 13% of the original
pool balance, which is significantly higher than expected. As a
result of high defaults, total parity has declined to
approximately 92.0%, thus leaving a significant portion of the
Class C notes, which represented 11.5% of the capital structure,
not collateralized. Although the balance of the 90+ day delinquent
loans was fairly low, at approximately 3.0% of the loans in active
repayment, the combined balance of loans in deferment and
forbearance was 28.7%. The accrued and capitalized interest on the
loans in deferment and forbearance will increase borrower
indebtedness and could lead to additional delinquencies and
defaults.

The review also reflects Moody's concern with respect to the
transaction's governance. According to the transaction documents,
principal allocation between classes A, B and C should have
switched from sequential to pro-rata on the Stepdown date, which
occurred on the May 2010 distribution date. The pro-rata pay
structure should continue unless certain trigger events occur.
However, to date the transaction's administrator has not directed
the trustee to make the change in the principal allocation.
Moody's has been advised that the transaction's administrator is
working on making this correction, and that the servicing reports
will be restated to reflect the change.

During the review period Moody's will project expected life-time
collateral losses and evaluate whether available credit
enhancement supports the current ratings of each class under
review.

Primary sources of uncertainty are the weak economic environment
and the high unemployment rate, which adversely impacts the
income-generating ability of the borrowers. Lower income levels
will effectively force increasing amounts of borrowers into
delinquency and default across all loan types.

The principal methodology used in these rating actions was
"Moody's Approach to Rating U.S. Private Student Loan-Backed
Securities" rating methodology, published on January 6th, 2010.
Other methodologies and factors that may have been considered in
the process of rating this issue can also be found on Moody's
website.

RATINGS

Issuer: PARTS Student Loan Trust 2007-CT1

Cl. A, Aa1 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 2, 2009 Downgraded to Aa1 (sf)

Cl. B, Baa3 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 2, 2009 Downgraded to Baa3 (sf)

Cl. C, B3 (sf) Placed Under Review for Possible Downgrade;
previously on Mar 2, 2009 Downgraded to B3 (sf)


PETRA CRE: Fitch Affirms Junk Ratings on Seven Note Classes
-----------------------------------------------------------
Fitch Ratings has placed two classes on Rating Watch Evolving and
Negative, downgraded two classes, and affirmed the remaining seven
classes of Petra CRE CDO 2007-1 (Petra 2007-1) reflecting Fitch's
increased base case loss expectation of 63.3%.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market values and cash flow declines.

Since November 2010, the CDO has been failing interest coverage
and overcollateralization tests resulting in the diversion of
interest payments from classes F and below and significant paydown
to class A-1 of $238.9 million.  However, on the July 2011 payment
date, interest proceeds were insufficient to pay the interest due
on classes A-1, A-2, and B; the interest due on these classes was
paid from principal proceeds.  The interest shortfall was
primarily the result of the CDO's high default rate (51%);
additional assets that are either capitalizing interest or
suffering interest shortfalls (7%); and the fact that the
transaction is over-hedged with swaps that are 'out-of the-money'
and senior in priority to the CDO's interest payments.

The credit enhancement to class A-1 has significantly increased to
84.9% compared to 67.2% at last review. Relative to the base case
expected loss; the class' credit profile has improved.  However,
Fitch is concerned about the CDO's ability to continue to make
timely interest payments to this class given the diminished amount
of interest proceeds and significant swap counterparty payments.
While the asset manager terminated two swaps in July 2011,
alleviating some of the cash flow pressure, several others remain
in place.  Principal proceeds are expected to be available at the
next payment date from the discounted payoff of a credit risk loan
should they be needed for interest payments.  However, going
forward that may not be the case, especially if there are further
defaults or delinquencies on the underlying collateral.  Fitch has
placed this class on Rating Watch Evolving and will monitor the
net interest proceeds relative to the timely interest due, which
is expected to settle out in the coming months.

The credit enhancement to Class A-2 is consistent with a rating of
'BB'; however, Fitch is also concerned about the CDO's ability to
continue to make timely interest payments to this class.  Should
cash flow to the CDO be further depleted over the next few months,
this class may face a downgrade of one or two rating categories.

The downgrades of classes B and C are the result of the increased
base case expected loss of 63.3% from 48.8% at last review and the
increase in defaulted assets and loans of concern to 51% and 20%
from 41.1% and 11.2%, respectively at last review.

As of the July 2011 trustee report and per Fitch categorizations,
the CDO was substantially invested as follows: whole loans/A-notes
(48%); B-notes (6%), mezzanine debt (19%), preferred equity (3%);
CMBS (10%), CRE CDO securities (6%), REIT Debt (6%), and a real
estate bank loan (1%). Since last review, 14 assets were removed
from the CDO, all at losses to par; total losses were $85.3
million.  The CDO also added 11 rated securities, which were
purchased at a discount and resulted in built par of $31.9
million.

Under Fitch's surveillance methodology, approximately 88.6% 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 9% from the most recent available cash flows
(generally year-end 2010 or TTM 1st quarter 2011).  Fitch
estimates that average recoveries will be 28.6%.

The largest component of Fitch's base case loss expectation is the
modeled losses on the rated collateral (24%).

The next largest component to Fitch's base case loss expectation
is related to a defaulted A-note (8.4%) secured by a failed
condominium conversion project located in New York City.  Through
the worsening economy the borrower tried to adapt its business
plan to alternative uses, which interrupted progress on the
renovation.  The project is only 60% - 75% complete, and the loan
is non-performing.  Fitch modeled a significant loss on the loan
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 default levels were then compared to the breakeven levels
generated by Fitch's cash flow model of the CDO under the various
default timing and interest rate stress scenarios, as described in
the report 'Global Criteria for Cash Flow Analysis in CDOs'.

The 'CCC' and below ratings for classes B 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.

Petra 2007-1 is managed by Petra Capital Management LLC. The CDO's
six-year reinvestment period ends in June 2013.

Fitch has placed the following class on Rating Watch Evolving:

  -- $121.1 million class A-1 at 'BBBsf'.

Fitch has placed the following class on Rating Watch Negative:

  -- $133.8 million class A-2 at 'BBsf'.

Fitch has downgraded the following classes, as indicated:

  -- $76.8 million class B to 'CCCsf/RR2' from 'Bsf';
  -- $57.6 million class C to 'CCsf/RR6' from 'CCCsf/RR5';

Fitch has affirmed the following classes, as indicated:

  -- $25.6 million class D at 'CCsf/RR6';
  -- $22.1 million class E at 'CCsf/RR6';
  -- $33.6 million class F at 'CCsf/RR6';
  -- $20.5 million class G at 'CCsf/RR6';
  -- $27.2 million class H at 'CCsf/RR6';
  -- $46.2 million class J at 'Csf/RR6';
  -- $37 million class K at 'Csf/RR6'.


PHOENIX CLO: Moody's Updgrades Ratings of Class D Notes to 'Ba2'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Phoenix CLO III, Ltd.:

US$37,000,000 Class A-2 Senior Notes Due July 17, 2019, Upgraded
to Aa1 (sf); previously on June 22, 2011 Aa3 (sf) Placed Under
Review for Possible Upgrade;

US$33,000,000 Class B Senior Notes Due July 17, 2019, Upgraded to
Aa3 (sf); previously on June 22, 2011 A3 (sf) Placed Under Review
for Possible Upgrade;

US$24,000,000 Class C Deferrable Mezzanine Notes Due July 17,
2019, Upgraded to Baa2 (sf); previously on June 22, 2011 Baa3 (sf)
Placed Under Review for Possible Upgrade;

US$19,000,000 Class D Deferrable Mezzanine Notes Due July 17,
2019, Upgraded to Ba2 (sf); previously on June 22, 2011 B1 (sf)
Placed Under Review for Possible Upgrade;

US$13,000,000 Class E Deferrable Junior Notes Due July 17, 2019,
Upgraded to B1 (sf); previously on June 22, 2011 Caa1 (sf) Placed
Under Review for Possible Upgrade;

US$3,000,000 Class F Combination Notes Due July 17, 2019 (current
Rated Balance of $1,456,491), Upgraded to Aaa (sf); previously on
June 22, 2011 A3 (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 $462 million,
defaulted par of $9 million, a weighted average default
probability of 21.71% (implying a WARF of 2749), a weighted
average recovery rate upon default of 48.99%, 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.

Phoenix CLO III, Ltd., issued in May 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 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. 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 spread, and diversity score.
   However, as part of the base case, Moody's considered WARF
   levels lower than the covenant level due to the large
   difference between the reported and covenant levels.


PLC CAPITAL: Moody's Rates Preferred Stock at (P) Ba1
-----------------------------------------------------
Moody's Investors Service has assigned ratings to Protective Life
Corporation's (Protective, NYSE: PL, senior debt at Baa2/stable),
universal shelf registration, which was filed on June 29, 2011.
All the shelf ratings have a stable outlook. Moody's expects
proceeds of securities issued under the shelf to be used for
general corporate purposes.

RATINGS RATIONALE

The multi-security shelf registration allows Protective to issue
senior unsecured debt, subordinated debt, and preferred stock. The
shelf registration also allows for the issuance of preferred
securities by PLC Capital Trusts VI, VII, and VIII, which are
statutory business trusts established by the company solely for
the purpose of raising financing for Protective. Preferred
securities issued by the PLC Capital Trusts will be irrevocably
and unconditionally guaranteed by Protective and will rank pari
passu with the company's subordinated debt.

Moody's assigned these provisional ratings with a stable outlook:

Protective Life Corporation: senior unsecured debt at (P) Baa2;
subordinated debt at (P) Baa3, preferred stock at (P) Ba1, junior
preferred stock at (P) Ba1;

PLC Capital Trust VI, VII, and VIII: preferred security at (P)
Baa3.

Protective is a life insurance holding company headquartered in
Birmingham, Alabama. At June 30, 2011, it reported consolidated
GAAP assets of approximately $51 billion and consolidated GAAP
shareholders' equity of $3.6 billion.

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

Moody's insurance financial strength ratings are opinions of the
ability of insurance companies to pay punctually senior
policyholder claims and obligations.


PREMIUM LOAN: Moody's Upgrades Rating of Class C Notes to 'Caa1'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Premium Loan Trust I, Ltd.:

US$16,000,000 Class X Deferrable Amortizing Senior Secured Notes
Due October 25, 2014 (current outstanding balance of $4,511,659),
Upgraded to Aaa (sf); previously on June 22, 2011 Aa1 (sf) Placed
Under Review for Possible Upgrade.

In addition, Moody's Investors Service has upgraded and left on
review for possible upgrade the ratings of these notes:

US$10,000,000 Class B Deferrable Senior Secured Notes Due
October 25, 2014 (current outstanding balance of $10,688,570),
Upgraded to A1 (sf) and Placed Under Review for Possible Upgrade;
previously on June 22, 2011 Ba1 (sf) Placed Under Review for
Possible Upgrade;

US$11,000,000 Class C Secured Notes Due October 25, 2014 (current
outstanding balance of $12,246,628), Upgraded to Caa1 (sf) and
Placed Under Review for Possible Upgrade; 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 and 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 49% or
$17.2 million since April 2011. As a result of the delevering,
certain overcollateralization ratios have increased. Based on the
latest trustee report dated July 14, 2011, the Class A, Class B,
and Class C overcollateralization ratios are reported at 185.47%,
133.01%, and 100.54%, respectively, versus February 2011 levels of
164.74%, 126.82%, and 100.49%, respectively. These
overcollateralization levels do not reflect the $8.8 million
repayment of the Class A notes on the July 25, 2011 payment date.

Notwithstanding the positive effect of delevering and improved
overcollateralization coverage for the Class A Notes, Class B
Notes, and Class C Notes, Moody's notes that the amount of
interest proceeds was insufficient to cover the entire portion of
the Class X Notes Principal and Interest Amount (which totaled
$510,308 last quarter) on the July 2011 payment date. As a result,
the Class X Notes did not receive the full amount of their
scheduled redemption, and the Class B Notes, Class C Notes, and
Class D Notes are all currently deferring interest. Moody's
expects the shortfall between interest receipts and required
payments on the Class X Notes to continue. Moreover, all principal
proceeds will be used to delever the Class A Notes before any
payments to the junior notes are made. As a result, today's rating
actions reflect concerns about the high likelihood of continued
interest deferral on the Class B Notes and Class C Notes. These
notes remain on review for possible upgrade, as Moody's plans on
re-evaluating the likelihood of the resumption of interest
receipts on the notes.

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 Moody's calculation,
reference securities that mature after the maturity date of the
notes currently make up approximately $3.0 million or 6.2% 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 balance of $47.6 million (excluding principal
proceeds of $8.8 million that delevered the Class A Notes on the
July 2011 payment date), defaulted par of $6.4 million, a weighted
average default probability of 17.96% (implying a WARF of 3545), a
weighted average recovery rate upon default of 43.29%, and a
diversity score of 23. 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.

Premium Loan Trust I, Ltd., 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.

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) 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.

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

4) Interest Payments on the Notes: Interest proceeds on the notes
   are currently not sufficient to pay the Class X Notes Principal
   and Interest Amount and principal proceeds are used to delever
   the Class A Notes. As a result, the Class B Notes, Class C
   Notes, and Class D Notes continue to defer interest payments.
   The Class B Notes, Class C Notes, and Class D Notes will resume
   interest payments following the complete repayment of the Class
   X Notes and Class A Notes, which are both currently being paid
   down, but the timing of the resumption of interest payments
   remains uncertain.


PRIMUS CLO: Moody's Upgrades Ratings of Five Classes of Notes
-------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Primus CLO I, Ltd.:

US$56,000,000 Class A-1-B Floating Rate Notes Due January 15,
2019, Upgraded to Aaa (sf); previously on June 22, 2011 A3 (sf)
Placed Under Review for Possible Upgrade;

US$29,000,000 Class A-2 Floating Rate Notes Due January 15, 2019,
Upgraded to Aaa (sf); previously on June 22, 2011 A1 (sf) Placed
Under Review for Possible Upgrade;

US$14,000,000 Class B Floating Rate Notes Due January 15, 2019,
Upgraded to Aa2 (sf); previously on June 22, 2011 Baa3 (sf) Placed
Under Review for Possible Upgrade;

US$23,000,000 Class C Floating Rate Deferrable Notes Due January
15, 2019, Upgraded to A2 (sf); previously on June 22, 2011 B1 (sf)
Placed Under Review for Possible Upgrade;

US$28,000,000 Class D Floating Rate Deferrable Notes Due January
15, 2019, Upgraded to Ba1 (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 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 7, 2011, the weighted average
rating factor, excluding the rating factor modifier, is currently
2250 compared to 2516 in the June 2010 report. The
overcollateralization ratio of the rated notes has also improved
since the rating action in July 2010. The Senior
overcollateralization ratio is reported at 119.15% versus a June
2010 level of 116.11%.

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 $392.8 million,
no defaulted par, a weighted average default probability of 16.88%
(implying a WARF of 2468), a weighted average recovery rate upon
default of 47.73%, and a diversity score of 76. 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.

Primus CLO I, 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) 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) 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.
   However, as part of the base case, Moody's considered spread,
   coupon, and diversity levels higher than the covenant levels
   due to the large difference between the reported and covenant
   levels.


RENTAL CAR: Moody's Raises Ratings of Rental Car Asset Notes
------------------------------------------------------------
Moody's has upgraded the Series 2007-1 rental car asset backed
notes issued by Rental Car Finance Corp., (RCFC or Issuer), a
special purpose entity wholly owned by Dollar Thrifty Automotive
Group, Inc. (Dollar Thrifty, B2 corporate family rating). The
servicer and primary lessee is DTG Operations, Inc. (DTG), whose
obligations are guaranteed by DTAG. This action is prompted by an
upgrade in the corporate rating of the sponsor to B2, outlook
positive, from B3, outlook positive, on April 19, 2011 and
concludes the review initiated on April 22, 2011.

COMPLETE RATING ACTION:

Issuer: Rental Car Finance Corp.

Series Description: Series 2007-1 Rental Car Asset-Backed Notes

Class Description: Class A

Current Rating: Ba1(sf); previously Ba2(sf) placed under review
for possible upgrade on April 22, 2011

Underlying Rating: Ba1(sf); previously Ba2(sf) placed under review
for possible upgraded on April 22, 2011

Financial Guarantor: Financial Guaranty Insurance Company (NR;
rating withdrawn on March 29, 2009)

RATINGS RATIONALE

The actions are motivated primarily by the strengthening credit
profiles of Dollar Thrifty as the sponsor, master servicer and
performance guarantor of the directly-owned DTG Operations, Inc.
as the lessee, as reflected by the upgrade of its rating to B2,
positive from B3, positive. The probability of default of the
sponsor, while only one of several important variables which drive
Moody's ratings of rental car asset-backed securities, is the
single most important factor.

The principal methodology used in this rating was "Moody's Global
Approach to Rating Rental Car ABS and Rental Truck ABS," published
in July 2011.


REPACS TRUST: Moody's Upgrades Ratings of Class A Debt Unit to B1
-----------------------------------------------------------------
Moody's Investors Service announced this rating action on
REPACS Trust Series Bayshore I, a collateralized debt obligation
transaction. REPACS Trust Series Bayshore I references a portfolio
of structured finance entities and six collateralized debt
obligations, each referencing a portfolio of corporate synthetic
senior unsecured bonds.

US$35,000,000 Class A Debt Unit, Upgraded to B1 (sf); previously
on April 13, 2009 Downgraded to Ca (sf)

US$750,000 Class B Debt Unit, Upgraded to B2 (sf); previously on
April 13, 2009 Downgraded to Ca (sf)

RATINGS RATIONALE

Moody's rating action reflects the execution of Article 4 under
the Investment Agreement and the posting of collateral by the swap
counterparty, Swiss Reinsurance Company Ltd., following the
downgrade of MBIA Insurance Company in November 2008. Today's
rating action also reflects the high rate of amortizations in the
structured finance portfolio and the shorter time-to-maturity of
the CSO.

The structure finance reference portfolio has amortized 62.5%
since November 2004, which is equal to 53.2% of all the underlying
portfolios combined. This has resulted in an increase in
subordination from 3.7% to 10.03% for the Class A notes, and 3.7%
to 7.9% for the Class B Notes, over the same time period. The
portfolio credit quality however, has deteriorated. There has been
five additional credit events since the last rating action in
April 2009.

The CSO has a remaining life of 3.25 years.

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:

* Moody's reviews a scenario consisting of reducing the maturity
  of the CSO by 6 months, keeping all other things equal. The
  result of this run is one notch higher than the base case for
  the Class A notes and two notches higher than the base case for
  the Class B notes.

* 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 two notches lower than
  the base case for the Class A notes and one notch lower than the
  base case for the Class B notes.

* Moody's performs a stress analysis consisting of defaulting all
  entities rated Caa1 and below. The result of this run is two
  notches below the base case for both Class A and Class B Notes.

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 this rating was "Moody's
Approach to Corporate Collateralized Synthetic Obligations"
published in September 2009.

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.


RESOURCE REAL: Fitch Affirms Junk Ratings on Nine Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed 14 classes of Resource Real Estate
Funding CDO 2007-1 Ltd./LLC (RRE 2007-1), reflecting Fitch's base
case loss expectation of 36.4%.  Fitch's performance expectation
incorporates prospective views regarding commercial real estate
market values and cash flow declines.

Fitch has affirmed the following classes, as indicated:

  -- $180,000,000 class A-1 at 'BBB' Rating Outlook Negative;
  -- $50,000,000 class A-1R at 'BBB' Rating Outlook Negative;
  -- $57,500,000 class A-2 at 'BB' Rating Outlook Negative;
  -- $15,000,000 class B at 'B' Rating Outlook Negative;
  -- $7,000,000 class C at 'B' Rating Outlook Negative;
  -- $26,750,000 class D at 'CCC/RR2';
  -- $11,875,000 class E at 'CCC/RR3';
  -- $5,375,000 class F at 'CCC/RR5';
  -- $5,000,000 class G at 'CCC/RR6';
  -- $625,000 class H at 'CCC/RR6';
  -- $11,250,000 class J at 'CCC/RR6';
  -- $10,000,000 class K at 'CCC/RR6';
  -- $18,750,000 class L at 'CCC/RR6';
  -- $28,750,000 class M at 'CC/RR6'.

RRE 2007-1 is collateralized by both senior and subordinate
commercial real estate (CRE) debt: 57.6% are either whole loans or
A-notes, while 9.7% are either B-notes or mezzanine loans as of
the July 2011 trustee report.  In addition, 15.2% are commercial
mortgage backed securities (CMBS) and 17.5% of the portfolio is
held in cash. As of the July 2011 trustee report, all over-
collateralization and interest coverage tests were in compliance.

Since last review, realized losses on defaulted/credit risk assets
totaled approximately $15 million.  Two loans (2.1%) are currently
defaulted or delinquent; Fitch considers nine other loans (32%) to
be Fitch Loans of Concern due to low current net operating income
relative to origination expectations.

Since last review, $30.9 million of notes were surrendered to the
trustee for cancellation, including partial amounts of classes B,
F, G and H.

Under Fitch's surveillance methodology, approximately 60.7% 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 8.3% from the most recent available cash
flows (generally trailing 12 months first quarter 2011).  Fitch
estimates that average recoveries will be 40.0%.

The largest component of Fitch's base case loss expectation is the
expected loss assigned to the CMBS collateral.  The weighted
average Fitch derived rating for the CMBS collateral is 'B+/B'
compared to 'BB-' at last review.

The next largest component of Fitch's base case loss expectation
is a whole loan (6.2%) secured by a full-service hotel located in
Tucson, AZ.  Current cash flow from the portfolio does not support
annual debt service.  Fitch modeled a significant loss on this
underperforming loan in its base case scenario.

The third largest component of Fitch's base case loss expectation
is a whole loan (6.3%) secured by a multifamily property in
Renton, WA.  Although occupancy has remained in the 90% range,
rental rates have continued to be pressured.  Current occupancy is
94.6% as of March 2011. Fitch modeled a substantial loss in its
base case scenario on this loan.

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 C was then compared
to the modeled expected losses.  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 'CCC' and below ratings for classes D through M 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.

Classes A-1 through C maintain their Negative Rating Outlook
reflecting Fitch's expectation of further potential negative
credit migration of the underlying collateral.

RRE 2007-1 is a $500 million CRE collateralized debt obligation
(CDO) managed by Resource Real Estate, Inc.  The transaction has a
five-year reinvestment period during which principal proceeds may
be used to invest in substitute collateral. The reinvestment
period ends in June 2012.


RESOURCE REAL: Fitch Affirms Junk Ratings on Six Note Classes
-------------------------------------------------------------
Fitch Ratings has affirmed 11 classes and withdrawn the rating on
one class of Resource Real Estate Funding CDO 2006-1 Ltd./LLC (RRE
2006-1) reflecting Fitch's base case loss expectation of 28.5%.
Fitch's performance expectation incorporates prospective views
regarding commercial real estate market values and cash flow
declines.

Fitch has affirmed the ratings and revised the Rating Outlooks for
the following classes:

  -- $129,370,000 class A-1 'BBBsf'; Outlook to Stable from
     Negative;
  -- $5,000,000 class A-2 FX 'BBsf'; Outlook to Stable from
     Negative;
  -- $17,420,000 class A-2 FL 'BBsf'; Outlook to Stable from
     Negative;
  -- $13,000,000 class C 'Bsf'; Outlook to Stable from Negative;
  -- $10,000,000 class D 'Bsf'; Outlook to Stable from Negative.

Fitch has affirmed the following classes:

  -- $13,700,000 class E at 'CCCsf/RR3';
  -- $14,580,000 class F at 'CCCsf/RR6';
  -- $17,250,000 class G at 'CCCsf/RR6';
  -- $12,930,000 class H at 'CCCsf/RR6';
  -- $14,660,000 class J at 'CCCsf/RR6';
  -- $28,460,000 class K at 'CCsf/RR6'.

Fitch has withdrawn the rating of class B following the full
surrender of those certificates. Fitch does not rate the
$36,260,000 preferred shares.

In June 2011, the trustee provided notice that $32,370,000 of RRE
2006-1 notes were submitted for cancellation.  The cancellations
were reflected in the June 27, 2011 trustee report and involved
the full cancellation of the class B notes and partial
cancellation of classes C through F.

Since Fitch's last review and as of the July 2011 trustee report,
the disposal of seven credit impaired assets has resulted in
realized losses to the CDO of $12.7 million.  Per the current
trustee reporting, the transaction passes all interest coverage
and overcollateralization tests.

Commercial real estate loans (CREL) comprise approximately 80.5%
of the collateral of the CDO. Two-thirds of the CREL are whole
loans or A-notes with the remainder B-notes or mezzanine loans.
Defaulted CREL assets have increased to 5.8% from 3%, while non-
defaulted loans of concern remained stable at approximately 25%
compared with last review.  CMBS/CDO collateral represents 10% of
the total collateral.  Compared with last review, the average
Fitch derived rating for the underlying CMBS/CDO collateral
remained unchanged at 'B-/CCC+'.

Under Fitch's updated methodology, approximately 57.3% 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 relatively strong at 50.4% due to the generally
low loss expectations on the CREL collateral.

While the largest component of Fitch's base case loss expectation
is the modeled loss on the CMBS/CDO bond collateral, the second
largest component is an A-note (8.3%) secured by a 598-key hotel
in downtown Los Angeles.  The business plan at origination was
significantly affected by the designation of the property as
single room occupancy (SRO).  The borrower was unable to brand a
portion of the hotel under a nationally recognized flag and had
entered into litigation with the city of Los Angeles.  According
to the asset manager, the borrower has entered into settlement
proceedings with the city. The revised exit strategy now involves
conversion to mixed-use, which may include affordable/transitional
housing and hotel.  Due to the continued uncertainty surrounding
the business plan, Fitch modeled a term default with sizable
losses in its base case scenario.

The next largest component of Fitch's base case loss expectation
is a B-note (4.3%) secured by two office properties totaling
562,000 square feet (sf) located in Indianapolis, IN.  The loan is
in special servicing after failing to pay off at its July 1, 2011
final maturity.  According to the asset manager, the special
servicing is working on a short-term extension of the loan while
the single tenant's lease is being renegotiated.  Based on in-
place property cash flow, Fitch modeled a term default with
significant losses in its base case.

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 D was then compared
to the modeled expected losses.  Despite a much lower Fitch base
case loss expectation compared with Fitch's last full review, the
current credit enhancement was determined to be consistent with
the ratings assigned below since modeled values for several assets
were not yet fully supported by in-place property cash flows.
Based on prior modeling results, no material impact was
anticipated from cash flow modeling of the transaction.

The 'CCC' and below ratings for classes E 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.

Resource Real Estate, Inc. is the collateral asset manager for the
transaction. The CDO's reinvestment period ends Aug. 19, 2011.


RFC CDO: Fitch Affirms Junk Ratings on All Notes Classes
--------------------------------------------------------
Fitch Ratings affirms all classes of RFC CDO 2007-1 (RFC 2007-1)
reflecting Fitch's base case loss expectation of 36.7%.  Fitch's
performance expectation incorporates prospective views regarding
commercial real estate market value and cash flow declines.

RFC 2007-1 is a CRE CDO managed by CWCapital Investments.  As of
the June 2011 trustee report and per Fitch categorizations, the
CDO was substantially invested as follows: CRE whole loans
(49.1%), B-notes (14.1%), mezzanine loans (2.3%), commercial
mortgage-backed securities (25.6%), and CRE CDOs (1.3%).

The transaction currently has defaulted interests totaling 45% of
the pool.  Additionally, there are three loans (4.6%) that are
considered Fitch Loans of Concern. Fitch expects significant
losses on the defaulted assets and Fitch Loans of Concern.  Since
last review, seven assets were removed from the CDO, all at losses
to par; total losses were approximately $95 million.
Since 2009, the CDO has been failing interest coverage and
overcollateralization tests resulting in the diversion of interest
payments from classes C and below; and significant paydown to
classes A-1 and A-1R of over $150 million.  Given the expectation
of further defaults, Fitch considers it unlikely that classes C
and below will receive any further proceeds over the life of the
transaction.

Further, as of the September 2009 payment date, interest proceeds
were insufficient to pay the interest due on classes A-1, A-1R A-
2, A-2R, and B; the interest due on these classes was paid from
available principal cash or via proceeds advanced by the trustee
as backup advancing agent.  The interest shortfall was primarily
the result of asset defaults, and the fact that the transaction is
over-hedged with swaps that are 'out-of the-money' and senior in
priority to the CDO's interest payments.  Uncertainty surrounding
future advances and the backup agent's requirements to fund these
advances remains a concern.

Under Fitch's 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 9.3% from generally year-end 2010 net operating income
(NOI).  Fitch estimates that average recoveries will be low at
36.5%.

The largest component of Fitch's base case loss expectation is the
modeled losses on the rated securities (27%).

The largest defaulted loan (8%) is secured by a 380,602 square
foot (sf) office property located in downtown Phoenix, AZ.  The
building is 72.7% occupied as of April 2011, with minimal lease
rollover until 2013.  The loan transferred to special servicing in
May 2011 for maturity default after the borrower was unable to
refinance the debt.

The next defaulted loan (4%) is secured by a multi-family property
located in Aurora, CO.  This loan is cross-collateralized with a
second specially serviced loan (3.5%) -- also secured by a multi-
family property in Aurora, CO. Performance for both properties has
declined since issuance, and when amortization began in December
2009, the properties were not able to support the higher debt
service payment.  The loans were modified in April 2011 with an
extended maturity, a reversion to an interest-only debt service,
and minor pay-down of principal.  The special servicer continues
to monitor the loans.

The next largest defaulted loan (2.2%) is collateralized by two
office buildings located in Lake Mary, FL, and one office building
in Orlando, FL, totaling 36,404sf.  Occupancy remains below
expectations from origination, most recently reported at 75%.  The
special servicer continues to discuss workout options with the
borrower, including a possible modification.  Foreclosure is also
being discussed should terms of a modification not be worked out.

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 'CCC' and below ratings for all classes 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.
  Additionally, the ability of advancing to the timely classes was
also taken into account.

All classes were assigned Recovery Ratings (RR) in order to
provide a forward-looking estimate of recoveries on currently
distressed or defaulted structured finance securities.

Fitch affirms the following classes, and revises the Recovery
Ratings as indicated:

  -- $352,726,573 class A-1 at 'CCC/RR1' from RR2;
  -- $39,191,841 class A-1R at 'CCC/RR1' from RR2;
  -- $125,000,000 class A-2 at 'CCC/RR5';
  -- $9,200,000 class A-2R at 'CCC/RR5';
  -- $86,500,000 class B at 'CCC/RR5';
  -- $49,189,591 class C at 'CC/RR6';
  -- $19,510,276 class D at 'CC/RR6';
  -- $15,418,422 class E at 'CC/RR6';
  -- $23,367,638 class F at 'C/RR6';
  -- $15,613,797 class G at 'C/RR6';
  -- $25,181,053 class H at 'C/RR6';
  -- $18,327,420 class J at 'C/RR6';
  -- $16,899,973 class K at 'C/RR6';
  -- $10,534,630 class L at 'C/RR6'.


SANDELMAN REALTY: Moody's Upgrades Cl. A-2 Notes Ratings to 'B3'
----------------------------------------------------------------
Moody's has upgraded three and affirmed eight classes of Notes
issued by Sandelman Realty CRE CDO I, Ltd. due to an increase in
the expected recovery rate. 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.

Moody's rating action is:

Cl. A-1, Upgraded to Aa3 (sf); previously on Aug 27, 2010
Confirmed at A2 (sf)

Cl. A-2, Upgraded to B3 (sf); previously on Aug 27, 2010
Downgraded to Caa2 (sf)

Cl. B, Upgraded to Caa2 (sf); previously on Aug 27, 2010
Downgraded to Ca (sf)

Cl. C, Affirmed at Ca (sf); previously on Aug 27, 2010 Downgraded
to Ca (sf)

Cl. D, Affirmed at C (sf); previously on Aug 27, 2010 Downgraded
to C (sf)

Cl. E, Affirmed at C (sf); previously on Aug 27, 2010 Downgraded
to C (sf)

Cl. F, Affirmed at C (sf); previously on Aug 27, 2010 Downgraded
to C (sf)

Cl. G, Affirmed at C (sf); previously on Aug 27, 2010 Downgraded
to C (sf)

Cl. J, Affirmed at C (sf); previously on Aug 27, 2010 Downgraded
to C (sf)

Cl. K, Affirmed at C (sf); previously on Aug 27, 2010 Downgraded
to C (sf)

Cl. L, Affirmed at C (sf); previously on Aug 27, 2010 Downgraded
to C (sf)

RATINGS RATIONALE

Sandelman Realty CRE CDO I, Ltd. is a CRE CDO transaction backed
by a portfolio of commercial mortgage backed securities (CMBS)
(38.3%), A-Notes and whole loans (26.0% of the pool balance), B-
Notes (18.7%), mezzanine loans (14.4%), and rake bonds (2.7%). As
of the July 22, 2011 Trustee report, the aggregate Note balance
of the transaction has decreased to $368.4 million from
$478.2 million at issuance with the paydown directed to the
Class A-1 Notes, as a result of failing the Class A/B/C par
value test. In addition to the paydown of the Class A-1, the
Note balance has also decreased by approximately $31 million
due to cancellation of the junior Notes.

There are twelve assets with a par balance of $137.2 million
(31.3% of the current pool balance) that are considered Defaulted
Securities as of the July 22, 2011 Trustee report. Two assets are
either A-Notes or whole loans (48.6% of the defaulted balance),
six assets are CMBS (27.2%), one asset is a B-Note(18.5%), and
three assets are rake bonds (5.5%). Defaulted Securities that are
not CMBS are defined as assets which are 60 or more days
delinquent in their debt service payment. Moody's does expect
significant losses to occur once they are realized.

Moody's has identified the following parameters as key indicators
of the expected loss within CRE CDO transactions: 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 6,252 compared to 6,333 at last review. The
distribution of current ratings and credit estimates is as
follows: Aaa-Aa3 (11.2% compared to 14.8% at last review), A1-A3
(5.8% compared to 6.2% at last review), Baa1-Baa3 (6.2% compared
to 0.0% at last review), Ba1-Ba3 (0.2% compared to 5.1% at last
review), B1-B3 (2.2% compared to 7.4% at last review), and Caa1-C
(74.3% compared to 66.1% 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 3.1 years compared
to 6.0 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
41.0% compared to 26.1% 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 0.0% compared to 99.9% at last review.
The low MAC is due to higher 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 down from
41% to 31% or up to 51% would result in average rating movement on
the rated tranches of 0 to 3 notches downward and 0 to3 notches
upward, respectively.

The performance expectations for a given variable indicate Moody's
forward-looking view of the likely range of performance over the
medium term. From time to time, Moody's may, if warranted, change
these expectations. Performance that falls outside the given range
may indicate that the collateral's credit quality is stronger or
weaker than Moody's had anticipated when the related securities
ratings were issued. Even so, a deviation from the expected range
will not necessarily result in a rating action nor does
performance within expectations preclude such actions. The
decision to take (or not take) a rating action is dependent on an
assessment of a range of factors including, but not exclusively,
the performance metrics. Primary sources of assumption uncertainty
are the 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 this rating was "Moody's
Approach to Rating SF CDOs" published in November 2010.

Other methodoglogy used in this rating was "Moody's Approach to
Rating Commercial Real Estate CDOs" published on July 2011.


SIERRA TIMESHARE: S&P Affirms Rating on Class C Notes at 'BB'
-------------------------------------------------------------
Standard & Poor's Ratings Services affirmed its ratings on Sierra
Timeshare Receivables' series 2010-2, 2010-3, and 2011-1. Wyndham
Consumer Finance Inc. (Wyndham) is the seller and servicer of the
vacation ownership interval (timeshare) loans that collateralized
the transactions.

"Due to an error, we used an incorrect priority of payments
sequence in our analysis, which could have potentially affected
the ratings we assigned to the class A notes from series 2010-3
and the class B notes from series 2011-1," S&P said.

"Following notification to Wyndham of the error and its potential
impact on the outstanding ratings, Wyndham appealed our rating
decision and subsequently added funds to newly created reserve
accounts for the series 2010-3 and series 2011-1 transactions. The
affirmations reflect the correction of the error, as well as our
assessment of the credit impact of Wyndham's addition of the newly
created reserve accounts for the two transactions," S&P related.

A similar error was identified in a third transaction, Sierra
Timeshare 2010-2 Receivables Funding LLC, but the correction does
not affect the ratings assigned to this transaction. "As a result,
we are also affirming the ratings on this transaction," S&P said.

"We have reviewed each of our rated timeshare securitizations, and
we concluded that the error affected only the three transactions
named," S&P said.

Ratings Affirmed

Sierra Timeshare 2010-2 Receivables Funding LLC
Class       Rating
A           A (sf)
B           BBB (sf)


Sierra Timeshare 2010-3 Receivables Funding LLC
Class       Rating
A           A+ (sf)
B           BBB (sf)

Sierra Timeshare 2011-1 Receivables Funding LLC
Class       Rating
A           A (sf)
B           BBB- (sf)
C           BB (sf)


SIMSBURY CLO: Fitch Lifts Junk Rating on $1 Mil. Notes to 'BBsf'
----------------------------------------------------------------
Fitch Ratings has upgraded one class of notes issued by Simsbury
CLO, Ltd/Corp. (Simsbury CLO) as follows:

  -- $1,048,819 class V mezzanine notes to 'BBsf' Outlook Stable
     from 'CCsf/RR1'.

The upgrade of the class V notes is due to the increased credit
enhancement resulting from the deleveraging of the capital
structure and the collateral coverage remaining for the notes.
Since the last review, the class IVA senior and IVB mezzanine
notes were paid in full, leaving the class V notes as the senior-
most remaining class.  At the last payment date in March 2011, the
class V notes received more than half of their $3.2 million
outstanding principal balance.

The remaining performing portfolio collateral is comprised of high
yield loans and bonds issued by four unique obligors, with an
aggregate par balance of $3.8 million.  In addition, there is
currently $3.1 million of defaulted assets in the portfolio, which
Fitch expects to recover approximately 25% on average.
Approximately 47% of the performing portfolio balance is scheduled
to mature after the stated legal final of the transaction in
September 2011, exposing the notes to potential market value risk.
One obligor with a par value of $2 million and a Fitch derived
rating in the 'BB' category is scheduled to mature prior to the
stated maturity.  Fitch expects available proceeds received prior
to maturity to be sufficient to pay the class V notes in full at
their scheduled maturity in September 2011.

This review did not utilize Fitch's Global Cash Flow model given
the short remaining tenor of the transaction and the high obligor
concentration of the portfolio.  Instead, the credit quality of
the single performing obligation maturing prior to the stated
legal maturity date of the notes was used to determine the long-
term credit rating of the remaining liabilities.  The structural
features of the transaction were also factored into the analysis.

Simsbury is a collateralized loan obligation (CLO) which closed
Sept. 15, 1999, and is managed by Babson Capital Management LLC.
The stated maturity of the transaction is Sept. 24, 2011.


SLM STUDENT: Fitch Affirms 'BBsf' Rating on Class B Notes
---------------------------------------------------------
Fitch Ratings affirms the senior notes at 'AAAsf' and subordinate
student loan note at 'BBsf' issued by SLM Student Loan Trust
Series 2003-10 The Rating Outlook remains Stable for both senior
and subordinate bonds.

The ratings on the senior and subordinate notes are affirmed based
on the sufficient level of credit enhancement to cover the
applicable basis factor stress.

Credit enhancement for Class B consists of projected minimum
excess spread.  Class A notes benefit from subordination provided
by the lower priority notes.

The loans are serviced and originated by SLM Corp. SLM Corp.
provides funds for educational loans, primarily federal guaranteed
student loans originated under the FFELP.  SLM Corp. and its
subsidiaries are not sponsored by or agencies of the U.S.
government.  Fitch has assigned SLM Corp. long- and short-term
Issuer Default Ratings (IDRs) of 'BBB-' and 'F3', respectively.
Fitch affirms the following classes of SLM Student Loan Trust
Series 2003-10:

  -- Class A-1A at 'AAAsf;
  -- Class A-1B at 'AAAsf';
  -- Class A-1C at 'AAAsf';
  -- Class A-1D at 'AAAsf';
  -- Class A-1E at 'AAAsf';
  -- Class A-1F at 'AAAsf';
  -- Class A-1G at 'AAAsf';
  -- Class A-1H at 'AAAsf';
  -- Class A-2 at 'AAAsf';
  -- Class A-3 at 'AAAsf';
  -- Class A-4 at 'AAAsf';
  -- Class B at 'BBsf'.

The Rating Outlooks for all classes is Stable


SILVER MARLIN: Fitch Withdraws 'D' Rating on Nine Note Classes
--------------------------------------------------------------
Fitch Ratings has affirmed five, downgraded four, and subsequently
withdrawn the ratings on all classes of notes issued by Silver
Marlin CDO I, Ltd. (Silver Marlin I) as:

-- $184,950,499 class A-1 notes downgraded to 'Dsf' from 'Csf'
    and withdrawn;
-- $437,345,970 class A-2 notes affirmed at 'Dsf' and withdrawn;
-- $62,477,996 class A-3 notes affirmed at 'Dsf' and withdrawn;
-- $66,976,411 class A-4 notes affirmed at 'Dsf' and withdrawn;
-- $21,492,431 class B notes affirmed at 'Dsf' and withdrawn;
-- $9,396,691 class C notes affirmed at 'Dsf' and withdrawn;
-- $8,283,962 class D notes downgraded to 'Dsf' from 'Csf' and
    withdrawn;
-- $4,642,426 class E notes downgraded to 'Dsf' from 'Csf' and
    withdrawn;
-- $12,235,379 class F notes downgraded to 'Dsf' from 'Csf' and
    withdrawn.

Silver Marlin I entered an event of default in February 2008 and
its maturity was accelerated in August 2008.  On June 2, 2011, the
trustee was directed by the hedge counterparty and the requisite
majority of the aggregate outstanding amount of each class to
liquidate the portfolio.

The final distribution occurred on Aug. 1, 2011.  The trustee
reports showed that the proceeds available for distribution were
insufficient to pay the class A-1 notes in full.  Consequently,
there were no available funds to make any payments on any other
classes of notes.

Silver Marlin I was a managed cash flow structured finance (SF)
collateralized debt obligation (CDO) invested in residential
mortgage-backed securities, CDOs and asset-backed securities.


TRICADIA CDO: Moody's Raises Class A-1LA Rating to Aa3 From Ba1
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of 6 classes of
notes issued by Tricadia CDO 2003-1. The classes of notes affected
by the rating actions are:

US$76,500,000 Class A-1LA Floating Rate Notes Due February 2016
(current balance: 32,318,781), Upgraded to Aa3 (sf) and Remains On
Review for Possible Upgrade; previously on June 24, 2011 Ba1 (sf)
Placed Under Review for Possible Upgrade;

US$ 8,500,000 Class A-1LB Floating Rate Notes Due February 2016,
Upgraded to Baa2 (sf) and Remains On Review for Possible Upgrade;
previously on June 24, 2011 B3 (sf) Placed Under Review for
Possible Upgrade;

US$85,000,000 Class A-2L Floating Rate Notes Due February 2016
(current balance: 40,818,781), Upgraded to A3 (sf) and Remains On
Review for Possible Upgrade; previously on June 24, 2011 Ba3 (sf)
Placed Under Review for Possible Upgrade;

US$35,000,000 Class A-3L Floating Rate Notes Due February 2016,
Upgraded to Ba3 (sf) and Remains On Review for Possible Upgrade;
previously on June 24, 2011 Caa3 (sf) Placed Under Review for
Possible Upgrade;

US$12,000,000 Class A-4L Floating Rate Notes Due February 2016,
Upgraded to B3 (sf) and Remains On Review for Possible Upgrade;
previously on June 24, 2011 C (sf) Placed Under Review for
Possible Upgrade;

US$20,000,000 Class B-1L Floating Rate Notes Due February 2016
(current balance: 15,345,189), Upgraded to Caa2 (sf) and Remains
On Review for Possible Upgrade; previously on June 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 in the credit quality of the
portfolio.

Since the last rating action in May 2011, the weighted average
rating factor has improved to 1436 compared to 3348 in the April
2011 report. Also of the latest trustee report in July 2011, the
Senior Class A, Class A and Class B overcollateralization ratios
have improved and are reported at 129.4%, 117.4%, 104.35% versus
April 2011 levels of 123.6%, 112.2% and 99.91% respectively.

Following an announcement by Moody's on June 22, 2011 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"). Today's rating action on the notes reflects
CLO tranche upgrades that have taken place thus far, as well as a
pro forma assumption that CLO tranches which remain on review for
possible upgrade will be upgraded by two notches. According to
Moody's, 63% of the collateral has been upgraded since June 22nd,
and 26% remains on review.

Tricadia CDO 2003-1 is a collateralized debt obligation backed
primarily by a portfolio of CLOs.

The principal methodology used in this rating was "Moody's
Approach to Rating SF CDOs" published in November 2010. Please see
the Credit Policy page on www.moodys.com for a copy of this
methodology.

Moody's applied the Monte Carlo simulation framework within
CDOROMv2.6 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:

CLO bucket on review for potential upgrade notched up by 3 rating
categories (instead of Moody's standard assumption of 2 notches):

Class A-1LA: +2

Class A-1LB: +3

Class A-2L: +3

Class A-3L: +3

Class A-4L: +3

Class B-1L: +3

CLO bucket on review for potential upgrade notched up by 1 rating
category (instead of Moody's standard assumption of 2 notches):

Class A-1LA: 0

Class A-1LA: -1

Class A-1LB: -1

Class A-2L: -1

Class A-3L: -1

Class A-4L: -2

Class B-1L: -1


TRICADIA CDO: Moody's Upgrades Class B Notes Rating to 'B3'
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of two classes
of notes issued by Tricadia CDO 2006-5, Ltd. The classes of notes
affected by the rating actions are:

US$55,000,000 Class B Senior Floating Rate Notes Due 2046,
Upgraded to B3 (sf), Remaining on Review for Possible Upgrade;
previously on Jun 24, 2011 Caa3 (sf) Placed Under Review for
Possible Upgrade;

US$56,000,000 Class C Senior Floating Rate Notes Due 2046,
Upgraded to Caa2 (sf), Remaining on Review for Possible Upgrade;
previously on Jun 24, 2011 Ca (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.

As of the latest trustee report dated June 30, 2011, the Senior
Class Par Coverage Ratio is reported at 83.44% versus May 2010
levels of 66.82%. Also based on this June report the WARF reported
is 1908 versus May 2010 reported WARF of 3022.

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").
Today's 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, 40% of the collateral has been upgraded
since June 22nd, and 57% remains on review.

Tricadia CDO 2006-5, Ltd 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. Please see
the Credit Policy page on www.moodys.com for a copy of this
methodology.

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.


TROPIC CDO: Moody's Downgrades Rating of Class A-3L Notes to Caa1
-----------------------------------------------------------------
Moody's Investors Service has downgraded the rating on these notes
issued by Tropic CDO II, Ltd.

US$35,000,000 Class A-3L Floating Rate Notes Due April 2034,
Downgraded to Caa3 (sf); previously on October 30, 2009 Downgraded
to Caa1 (sf).

RATINGS RATIONALE

According to Moody's, the rating downgrade action taken is
primarily the result of the par loss due to an increase in the
defaulted amount which has resulted in loss of
overcollateralization for the Class A-3L Notes and an increase in
their expected losses since the last rating action. As of the
latest trustee report dated July 14, 2011, the Senior
Overcollateralization Test is at 93.33% (limit 120.00%), and the
Subordinate Overcollateralization Test is at 66.07% (limit
104.00%), versus trustee reported levels from the report dated
October 14, 2009 of 106.68% and 76.23% respectively, which were
used during the last rating action.

In addition, Moody's notes that there has been an increase in the
assumed defaulted amount in the underlying portfolio. The assumed
defaulted amount increased by $27.57 million since the last rating
action in October 2009. Assumed defaulted amount now total $142.57
million (45.52% of the current portfolio). The credit metrics of
the remaining portfolio have shown a slight deterioration, as
indicated by a weighted average weighting factor (WARF) increase
to 1656, from 1314, as of the last rating action date.

Tropic CDO II, Ltd., issued on October 15, 2003, is a collateral
debt obligation backed by a portfolio of bank trust preferred
securities (the 'TRUP CDO'). On October 30, 2009, the last rating
action date, Moody's downgraded four classes of notes as a result
of the deterioration in the credit quality of the transaction's
underlying portfolio.

The credit deterioration exhibited by the TRUP CDO portfolio is a
reflection of the continued pressure in the banking sector. In
Moody's opinion, the banking sector outlook continues to remain
negative although there have been some recent signs of
stabilization. The pace of bank failures in 2011 has declined
compared to 2009 and 2010, and a handful of previously deferring
banks have resumed interest payment on their trust preferred
securities.

The portfolio of this CDO is mainly composed of trust preferred
securities issued by small to medium sized U.S. community banks
that are generally not publicly rated by Moody's. To evaluate
their credit quality, Moody's uses RiskCalc model, an econometric
model developed by Moody's KMV, to derive credit scores for these
non-publicly rated bank trust preferred securities. Moody's
evaluation of the credit risk for a majority of bank obligors in
the pool relies on FDIC financial data received as of Q1-2011.
Moody's also evaluates the sensitivity of the rated transactions
to the volatility of the credit estimates, as described in Moody's
Rating Implementation Guidance "Updated Approach to the Usage of
Credit Estimates in Rated Transactions," October 2009.

Moody's performed a number of sensitivity analyses of the results
to some of the key factors driving the ratings including the
analysis of a scenario where a material percentage of deferred
assets are cured. Moody's also assessed how much additional
defaults are needed for the current ratings to be downgraded by
one subcategory across the capital structure.

In addition to the quantitative factors that are explicitly
modeled, qualitative factors are part of rating committee
considerations. Moody's considers as well the structural
protections in each transaction, the risk of triggering an Event
of Default, the recent deal performance in the current market
conditions, 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 this rating was "Moody's
Approach to Rating TRUP CDOs" published in May 2011.

Due to the impact of revised and updated key assumptions
referenced in these rating methodologies, key model inputs used by
Moody's in its analysis, such as par, weighted average rating
factor, Moody's Asset Correlation, and weighted average recovery
rate, may be different from the trustee's reported numbers. The
transaction's portfolio was modeled, according to Moody's rating
approach, using CDOROM v.2.8 to develop the default distribution
from which the Moody's Asset Correlation parameter was obtained.
This parameter was then used as an input in a cash flow model
using CDOEdge. CDOROM v.2.8 is available on moodys.com under
Products and Solutions -- Analytical models, upon return of a
signed free license agreement.


VERITAS CLO: Moody's Upgrades Class D Notes Rating to 'Ba1'
-----------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Veritas CLO I, Ltd.:

US$19,000,000 Class B Second Priority Senior Secured Floating Rate
Notes due September 5, 2016, Upgraded to Aaa (sf); previously on
June 22, 2011 A1 (sf) Placed Under Review for Possible Upgrade;

US$16,000,000 Class C Third Priority Mezzanine Secured Floating
Rate Deferrable Interest Notes due September 5, 2016, Upgraded to
A1 (sf); previously on June 22, 2011 Baa3 (sf) Placed Under Review
for Possible Upgrade;

US$10,500,000 Class D Fourth Priority Mezzanine Secured Floating
Rate Deferrable Interest Notes due September 5, 2016, Upgraded to
Ba1 (sf); previously on June 22, 2011 B3 (sf) Placed Under Review
for Possible Upgrade;

US$8,000,000 Class E Fifth Priority Mezzanine Secured Floating
Rate Deferrable Interest Notes due September 5, 2016, Upgraded to
B3 (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 and amortization of the
senior notes since the rating action in February 2011. Moody's
notes that the Class A Notes have been paid down by approximately
38% or $48.2 million since the rating action in February 2011. As
a result of the deleveraging, the overcollateralization ratios
have increased. Based on the latest trustee report dated June 30,
2011, the Class A/B, Class C, Class D, and Class E
overcollateralization ratios are reported at 143.82%, 123.70%,
113.30%, and 106.48%, respectively, versus December 2010 levels of
126.97%, 114.48%, 107.54%, and 102.79%, respectively.

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 13.86% 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 $145 million,
defaulted par of $1 million, a weighted average default
probability of 17.34% (implying a WARF of 2785), a weighted
average recovery rate upon default of 48.93%, and a diversity
score of 44. 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.

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

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

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.


VICTORIA FALLS: Moody's Upgrades Class D Notes Due 2017 to 'B1'
---------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Victoria Falls CLO, Ltd.:

US$28,600,000 Class A-1B Floating Rate Notes, Due 2017 Upgraded to
Aa1 (sf); previously on Jun 22, 2011 A2 (sf) Placed Under Review
for Possible Upgrade;

US$75,000,000 Class A-2 Floating Rate Notes, Due 2017 Upgraded to
Aaa (sf); previously on Jun 22, 2011 A1 (sf) Placed Under Review
for Possible Upgrade;

US$10,000,000 Class A-3 Fixed Rate Notes, Due 2017 Upgraded to Aaa
(sf); previously on Jun 22, 2011 A1 (sf) Placed Under Review for
Possible Upgrade;

US$8,500,000 Class B-1 Floating Rate Notes, Due 2017 Upgraded to
Aa3 (sf); previously on Jun 22, 2011 Baa2 (sf) Placed Under Review
for Possible Upgrade;

US$2,000,000 Class B-2 Fixed Rate Notes, Due 2017 Upgraded to Aa3
(sf); previously on Jun 22, 2011 Baa2 (sf) Placed Under Review for
Possible Upgrade;

US$18,000,000 Class C Deferrable Floating Rate Notes, Due 2017
Upgraded to Baa3 (sf); previously on Jun 22, 2011 Ba2 (sf) Placed
Under Review for Possible Upgrade; and

US$21,000,000 Class D Deferrable Floating Rate Notes, Due 2017
Upgraded to B1 (sf); previously on Jun 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 due to delevering of the Class A
Notes, which have been paid down by approximately 4% or
$9.18 million since the rating action in September 2009. Based on
the latest trustee report dated July 10, 2011, the weighted
average rating factor is currently 2481 compared to 2753 in August
2009. The Class A/B, Class C, and Class D overcollateralization
ratios are reported at 119.23%, 110.33%, and 102.26%,
respectively, versus August 2009 levels of 113.93%, 105.82%, and
97.71%, 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 $265.95 million,
defaulted par of $3.5 million, a weighted average default
probability of 15.16% (implying a WARF of 2587), a weighted
average recovery rate upon default of 50.44%, 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.

Victoria Falls CLO, Ltd., issued in February 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. 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: 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.


VITESSE CLO: Moody's Raises Rating of Class B-1L Rating to 'Ba1'
----------------------------------------------------------------
Moody's Investors Service has upgraded the ratings of these notes
issued by Vitesse CLO Ltd.:

US$28,000,000 Class A-2L Floating Rate Notes Due August 17, 2020,
Upgraded to Aa2 (sf); previously on June 22, 2011 Aa3 (sf) Placed
Under Review for Possible Upgrade;

US$41,000,000 Class A-3L Floating Rate Notes Due August 17, 2020,
Upgraded to Baa1 (sf); previously on June 22, 2011 Baa3(sf) Placed
Under Review for Possible Upgrade;

US$25,000,000 Class B-1L Floating Rate Notes Due August 17, 2020,
Upgraded to Ba1 (sf); previously on June 22, 2011 Ba3(sf) Placed
Under Review for Possible Upgrade;

US$17,000,000 Class B-2L Floating Rate Notes Due August 17, 2020
(current outstanding balance $16,517,456), Upgraded to Ba3 (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 improvement in the
credit quality of the underlying portfolio. Based on the latest
trustee report dated July 11, 2011, the weighted average rating
factor is currently 2550 compared to 2947 in the June 2009 report.
The overcollateralization ratios of the rated notes have also
improved since the rating action in September 2009. The Senior
Class A, Class A, Class B-1L and Class B-2L overcollateralization
ratios are reported at 124.26%, 114.06%, 108.62%, and 105.31%,
respectively, versus June 2009 levels of 120.74%, 111.12%,
105.97%, and 99.86%, 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 $570 million,
defaulted par of $247,958, a weighted average default probability
of 21.09% (implying a WARF of 2750), a weighted average recovery
rate upon default of 51.80%, 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.

Vitesse CLO 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. 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) 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.


WACHOVIA BANK: Moody's Affirms Cl. LXR-1 Notes Rating at 'B2'
-------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded four rake, or non-
pooled classes and affirmed ten classes of Wachovia Bank
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2007-WHALE 8. Moody's rating action is:

Cl. A-1, Affirmed at Aaa (sf); previously on July 6, 2007
Definitive Rating Assigned Aaa (sf)

Cl. A-2, Affirmed at A2 (sf); previously on December 9, 2010
Downgraded to A2 (sf)

Cl. B, Affirmed at Baa1 (sf); previously on December 9, 2010
Downgraded to Baa1 (sf)

Cl. LXR-1, Affirmed at B2 (sf); previously on December 9, 2010
Downgraded to B2 (sf)

Cl. LXR-2, Affirmed at Caa1 (sf); previously on December 9, 2010
Downgraded to Caa1 (sf)

Cl. AP-1, Upgraded to B1 (sf); previously on December 9, 2010
Downgraded to B2 (sf)

Cl. AP-2, Upgraded to B2 (sf); previously on December 9, 2010
Downgraded to B3 (sf)

Cl. AP-3, Upgraded to B3 (sf); previously on December 9, 2010
Downgraded to Caa1 (sf)

Cl. AP-4, Upgraded to Caa1 (sf); previously on December 9, 2010
Downgraded to Caa2 (sf)

Cl. LP-3, Affirmed at Caa3 (sf); previously on December 9, 2010
Downgraded to Caa3 (sf)

Cl. HH-1, Affirmed at B1 (sf); previously on October 21, 2010
Downgraded to B1 (sf)

Cl. FSN-1, Affirmed at Caa3 (sf); previously on December 9, 2010
Downgraded to Caa3 (sf)

Cl. FSN-2, Affirmed at Ca (sf); previously on December 9, 2010
Downgraded to Ca (sf)

Cl. X-1B, Affirmed at Aaa (sf); previously on July 6, 2007
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The affirmations are due to key parameters, including Moody's loan
to value (LTV) ratio and Moody's stressed debt service coverage
ratio (DSCR) remaining within acceptable ranges. Moody's does not
rate pooled classes C, D, E, F, G, H, J, K, and L which provide
additional credit support for the pool.

The upgrades of the rakes, or non-pooled classes tied to the
Ashford Portfolio Loan were due to collateral performance of the
loan exceeding Moody's expectations since last review.

Moody's analysis reflects a forward-looking view of the likely
range of collateral performance over the medium term. From time to
time, Moody's may, if warranted change these expectations.
Performance that falls outside an acceptable range of the key
parameters may indicate that the collateral's credit quality is
stronger or weaker than Moody's had anticipated during the
previous 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 principal methodology used in this rating was "Moody's
Approach to Rating CMBS Large Loan/Single Borrower Transactions"
published on July 2000.

Moody's review incorporated the use of 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 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. Large
loan transactions generally have a Herf of less than 20. The pool
has a Herf of 2.

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.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
certificate balance decreased slightly to $1.66 billion from $1.68
billion at last review and from $1.97 billion at securitization.
The Certificates are collateralized by eight floating rate whole
loans and senior interests in whole loans. One loan (the Mondrian
Hotel Loan) paid off since last review. One loan (the Hudson Hotel
Loan) has pari-passu portions in Citibank Commercial Mortgage
Trust Commercial Mortgage Pass-Through Certificates, Series 2007-
FL3 transaction. The loans range in size from 2% to 65% of the
pooled balance, with the top three loans representing
approximately 82% of the pool. All of the loans have additional
debt in the form of a non-pooled or rake bond within the trust, B
note or mezzanine debt outside of the trust.

Recent volatility in the CMBS lending markets may reduce liquidity
options available to large loan borrowers. Given the current low
interest rate environment and existing low loan spreads, which
determine rates on most floating-rate loans, borrowers may seek
loan maturity extensions even if alternative financing options
were available. In either case, borrower requests for maturity
date extensions may increase. Moody's believes that the special
servicers will evaluate these requests and act in the best
interest of certificate holders as a whole.

The largest loan in the pool is secured by fee interests in the
LXR Hospitality Pool Loan ($948 million, or 65% of the pooled
balance plus $124 million of rake bonds within the trust). The
hotel portfolio includes 12 properties located in Puerto Rico, FL,
CA, AZ, Jamaica and NY. The Park Shore Waikiki asset located in
Hawaii was released. The sponsor is The Blackstone Group. There is
additional debt in the form of non-trust junior component and
mezzanine debt outside the trust.

For the year-end 2010, the LXR Hospitality Pool Loan achieved an
EBITDA of $57 million, and $65 million for the trailing twelve
month period ending June 2011. The portfolio is heavily
concentrated in upper upscale resort and destination properties.
The weighted average LTV for the pooled portion is 89%, including
rakes is 101% and for the first mortgage is 119%. Moody's current
credit estimate for the pooled portion is B1, the same as last
review.

The pool's second largest loan, the Longhouse Hospitality Pool
Loan ($150 million, or 10% of pooled balance plus $16 million of
rake bonds within the trust), is secured by cross-collateralized
and cross-defaulted 42 extended-hotel properties totaling 5,600
guestrooms. The sponsor is JER Partners and Longhouse Hospitality
Trust. The loan was transferred to special servicing on October
26, 2010 due to imminent default, but has been modified and is
pending return to master servicer.

The portfolio's Net Cash Flow (NCF) for year-end 2010 was
$13.3 million and the trailing twelve month period ending March
2011 was $10.5 million. The portfolio was damaged by two storms
in April and the borrower and the servicer are currently in the
process of going through the claim process. There is additional
debt in the form of mezzanine outside the trust. Moody's weighted
average LTV for the pooled portion is 101%, and including rakes is
111%. Moody's current credit estimate for the pooled portion is
Caa2, same as last review.

The third largest loan, the Ashford Hospitality Pool Loan
($79 million, or 5% of pooled balance plus $15 million of rake
bonds within the trust), is secured by ten cross-collateralized
and cross-defaulted hotel properties totaling 1,711 guestrooms.
The sponsor is Ashford Hospitality Trust, Inc. Eight properties
have been released since securitization, and the trust debt amount
was reduced by approximately $117 million.

Continuing to show improvement, the portfolio's Net Cash Flow
(NCF) for the trailing twelve month period ending April 2011 was
$12.1 million. There is additional debt in the form of a mezzanine
loan outside the trust. Moody's weighted average LTV for the
pooled portion is 74%, and including rakes is 89%. Moody's current
credit estimate for the pooled portion is Ba3 compared to B1 at
last review.

There are currently five loans totaling 25% of pooled balance in
special servicing. Four of the five loans have been modified and
pending return to master servicer or are in forbearance. The fifth
loan, the Four Seasons Nevis Loan (3% of the pooled balance) was
transferred to special servicing in October 2008 when it was
damaged by Hurricane Omar. The trust foreclosed on the property on
May 27, 2010, and the property's current status is REO. The
property reopened on December 15, 2010, and is in the process
stabilizing its operations.

Moody's weighted average pooled LTV ratio is 90% and Moody's
weighted average stressed debt service coverage ratio (DSCR) for
pooled trust debt is 0.75X. Moody's weighted average LTV for the
trust including the rake bonds is 101% and Moody's weighted
average stressed debt service coverage ratio (DSCR) for the trust
including the rake bonds is 0.67X. Classes K, L, FSN-1 and FSN-2
have incurred interest shortfalls and Class HH-2 has suffered
losses totaling $36,744 as of July 2011 distribution date.


WACHOVIA BANK: Moody's Affirms Ratings of 17 Classes of Notes
-------------------------------------------------------------
Moody's Investors Service (Moody's) upgraded the ratings of four
classes and affirmed the ratings of 17 classes of Wachovia Bank
Commercial Mortgage Trust, Commercial Mortgage Pass-Through
Certificates, Series 2005-C18:

Cl. A-3, Affirmed at Aaa (sf); previously on Jun 6, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-PB, Affirmed at Aaa (sf); previously on Jun 6, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-4, Affirmed at Aaa (sf); previously on Jun 6, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-1A, Affirmed at Aaa (sf); previously on Jun 6, 2005
Definitive Rating Assigned Aaa (sf)

Cl. A-J-2, Affirmed at A3 (sf); previously on Dec 10, 2010
Downgraded to A3 (sf)

Cl. A-J-1, Affirmed at Aaa (sf); previously on Dec 10, 2010
Confirmed at Aaa (sf)

Cl. B, Affirmed at Baa3 (sf); previously on Dec 10, 2010
Downgraded to Baa3 (sf)

Cl. C, Affirmed at Ba2 (sf); previously on Dec 10, 2010 Downgraded
to Ba2 (sf)

Cl. D, Affirmed at B3 (sf); previously on Dec 10, 2010 Downgraded
to B3 (sf)

Cl. E, Upgraded to Caa1 (sf); previously on Dec 10, 2010
Downgraded to Caa2 (sf)

Cl. F, Upgraded to Caa2 (sf); previously on Dec 10, 2010
Downgraded to Caa3 (sf)

Cl. G, Upgraded to Caa3 (sf); previously on Dec 10, 2010
Downgraded to Ca (sf)

Cl. H, Upgraded to Ca (sf); previously on Dec 10, 2010 Downgraded
to C (sf)

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

Cl. K, Affirmed at C (sf); previously on Oct 15, 2009 Downgraded
to C (sf)

Cl. L, Affirmed at C (sf); previously on Oct 15, 2009 Downgraded
to C (sf)

Cl. M, Affirmed at C (sf); previously on Oct 15, 2009 Downgraded
to C (sf)

Cl. N, Affirmed at C (sf); previously on Oct 15, 2009 Downgraded
to C (sf)

Cl. O, Affirmed at C (sf); previously on Oct 15, 2009 Downgraded
to C (sf)

Cl. X-P, Affirmed at Aaa (sf); previously on Jun 6, 2005
Definitive Rating Assigned Aaa (sf)

Cl. X-C, Affirmed at Aaa (sf); previously on Jun 6, 2005
Definitive Rating Assigned Aaa (sf)

RATINGS RATIONALE

The upgrades are due to lower than expected losses from loans in
special servicing along with increased credit support due to loan
payoffs and amortization. Since the prior review, the special
servicer, Helios AMC, successfully restructured four loans; three
of which have already returned to the master servicer. All four
loans are current and performing.

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
6.5% of the current balance. At last review, Moody's cumulative
base expected loss was 7.6%. Moody's stressed scenario loss is
14.0% 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.

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 performance in the commercial real
estate property markets. While commercial real estate property
markets are gaining momentum, a consistent upward trend will not
be evident until the volume of transactions increases, distressed
properties are cleared from the pipeline, and job creation
rebounds. The hotel and multifamily sectors are continuing to show
signs of recovery through the first half of 2011, while recovery
in the non-core office and retail sectors are tied to pace of
recovery of the broader economy. Core office markets are showing
signs of recovery through lending and leasing activity. 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 as
the most likely scenario through 2012, amidst ongoing individual,
corporate and governmental deleveraging, persistent unemployment,
and government budget considerations, however the downside risks
to the outlook have risen since last quarter.

The primary methodologies used in these ratings were: "Moody's
Approach to Rating Fusion U.S. CMBS Transactions" published on
April 2005 and "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 2.60 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 13 compared to 15 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 8.1 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 10, 2010.

DEAL PERFORMANCE

As of the July 15, 2011 distribution date, the transaction's
aggregate certificate balance has decreased by 19% to $1.14
billion from $1.41 billion at securitization. The Certificates are
collateralized by 56 mortgage loans ranging in size from less than
1% to 13% of the pool, with the top ten non-defeased loans
representing 54% of the pool. Three loans, representing 13% of the
pool, have defeased and are secured by U.S. Government securities.
Defeasance at last review represented 14% of the pool. The pool
contains one loan with an investment grade credit estimate,
representing 2% of the pool.

Fourteen loans, representing 27% 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.

One loan has been liquidated from the pool, resulting in a
realized loss of $18.0 million (33% loss severity). Currently
three loans, representing 9% of the pool, are in special
servicing. The largest specially serviced loan is the Park Place
II Loan ($94.2 million -- 8.2% of the pool), which is secured by a
550,000 square foot (SF) mixed use building located in Irvine,
California. The loan was transferred to special servicing in
August 2009 due to imminent default related to a decline in market
conditions. In July 2010, a new borrower purchased the property
and assumed the existing debt. The special servicer and new
borrower successfully executed a loan modification where the
borrower made a $4 million principal pay down of the note while
bifurcating the existing debt into a $84 million A-Note and $10.2
million B-Note. Though the loan is current and pending return to
the master servicer, Moody's is expecting a loss on the whole loan
at this time.

The remaining two specially serviced properties are secured by an
apartment complex and self storage center. Moody's estimates an
aggregate $24.0 million loss for the specially serviced loans
(23.0% expected loss on average).

Moody's has assumed a high default probability for seven poorly
performing loans representing 11% of the pool and has estimated an
aggregate $22.6 million loss (18.9% expected loss on average) from
these troubled loans.

Excluding specially serviced and defeased loans, Moody's was
provided with full year 2010 operating results for 100% of the
pool. Excluding specially serviced and troubled loans, Moody's
weighted average LTV is 96% compared to 99% 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
9.4%.

Excluding special serviced and troubled loans, Moody's actual and
stressed DSCRs are 1.48X and 1.08X, respectively, compared to
1.41X and 1.06X 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 2700 Broadway Loan ($27.5
million -- 2.4% of the pool), which is secured by a 25,000 SF
condominium interest in the retail portion of a mixed-use building
located in New York City. The condo unit is 100% leased to the
Trustees of Columbia University through October 2054. Moody's
current credit estimate is A2, the same as at last review.

The top three performing conduit loans represent 31% of the pool
balance. The largest loan is the One & Two International Place
Loan ($201.6 million -- 17.6% of the pool), which represents a 50%
pari-passu interest in a first mortgage loan. The loan is secured
by two Class A office towers, totaling 1.9 million SF located in
Boston, Massachusetts. The property was 73% leased as of March
2011 compared to 70% at last review. Performance improved since
last review due to increased revenue from new tenants along with a
$2.2 million cost saving in real estate taxes. Moody's LTV and
stressed DSCR are 80% and 1.15X, respectively, compared to 83% and
1.11X at last review.

The second largest loan is the Kadima Medical Office Pool Loan
($108.3 million -- 9.5% of the pool), which is secured by 16
medical office buildings totaling 779,000 SF. The properties are
located in eight states with the largest concentration in Florida
(8 properties). The portfolio was 94% leased as of March 2011
compared to 91% at last review. Property performance has been
stable and the loan has amortized 15% since securitization.
Moody's LTV and stressed DSCR are 106% and 1.05X, respectively,
compared to 111% and 1.00X at last review.

The third largest loan is the 590 Fifth Avenue Loan ($38.7 million
-- 3.4% of the pool), which is secured by a 98,000 SF office
building in New York City. The property was 72% leased as of March
2011 compared to 79% at last review. Though occupancy declined
since the last review, a tenant's (19% of the NRA) free rent
period recently expired in November 2010. This additional income
was not reflected in the 2010 net operating income. Moody's
current valuation includes this additional future income. Moody's
LTV and stressed DSCR are 111% and 0.88X, respectively, compared
to 124% and 0.87X at last review.


WASHINGTON MUTUAL: Modeled Losses Cue Fitch to Downgrade Ratings
----------------------------------------------------------------
Fitch Ratings downgrades three and upgrades five classes of
Washington Mutual Asset Securities Corporation (WAMU) commercial
mortgage pass-through certificates, series 2005-C1.

The downgrades are the result an increase in Fitch modeled losses
attributed primarily to delinquent loans. Fitch modeled losses of
4.6% of the remaining pool.  The upgrades of the senior classes
are the result of increased credit enhancement due to paydown
which is sufficient to offset Fitch expected losses.

As of the July 2011 distribution date, the pool's collateral
balance has paid down 87% to $87.1 million from $649.5 million at
issuance.  Two loans (11.3%) are currently in special servicing.
Fitch has identified 12 loans (32%) as Fitch loans of concern
including the two (11.3%) specially serviced loans.

The largest contributor to Fitch modeled loss (9.2%) is secured by
a single tenant office building located in Seattle, WA.  The
property vacated at their lease expiration in July 2011 and the
property is not 100% vacant.  The loan is scheduled to mature in
November 2011 and Fitch expects the borrower may be unable to
refinance without a replacement tenant.

The largest specially serviced loan (6.3%) is secured by a 60,448
square foot (sf) office building located in Bothell, WA.  The loan
transferred to special servicing in February 2011 due to a
maturity default.  The borrower is expected to refinance the loan
once the lease renewal with the tenant, McGraw Hill is executed.
McGraw Hill's current lease expires on Dec. 31, 2011.  The
borrower continues to make the monthly debt service payments.

Fitch downgrades and revises Recovery Ratings (RR) Outlooks as
follows:

  -- $2.4 million class K to 'Bsf' from 'BB-sf'; Outlook Negative;
  -- $2.4 million class L to 'CCsf/RR2' from 'B+sf';
  -- $812,000 class M to 'Csf/RR6' from 'CCCsf/RR2'.

Fitch also upgrades and revises rating outlooks on the following
classes:

  -- $4.1 million class D to 'AAAsf' from 'AAsf'; Outlook Stable;
  -- $5.7 million class E to 'AAAsf' from 'A+sf'; Outlook Stable;
  -- $4.9 million class F to 'AAsf' from 'Asf'; Outlook Stable;
  -- $5.7 million class G to 'Asf' from 'BBB+sf'; Outlook to
     Stable from Negative;
  -- $8.1 million class H to 'BBBsf' from 'BB+sf'; Outlook to
     Stable from Negative.

In addition, Fitch affirms the following classes as indicated:

  -- $26.3 million class A-J at 'AAAsf'; Outlook Stable;
  -- $8.9 million class B at 'AAAsf'; Outlook Stable;
  -- $13 million class C at 'AAAsf'; Outlook Stable;
  -- $3.3 million class J at 'BBsf'; Outlook Negative.

The $1.5 million class N remains at 'D' recovery rating revised to
'RR6' from 'RR2'.

Classes A-1 and A-2 are paid in full.

Fitch withdraws the rating of the interest-only class X.  For
additional information on the withdrawal of the rating on the
interest-only classes, see 'Fitch Revises Practice for Rating IO &
Pre-Payment Related Structured Finance Securities', dated June 23,
2010.


WFRBS COMMERCIAL: Moody's Assigns Ratings to 14 CMBS Classes
------------------------------------------------------------
Moody's Investors Service has assigned ratings to 14 classes of
CMBS securities, issued by WFRBS Commercial Mortgage Trust 2011-
C4, Commercial Mortgage Pass-Through Certificates, Series 2011-C4.

Cl. A-1, Definitive Rating Assigned Aaa (sf)

Cl. A-2, Definitive Rating Assigned Aaa (sf)

Cl. A-3, Definitive Rating Assigned Aaa (sf)

Cl. A-FL*, Definitive Rating Assigned Aaa (sf)

Cl. A-4, Definitive Rating Assigned Aaa (sf)

Cl. B, Definitive Rating Assigned Aa2 (sf)

Cl. C, Definitive Rating Assigned A2 (sf)

Cl. D, Definitive Rating Assigned Baa1 (sf)

Cl. E, Definitive Rating Assigned Baa3 (sf)

Cl. F, Definitive Rating Assigned Ba2 (sf)

Cl. G, Definitive Rating Assigned B2 (sf)

Cl. A-FX*, Definitive Rating Assigned Aaa (sf)

Cl. X-A, Definitive Rating Assigned Aaa (sf)

Cl. X-B, Definitive Rating Assigned Aaa (sf)

* Exchangeable.

RATINGS RATIONALE

The Certificates are collateralized by 76 fixed rate loans secured
by 132 properties. The ratings are based on the collateral and the
structure of the transaction.

Moody's CMBS ratings methodology combines both commercial real
estate and structured finance analysis. Based on commercial real
estate analysis, Moody's determines the credit quality of each
mortgage loan and calculates an expected loss on a loan specific
basis. Under structured finance, the credit enhancement for each
certificate typically depends on the expected frequency, severity,
and timing of future losses. Moody's also considers a range of
qualitative issues as well as the transaction's structural and
legal aspects.

The credit risk of loans is determined primarily by two factors:
1) Moody's assessment of the probability of default, which is
largely driven by each loan's DSCR, and 2) Moody's assessment of
the severity of loss upon a default, which is largely driven by
each loan's LTV ratio.

The Moody's Actual DSCR of 1.72X is higher than the 2007
conduit/fusion transaction average of 1.31X. The Moody's Stressed
DSCR of 1.19X is higher than the 2007 conduit/fusion transaction
average of 0.92X. Moody's Trust LTV ratio of 88.3% is lower than
the 2007 conduit/fusion transaction average of 110.6%.

Moody's also considers both loan level diversity and property
level diversity when selecting a ratings approach. With respect to
loan level diversity, the pool's loan level Herfindahl score is
27.9. With respect to property level diversity, the pool's
property level Herfindahl score is 40.7. The transaction's
property diversity profile is within the band of Herfindahl scores
found in previously rated conduit and fusion securitizations.

Moody's also grades properties on a scale of 1 to 5 (best to
worst) and considers those grades when assessing the likelihood of
debt payment. The factors considered include property age, quality
of construction, location, market, and tenancy. The pool's
weighted average property quality grade is 2.3, which is in the
band of average grades found in previously rated conduit and
fusion securitizations.

The transaction benefits from two loans, representing
approximately 10.6% of the pool balance in aggregate, assigned an
investment grade credit estimate. Loans assigned investment grade
credit estimates are not expected to contribute any loss to a
transaction in low stress scenarios, but are expected to
contribute minimal amounts of loss in high stress scenarios.

The principal methodology used in rating WFRBS 2011-C4 was "CMBS:
Moody's Approach to Rating Fusion Transactions" published in April
2005.

Other methodologies and factors that may have been considered in
the process of rating this issuer can also be found on Moody's
website.

In addition, Moody's publishes a weekly summary of structured
finance credit, ratings and methodologies, available to all
registered users of Moody's website, at
www.moodys.com/SFQuickCheck.

Moody's analysis employs the excel-based CMBS Conduit Model v2.50
which derives credit enhancement levels based on an aggregation of
adjusted loan level proceeds derived from Moody's loan level DSCR
and LTV ratios. Major adjustments to determining proceeds include
loan structure, property type, sponsorship and diversity.

The V Score for this transaction is assessed as Low/Medium, the
same as the V score assigned to the U.S. Conduit and CMBS sector.
This reflects typical volatility with respect to the critical
assumptions used in the rating process as well as an average
disclosure of securitization collateral and ongoing performance.

Moody's V Scores provide a relative assessment of the quality of
available credit information and the potential variability around
the various inputs to a rating determination. The V Score ranks
transactions by the potential for significant rating changes owing
to uncertainty around the assumptions due to data quality,
historical performance, the level of disclosure, transaction
complexity, the modeling, and the transaction governance that
underlie the ratings. V Scores apply to the entire transaction
(rather than individual tranches).

Moody's Parameter Sensitivities: If Moody's value of the
collateral used in determining the initial rating were decreased
by 5%, 14%, or 23%, the model-indicated rating for the currently
rated Aaa classes would be Aa1, Aa3, A2, respectively. Parameter
Sensitivities are not intended to measure how the rating of the
security might migrate over time; rather they are designed to
provide a quantitative calculation of how the initial rating might
change if key input parameters used in the initial rating process
differed. The analysis assumes that the deal has not aged.
Parameter Sensitivities only reflect the ratings impact of each
scenario from a quantitative/model-indicated standpoint.
Qualitative factors are also taken into consideration in the
ratings process, so the actual ratings that would be assigned in
each case could vary from the information presented in the
Parameter Sensitivity analysis.

These ratings: (a) are based solely on information in the public
domain and/or information communicated to Moody's by the issuer at
the date it was prepared and such information has not been
independently verified by Moody's; (b) must be construed solely as
a statement of opinion and not a statement of fact or an offer,
invitation, inducement or recommendation to purchase, sell or hold
any securities or otherwise act in relation to the issuer or any
other entity or in connection with any other matter. Moody's does
not guarantee or make any representation or warranty as to the
correctness of any information, rating or communication relating
to the issuer. Moody's shall not be liable in contract, tort,
statutory duty or otherwise to the issuer or any other third party
for any loss, injury or cost caused to the issuer or any other
third party, in whole or in part, including by any negligence (but
excluding fraud, dishonesty and/or willful misconduct or any other
type of liability that by law cannot be excluded) on the part of,
or any contingency beyond the control of, Moody's, or any of its
employees or agents, including any losses arising from or in
connection with the procurement, compilation, analysis,
interpretation, communication, dissemination, or delivery of any
information or rating relating to the issuer.


WHITE KNIGHT: DBRS Confirms Floating Rate Note Rating at 'B'
------------------------------------------------------------
DBRS has confirmed the Floating Rate Notes (the Notes) issued by
White Knight Investment Trust (WKIT) at B (high) (sf).

WKIT was created as part of a restructuring of Skeena Capital
Trust in December 2007.  WKIT is a bankruptcy-remote special-
purpose vehicle whose business is strictly limited to entering
into and administering WKIT's asset interests (the Asset
Interests), which consist of tranche investments in six
highly rated underlying credit default swaps (CDSs).

As part of the restructuring, a significant amount of leverage was
employed for each of the synthetic collateralized debt obligation
(CDO) tranches.  However, the concept of margin calls to increase
the funded amount for negative mark-to-market movements on the
value of each underlying Asset Interest was removed for all
transactions.  As a result, the rating of the Notes is primarily
based on the credit quality of the Asset Interests.

The Notes have been downgraded on a number of occasions since the
restructuring due to the credit deterioration of many of the
underlying corporate credits referenced by one of the six CDSs
(the Transaction).  The Notes were last downgraded on October 16,
2009, when DBRS downgraded the Transaction to B (high) (sf) due to
severe downgrades to the rating of AIFUL Corporation (AIFUL) and
other downgrades affecting entities referenced by the Transaction.

In November 2010, a credit event was triggered for Ambac Financial
Group Inc.  DBRS had used conservative probability of default
assumptions for the entity in the months leading up to the credit
event.  As a result, the credit event did not have an impact on
the rating of the Notes.  No other credit events have occurred
since November 2010.  In total, nine underlying entities in the
Transaction have suffered credit events since inception, resulting
in 500 bps in losses.  The remaining subordination of the
Transaction is 10%.  The performance of the Transaction has been
stable over the past few months as very few significant negative
rating actions have occurred.

The rating of B (high) (sf) is sufficient based on the current
level of subordination relative to the required level of
subordination, which is mainly based on the ratings distribution,
industry diversification and regional diversification of obligors
referenced by the Transaction's portfolio, as well as on the
remaining term of the Transaction.

DBRS rates the Notes at the level of the lowest-rated transaction
funded by the Notes. The Transaction remains the lowest-rated
transaction and its rating therefore determines the highest
possible rating for WKIT overall.

WKIT has these challenges:

  * The Transaction has 42% exposure to non-investment-grade
    obligors.  Rating downgrades or defaults could negatively
    affect the rating of the Transaction (and the Notes).

  * Of the portfolio's underlying ratings (notional-weighted), 28%
    are currently on negative watch or negative trend by at least
    one rating agency.

  * Due to the significant amount of leverage employed in each
    underlying CDS, the collateral-commingling arrangement at
    final maturity subjects noteholders to the risk that an
    incurred loss experienced under any of the six underlying CDO
    tranches will result in severe losses to the Notes.

The scheduled maturity of the Notes is December 20, 2016.  DBRS
actively monitors the credit quality of WKIT and will provide
further updates as necessary.


* S&P Cuts Ratings on 11 Classes of 3 Wachovia Bank Certs. to 'D'
-----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 15
classes of commercial mortgage pass-through certificates from
Wachovia Bank Commercial Mortgage Trust's series 2004-C11,
2006-C29, and 2007-C30, which are U.S. commercial mortgage-backed
securities (CMBS) transactions.

The downgrades reflect current and potential interest shortfalls.
"We lowered our ratings on 11 of these classes to 'D (sf)' because
we expect the accumulated interest shortfalls to remain
outstanding for the foreseeable future. The 11 classes that we
downgraded to 'D (sf)' have had accumulated interest shortfalls
outstanding between four and 14 months," S&P related. The
recurring interest shortfalls for the certificates are primarily
due to one or more of the 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 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.

     Wachovia Bank Commercial Mortgage Trust Series 2004-C11

"We lowered our ratings on the class N and O certificates.
We lowered our rating to 'D (sf)' on the class O certificate
to reflect accumulated interest shortfalls outstanding for
four months, resulting from ASER amounts related to three
($42.9 million, 5.4%) of the five assets ($131.0 million, 16.5%)
that are currently with the special servicer, CWCapital Asset
Management LLC (CWCapital), as well as special servicing fees. We
lowered our rating on class N due to reduced liquidity support
available to this class resulting from the recurring interest
shortfalls. As of the July 15, 2011, trustee remittance report,
ARAs totaling $5.9 million were in effect for three assets, and
the total reported monthly ASER amount on these assets was
$25,868. The reported monthly interest shortfalls totaled
$49,776," S&P stated.

      Wachovia Bank Commercial Mortgage Trust Series 2006-C29

"We lowered our ratings on the class G, H, J, K, and L
certificates. We lowered our ratings on classes J, K, and
L to 'D (sf)' to reflect accumulated interest shortfalls
outstanding for 14 months, resulting from ASER amounts
related to 12 ($249.4 million, 7.5%) of the 17 ($323.1 million,
9.7%) assets that are currently with the special servicer, Helios
AMC LLC (Helios), as well as special servicing fees and interest
rate reduction due to loan modifications ($265,156). We downgraded
the class G and H certificates due to reduced liquidity support
available to these classes as a result of the continued interest
shortfalls. As of the July 15, 2011, trustee remittance report,
ARAs totaling $98.7 million were in effect for 12 assets, and the
total reported monthly ASER amount on these assets was $417,029.
The total monthly interest shortfall reported this month was
$1.63 million; however, it is our understanding from the master
servicer and trustee that interest reduction due to nonrecoverable
determination of $113,277 for the Santan Village Phase III
loan as reported in the July 2011 trustee remittance report
was erroneous, and interest adjustment of $735,779 related to
the Hilton - Providence, R.I., loan was due to correcting a
miscalculation of interest. The current reported monthly interest
shortfalls affected all of the classes subordinate to and
including class B," S&P said.

     Wachovia Bank Commercial Mortgage Trust Series 2007-C30

"We lowered our ratings on the class D, E, F, G, H, J, K, and
L certificates. We lowered our ratings on classes E, F, G, H,
J, K, and L to 'D (sf)' to reflect accumulated interest
shortfalls outstanding between six and 10 months, resulting
from ASER amounts related to nine ($1.58 billion, 20.3%) of the
thirteen ($1.64 billion, 21.1%) assets that are currently with
the special servicer, CWCapital, as well as special servicing
fees, nonrecoverability determination ($26,736), and interest
rate reduction due to loan modifications ($880,463). We downgraded
class D 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 $433.1 million were in effect for 11 assets, and the
total reported monthly ASER amount on these assets, net of ASER
recovery of $156,266 on a modified loan, was $1.68 million. The
reported monthly ASER on the largest specially serviced asset,
the Peter Copper Village & Stuyvesant Town Multifamily Pool loan,
was $1.65 million. The reported monthly interest shortfalls
totaled $2.98 million, and have affected all of the classes
subordinate to and including class E," S&P added.

Ratings Lowered

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2004-C11

                            Credit            Reported
          Rating       enhancement     interest shortfalls ($)
Class  To        From          (%)     Current     Accumulated
N      CCC- (sf) B (sf)       1.81        (746)              0
O      D (sf)    CCC+ (sf)    1.48      (1,327)         44,764

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C29

                              Credit         Reported
          Rating         enhancement   interest shortfalls ($)
Class  To        From            (%)    Current    Accumulated
G      CCC- (sf) B (sf)         4.53     177,758       177,758
H      CCC- (sf) B- (sf)        3.52     160,115       160,115
J      D (sf)    CCC- (sf)      2.38     180,129     1,261,747
K      D (sf)    CCC- (sf)      2.00      53,402       747,627
L      D (sf)    CCC- (sf)      1.75      35,601       498,418

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2007-C30

                              Credit          Reported
             Rating      enhancement  interest shortfalls ($)
Class  To        From            (%)     Current  Accumulated
D      CCC- (sf) CCC+ (sf)      8.57           0            0
E      D (sf)    CCC (sf)       7.81     185,512    1,140,402
F      D (sf)    CCC- (sf)      6.92     322,896    1,937,377
G      D (sf)    CCC- (sf)      5.65     467,790    3,465,058
H      D (sf)    CCC- (sf)      4.64     383,923    3,493,740
J      D (sf)    CCC- (sf)      3.50     431,911    3,930,441
K      D (sf)    CCC- (sf)      2.48     383,923    3,493,740
L      D (sf)    CCC- (sf)      1.97     165,119    1,611,014


* S&P Cuts Ratings on 1,435 Classes from 363 CMBS Subprime Deals
----------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 1,435
classes from 356 U.S. residential mortgage-backed securities
(RMBS) transactions backed by subprime mortgage loans issued in
2005-2007, and removed 901 of them from CreditWatch with negative
implications. "In addition, we affirmed our ratings on 1,313
classes from 307 of the transactions with lowered ratings and
seven additional transactions, and removed 810 of them from
CreditWatch negative," S&P related.

The complete ratings rating list is available for free at:

     http://bankrupt.com/misc/S&P_Subprime_RMBS_RA_81111.pdf

"The downgrades reflect our opinion that the projected credit
enhancement for the affected classes is insufficient to maintain
the previous ratings, given our current projected losses. The
affirmations reflect our belief that the projected credit
enhancement available for these classes is sufficient to
cover projected losses associated with these rating levels," S&P
related.

"In our review, we included transaction-specific loss projections,
which were published in 'Transaction-Specific Lifetime Loss
Projections For Prime, Subprime, And Alternative-A U.S. RMBS
Issued In 2005-2007,' on June 27, 2011. In order to maintain a 'B'
rating on a class, we assessed whether, in our view, a class could
absorb the 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,
while we would assess whether a different class could withstand
approximately 120% of our remaining base-case loss assumptions to
maintain a 'BBB' rating. 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 and overcollateralization (prior to its depletion)
and excess spread, when applicable, provide credit support for the
affected transactions. The underlying collateral for these deals
consists of fixed- and adjustable-rate U.S. subprime mortgage
loans secured mostly by first liens on one- to four-family
residential properties.


* S&P Cuts Ratings on 1,692 Classes from 256 CMBS Transactions
--------------------------------------------------------------
Standard & Poor's Ratings Services lowered its ratings on 1,692
classes from 244 U.S. residential mortgage-backed securities
(RMBS) transactions and removed 763 of them from CreditWatch with
negative implications. "Concurrently, we affirmed our ratings on
558 classes from the downgraded transactions, as well as 11 other
transactions, and removed 186 of them from CreditWatch negative.
We also withdrew our ratings on 38 classes from 25 transactions
based on our interest-only criteria and removed 33 of them from
CreditWatch negative," S&P said.

The complete rating list is available for free at:

    http://bankrupt.com/misc/S&P_RMBS_RA_81111.pdf


The 256 RMBS transactions in this review are backed by
Alternative-A (Alt-A) or prime jumbo mortgage loan collateral
issued from 2004 through 2007.

"On May 11, 2011, we placed a number of U.S. RMBS ratings on
CreditWatch with negative implications (see '7,389 Ratings From
2005-2007 U.S. Prime, Subprime, And Alt-A RMBS On Watch Neg Due To
Revised Loss Projections'). For revised transaction specific loss
projections associated with these transactions, see 'RMBS:
Transaction-Specific Lifetime Loss Projections For Prime,
Subprime, And Alternative-A U.S. RMBS Issued In 2005-2007,'
published June 27, 2011," S&P said.

"We applied our criteria listed in the "Related Criteria And
Research" section to derive the loss assumptions used in our
analysis," S&P stated.

"The downgrades reflect our belief that projected credit
enhancement for 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 enhancement available for these classes is sufficient to
cover projected losses associated with these rating levels," S&P
related.

Rating actions in this release take into account transaction
specific loss projections where applicable, as well as the
criteria associated for additional transactions. "In order to
maintain a 'B' rating on a class, we assessed whether, in our
view, a class could absorb the base-case loss assumptions we used
in our analysis. For Alt-A transactions, 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,
while we would assess whether a different class could withstand
approximately 120% of our remaining base-case loss assumptions to
maintain a 'BBB' rating. Each class with an affirmed 'AAA' rating
can, in our view, withstand approximately 150% of our remaining
base-case loss assumptions under our analysis. For prime jumbo
transactions, we assessed whether a class could withstand 127% of
our base-case loss assumption in order to maintain a 'BB'
rating, while we assessed whether a different class could
withstand 154% of our base-case loss assumptions to maintain a
'BBB' rating. Each class that has an affirmed 'AAA' rating can
withstand approximately 235% of our base-case loss assumptions,"
S&P stated.

Subordination and overcollateralization (prior to its depletion)
and excess spread, when applicable, provide credit support for the
affected transactions.


* S&P Withdraws Ratings on 119 Classes from 59 CMBS and CDO Deals
-----------------------------------------------------------------
Standard & Poor's Ratings Services withdrew its ratings on 119
classes from 59 commercial mortgage-backed securities (CMBS), and
commercial real estate collateralized debt obligation (CRE CDO)
transactions.

"We withdrew our ratings on 106 classes from 56 CMBS and CRE CDO
transactions following the repayment of each classes' principal
balance, as noted in each transaction's June and/or July 2011
trustee remittance reports. We withdrew our ratings on seven
interest-only (IO) classes from six transactions following the
reduction of the classes' notional balances as noted in each
transaction's June and/or July 2011 trustee remittance reports,"
S&P related.

"We also withdrew our ratings on six additional IO classes
following the repayment of all principal and interest paying
classes rated 'AA- (sf)' or higher from the CMBS transaction, in
accordance with our criteria for rating IO securities," S&P said.

Ratings Withdrawn Following Repayment or Reduction of Notional
Balance

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2000-1
                                 Rating
Class                    To                  From
E                        NR                  AAA (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2000-2
                                 Rating
Class                    To                  From
F                        NR                  AA+ (sf)
G                        NR                  A+ (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through, certificates, series 2001-PB1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)
A-2F                     NR                  AAA (sf)
B                        NR                  AAA (sf)
C                        NR                  AAA (sf)

Banc of America Commercial Mortgage Inc.
Commercial mortgage pass-through certificates series 2005-6
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Banc of America Commercial Mortgage Trust 2007-4
Commercial mortgage pass-through, certificates, series 2007-4
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Banc of America Structured Securities Trust
Commercial mortgage pass-through certificates series 2002-X1
                                 Rating
Class                    To                  From
O                        NR                  CCC-(sf)
P                        NR                  CCC-(sf)

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2001-TOP2
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2006-BBA7
                                 Rating
Class                    To                  From
A-1                      NR                  AA (sf)
A-2                      NR                  BBB (sf)
B                        NR                  BB+ (sf)
C                        NR                  BB (sf)
D                        NR                  B+ (sf)
E                        NR                  B (sf)
F                        NR                  B (sf)
G                        NR                  B-(sf)
X-3                      NR                  AA (sf)

Bear Stearns Commercial Mortgage Securities Trust
Commercial mortgage pass-through certificates series 2007-BBA8
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Brascan Structured Notes 2005-2 Ltd.
Collateralized debt obligations series 2005-2
                                 Rating
Class                    To                  From
C                        NR                  BB+ (sf)

California Infrastructure and Economic Development Bank Revenue
Bonds
Kaiser Hospital Assistance I - LLC Series 2001 B
                                 Rating
Class                    To                  From
B                        NR                  A (sf)

CAM 2002-CAM2
Commercial mortgage pass-through certificates series CAM02-CAM2
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Chase Manhattan Bank-First Union National Bank Commercial Mortgage
Trust
Commercial mortgage pass-through certificates series 1999-1
                                 Rating
Class                    To                  From
E                        NR                  AAA (sf)
F                        NR                  AAA (sf)

Column Canada Issuer Corp.
Commercial mortgage pass-through certificates series 2002-CCL1
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

COMM 2004-LNB3
Commercial mortgage pass-through certificates series 2004-LNB3
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

COMM 2006-FL12
                                 Rating
Class                    To                  From
AH1                      NR                  CCC-(sf)
AH2                      NR                  CCC-(sf)
AH3                      NR                  CCC-(sf)
AH4                      NR                  CCC-(sf)

Credit Suisse Commercial Mortgage Trust Series
Commercial mortgage pass-through certificates series 2006-C1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2000-C1
                                 Rating
Class                    To                  From
F                        NR                  AA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2004-C2
                                 Rating
Class                    To                  From
A-SP                     NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2005-C6
                                 Rating
Class                    To                  From
A-2FL                    NR                  AAA (sf)
A-2FX                    NR                  AAA (sf)

Credit Suisse First Boston Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2006-TFL1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)
A-X-1                    NR                  AAA (sf)
A-X-2                    NR                  AAA (sf)
B                        NR                  AAA (sf)
C                        NR                  AA (sf)
D                        NR                  A+ (sf)
E                        NR                  A-(sf)
F                        NR                  BBB+ (sf)
G                        NR                  BBB (sf)
H                        NR                  BBB-(sf)
J                        NR                  BB+ (sf)
K                        NR                  BB (sf)
L                        NR                  BB-(sf)

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2001-C2
                                 Rating
Class                    To                  From
J                        NR                  A+ (sf)
K                        NR                  BBB+ (sf)

First Union National Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2001-C3
                                 Rating
Class                    To                  From
D                        NR                  AAA (sf)
E                        NR                  AAA (sf)
F                        NR                  AA+ (sf)

First Union-Lehman Brothers-Bank of America Commercial Mortgage
Trust
Commercial mortgage pass-through certificates series 1998-C2
                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)

GE Capital Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2002-3
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

GE Commercial Mortgage Corp.
Commercial mortgage pass-through certificates series 2004-C3
                                 Rating
Class                    To                  From
X-2                      NR                  AAA (sf)

GE Commercial Mortgage Corp. Series 2007-C1 Trust
Commercial mortgage pass-through certificates series 2007-C1
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

GMAC Commercial Mortgage Securities Inc.
Commercial mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)

GS Mortgage Securities Corp. II
Commercial mortgage pass-through certificates series 2001-1285
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)
A-2                      NR                  AAA (sf)
B                        NR                  AAA (sf)
C                        NR                  AAA (sf)
D                        NR                  AA+ (sf)
E                        NR                  AA (sf)
X                        NR                  AAA (sf)

GS Mortgage Securities Corp. II
Commercial mortgage pass-through certificates series 2001-GLIII
                                 Rating
Class                    To                  From
J-GGP                    NR                  A+ (sf)

GS Mortgage Securities Corp. II
Commercial mortgage pass-through certificates series 2006-GSFL
VIII
                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)
D                        NR                  AA-(sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2001-A
                                 Rating
Class                    To                  From
C                        NR                  A+ (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-C1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2002-C3
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

JPMorgan Chase Commercial Mortgage Securities Corp.
Commercial mortgage pass-through certificates series 2004-CIBC9
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

JPMorgan Chase Commercial Mortgage Securities Trust
Commercial mortgage pass-through certificates series 2006-14
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

JPMorgan Chase Commercial Mortgage Securities Trust 2007-C1
Commercial mortgage pass-through certificates series 2007-C1
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

JPMorgan Commercial Mortgage Finance Corp.
Mortgage pass-through certs ser 1998-C6
                                 Rating
Class                    To                  From
E                        NR                  A (sf)

JPMorgan Commercial Mortgage Finance Corp.
Commercial mortgage pass-through certificates series 99-PLS1
                                 Rating
Class                    To                  From
F                        NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2005-C3
Commercial mortgage pass-through certificates series 2005-C3
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

LB-UBS Commercial Mortgage Trust 2006-C6
Commercial mortgage pass-through certificates series 2006-C6
                                 Rating
Class                    To                  From
JRP-3                    NR                  AAA (sf)
JRP-4                    NR                  AA+ (sf)
JRP-5                    NR                  AA-(sf)
JRP-6                    NR                  A+ (sf)
JRP-7                    NR                  A (sf)
JRP-8                    NR                  A-(sf)
JRP-9                    NR                  BBB+ (sf)

Lehman Brothers Floating Rate Commercial Mortgage Trust 2007-LLF C
Commercial mortgage pass-through certificates series 2007-LLF C5
                                 Rating
Class                    To                  From
FTC-1                    NR                  CCC-(sf)
FTC-2                    NR                  CCC-(sf)

LNR CFL 2004-1 Ltd.
CMBS resecuritization notes series 2004-CFL
                                 Rating
Class                    To                  From
I-8                      NR                  A+ (sf)
I-9                      NR                  BBB+ (sf)
I-10                     NR                  BBB-(sf)
I-11                     NR                  BB (sf)
I-12                     NR                  BB-(sf)
I-13                     NR                  B+ (sf)

Merrill Lynch Financial Assets Inc.
Commercial mortgage pass-through certificates series 2002-CAD7
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2005-IQ9
Commercial mortgage pass-through certificates series 2005-IQ9
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Morgan Stanley Capital I Trust 2007-HQ11
Commercial mortgage pass-through certificates series 2007-HQ11
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Morgan Stanley Dean Witter Capital I Trust 2002-IQ3
Commercial mortgage pass-through certificates series 2002-IQ3
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)
A-3                      NR                  AAA (sf)

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 1999-CM1
                                 Rating
Class                    To                  From
B-3                      NR                  BBB+ (sf)

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2000-C2
                                 Rating
Class                    To                  From
C                        NR                  AAA (sf)
D                        NR                  AAA (sf)

PNC Mortgage Acceptance Corp.
Commercial mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Prudential Securities Secured Financing Corp.
Comm mtg pass-thru certs ser 1998-C1
                                 Rating
Class                    To                  From
E                        NR                  AAA (sf)

Prudential Securities Secured Financing Corp.
Commercial mortgage pass-through certificates series KEY2000-C1
                                 Rating
Class                    To                  From
F                        NR                  AA-(sf)

Salomon Brothers Commercial Mortgage Trust 2001-C2
Commercial mortgage pass-through certificates series 2001-C2
                                 Rating
Class                    To                  From
BR                       NR                  AAA (sf)

STRIPs III Ltd.
STRIPs III CDO Ltd series 2003-1
                                 Rating
Class                    To                  From
K                        NR                  BBB-(sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2003-C5
                                 Rating
Class                    To                  From
X-P                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2003-C8
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2004-C12
                                 Rating
Class                    To                  From
A-2                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2005-C21
                                 Rating
Class                    To                  From
A-3                      NR                  AAA (sf)

Wachovia Bank Commercial Mortgage Trust
Commercial mortgage pass-through certificates series 2006-C29
                                 Rating
Class                    To                  From
A-1                      NR                  AAA (sf)

Ratings Withdrawn Following Application of Criteria for IO
Securities

Bear Stearns Commercial Mortgage Securities Inc.
Commercial mortgage pass-through, certificates, series 2006-BBA7
                                 Rating
Class                    To                  From
X-1B                     NR                  AA (sf)

Chase Manhattan Bank-First Union National Bank Commercial Mortgage
Trust
Commercial mortgage pass-through certificates series 1999-1
                                 Rating
Class                    To                  From
X                        NR                  AAA (sf)

GMAC Commercial Mortgage Securities, Inc.
Commercial mortgage pass-through certificates series 2001-C1
                                 Rating
Class                    To                  From
X-1                      NR                  AAA (sf)

GS Mortgage Securities Corp. II
Commercial mortgage pass-through certificates series 2006-GSFL
VIII
                                 Rating
Class                    To                  From
X                        NR                  AAA (sf)

JPMorgan Commercial Mortgage Finance Corp.
Commercial mortgage pass-through certificates series 99-PLS1
                                 Rating
Class                    To                  From
X                        NR                  AAA (sf)

Prudential Securities Secured Financing Corp.
Commercial mortgage pass-through certificates series KEY2000-C1
                                 Rating
Class                    To                  From
X                        NR                  AAA (sf)

                           *********

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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